Complicity of Social Media Companies in Inciting Genocide Hakim available but also sufficiently understand cultural context to know when implicit statements may be indicative of calls for genocide. Social media companies should also continue building partnerships with civil society organizations that can serve as an additional source of early alerts that an incitement campaign is underway. Such partnerships must not be considered replacements, however, for internal mechanisms to identify and root out incitement. VI. C ONCLUSION This Comment examined whether social media companies and their employees risk international criminal liability when they provide a platform to the perpetrators of direct and public incitement to commit genocide. In doing so, this Comment took a substantive approach rather than a procedural one, which might examine issues such as jurisdiction. It explored the ICL around genocide and the incitement to genocide (Section II), complicity (Section III), and corporate liability (Section IV) to conclude that although a social media company cannot be implicated in a crime as a distinct entity, individual employees at these companies can be complicit in inciting genocide. This Comment took the position, citing precedent, that complicity in incitement is not only a valid legal theory under ICL but also a potentially powerful tool for the ICC prosecutor to combat genocide’s early stages. This Comment also considered how complicity in incitement applies at three levels in the hierarchy of a social media company, including the CEO, the manager, and the content moderator (Section V). This analysis ought to provoke broader discussion about how ICL might be reformed to deter future incitements to genocide. Accordingly, this Comment concluded with a brief list of recommendations to serve as a starting point for future dialogue. Summer 2020 117