1 93. Facebook, by its very design, turned out to be the perfect tool for the Burmese 2 military and Buddhist extremists to use in promoting their message of religious intolerance and, 3 ultimately, ethnic cleansing. The amplification and propagation of hateful, extremist, and 4 polarizing messages and the radicalization of users are inevitable results of the algorithms that 5 Facebook intentionally and meticulously built into its system. 6 A. Facebook Participated in Inciting Violence Against the Rohingya (2012-2017) 94. On June 8, 2012, there were violent confrontations between Rohingya and ethnic 7 8 9 Rakhine groups; security forces killed a number of the Rohingya and Muslim homes and shops 10 were set on fire and looted.91 In the ensuing weeks and months, the Rohingya suffered more 11 killings at the hands of Tatmadaw soldiers, burnings and lootings, sexual and gender-based 12 violence, arbitrary arrests, and torture in prison. 92 The U.N. Mission drew a direct connection 13 between the Burmese government’s use of Facebook and the violence against the Rohingya that 14 began in June 2012: 15 On 1 June 2012 … the spokesperson of the President of Myanmar … posted a statement on his personal Facebook account. He warned about the arrival from abroad of “Rohingya terrorists” … and stated that the Myanmar troops would “completely destroy them….” Although this post was later deleted, the impact of a high official equating the Rohingya population with terrorism may have been significant ahead of the 2012 violence, which erupted a week later. 93 16 17 18 19 [P]osts early in 2012 about the alleged rape and murder by Rohingya men of a Buddhist woman were reportedly shared widely and are considered to have contributed to the tension and violence in Rakhine State in that year.94 20 21 22 95. Incitement of violence on Facebook continued beyond 2012: “[A]n online news 23 report from 30 June 2014 … alleged that two Muslim teashop owners had raped a Buddhist 24 woman…. [A prominent Buddhist monk] reposted the article on his Facebook page…. Violence 25 26 27 91 92 93 94 28 Id. ¶¶ 630-33. Id. ¶¶ 635-39, 662-63, 669-78. Id. ¶¶ 705-06. Id. ¶ 1347. CLASS ACTION COMPLAINT 35 Case No. __________________

Select target paragraph3