Snap Inc. faced two major class action settlements totaling $100 million related to privacy practices and misleading investor statements. The company settled biometric privacy claims in Illinois for $35 million and investor litigation for $65 million, addressing years of disputes over how Snapchat collected user data without adequate consent and how executives misrepresented the impact of privacy changes on advertising revenue.
These settlements affect millions of Snapchat users who employed the app’s Lenses and Filters features, as well as investors who purchased Snap stock during the class period. The settlements represent significant consequences for a company that built its reputation on privacy-focused messaging. For users and investors alike, they underscore how companies can face substantial legal liability when their data practices and public disclosures conflict with actual policies and revenue impacts.
Table of Contents
- What Was the Snapchat Biometric Privacy Settlement About?
- Understanding the Biometric Data Collection Concerns
- The Securities Settlement and False Statements to Investors
- Who Can Claim Money from These Settlements?
- How Much Did Claimants Actually Receive?
- Snap’s Response and What Changed
- Implications for Privacy Law and Future Settlements
- Conclusion
What Was the Snapchat Biometric Privacy Settlement About?
The primary settlement centered on allegations that Snapchat’s wildly popular Lenses and Filters features collected facial biometric data without explicit user consent, violating Illinois’s Biometric Information Privacy Act (BIPA). BIPA, one of the nation’s strictest biometric privacy laws, requires companies to obtain written consent before collecting, using, or storing biometric identifiers like facial recognition data. The lawsuit, titled Boone, et al. v.
Snap Inc., claimed that every time a user activated a filter or lens, Snapchat secretly processed and retained facial biometric information. Snap denied the allegations, arguing that its Lenses and Filters relied on machine learning and object recognition rather than true biometric collection or storage. The company maintained it did not store facial biometric templates or unique biometric identifiers. Despite this defense, Snap agreed to settle for $35 million without admitting wrongdoing on August 23, 2022, with final court approval following on November 17, 2022. The distinction between Snap’s technical claims and user privacy concerns highlights how companies and regulators often interpret data collection differently—what one party calls “object recognition” another views as biometric surveillance.
Understanding the Biometric Data Collection Concerns
The core issue was scope and consent. Illinois residents who used Snapchat Lenses or Filters anytime from November 17, 2015, onward were considered part of the class—a massive population given how central these features were to the app’s appeal. A filter that lets you add bunny ears to your face or applies a beauty effect requires the app to analyze your facial structure to work properly.
The question wasn’t whether facial analysis occurred, but whether users understood what data was being collected and whether they consented to its use and retention. The limitation of this settlement is that it resolved only Illinois residents’ claims under BIPA; users in other states had no similar statutory protection and faced much steeper barriers to bringing biometric privacy claims. California, Texas, and a handful of other states have passed biometric privacy laws since, but they came after this 2022 settlement, leaving years of data collection unaddressed for out-of-state users. Additionally, the company still did not have to admit it collected or stored biometric data, making it unclear what actual policy changes resulted from the settlement beyond a financial payout.
The Securities Settlement and False Statements to Investors
Alongside the biometric case, Snap faced investor litigation over misleading statements about its advertising business. In December 2025, the court gave preliminary approval to a $65 million settlement resolving claims that Snap misled shareholders about the impact of Apple’s App Tracking Transparency (ATT) privacy changes on advertising revenue. The final approval hearing was scheduled for April 23, 2026, before Judge George H. Wu in the U.S.
District Court for the Central District of California. The specific allegation centered on statements made during the class period from February 5, 2021, to October 21, 2021. On April 22, 2021, Snapchat’s then-Chief Business Officer Jeremi Gorman told investors that the “majority” of advertisers had “successfully implemented” SKAdNetwork solutions to work around Apple’s tracking restrictions. This statement allegedly downplayed the real impact ATT was having on Snap’s ability to target and measure advertising effectiveness. In reality, advertisers were struggling to adapt, and Snap’s ad platform was significantly disrupted—a gap between public statements and private reality that led to shareholder losses when the stock price eventually reflected the true revenue challenges.
Who Can Claim Money from These Settlements?
For the biometric settlement, eligibility was straightforward but geographically limited: Illinois residents who used Snapchat Lenses or Filters at any point from November 17, 2015, onward qualified. The original estimate suggested approximately 800,000 people would file claims, with each person receiving roughly $28.75 based on a $23 million net payout pool (after $12 million in attorney fees and administrative costs). In practice, actual payouts varied depending on how many valid claims were submitted and approved.
For the securities settlement with its May 6, 2026, claim deadline, eligibility was tied to purchasing Snap stock during the class period of February 5, 2021, to October 21, 2021. Investors had to submit proof of purchase, hold period, and loss calculations. The comparison between the two settlements is instructive: the biometric class affected consumers based on their use of free features, while the securities class affected only those who invested money in Snap stock—a much smaller but potentially larger-loss group. The securities claimant population was significantly smaller, meaning the $65 million settlement would be divided among fewer people, resulting in potentially larger per-person awards for investors who qualify.
How Much Did Claimants Actually Receive?
The payout structure for the biometric settlement was complicated by the fact that not all 800,000 eligible people filed claims. Those who did submit valid claims shared the $23 million net fund. The original estimate of $28.75 per person assumed full participation, but typical claims processes see significantly lower response rates, especially for class members who don’t actively monitor settlement news. Anyone who failed to file a claim by the deadline received nothing; unlike court judgments, class settlements expire and unclaimed funds don’t automatically go to claimants who missed the deadline. A critical warning: the actual timeline for receiving settlement money often stretched far longer than expected.
Claim administrators needed months to process submissions, verify eligibility, and distribute funds. Some claimants waited over a year to receive their checks. For the securities settlement, individual recoveries varied based on the size of losses, creating a more complex calculation than the biometric case. Investors had to prove their losses exceeded the stock’s price decline—a determination requiring documentation that many did not keep. The lesson from both settlements is that settlements, while theoretically beneficial, involve procedural hurdles and delays that many eligible parties never navigate.
Snap’s Response and What Changed
Snap’s settlement approach was to pay without admitting liability, a common strategy in privacy litigation that allows companies to resolve cases while maintaining they did nothing wrong. The company did not need to disclose exactly what data practices changed following the settlement, though increased transparency about how Lenses and Filters process facial information became more standard across the tech industry afterward. However, Snap continued operating Lenses and Filters exactly as before—no technological changes were required.
The broader context matters here. While Snapchat settled the biometric case in August 2022, the company continued to face privacy concerns beyond these two major settlements. Users and privacy advocates still questioned whether real reform occurred or whether the company simply paid the cost of doing business as usual. The settlement served as a financial penalty more than a catalyst for fundamental change in how Snapchat handles biometric data or how it communicates with investors about business challenges.
Implications for Privacy Law and Future Settlements
The Snap settlements became precedent points in a growing wave of biometric privacy litigation. The $35 million BIPA settlement was substantial enough to prompt other tech companies to review their own facial recognition and biometric data practices, knowing they could face similar liability.
However, the fact that Snap did not admit wrongdoing or implement visible changes limited the precedent’s impact—if companies could pay settlements without admitting fault or reforming practices, what incentive did they have to change proactively? The securities settlement reinforced that companies must disclose material risks to investors accurately. Understating the impact of market-disrupting privacy changes like ATT proved costly for Snap, setting a precedent that executives cannot publicly downplay challenges they privately acknowledge. Both settlements signaled that regulatory and legal pressure on tech companies’ data practices and investor communications would continue intensifying through the mid-2020s, with companies facing layered liability in privacy, consumer, and securities domains simultaneously.
Conclusion
The Snap Inc. settlements for $35 million (biometric privacy) and $65 million (securities fraud) addressed two different but interconnected failures: collecting biometric data without clear consent and misleading investors about the company’s ability to adapt to privacy-driven market changes. For Illinois residents who used Snapchat Lenses and Filters, the settlements provided some financial recovery, though actual per-person payouts were modest. For investors, the securities settlement acknowledged that Snap’s public statements about advertising resilience diverged sharply from reality.
If you believe you qualify for either settlement, verify your eligibility by reviewing the claim deadlines and filing requirements with a settlement administrator or class counsel. For the biometric case, the class period ran through November 2022 for filing claims. For the securities case, the deadline was May 6, 2026. Missing these deadlines means forfeiting any recovery. Both settlements demonstrate that while companies may eventually pay for privacy violations and misleading disclosures, users and investors bear the burden of actively claiming their share and accepting that settlements often arrive years after the underlying harms occurred.