834 HASTINGS LAW JOURNAL [Vol. 71:813 and messages have led to real-world discrimination and violence must be independently and thoroughly examined.170 At times, Facebook’s response seemed uninformed.171 In 2014, Facebook only had one content reviewer who spoke Burmese and only hired three more by 2015.172 Facebook struggled to identify hate speech due to difficulties with the Burmese language on its platform.173 Facebook’s response to the Myanmar crisis was, in fact, “slow and ineffective.”174 V. FACEBOOK’S POTENTIAL CRIMINAL LIABILITY IN THE MYANMAR CRISIS A. KNOWLEDGE OF TATMADAW’S CRIMES Applying the first requirement as discussed in Subpart III.A, Facebook may have knowingly provided assistance to those who perpetrated hate crimes against the Rohingya in Myanmar.175 Not only did numerous users flag content using Facebook’s internal reporting system, but civil society organizations directly reported misuse of the platform to various officers at Facebook.176 Users in Myanmar flagged hateful speech against the Rohingya; however, Facebook’s system was unequipped to interpret the reported posts, taking days or even weeks to remove inappropriate content.177 Because the Burmese script is incompatible with Facebook’s platform coding, Facebook had difficulty interpreting the script even though users were flagging content.178 Only recently has Facebook addressed this problem by replacing the code for Burmese script with a more accepted code, Unicode.179 This technical challenge and the prolonged response from Facebook may not show “knowing assistance” in the perpetration of crimes against humanity. However, in Myanmar in particular, additional warnings from civil society organizations evidenced more than mere suspicious warnings of misuse of Facebook’s platform. More significantly, because of these warnings, Facebook knew of potential crimes against humanity occurring on its platform. 170. Id. at 14. 171. Stecklow, supra note 145. 172. Id. 173. Id. 174. Report, supra note 11, at 14. 175. See supra Subpart III.A. 176. Laignee Barron, Could Facebook Have Helped Stop the Spread of Hate in Myanmar?, TIME, https://time.com/5230474/facebook-myanmar-hate-speech-rohingya/ (last updated Apr. 8, 2019, 7:38 AM). 177. Id. 178. Alex Warofka, An Independent Assessment of the Human Rights Impact of Facebook in Myanmar, FACEBOOK (Nov. 5, 2018), https://about.fb.com/news/2018/11/myanmar-hria/ (“Myanmar is currently the only country in the world with a significant online presence that hasn’t standardized on Unicode—the international text encoding standard. Instead, Zawgyi is used to encode Burmese language characters and is the dominant typeface in Myanmar.”). 179. Nick LaGrow & Miri Pruzan, Integrating Autoconversion: Facebook’s Path from Zawgyi to Unicode, FACEBOOK ENGINEERING (Sept. 26, 2019), https://engineering.fb.com/android/unicode-font-converter/.