On December 23, 2025, a federal judge enjoined enforcement of Texas’ App Store Accountability Act (SB 2420) by Texas Attorney General, Ken Paxton. The law, which was slated to go into effect on January 1, 2026, would have imposed onerous age assurance and parental consent obligations on app stores and app developers, which our expert panelists analyzed in depth in a webinar last month (and which we detailed in a FAQ).

The Orders (here  and here ) come on the heels of the consolidated hearing that took place on December 16, during which U.S. District Court Judge Robert Pitman heard arguments from all parties on the Plaintiffs’ motion for a preliminary injunction. AG Paxton filed an appeal the same day. The Computer & Communications Industry Association (CCIA) originally filed suit on October 16, 2025, alleging violations of First Amendment speech protections for users, app stores, and app developers as well as unconstitutional vagueness. A separate lawsuit was filed the same day by two individual students and Students Engaged in Advancing Texas (SEAT), arguing the law burdens minors’ free speech rights. Plaintiffs in both cases filed a motion for a preliminary injunction on October 23, to which Texas Attorney General Paxton filed a response two weeks later followed by the Plaintiffs’ respective replies on November 20.

The Court noted its concerns with a few specific effects of the law: (1) imposing duties on both app stores and developers to implement the law’s age rating system and display the system to users, (2) shifting age verification duties onto app stores, (3) requiring parental consent before a minor can make an app download, app purchase, and in-app purchase, and (4) mandating app stores to revoke minors’ access to an app whenever its content rating, functionality, or user experience undergoes a “material change,” subsequently requiring parental consent.

The Court determined that the law’s coverage definition and objective of restricting content deemed harmful to minors constitute a content-based regulation. As a result, the Court applied a standard of strict scrutiny and ultimately decided the law fails both prongs of the test. First, the Court found that the State did not demonstrate a compelling interest in preventing minors’ access to the broad categories of speech encompassed by SB 2420. Second, the Court found that SB 2420 does not use the least restrictive means possible to stop minors from accessing harmful material. Additionally, the Court noted that the law is both under- and over-inclusive; the law does not restrict minors from accessing potentially harmful content on pre-downloaded apps while simultaneously prohibiting minors from “participating in the democratic exchange of views online.”

Lastly, the Court supported the CCIA’s argument that the law was unconstitutionally vague. Specifically, two portions of the law were found impermissibly vague: (1) app stores’ and developers’ liability for knowingly misrepresenting age ratings and (2) app developers’ obligations to provide notice of “significant changes.”

As AG Paxton immediately filed an appeal of the order on December 23, 2025, we expect to see developments on the injunction in the first quarter of 2026. Those interested and/or impacted by these laws should continue to follow these developments as well as any that may occur with respect to similar laws in Utah and Louisiana that are slated to go into effect in the middle of 2026, and in California, which is effective January 1, 2027.

Disclaimer: While every effort has been made to ensure that the information contained in this article is accurate, neither its authors nor Squire Patton Boggs accepts responsibility for any errors or omissions. The content of this article is for general information only, and is not intended to constitute or be relied upon as legal advice.

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