1 example, real news from misinformation).” 66 As noted by Sarah Su, a Facebook employee who 2 works on content safety issues on the News Feed, “[w]hat you’ve seen in the past five years is 3 almost an entire country getting online at the same time, we realized that digital literacy is quite 4 low. They don’t have the antibodies to [fight] viral misinformation.” 67 5 84. The U.N. Independent International Fact-Finding Mission on Myanmar (the 6 “U.N. Mission”) investigating the genocide in Burma reported: “[t]he Myanmar context is 7 distinctive … because of the relatively new exposure of the Myanmar population to the Internet 8 and social media…. In a context of low digital and social media literacy, the Government’s use 9 of Facebook for official announcements and sharing of information further contributes to users’ 10 perception of Facebook as a reliable source of information.” 68 11 85. Thet Swei Win, the director of an organization that works to promote social 12 harmony between ethnic groups in Burma, told the BBC “[w]e have no internet literacy…[w]e 13 have no proper education on how to use the internet, how to filter the news, how to use the 14 internet effectively.”69 15 86. As described by the U.N., “[t]he relative unfamiliarity of the population with the 16 Internet and with digital platforms and the easier and cheaper access to Facebook have led to a 17 situation in [Burma] where Facebook is the Internet…. For many people, Facebook is the main, 18 if not only, platform for online news and for using the Internet more broadly.” 70 “Facebook is 19 arguably the only source of information online for the majority in [Burma]”71 and “Facebook is a 20 21 66 67 22 23 24 25 26 27 28 Id. Steven Levy, Facebook: the Inside Story (Blue Rider Press 2020). 68 UNHRC Report, ¶¶ 1342, 1345, https://digitallibrary.un.org/record/1643079/files/A_HRC_39_CRP-2-EN.pdf. 69 Anisa Sudebar, The country where Facebook posts whipped up hate, BBC TRENDING (Sept. 12, 2018), https://www.bbc.com/news/blogs-trending-45449938. 70 UNHRC Report, ¶ 1345, https://digitallibrary.un.org/record/1643079/files/A_HRC_39_CRP-2-EN.pdf. 71 Libby Hogan, Michael Safi, Revealed: Facebook hate speech exploded in Myanmar during Rohingya crisis, THE GUARDIAN (Apr. 2, 2018), https://www.theguardian.com/world/2018/apr/03/revealed-facebook-hate-speech-exploded-inmyanmar-during-rohingya-crisis. CLASS ACTION COMPLAINT 31 Case No. __________________