1 information, and the whistleblower’s knowledge of Facebook’s lack of response, led this person 2 to conclude: “I, working for Facebook, had been a party to genocide.”3 3 3. For years, the Myanmar military, along with the support of civilian terrorists in 4 the majority Buddhist population, have treated the Rohingya as less than human, limiting their 5 rights, restricting their movements, and committing widespread human rights violations. While 6 various incidents of violence occurred periodically for years, nothing could prepare the 7 Rohingya, or the international community, for what was to come after Facebook entered the 8 picture in 2012. 9 4. Following confrontations on the Rakhine State border, the Myanmar military, and 10 its civilian conspirators, now armed with Facebook to organize and spread terror, escalated their 11 brutal crackdown, carrying out violent acts of ethnic cleansing that defy comprehension. 12 5. In the ensuing months and years, tens of thousands of Rohingya were brutally 13 murdered, gang raped, and tortured. Men, women, and children were burned alive inside their 14 homes and schools. Family members were tortured, raped, and killed in front of each other. More 15 than ten thousand lost their lives, while hundreds of thousands were brutalized, maimed, and 16 bore witness to indescribable violence and misery that they will carry with them for the rest of 17 their lives. Families were destroyed, childhoods were lost, lives were ruined, and entire 18 communities were erased from the face of the earth. 19 6. As this wave of violence persisted with little end in sight, hundreds of thousands 20 of Rohingya fled their home country and sought refuge around the world. The vast majority of 21 those refugees ended up, and still live, in Bangladesh in what is now the largest refugee camp in 22 the world. Over ten thousand individuals, including Plaintiff, eventually arrived in the United 23 States and many are living here under refugee status. 24 25 26 27 28 3 Craig Timberg, New whistleblower claims Facebook allowed hate, illegal activity to go unchecked, THE WASHINGTON POST (Oct. 22, 2021), https://www.washingtonpost.com/technology/2021/10/22/facebook-new-whistleblowercomplaint/. CLASS ACTION COMPLAINT 3 Case No. __________________