1 algorithm “to reverse [a] decline in comments, and other forms of engagement, and to encourage 2 more original posting” by users.37 3 61. Simply put, it is clear—based largely on admissions from former Facebook 4 executives—that Facebook’s algorithms are not “neutral.” The algorithms do not merely 5 recommend content based on users’ previously expressed interests; rather, to maximize 6 engagement, they are heavily biased toward promoting content that will enrage, polarize, and 7 radicalize users. Facebook does not simply “connect” people with similar interests; it exploits the 8 universal human instinct for tribalism by actively herding people into groups that define 9 themselves through their violent opposition to “other” people—often identified by race, religion, 10 or political ideology. 11 C. Facebook Curates and Promotes Extremist Group Content 12 62. Facebook’s algorithms curate and promote content that attracts new members to 13 extremist groups. A presentation by a researcher employed at Facebook, which was leaked in 14 2020, showed that Facebook’s algorithms were responsible for the growth of German extremist 15 groups on the website: “The 2016 presentation states that ‘64% of all extremist group joins are 16 due to our recommendation tools’ and that most of the activity came from the platform’s ‘Groups 17 You Should Join’ and ‘Discover’ algorithms. ‘Our recommendation systems grow the problem.’” 18 Ultimately, however, because “combating polarization might come at the cost of lower 19 engagement … Mr. Zuckerberg and other senior executives largely shelved the basic research … 20 and weakened or blocked efforts to apply its conclusions to Facebook products.” 38 21 63. 22 [I]f I am active in a Facebook Group associated with a conspiracy theory and then stop using the platform for a time, Facebook will do something surprising when I return. It may suggest other 23 24 25 26 27 28 Roger McNamee gave this example: 37 Keach Hagey, Jeff Horwitz, Facebook Tried to Make Its Platform a Healthier Place. It Got Angrier Instead, THE WALL STREET JOURNAL (Sept. 15, 2021), https://www.wsj.com/articles/facebook-algorithm-change-zuckerberg-11631654215. 38 Jeff Horwitz, Deepa Seetharaman, Facebook Executives Shut Down Efforts to Make the Site Less Divisive, WALL STREET JOURNAL (May 26, 2020), https://www.wsj.com/articles/facebook-knows-it-encourages-division-top-executives-nixedsolutions-11590507499. CLASS ACTION COMPLAINT 23 Case No. __________________