Case 1:20-mc-00036-JEB-ZMF Document 22 Filed 09/22/21 Page 27 of 32 Report of the Independent International Fact-Finding Mission on Myanmar, A/HRC/39/64 at ¶ 74, U.N. Human Rights Council (Sept. 12, 2018). Facebook has admitted that Myanmar authorities used Facebook as part of a coordinated campaign of hate against the Rohingya. See Deplatforming Post. Yet the scope and underlying proof of this conclusion is unknown to The Gambia. See Conf. Tr. at 51. The records sought by The Gambia answer these questions, which are the gravamen of the ICJ inquiry. Moreover, the U.N. Mission’s report and Facebook’s HRIA each independently corroborate the relevancy of the request. That the records are highly relevant to the foreign proceeding balances out any incremental burden on Facebook. Alternative Avenues Of Discovery Facebook opines that The Gambia should have made its request via a mutual legal assistance treaty (MLAT), the CLOUD Act, or a different international body. This is a nonstarter. The only issue is whether The Gambia has met the requirements of § 1782. A court need not consider whether other paths exist to collecting records. Cf. HT S.R.L. v. Velasco, No. 15-mc-664, 2015 WL 13759884, at *3 (D.D.C. Nov. 13, 2015) (“nothing in the text of 28 U.S.C. § 1782 . . . supports a quasi-exhaustion requirement” in part because doing so would impose an additional burden on parties seeking assistance from federal courts for matters relating to international litigation). And the alternatives Facebook suggests largely involve voluntary compliance, whereas an order under § 1782 mandates compulsory production. Specifically, Facebook directs The Gambia to obtain discovery through the U.N. Independent Investigative Mechanism for Myanmar (“IIMM”), which “Facebook is actively working to support.” Resp’t’s Surreply at 1. However, Facebook’s “voluntar[y] produc[tion]” of records to the IIMM only began in August 2020, id., and reportedly has been stilted, see Poppy McPherson, U.N. investigator says Facebook has not shared ‘evidence’ of Myanmar crime, 27