1 erupted the following day [resulting in two deaths]. The rape allegations were false, with the 2 ‘victim’ reportedly admitting that she had fabricated the rape allegations.” 95 3 The U.N. Report continued, “[t]here is no doubt that hate speech against Muslims 96. 4 in general, and Rohingya in particular, is extremely widespread in Myanmar…. Given 5 Facebook’s dominance in Myanmar, the Mission paid specific attention to a number of Facebook 6 accounts that appear to be particularly influential….” 96 For example: 7 • [T]he late U Ko Ni, a well-known Muslim and legal advisor of the NLD, was frequently targeted on Facebook…. In one post from March 2016, a photo of U Ko Ni next to president Htin Kyaw was captioned ‘this [dog] getting his foot in the door in Myanmar politics is not something we should sit by and watch….’ The Mission has seen multiple other posts with a similar message and threats towards U Ko Ni dating from between March and October 2016. On 29 January 2017, U Ko Ni was assassinated….97 • [I]n January 2017, a self-described pro-Myanmar patriot with more than 17,000 followers on Facebook posted a graphic video of police violence against civilians in another country. He captioned the post as follows: “Watch this video. The kicks and beatings are very brutal…. [The] disgusting race of [Muslim] terrorists who sneaked into our country … need to be beaten like that….” One comment under the post reads: “It is very satisfying to watch this…. It’s sad that Myanmar security forces are not as skillful in their beating.” In July 2018, the post had over 23,000 views, 830 reactions and 517 shares.98 • [O]ne account holder, supposedly a monk, posted a poem with graphic photos allegedly showing Buddhist Mros killed by the “Bengali” on 3 August 2017, along with photos of damage to a pagoda allegedly done by “Bengali”.99 (The Myanmar authorities refer to the Rohingya as “Bengalis” to suggest that, rather than being native to Myanmar, they are illegal immigrants from Bangladesh.100) • [O]n 11 February 2018, … Shwewiki.com, a self-proclaimed “Media/News Company in Yangon” with over 1.3 million 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 95 96 25 26 27 97 98 99 100 28 Id. ¶ 1325. Id. ¶ 1310. Id. ¶ 1312. Id. Id. Id. ¶ 460. CLASS ACTION COMPLAINT 36 Case No. __________________

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