Case 1:20-mc-00036-JEB-DAR Document 10 Filed 08/18/20 Page 26 of 29 the requested information to The Gambia’s case. Opp’n 10. The Gambia’s requests are targeted to discovery that will help prove Myanmar intended to commit genocide against the Rohingya. Myanmar has engaged in a coordinated effort to incite genocide that has involved a variety of government actors and entities. Facebook has publicly stated that it has reviewed content from Myanmar’s government, its officials, its entities, and its actors and determined that they used Facebook to spread hate speech, enable serious human rights abuses, or used the platform to inflame ethnic and religious tensions.45 The information The Gambia is requesting is information that Facebook has already reviewed and analyzed. Accordingly, our requests are limited to four discrete categories of information: (1) Requests 1-7 draw on information that is publicly available and are targeted to specific accounts, groups, and organizations that Facebook has suspended or blocked. Those requests are limited to “documents and communications produced, drafted, posted or published” by specific Myanmar government or military officials or entities or organizations affiliated with the Myanmar government. (2) Requests 8-12 are limited to “documents and communications produced, drafted, or published” by Myanmar state officials, representatives entities, or groups that Facebook has suspended or terminated from 2012 to the present because for concerns relating to human rights, dissemination of hate speech, engaging in coordinated inauthentic behavior, violating Facebook’s misrepresentation policy. The 2012 timeframe is relevant because, according to a 2018 United Nations Report, violence erupted across Rakhine State and, during this period, Myanmar 45 See generally Removing Myanmar Military Officials From Facebook, Facebook (Aug. 28, 2018) (Updated Dec. 18, 2018), https://about.fb.com/news/2018/08/removing-myanmar-officials/; Sara Su, Update on Myanmar, Facebook (Aug. 15, 2018), https://about.fb.com/news/2018/08/update-on-myanmar/ (“It has also become clear that in Myanmar, false news can be used to incite violence, especially when coupled with ethnic and religious tensions. We have updated our credible violence policies to account for this, removing misinformation that has the potential to contribute to imminent violence or physical harm … While we’re adapting our approach to false news given the changing circumstances, our rules on hate speech have stayed the same: it’s not allowed. And we are getting much more proactive in designating Myanmar hate figures and organizations on Facebook …”); BSR, Human Rights Impact Assessment Facebook in Myanmar 27, Facebook (Oct. 2018), https://about.fb.com/wp-content/uploads/2018/11/bsrfacebook-myanmar-hria_final.pdf (“The decision to ban 20 military individuals and organizations from Facebook in August 2018 was a strong statement of the company’s determination to act against those seeking to use Facebook in ways that spread violence and enable genocide.”). 20