830 HASTINGS LAW JOURNAL [Vol. 71:813 contrast, international law does not provide similar protections for social media corporations. At first glance, social media companies do not seem to contribute to human rights abuses—they act more like megaphones by amplifying speech written by its users. During the Nuremberg Trials, the International Military Tribunal convicted Julius Streicher for inciting violence through the anti-Semitic articles he published in his weekly newspaper, Der Stürmer.127 The tribunal found that Streicher incited genocide and anti-Semitism through his articles in Der Stürmer, which reached a circulation of 600,000 in 1935.128 Interestingly, the tribunal did not suggest that the printing press bore responsibility, even though the articles would not have been disseminated without it. Similarly, in Prosecutor v. Ferdinand Nahimana, Jean-Bosco Barayagwiza and Hassan Ngeze, the ICTR held three editors liable for inciting violence and killings through radio broadcasts during the Rwandan genocide.129 In sentencing one of the three editors, Judge Pillay stated: “You were fully aware of the power of words, and you used the radio—the medium of communication with the widest public reach—to disseminate hatred and violence . . . . Without a firearm, machete or any physical weapon, you caused the death of thousands of innocent civilians.”130 Like Streicher’s trial, the tribunal did not mention the radio broadcasting company’s liability. Drawing on these two examples, international tribunals do not seem to charge the vehicle through which information is disseminated. Under this reasoning, Facebook would likely not be found liable for materially contributing to a crime because the platform reproduces information but does not create the speech. Facebook, however, is significantly more active in producing content than a paper press.131 The company not only reproduces information on each user’s page,132 but it curates a personalized Newsfeed for the user according to its algorithms.133 These algorithms move content higher or lower on users’ Newsfeeds in an effort to personalize content according to user preferences.134 This personalization is analogous to “buying a newspaper or magazine on the street and having the vendor cut out the articles that he or she decided would not 127. Judgment (Oct. 1, 1946) in 1 THE TRIAL OF THE MAJOR WAR CRIMINALS BEFORE THE INTERNATIONAL MILITARY TRIBUNAL NUREMBERG, 14 NOVEMBER 1945–1 OCTOBER 1946, at 304 (1947). 128. Id. 129. See Prosecutor v. Ferdinand Nahimana Jean-Bosco Barayagwiza, & Hassan Ngeze, Case No. ICTR99-52-T, Judgement and Sentence (Int’l Crim. Trib. for Rwanda Dec 3, 2003). 130. Press Release, Int’l Criminal Tribunal for Rwanda, Three Media Leaders Convicted for Genocide, (Dec. 3, 2003), http://unictr.irmct.org/en/news/three-media-leaders-convicted-genocide. 131. See Josh Constine, Facebook Changes Algorithm to Promote Worthwhile & Close Friend Content, TECHCRUNCH (May 16, 2019, 8:14 AM), https://techcrunch.com/2019/05/16/facebook-algorithm-links/. 132. Newsfeed is the primary interface for Facebook and is a stream of information from various users and pages. For further information, see Cade Metz, How Facebook Ads Work, N.Y. TIMES (Oct. 12, 2017), https://www.nytimes.com/2017/10/12/technology/how-facebook-ads-work.html. 133. See Constine, supra note 131. 134. Id.