April 2020] THE "WEAPONIZATION" OF FACEBOOK 823 labor, . . . murder[,] and rape;69 and “Wal-mart for failing to stop suppliers from committing labor abuses.”70 In the United Kingdom, laws on corporate criminal liability focus on the “identification principle.”71 This requires a prosecutor to prove criminal responsibility of the most senior officers who represent the “directing mind and will” of the entire organization, and whose mental state may be attributed to, or identified, with the company.72 These laws, dating back to the 1990s, represent the growing recognition and willingness of countries to prosecute corporations criminally. Instead of the domestic forum, scholars suggest international courts act as the appropriate forum to resolve human rights abuses by corporations.73 Jelena Aparac, former Legal Advisor for Médecins Sans Frontières, lists three justifications for why international tribunals are the appropriate forum for adjudicating human rights violations.74 First, international tribunals are better suited to adjudicate gross violations of human rights because international law governs the gravest violations to humanity: war crimes, crimes against humanity and genocide.75 Second, such crimes universally hurt values respected by all actors in the international community and therefore, the international forum is the best suited for adjudication.76 Lastly, international justice can eliminate obstacles present in domestic courts.77 In analyzing the theory of corporate criminal liability, there are two actors who may be subject to liability: the corporation itself and/or its officers and directors. Arguably, a more realistic discussion about corporate criminal liability for social media corporations focuses on holding the individual officers and directors liable rather than the corporate entity. There is, however, an argument in favor of holding the corporations themselves liable. In the United States, the Supreme Court held that corporations have First Amendment rights in Citizens United v. Federal Election Commission.78 Analogizing the corporate entity with a human individual, Justice Anthony Kennedy wrote, “[c]orporations and other associations, like individuals, contribute to the ‘discussion, debate, and the dissemination of information and ideas’ that the First Amendment seeks to 69. Cassel, supra note 68, at 306; cf. Duncan Campbell, Energy Giant Agrees Settlement with Burmese Villagers, GUARDIAN (Dec. 14, 2004, 7:04 PM), https://www.theguardian.com/world/2004/dec/15/ burma.duncancampbell. 70. Cassel, supra note 68, at 305–06; see also John Sifton, Walmart’s Human Trafficking Problem, HUM. RTS. WATCH (Sept. 17, 2012, 5:43 PM), https://www.hrw.org/news/2012/09/17/walmarts-human-traffickingproblem. 71. Corporate Prosecutions, CROWN PROSECUTION SERV., https://www.cps.gov.uk/legalguidance/corporate-prosecutions (last visited Mar. 20, 2020). 72. Id. 73. Jelena Aparac, Which International Jurisdiction for Corporate Crimes in Armed Conflicts?, 57 HARV. INT’L L.J. 40, 40–41 (2016). 74. Id. at 40–41. 75. Id.; see also Heyer, supra note 63, at 16. 76. Id. at 41. 77. Id. 78. 558 U.S. 310 (2010).