Page 3 of 4 Documents means hard copy documents; electronic documents (including those held on computers, laptops, tablets, mobile phones, USB drives, or in online storage services); emails; and other forms of electronic messages (including text messages and messages or posts on any Facebook platform or other social media messages or posts). Documents include internal emails, meeting notes, internal research, strategy and position documents, advices including external third party advices (including experts and legal advices (so far as they are not legally privileged)), and public relations. Subject Matter means: 1. The operation of the Facebook platform (including in relation to content moderation) in, or in any way relating to, Myanmar since 2010. 2. Policy in place (from 2010 to the present day) in relation to hate speech and incitement of violence against the Rohingya people on the Facebook platform. 3. Steps taken by Facebook in relation to allegations of hate speech and incitement of violence against the Rohingya people on the Facebook platform including in relation to: 4. a. complaints made about posts / groups / accounts that were allegedly antiRohingya; and b. content moderation decisions about posts / groups / accounts that were apparently anti-Rohingya (those that were subject to complaints and those that were not). The extent to which the algorithm used by the Facebook platform encouraged and/or encourages division, dispute and hatred, including in relation to: a. the question of whether Facebook knowingly ignored / deprioritised concerns about the anti-Rohingya content on the Facebook platform for financial or other reasons; and b. any analogous situations or investigations that would cast light on the operation of the algorithm in this respect (i.e., any internal Facebook research, any similar complaints, any evidence of internal concerns being raised, any external complaints, any internal investigations etc). Clearly, this list is not exhaustive and more detailed disclosure requests will be produced at the appropriate times in the proceedings. We expect there to be many thousands of documents that will touch directly on the issues of the Rohingya people and the campaign against them and, similarly, many that address the issue of whether Facebook's algorithms operated and/or operate in a way that contributed and/or contribute to violence, hatred or harassment. We look to you to approach the issue of disclosure in the most open and proactive manner, given the extraordinary interest of this matter to the Rohingya people and society as a whole. 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.