1 from another user regarding one’s post” and tested the assumption that likes “function as a social 2 reward.”20 3 44. 4 Roger McNamee, an early investor in Facebook and advisor to Mark Zuckerberg, wrote in his New York Times bestseller, “Zucked: Waking Up to the Facebook Catastrophe”: 5 Getting a user outraged, anxious, or afraid is a powerful way to increase engagement. Anxious and fearful users check the site more frequently. Outraged users share more content to let other people know what they should also be outraged about. Best of all from Facebook’s perspective, outraged or fearful users in an emotionally hijacked state become more reactive to further emotionally charged content. It is easy to imagine how inflammatory content would accelerate the heart rate and trigger dopamine hits.21 6 7 8 9 10 45. 11 A Nature article published in 2020 further explained: [I]ncendiary, polarizing posts consistently achieve high engagement…. This content is meant to draw engagement, to provide a reaction…. 12 13 This divisive material often has a strong moral charge. It takes a controversial topic and establishes two sharply opposed camps, championing one group while condemning the other. These are the headlines and imagery that leap out at a user as they scroll past, forcing them to come to a halt. This offensive material hits a nerve, inducing a feeling of disgust or outrage. “Emotional reactions like outrage are strong indicators of engagement…. [T]his kind of divisive content will be shown first, because it captures more attention than other types of content.” … 14 15 16 17 18 The design of Facebook means that … forwarding and redistribution is only a few clicks away…. Moreover, the networked nature of social media amplifies this single response, distributing it to hundreds of friends and acquaintances. They too receive this incendiary content and they too share, inducing … “outrage cascades — viral explosions of moral judgment and disgust.” Outrage does not just remain constrained to a single user, 19 20 21 22 23 24 25 26 27 28 20 Björn Lindström, Martin Bellander, David T. Schultner, Allen Chang, Philippe N. Tobler, David M. Amodio, A computational reward learning account of social media engagement, NATURE COMMUNICATIONS 12, Art. No. 1311 (Feb. 26, 2021), https://www.nature.com/articles/s41467-020-19607x#:~:text=%20A%20computational%20reward%20learning%20account%20of%20social,our%2 0hypothesis%20that%20online%20social%20behavior%2C…%20More%20. 21 Roger McNamee, Zucked: Waking Up to the Facebook Catastrophe, at 88 (Penguin 2020 ed.). CLASS ACTION COMPLAINT 15 Case No. __________________

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