1 130. Reuters’ Steve Stecklow sent the examples of hate speech that he and his team 2 had found on the system, some of which was “extremely violent and graphic,” to Facebook: “It 3 was sickening to read…. When I sent it to Facebook, I put a warning on the email saying I just 4 want you to know these are very disturbing things…. What was so remarkable was that [some 5 of] this had been on Facebook for five years and it wasn’t until we notified them in August [of 6 2018] that it was removed.”176 7 131. “The [U.N.] Mission itself experienced a slow and ineffective response from 8 Facebook when it used the standard reporting mechanism to alert the company to a post targeting 9 a human rights defender for his alleged cooperation with the Mission.” “The post described the 10 individual as a ‘national traitor,’ consistently adding the adjective ‘Muslim.’ It was shared and 11 reposted over 1,000 times. Numerous comments to the post explicitly called for the person to be 12 killed, in unequivocal terms: … ‘If this animal is still around, find him and kill him….’ ‘He is a 13 Muslim. Muslims are dogs and need to be shot….’ ‘Remove his whole race.’ … In the weeks 14 and months after the post went online, the human rights defender received multiple death threats 15 from Facebook users….” “The Mission reported this post to Facebook on four occasions; in each 16 instance the response received was that the post was examined but ‘doesn’t go against one of 17 [Facebook’s] specific Community Standards.’ … The post was finally removed several weeks 18 later but only through the support of a contact at Facebook, not through the official channel. 19 Several months later, however, the Mission found at least 16 re-posts of the original post still 20 circulating on Facebook.”177 21 132. On February 25, 2015, Susan Benesch, a human rights lawyer and researcher who 22 directs the Dangerous Speech Project at the Berkman Klein Center for Internet & Society at 23 Harvard University, gave a presentation entitled “The Dangerous Side of Language” at 24 Facebook. The presentation showed how anti-Rohingya speech being disseminated by Facebook 25 26 27 28 176 Anisa Sudebar, The country where Facebook posts whipped up hate, BBC TRENDING (Sept. 12, 2018), https://www.bbc.com/news/blogs-trending-45449938. 177 UNHRC Report, ¶ 1351, https://digitallibrary.un.org/record/1643079/files/A_HRC_39_CRP-2-EN.pdf. CLASS ACTION COMPLAINT 55 Case No. __________________

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