Case 1:20-mc-00036-JEB-ZMF Document 22 Filed 09/22/21 Page 4 of 32 burning. . . . Death by burning in this manner disproportionately affected vulnerable persons less able to run and escape from the ‘clearance operations,’ including the elderly, disabled, young children and pregnant women.” Id. at ¶ 905. Myanmar military forces “perpetrated on a massive scale” “[r]ape and other sexual and gender-based violence . . . includ[ing] mass gang rapes, sexually humiliating acts, sexual slavery and sexual mutilations.” Id. at ¶ 920. “Many of the women and girls had infants and children with them, who were killed or severely injured, while their mothers were raped.” Id. at ¶ 924. “Many victims were killed after being raped. Most had their throats slit, or were burned to death.” Id. at ¶ 927. The U.N. Mission concluded Myanmar intended to eradicate the Rohingya. Id. at ¶¶ 1439– 41. Multiple other international human rights organizations likewise concluded that Myanmar’s actions constituted genocide. See Pet’r’s Mot. at 4–6. B. Facebook’s Role In The Genocide The U.N. Mission found that Facebook has been “by far the most common social media platform in use in Myanmar” since 2012. U.N. Report at ¶ 1344. “Facebook [was] the main, if not only, platform for online news.” Id. at ¶ 1345. The Myanmar officials “rel[ied] on Facebook to release news and information” and media outlets “use[d] Facebook as a main way of disseminating articles.” Id. In October 2018, Facebook commissioned a human rights impact assessment (HRIA) 3 of its presence in Myanmar. It too revealed that, in Myanmar, “Facebook is the internet.” HRIA at 3 Facebook commissioned BSR to author the HRIA using a methodology based on recognized international principles. The assessment identified actual and potential human rights impacts, reached conclusions about those impacts, and made recommendations for mitigation and management. Although Facebook funded the HRIA, BSR retained editorial control over its contents. See BSR, Human Rights Impact Assessment: Facebook in Myanmar, 1 (2018), https://about.fb.com/wp-content/uploads/2018/11/bsr-facebook-myanmar-hria_final.pdf (“HRIA”). 4