818 HASTINGS LAW JOURNAL [Vol. 71:813 world.”24 Although some scholars and reporters are hesitant to credit Facebook as the platform that unleashed the social revolutions in Egypt and Tunisia,25 social media, as a whole, informed communities about developing news and accelerated communication between communities during the Arab Spring.26 Social media, however, is only as powerful as the actor who wields it.27 Governments around the world continue to suppress speech using traditional methods such as Internet shutdowns and restrictive laws.28 In a more sophisticated manner, authoritarian governments today engage users directly on social media platforms.29 Anne Applebaum, Program Director at the Legatum Institute in London, commented on this phenomenon, stating: “[Authoritarian governments] can now create a narrative saying a democra[tic] activist was a traitor and a pedophile. . . . The possibility of creating an alternative narrative is one people didn’t consider, and it turns out people in authoritarian regimes are quite good at it.”30 For Facebook in particular, scholars and news reporters coin this phenomenon as “the weaponization of Facebook.”31 Such governments employ a variety of tactics to construct alternative narratives on social media platforms. For example, Russia developed a number of disinformation tactics during the 2016 United States presidential election, as detailed by the United States’ indictment (the “Indictment”) of the Internet Research Agency (IRA).32 While this Note does not focus on foreign interference with sovereign democracies, the Indictment outlines key disinformation tactics used by Russia on its own citizens, in addition to 24. Saleem Kassim, Twitter Revolution: How the Arab Spring Was Helped by Social Media, MIC (July 3, 2012), https://www.mic.com/articles/10642/twitter-revolution-how-the-arab-spring-was-helped-by-socialmedia. 25. Jay Rosen, The “Twitter Can’t Topple Dictators” Article, PRESSTHINK (Feb. 13, 2011, 1:08 AM), http://pressthink.org/2011/02/the-twitter-cant-topple-dictators-article/. 26. Rebecca J. Rosen, So, Was Facebook Responsible for the Arab Spring After All?, ATLANTIC (Sept. 3, 2011), https://www.theatlantic.com/technology/archive/2011/09/so-was-facebook-responsible-for-the-arabspring-after-all/244314/. 27. Jessi Hempel, Social Media Made the Arab Spring, But Couldn’t Save It, WIRED (Jan. 26, 2016, 3:06 PM), https://www.wired.com/2016/01/social-media-made-the-arab-spring-but-couldnt-save-it/. 28. See, e.g., Salem Solomon, Benin Internet Shutdown Repeats Pattern of Government Censorship Across Africa, VOA NEWS (Apr. 30, 2019, 4:16 AM), https://www.voanews.com/africa/benin-internet-shutdownrepeats-pattern-government-censorship-across-africa; Samuel Woodhams, Ethiopia’s Leader Promised to Protect Freedom of Expression. But He Keeps Flicking the Internet Kill Switch, CNN, https://www.cnn.com/2019/07/15/africa/ethiopia-internet-shutdowns-old-regime/index.html (last updated Jan. 15, 2019, 11:02 AM. ADRIAN SHAHBAZ, FREEDOM ON THE NET 2018 1, 2 (2018), https://freedomhouse.org/sites/default/files/FOTN_2018_Final%20Booklet_11_1_2018.pdf. 29. See CARLY NYST & NICK MONACO, STATE SPONSORED TROLLING: HOW GOVERNMENTS ARE DEPLOYING DISINFORMATION AS PART OF BROADER DIGITAL HARASSMENT CAMPAIGNS (2018). 30. Hempel, supra note 27. 31. See generally Lauren Etter, What Happens When the Government Uses Facebook as a Weapon?, BLOOMBERG BUSINESSWEEK (Dec. 7, 2017, 1:00 AM), https://www.bloomberg.com/news/features/2017-1207/how-rodrigo-duterte-turned-facebook-into-a-weapon-with-a-little-help-from-facebook. 32. Indictment at 14–23, United States of America v. Internet Research Agency, LLC, No. 1:18-CR-00032DLF (Feb. 16, 2018) [hereinafter Indictment].