1 used the alleged “ethnic threat to national sovereignty and territorial integrity as the excuse for 2 its control of the country….”84 The main concern to those in power was to “maintain power and 3 to attain and preserve ‘national unity in the face of ethnic diversity.’ Human rights were 4 ‘subordinate to these imperatives.’ … Reports of serious human rights violations were 5 pervasive….”85 6 92. The government found that it could increase its own popularity by, first, instilling 7 fear and hatred of the Rohingya among the Buddhist majority in Burma and then publicly 8 oppressing, marginalizing, and persecuting the Rohingya. The U.N. found that “the Rohingya 9 have gradually been denied birth registration, citizenship and membership of the political 10 community. This lack of legal status and identity is the cornerstone of the oppressive system 11 targeting the Rohingya…. It is State-sanctioned and in violation of Myanmar’s obligations under 12 international law because it discriminates on the basis of race, ethnicity and religion.”86 The four 13 Special Rapporteurs on the human rights situation in Burma appointed by the United Nations 14 from 1992 to 201187 concluded, inter alia: 15 [S]ince late 1989, the Rohingya citizens of Myanmar … have been subjected to persecution based on their religious beliefs involving extrajudicial executions, torture, arbitrary detention, forced disappearances, intimidation, gang-rape, forced labour, robbery, setting of fire to homes, eviction, land confiscation and population resettlement as well as the systematic destruction of towns and mosques.88 16 17 18 19 [S]ome of these human rights violations may entail categories of crimes against humanity or war crimes. 89 20 21 Yet, “the Tatmadaw enjoys considerable popularity among the Bamar-Buddhist majority.”90 22 23 24 84 85 86 25 26 27 87 88 89 90 28 Id. Id. ¶ 94. Id. ¶ 491. Id. ¶ 96-97. Id. ¶ 100. Id. ¶ 97. Id. ¶ 93. CLASS ACTION COMPLAINT 34 Case No. __________________