Case 1:20-mc-00036-JEB-ZMF Document 22 Filed 09/22/21 Page 26 of 32 and 2017 could only be understood by examining Myanmar officials’ activities dating back to 2012. See id. at ¶¶ 745–48. Second, Facebook has not demonstrated how the additional four years of content unduly expands the document production. Facebook could have analyzed the metadata of its records to substantiate its claim, but it did not. Third, there is nothing to suggest The Gambia’s request for content dating back to 2012 was “made in bad faith, for the purpose of harassment, or [was] part of a fishing expedition.” Intel, 542 U.S. at 265. Ultimately, this case raises at most the normal burdens of discovery—including for § 1782 requests. Facebook can mitigate the primary burden it identified by using “technology assisted review [which] is cheaper, more efficient and superior to keyword searching.” In re MercedesBenz Emissions Litig., No. 216-cv-881, 2020 WL 747195, at *6 (D.N.J. Feb. 14, 2020); see also Conf. Tr. at 141–42. The parties are otherwise left to negotiate how to efficiently comply with this Court’s order. For example, The Gambia has already offered to take the full de-platformed data set, minus any content searches, to alleviate the burden on Facebook. See Conf. Tr. at 144– 45. Relevance “[W]hether the [ICJ] will ultimately find [the requested discovery] ‘useful’ . . . comes into play only in the context of the discretionary Intel factors.” In re Veiga, 746 F. Supp. 2d 8, 19 (D.D.C. 2010). The ICJ is considering whether Myanmar violated the Genocide Convention. The Gambia seeks evidence to prove genocidal intent. As the U.N. Mission concluded: The role of social media [in Myanmar] is significant. Facebook has been a useful instrument for those seeking to spread hate, in a context where, for most users, Facebook is the Internet. Although improved in recent months, the response of Facebook has been slow and ineffective. The extent to which Facebook posts and messages have led to real-world discrimination and violence must be independently and thoroughly examined.” 26