1 • “‘They were warned so many times,’ said David Madden, a tech entrepreneur who worked in Myanmar. He said he told Facebook officials in 2015 that its platform was being exploited to foment hatred in a talk he gave at its headquarters in Menlo Park, California. About a dozen Facebook people attended the meeting in person…. Others joined via video. ‘It couldn’t have been presented to them more clearly, and they didn’t take the necessary steps,’ Madden said.”169 • Brooke Binkowski, who worked for an organization that did factchecking for Facebook beginning in early 2017, “said she tried to raise concerns about misuse of the platform abroad, such as the explosion of hate speech and misinformation during the Rohingya crisis in Myanmar…. ‘I was bringing up Myanmar over and over and over,’ she said. ‘They were absolutely resistant.’ Binkowski, who previously reported on immigration and refugees, said Facebook largely ignored her: ‘I strongly believe that they are spreading fake news on behalf of hostile foreign powers and authoritarian governments as part of their business model.’” 170 2 3 4 5 6 7 8 9 10 11 126. Facebook’s response to such warnings about hate speech on its websites in Burma 12 was, however, utterly ineffective. The extreme import of what Matt Schissler was describing 13 “didn’t seem to register with the Facebook representatives. They seemed to equate the harmful 14 content with cyberbullying: Facebook wanted to discourage people from bulling across the 15 system, he said, and they believed that the same set of tools they used to stop a high school 16 senior from intimidating an incoming freshman could be used to stop Buddhist monks in 17 Myanmar from spreading malicious conspiracy theories about Rohingya Muslims.”171 18 127. Facebook had almost no capability to monitor the activity of millions of users in 19 Burma: “In 2014, the social media behemoth had just one content reviewer who spoke Burmese: 20 a local contractor in Dublin, according to messages sent by Facebook employees in the private 21 Facebook chat group. A second Burmese speaker began working in early 2015, the messages 22 show.” Accenture, to whom Facebook outsourced the task of monitoring for violations of its 23 169 24 25 26 27 28 Steve Stecklow, Why Facebook is losing the war on hate speech in Myanmar, REUTERS (Aug. 15, 2018), https://www.reuters.com/investigates/special-report/myanmar-facebook-hate/. 170 Sam Levin, ‘They don’t care’: Facebook factchecking in disarray as journalists push to cut ties, THE GUARDIAN (Dec. 13, 2018), https://www.theguardian.com/technology/2018/dec/13/they-dont-care-facebook-fact-checkingin-disarray-as-journalists-push-to-cut-ties. 171 Sheera Frenkel and Cecilia Kang, An Ugly Truth: Inside Facebook’s Battle for Domination, at 178 (HarperCollins 2021) (emphasis added). CLASS ACTION COMPLAINT 53 Case No. __________________