1 platform … creating an incentive to produce more of it…. Company researchers discovered that 2 publishers and political parties were reorienting their posts toward outrage and sensationalism. 3 That tactic produced high levels of comments and reactions that translated into success on 4 Facebook.” Facebook researchers further discovered that “the new algorithm’s heavy weighting 5 of reshared material in its News Feed made the angry voices louder. ‘Misinformation, toxicity, 6 and violent content are inordinately prevalent among reshares,’ researchers noted in internal 7 memos.” Facebook data scientists suggested “a number of potential changes to curb the tendency 8 of the overhauled algorithm to reward outrage and lies” but “Mr. Zuckerberg resisted some of the 9 proposed fixes, the documents show, because he was worried they might hurt the company’s 10 other objective—making users engage more with Facebook.” 30 11 55. In October 2021, NBC News described, based on internal documents leaked by 12 Frances Haugen, an experiment in which an account created by Facebook researchers 13 experienced “a barrage of extreme, conspiratorial, and graphic content”—even though the 14 fictitious user had never expressed interest in such content. For years, Facebook “researchers had 15 been running [similar] experiments … to gauge the platform’s hand in radicalizing users, 16 according to the documents seen by NBC News,” and among Haugen’s disclosures are 17 “research, reports and internal posts that suggest Facebook has long known its algorithms and 18 recommendation systems push some users to extremes.”31 19 56. It is not surprising that the true nature of Facebook’s algorithms has become fully 20 apparent only through leaked documents and whistleblower testimony, since Facebook goes to 21 great lengths to hinder outside academic research regarding the design of those algorithms. In a 22 congressional hearing entitled “The Disinformation Black Box: Researching Social Media Data” 23 24 25 26 30 Keach Hagey, Jeff Horwitz, Facebook Tried to Make Its Platform a Healthier Place. It Got Angrier Instead, WALL STREET JOURNAL (Sept. 15, 2021), https://www.wsj.com/articles/facebook-algorithm-change-zuckerberg-11631654215. Brandy Zadrozny, “Carol’s Journey”: What Facebook knew about how it radicalizes users, NBC NEWS (Oct. 22, 2021), https://www.nbcnews.com/tech/tech-news/facebook-knewradicalized-users-rcna3581. 31 27 28 CLASS ACTION COMPLAINT 20 Case No. __________________