cementing the demographic re-engineering of Rakhine State that resulted from mass displacement. Much of this is being done under the guise of ‘development,’ with a clear discourse emerging to this effect in the immediate aftermath of the August 2017 ‘clearance operations.’133 1 2 3 4 110. In addition to loss of life, physical injuries, emotional trauma, and destruction or 5 taking of property, Plaintiff and the Class have been deprived of their culture and community. 6 The Rohingya people have their own language, not spoken anywhere else in the world. They 7 have lost their traditional places of worship. Family and community ties dating back generations 8 have been torn apart. 9 111. Having become refugees in foreign countries where they largely do not speak the 10 language, have no financial resources, and lack knowledge of the culture or legal system, 11 Plaintiff and the Class have been denied meaningful justice. Most Class members have been 12 attempting to recover from severe physical and/or emotional trauma and struggling to survive in 13 dangerous, overcrowded refugee camps in Bangladesh—thousands of miles from any court 14 having jurisdiction over Facebook—since they were forced from Myanmar. 15 112. The U.N. concluded that “[t]he attack on the Rohingya population of Myanmar 16 was horrendous in scope. The images of an entire community fleeing from their homes across 17 rivers and muddy banks, carrying their babies and infants and elderly, their injured and dying, 18 will and must remain burned in the minds of the international community. So will the ‘before 19 and after’ satellite imagery, revealing whole villages literally wiped off the map. In much of 20 northern Rakhine State, every trace of the Rohingya, their life and community as it has existed 21 for decades, was removed…. The ‘clearance operations’ were indeed successful.” 134 22 113. 23 • 24 25 26 27 28 Among the U.N. Mission’s findings were: The elements of the crime of genocide were satisfied. “The Mission is satisfied that the Rohingya … constitute a protected 133 Report of the detailed findings of the Independent International Fact-Finding Mission on Myanmar, UNITED NATIONS HUMAN RIGHTS COUNCIL (Sept. 16, 2019), https://www.ohchr.org/Documents/HRBodies/HRCouncil/FFMMyanmar/20190916/A_HRC_42_CRP.5.pdf, (“UNHRC 2019 Report”) ¶ 139. 134 UNHRC Report, ¶ 1439, https://digitallibrary.un.org/record/1643079/files/A_HRC_39_CRP-2-EN.pdf. CLASS ACTION COMPLAINT 44 Case No. __________________