other celebrities, like a beauty queen with a penchant for parroting military propaganda…. 1 2 Those then became distribution channels for lurid photos, false news and inflammatory posts, often aimed at Myanmar’s Muslims, the people said. Troll accounts run by the military helped spread the content, shout down critics and fuel arguments between commenters to rile people up. Often, they posted sham photos of corpses that they said were evidence of Rohingya-perpetrated massacres, said one of the people. 3 4 5 6 Digital fingerprints showed that one major source of the Facebook content came from areas outside Naypyidaw, where the military keeps compounds, some of the people said. 108 7 8 9 102. By October 2015, the Allard K. Lowenstein International Human Rights Clinic at 10 Yale Law School had already concluded that there was “strong evidence that genocide is being 11 committed against Rohingya.”109 The worst, however, was yet to come. 12 13 14 B. The August 2017 “Clearance Operations” and Their Aftermath: A “Human Rights Catastrophe” 103. The Myanmar military’s campaign of ethnic cleansing culminated in August 2017 15 with the “Clearance Operations.” The U.N. reported that “[d]uring the course of the operation 16 more than 40 percent of all villages in northern Rakhine State were partially or totally 17 destroyed…. As a result, over 725,000 Rohingya had fled to Bangladesh by September 2018.”110 18 The August 2017 clearance operations “caused the disintegration of a community and resulted in 19 a human rights catastrophe, the effects of which will span generations.” 111 Additional “clearance 20 21 22 23 24 25 26 27 28 Paul Mozur, A Genocide Incited on Facebook, With Posts From Myanmar’s Military, NEW YORK TIMES (Oct. 15, 2018), https://www.nytimes.com/2018/10/15/technology/myanmarfacebook-genocide.html. 109 Persecution of the Rohingya Muslims: Is Genocide Occurring in Myanmar’s Rakhine State, ALLARD K. LOWENSTEIN INTERNATIONAL HUMAN RIGHTS CLINIC, YALE LAW SCHOOL (Oct. 2015) at 1, https://law.yale.edu/sites/default/files/documents/pdf/Clinics/fortifyrights.pdf. 110 UNHRC Report, ¶ 751, https://digitallibrary.un.org/record/1643079/files/A_HRC_39_CRP-2-EN.pdf. The U.N. Mission documented the clearance operations exhaustively: “The Mission obtained a wealth of information on these events, including over 600 interviews with victims and eyewitnesses, satellite imagery, documents, photographs and videos. It examined many incidents in detail. It found consistent patterns of the most serious human rights violations and abuses.” Id. ¶ 754. 111 Id. ¶ 749. 108 CLASS ACTION COMPLAINT 39 Case No. __________________

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