1 122. In a 162-page report based on 254 interviews, the human rights group Fortify 2 Rights documented how, in August 2017, ��Myanmar authorities … activated non-Rohingya 3 civilian squads, some of whom the authorities previously armed and/or trained. These civilian 4 perpetrators … acted under the Myanmar military and police in razing hundreds of Rohingya 5 villages throughout northern Rakhine State, brutally killing masses of unarmed Rohingya men, 6 women, and children.”154 The title of the report, “They Gave Them Long Swords,” referred to an 7 eyewitness account of Myanmar soldiers arming non-Rohingya civilians.155 8 9 123. In a chapter of its report entitled “Criminal Acts Against Rohingya by Civilian Perpetrators Since August 25, 2017,” Fortify Rights stated: 10 After arming and training local non-Rohingya citizens who had a demonstrated history of hostility toward Rohingya Muslims in northern Rakhine State, the Myanmar authorities activated them on August 25…. Groups of local non-Rohingya citizens, in some cases trained, armed, and operating alongside Myanmar security forces, murdered Rohingya men, women, and children, destroyed and looted Rohingya property, and assisted the Myanmar Army and Police in razing villages. 156 11 12 13 14 15 124. In a Facebook post on September 22, 2017, the Burmese Commander-in-Chief 16 “encouraged further cooperation between local non-Rohingya citizens and the Myanmar 17 military, saying ‘[l]ocal ethnics can strengthen the defense prowess by living in unity and by 18 joining hands with the administrative bodies and security forces in oneness.’”157 19 E. Facebook Ignored Complaints of Hate Speech on its Website 20 125. Because Myanmar’s history of repressive military rule and ethnic violence was 21 well-documented by the time Facebook became widely available in Myanmar around 2012, 22 Facebook should have known that its product could be used to spread hate speech and 23 24 25 26 27 28 154 Fortify Rights Report, at 12-13, 14, https://www.fortifyrights.org/downloads/Fortify_Rights_Long_Swords_July_2018.pdf. 155 Id. at 16. 156 Id. at 55. 157 Id. at 46 & n.87 (citing Facebook post). CLASS ACTION COMPLAINT 50 Case No. __________________