Tate Brothers' Complaint Against Meta Over Instagram Account Removal
Exhibit A to Meta's notice of removal contains the complaint filed by Emory Andrew Tate III and Tristan Tate against Meta Platforms, Inc. The 22-page document alleges wrongful termination of Instagram accounts and presents 12 causes of action including breach of contract and civil rights violations.
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Account Termination and Policy Violations
The complaint alleges Meta removed plaintiffs' Instagram accounts including @cobratate (Andrew Tate's account with millions of followers), @talismantate (Tristan Tate's account), and @t8cars (a car-focused account) without prior notice or explanation. Plaintiffs claim this violated specific provisions in Instagram's Terms of Use that promise users notification and appeal rights when accounts are disabled. The document quotes policy language stating 'we'll let you know and explain any options you have to request a review' which plaintiffs argue was not followed. They note the removal affected multiple accounts simultaneously, including @t8cars which they state contained only automotive photography and car showcases with no political or opinion content.
Supported by PDF pages 1, 2, 3, 4, 5, 6Alleged Financial and Professional Consequences
Plaintiffs claim their removed accounts had millions of followers and generated substantial revenue through endorsements, affiliate partnerships, and direct monetization. They estimate losses exceeding $10,000,000.00 per cause of action from terminated business relationships. The complaint details how plaintiffs' business model relied on social media engagement, mentioning their ventures included educational platforms, subscription-based content services, and real estate investments. It states the immediate removal severed access to commercial tools and audience connections built over years. Plaintiffs reference being placed under house arrest in Romania in connection with criminal investigations (noting no convictions resulted) and allege Meta's actions compounded professional difficulties during this period.
Supported by PDF pages 3, 4, 5, 6, 13, 14Contractual and Policy-Based Claims
The complaint extensively cites Instagram's Terms of Use and Community Standards that formed the contractual relationship. It highlights provisions requiring: (1) notice when content violates policies, (2) explanation of enforcement actions, and (3) access to appeal processes. Plaintiffs contrast these promises with their experience of receiving no advance warning or opportunity to address alleged violations. The document quotes the Community Standards stating violations usually appear in users' feeds when they log in, which plaintiffs say didn't occur. They also reference Meta's Privacy Policy assertions about users retaining access to data and communications, claiming these commitments were breached when they were denied even login access to review alleged offending posts.
Supported by PDF pages 5, 6, 7, 8, 9Discrimination and Constitutional Allegations
The complaint alleges gender-based discrimination under California Civil Code §51(b) (Unruh Civil Rights Act). It provides examples of female creators like SheraSeven (known for content about transactional relationships) and @itgirls.only_ (posting about emotional detachment in relationships) whose content remained on Instagram. The document asserts First Amendment violations under 42 U.S.C. §1983, claiming Meta acted as a state actor by allegedly coordinating with government officials to suppress disfavored viewpoints. It references Meta leadership's admissions about content decisions being influenced by direction from federal agencies, though without specifying particular agencies. Plaintiffs allege this transformed Meta into a state actor for constitutional liability purposes.
Supported by PDF pages 9, 10, 11, 12, 13Specific Causes of Action and Alleged Harms
The complaint details 12 legal claims including: (1) Breach of Contract, (2) California Business & Professions Code violations, (3) Tortious Interference, (4) Unjust Enrichment, (5) Intentional Infliction of Emotional Distress, (6) Unruh Civil Rights Act violation, (7) Breach of Implied Covenant, (8) Misrepresentation, (9) Promissory Estoppel, (10) Fraud, (11) 42 U.S.C. §1983 violation, and (12) False Light. The emotional distress claim references physical symptoms including insomnia and weight loss allegedly resulting from the account removals. The false light claim alleges Meta's actions falsely portrayed plaintiffs as violent, misogynistic, and criminal through implied messaging in media reports about the ban.
Supported by PDF pages 1, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20Requested Relief and Document Details
Plaintiffs seek compensatory damages exceeding $50,000,000.00, punitive damages, attorney fees, and injunctive relief including potential account restoration. They demand a jury trial on all triable issues. The document includes signed verifications from both plaintiffs under penalty of perjury, with Andrew Tate's verification dated August 8, 2025 from Dubai and Tristan Tate's similarly verified. It attaches Instagram's Terms of Use (Exhibit A, 22 pages), Community Standards (Exhibit B), and Data Policy (Exhibit C) as exhibits. Originally filed in Los Angeles Superior Court case 25SM CV04193 on August 8, 2025, it was removed to federal court. Attorneys Raymond Brenneman (California bar no. 333699) and Thomas Maniotis (seeking pro hac vice admission) represent the plaintiffs.
Supported by PDF pages 1, 17, 18, 19, 20, 21, 22Document record
- Document type
- Court exhibit
- Category
- Civil
- Publication date
- 2025-08-22
- Court or office
- Not stated by source
- Case number
- 3:26-cv-00901
- Collected
- 2026-11-13
- Original filename
- gov.uscourts.cand.463442.1.1.pdf
Source & integrity
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