Page 2 of 4 That position is changing today. After substantial research and preparation, we and our colleagues in the United States have initiated a co-ordinated trans-Atlantic legal campaign to seek justice for the Rohingya people. The purpose of this letter is to give notice to Facebook UK Limited (FB UK) that our clients intend to bring proceedings against FB UK in the High Court for its acts and omissions that contributed to the serious, sometimes fatal, harm suffered by our clients and their family members. In particular, our clients will claim that Facebook: 1. used algorithms that amplified hate speech against the Rohingya people on the Facebook platform; 2. failed in its policy to invest sufficiently in content moderators who spoke Burmese or Rohingya or in local fact checkers with an understanding of the political situation in Myanmar; 3. failed to take down specific posts inciting violence against or, containing hate speech directed towards, the Rohingya people; 4. failed to close specific accounts or delete specific groups or pages, which were being used to propagate hate speech and/or incite violence against the Rohingya people; and 5. regardless of being warned from 2014 onwards by NGOs and media about extensive anti-Rohingya posts, groups and accounts on its platform, failed to take appropriate and timely action. We note that notwithstanding Facebook's public acknowledgements that it needs "to do more" in relation to the situation in Myanmar, to this day Facebook uses a recommendation algorithm that invites users to "like" pages that share pro-military propaganda that violate its own rules. In addition, we understand that associates and proxies of the Myanmar military regime (the key organisation used to perpetrate the genocide) are still using the Facebook platform. We request that, in accordance with its obligations under the Civil Procedure Rules, FB UK preserves all documents that may be disclosable in these intended proceedings. Such documents will include (without limitation): 1. the Documents relating to the Subject Matter (both as defined below); and 2. copies of all public and private posts on the Facebook platform that in any way relate to the Rohingya people. In particular, copies of all such posts which cast the Rohingya people in a negative light and/or incite hatred and/or violence against the Rohingya people. For the avoidance of doubt, it should also include posts that detail the instruction, organisation or management of users in potential and actual acts of violence against the Rohingya people or their property. This should include all messages in all languages, including Burmese, Rohingya and English. 84 Brook Street, Mayfair, London, W1K 5EH, UK +44 (0) 207 096 3767 | enquiries@mccue-law.com | mccue-law.com McCue Jury & Partners LLP is a limited liability partnership registered in England and Wales under registered number 0364119, whose registered office is 84 Brook Street, Mayfair, London, W1K 5EH, United Kingdom and is authorised and regulated by the Solicitors Regulation Authority under number 560315. The term partner refers to a member of McCue Jury & Partners LLP. The partners are Jason McCue and Matthew Jury.