1 7. The Rohingya people who are left in Burma live under constant threat of arrest, 2 violence, abuse, and discrimination. Those who made it out, too, live in fear for themselves and 3 their loved ones. Many Rohingya refugees around the world live in abject poverty and in highly 4 unstable situations that could change at any time depending on the political climate of the 5 country in which they now reside. Even those in the Bangladesh refugee camp are not safe: In 6 September 2021, a well-known and outspoken Rohingya community leader was murdered in the 7 camp, with many believing that the murder was carried out by supporters of the Myanmar 8 military. 9 8. Woven throughout the years of this horrific tragedy are two constants: (1) the 10 enduring resilience of the Rohingya people and (2) the willingness of Defendant Meta to 11 knowingly facilitate the spread of anti-Rohingya hate speech, misinformation, and the 12 widespread incitement of violence against the Rohingya people. 13 9. So deep was Facebook’s penetration into daily life in Burma and its role in the 14 out-of-control spread of anti-Rohingya content, that Marzuki Darusman, chairman of the U.N. 15 Independent International Fact-Finding Mission on Myanmar, described Facebook as having 16 played a “determining role” in the genocide. And, worst of all, it allowed the dissemination of 17 hateful and dangerous misinformation to continue for years, long after it was repeatedly put on 18 notice of the horrific and deadly consequences of its inaction. 19 10. Amazingly (at least to those not privy to Facebook’s inner workings), Facebook 20 has long been aware that hateful, outraged, and politically extreme content (especially content 21 attacking a perceived “out-group”) is oxygen to the company’s blood. The more horrendous the 22 content, the more it generates “engagement” (a measure of users’ interaction with content on the 23 system (“likes,” “shares,” comments, etc.)). As Facebook has determined through years of study 24 and analysis: hate and toxicity fuel its growth far more effectively than updates about a user’s 25 favorite type of latte. 26 27 11. Rather than taking what it’s learned to change its practices, Facebook made a corporate decision to lean into the hate. Its algorithms were carefully designed to actively exploit 28 CLASS ACTION COMPLAINT 4 Case No. __________________