Chicago Journal of International Law the public,” to fuel nationwide majoritarian hatred toward the Rohingya.11 All the while, Facebook provided the Tatmadaw with a massive platform to propagate dehumanizing narratives about the Rohingya.12 For example, officials used their accounts to frame the Rohingya as illegal immigrants, terrorists, and “inherently violent.”13 As the Tatmadaw used Facebook to disparage the minority group, civilian users joined in the attacks online.14 Reuters uncovered more than 1,000 examples of violent Facebook posts, some dating back to 2012, which referred to the Rohingya as “dogs,” “maggots,” and “rapists” who ought to be “fed to pigs” and “exterminated.”15 As dehumanizing speech spread on Facebook, and the hostility toward the Rohingya worsened, human rights activists and experts on the region reportedly warned Facebook executives as early as 2013 that their platform facilitated and exacerbated the ethnic tensions in Myanmar.16 Despite these warnings, Facebook continued providing Tatmadaw officials with a platform, devoting insufficient resources toward preventing the spread of disinformation. For example, around 2015, “there were only two people at Facebook who could speak Burmese.”17 It was not until 2018, when U.N. investigators formally accused Tatmadaw officials of genocide, that the company began the systematic removal of content and accounts belonging to military leaders.18 Facebook thereafter conceded in a blog post, “[w]e weren’t doing enough to help prevent our platform from being used to foment division and incite offline violence.”19 The U.N. concluded, after lengthy investigation, that there was “sufficient information to warrant the investigation and prosecution” of senior Tatmadaw officials for genocide.20 For its part, the International Criminal Court (ICC) held that although Myanmar is not a member of the court, the ICC may exercise jurisdiction over crimes committed against the Rohingya with a “cross-border” 11 12 13 14 15 16 17 18 19 20 Human Rights Council, Thirty-Ninth Session, Rep. of the Detailed Findings of the Indep. Int’l Fact-Finding Mission on Myan. Established Pursuant to Resolution 34/22, ¶ 1345, U.N. Doc. A/HRC/39/CRP.2 (Sept. 17, 2018) [hereinafter Detailed Report]. See Stecklow, supra note 10. See Detailed Report, supra note 11, at ¶ 1334. Id. at ¶ 1312. Stecklow, supra note 10. Id. Id. Burmese is the main local language in Myanmar. Id. Antoni Slodkowski, Facebook Bans Myanmar Army Chief, Others in Unprecedented Move, REUTERS (Aug. 27, 2018), http://perma.cc/CBB8-2DNH. Hannah Ellis-Petersen, Facebook Admits Failings Over Incitement to Violence in Myanmar, THE GUARDIAN (Nov. 6, 2018), http://perma.cc/4NJY-LZQU. See Report, supra note 6, at ¶ 87. 86 Vol. 21 No. 1