SHERYL SANDBERG: I strongly believe that. In the case of what’s happened in Myanmar, it’s, it’s devastating and we’re taking aggressive steps and we know we need to do more….184 1 2 3 140. In October 2018, BSR (Business for Social Responsibility) published a human 4 rights impact assessment—commissioned by Facebook itself—of Facebook’s presence in 5 Burma; BSR found that: 6 • “Facebook is … used to spread rumors about people and events. Character assassinations were described to BSR during this assessment, and in extreme cases these have extended to online death threats…. There are indications that organized groups make use of multiple fake accounts and news pages to spread hate speech, fake news, and misinformation for political gain. Rumors spread on social media have been associated with communal violence and mob justice.”185 • “The Facebook platform in Myanmar is being used by bad actors to spread hate speech, incite violence, and coordinate harm…. Facebook has become a means for those seeking to spread hate and cause harm, and posts have been linked to offline violence…. [F]or example, the Report of the Independent International Fact-Finding Mission on Myanmar describes how Facebook has been used by bad actors to spread anti-Muslim, anti-Rohingya, and anti-activist sentiment.”186 • “The consequences for the victim are severe, with lives and bodily integrity placed at risk from incitement to violence.” 187 7 8 9 10 11 12 13 14 15 16 17 141. On November 5, 2018, Alex Warofka, Facebook’s Product Policy Manager, 18 issued a statement on the BSR report: “The report concludes that, prior to this year, we weren’t 19 doing enough to help prevent our platform from being used to foment division and incite offline 20 violence. We agree that we can and should do more.”188 21 22 23 24 25 26 Open Hearing on Foreign Influence Operations’ Use of Social Media Platforms, Senate Hearing 115-460 before the Select Comm. of Intel., 115th Cong. (Sept. 5, 2018), https://www.govinfo.gov/content/pkg/CHRG-115shrg31350/html/CHRG-115shrg31350.htm. 185 BSR Report, at 13, https://about.fb.com/wp-content/uploads/2018/11/bsr-facebookmyanmar-hria_final.pdf. 184 186 187 Id. at 24. Id. at 35. 188 27 28 Alex Warofka, An Independent Assessment of the Human Rights Impact of Facebook in Myanmar, FACEBOOK NEWSROOM (Nov. 5, 2018), https://about.fb.com/news/2018/11/myanmarhria/. CLASS ACTION COMPLAINT 59 Case No. __________________