1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 142. In October 2021, a former member of Facebook’s Integrity Team submitted a sworn whistleblower declaration to the SEC. It stated, inter alia: At Facebook, … there’s no will to actually fix problems, in particular if doing so might reduce user engagement, and therefore profits…. Any projects Facebook undertakes under the banner of charity or community building are actually intended to drive engagement…. Internet.org, Facebook’s scheme to provide Internet to the developing world, wasn’t about charity…. Inside the company, the dialogue was that this is about gaining an impenetrable foothold in order to harvest data from untapped markets. Through Internet.org, which provided Facebook at free or greatly reduced rates in key markets, Facebook effectively became the Internet for people in many developing countries…. [Facebook executives would] say ‘When you are the sole source for the Internet you are the sole source for news.’ Facebook executives often use data to confuse, rather than clarify what is occurring. There is a conscious effort to answer questions from regulators in ways that intentionally downplay the severity of virtually any given issue…. An[] example of their playbook played out in the wake of the genocide of the Rohingya refugees in Myanmar, a country where Facebook was effectively the Internet for most people, and where the long-isolated population was vulnerable to information manipulation. Facebook executives were fully aware that posts ordering hits by the Myanmar government on the minority Muslim Rohingya were spreading wildly on Facebook, because it was being reported in the media and multiple aid-organizations, as well as major, top-tier reporters who used to call the company when they discovered early on that the genocide was being accommodated on Facebook. It was clear before the killing even started that members of the military junta in Myanmar were directing this activity. But, when the violence of the early stages of the Myanmar government-directed genocide metastasized and the murders were unmistakably being directed on Facebook, I was instructed to tell the media, “We know now, and we finally managed to remove their access, but we did not have enough Burmese-speaking moderators.” This part was true; there was only one Burmese translator on the team of moderators for years, in the same period when the communications apparatus grew by leaps and bounds. But the issue of the Rohingya being targeted on Facebook was well known inside the company for years. I refused to deploy the approved talking point. Later, after widespread public blowback forced the company to hire a human rights group to conduct an independent review, Facebook’s policy manager Alex Warofka released a statement with the typical Facebook ‘mea culpa’ response: ‘We agree that we CLASS ACTION COMPLAINT 60 Case No. __________________