820 HASTINGS LAW JOURNAL [Vol. 71:813 In other countries, leaders spread propaganda by boosting likes on their respective social media pages.43 For example, in Cambodia, Prime Minister Hun Sen maintains his official page and often posts pro-government updates on Facebook.44 Communications firm, Bursen-Marsteller, revealed in a 2018 report that Prime Minister Hun Sen interestingly had more Facebook fans than Cambodia had Facebook users, suggesting that Prime Minister Hun Sen bought a majority of his likes from “click farms”45 outside Cambodia to increase his popularity.46 C. SPREAD OF DEROGATORY AND DEFAMATORY INFORMATION Another technique utilized by autocrats is the spread of derogatory and defamatory information, otherwise known as hate speech.47 The Indictment charged the IRA and Russia with interfering in the presidential election by “post[ing] derogatory information about a number of candidates,” mostly supporting President Donald Trump and disparaging Hillary Clinton.48 Authoritarian regimes are not the only actors to utilize hate speech, but their use of it is particularly dangerous because their leaders are uniquely positioned in seats of power and influence. In Myanmar, the military’s rhetoric regarding the Rohingya ethnic group mirrored that of Burmese nationalists who used “[d]ehumanizing and stigmatizing” language when speaking about the Rohingya.49 Myanmar authorities have even denied the term “Rohingya” existed, insisting that the Rohingya “do not exist or belong in Myanmar.”50 This last category, the spread of hate speech, has led to violent attacks on certain peoples, amounting to serious human rights concerns. Social media companies do not directly perpetrate human rights abuses, yet they play a significant role, governing the type of speech that appears on their platform and the frequency at which it appears.51 Some jurisdictions have held certain 43. Peter Ford, Facebook’s Autocrat Problem, THINK PROGRESS (May 18, 2018, 8:00 AM), https://thinkprogress.org/facebooks-problematic-role-in-cambodias-diminishing-democracy-c279f8b98229/. 44. Andrew Nachemson, Hun Sen Fourth-Most “Liked” Leader: Report, PHNOM PENH POST (May 3, 2018, 4:42 PM), https://www.phnompenhpost.com/national/hun-sen-fourth-most-liked-leader-report. 45. Companies pay workers to sit in a room and click on content, known as “click farms,” to boost their popularity and reliability to Internet users. According to the Mashable, “sometimes these farms manifest as rooms with hundreds if not thousands of phones, all at the ready for when a company pays for traffic.” Molly Sequin, Say Goodbye to Those Fake Likes: Huge Click Farm Discovered in Thailand, MASHABLE (June 13, 2017), https://mashable.com/2017/06/13/thailand-click-farm-caught/. 46. See Ford, supra note 43. 47. For an in-depth discussion on hate speech, see DANGEROUS SPEECH PROJECT, https://dangerousspeech.org/ (last visited Mar. 20, 2020). 48. Indictment, supra note 32, at 4. 49. Report, supra note 11, at 14. 50. Id. 51. See, e.g., PAUL HITLIN & LEE RAINIE, PEW RESEARCH CTR., FACEBOOK ALGORITHMS AND PERSONAL DATA (2019), https://www.pewinternet.org/wp-content/uploads/sites/9/2019/01/PI_2019.01.16_Facebookalgorithms_FINAL2.pdf.