3 conspiracy theory Groups to join…. And because conspiracy theory Groups are highly engaging, they are very likely to encourage reengagement with the platform. If you join the Group, the choice appears to be yours, but the reality is that Facebook planted the seed. It does so not because conspiracy theories are good for you but because conspiracy theories are good for them. 39 4 McNamee described how, in 2016, he had raised his concerns with Mark Zuckerberg and Sheryl 5 Sandberg, to no avail.40 1 2 6 64. In the August 2021 study discussed above, the authors stated: “[U]sers conform to 7 the expressive norms of their social network, expressing more outrage when they are embedded 8 in ideologically extreme networks where outrage expressions are more widespread…. Such norm 9 learning processes, combined with social reinforcement learning, might encourage more 10 moderate users to become less moderate over time, as they are repeatedly reinforced by their 11 peers for expressing outrage.”41 12 65. Indeed, the positive feedback loop created by Facebook in the form of “likes,” 13 “comments,” and “shares” drive user engagement with extremist content and reward user 14 participation in creating such content. Together with algorithms promoting hate speech, 15 misinformation, and conspiracy theories, Facebook has steered users to extremist groups and 16 trained those users to express more outrage. 17 D. Exploitation by Autocrats 18 66. Facebook’s system and algorithms are also susceptible to exploitation by 19 unscrupulous and autocratic politicians and regimes. In his book, McNamee wrote: 20 Facebook’s culture, design goals, and business priorities made the platform an easy target for bad actors, which Facebook aggravated with algorithms and moderation policies that amplified extreme voices. The architecture and business model that make Facebook successful also make it dangerous. Economics drive the company 21 22 23 24 39 25 26 Roger McNamee, Zucked: Waking Up to the Facebook Catastrophe, at 94-95 (Penguin 2020 ed.). 40 Id. at 4-7. 41 27 28 William J. Brady, Killian McLoughlin, Tuan N. Doan, Molly J. Crockett, How social learning amplifies moral outrage expression in online social networks, 7 SCIENCE ADVANCES, no. 33 (Aug. 13, 2021), https://www.science.org/doi/10.1126/sciadv.abe5641. CLASS ACTION COMPLAINT 24 Case No. __________________

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