followers on Facebook, posted a link to an article titled “The lies of the [Rohingya liars] are exposed[.]”101 1 2 In a Pulitzer Prize winning report, Reuters found numerous “posts, comments, 97. 3 images and videos attacking the Rohingya or other Myanmar Muslims that were on Facebook as 4 of [August 2018].” For example: 5 • In December 2013, one user posted: “We must fight them the way Hitler did the Jews, damn kalars [a pejorative for the Rohingya].” • In September 2017, another wrote: “These non-human kalar dogs, the Bengalis, are killing and destroying our land, our water and our ethnic people…. We need to destroy their race.” • In April 2018, another user posted, with a picture of a boatload of Rohingya refugees, “Pour fuel and set fire so that they can meet Allah faster.”102 6 7 8 9 10 11 98. Facebook was used to instigate communal unrest “in early September 2017, … 12 through the parallel distribution of similar but conflicting chain messages on Facebook 13 Messenger to Muslim and Buddhist communities. Each chain message stated that the other group 14 was preparing for major violence on 11 September and encouraged the recipient to get ready to 15 resist…. [T]he messages … caused widespread fear and at least three violent incidents.”103 One 16 of the most dangerous campaigns came in 2017, when “the military’s intelligence arm spread 17 rumors on Facebook to both Muslim and Buddhist groups that an attack from the other side was 18 imminent….”104 19 20 99. Steve Stecklow, author of the Reuters report, observed that several of the posts that he and his team catalogued “described Rohingyas as dogs or pigs. ‘This is a way of 21 22 23 24 25 26 101 Id. ¶ 1312. 102 Steve Stecklow, Why Facebook is losing the war on hate speech in Myanmar, REUTERS (Aug. 15, 2018), https://www.reuters.com/investigates/special-report/myanmar-facebook-hate/. 103 UNHRC Report, ¶ 1348, https://digitallibrary.un.org/record/1643079/files/A_HRC_39_CRP-2-EN.pdf. Paul Mozur, A Genocide Incited on Facebook, With Posts From Myanmar’s Military, NEW YORK TIMES (Oct. 15, 2018), https://www.nytimes.com/2018/10/15/technology/myanmarfacebook-genocide.html. 104 27 28 CLASS ACTION COMPLAINT 37 Case No. __________________