the Rohingya and manipulated the public into supporting their military onslaught.179 1 2 Apparently not eager to help prove that Facebook had been complicit in genocide, Facebook’s lawyers denied Smith’s requests for access to the data: “‘Facebook had the chance to do the right thing again and again, but they didn’t. Not in Myanmar,’ said Smith. ‘It was a decision, and they chose not to help.’”180 3 4 5 6 7 134. participating in disinformation efforts that led to the genocide. 8 9 Worst yet, Facebook’s activity promoted such content to its users, thus actively 135. Facebook ultimately ratified its conduct and its involvement of the genocide and violence in Burma by admitting shortcomings of its system. 10 11 12 F. Facebook Admits That It Had a Responsibility to Prevent Its Product From Being Used to Incite Violence and Genocide 136. In 2018, after the “clearance operations,” several senior Facebook executives, 13 including Mark Zuckerberg, belatedly admitted that the company had a responsibility to prevent 14 its product from being used to incite violence in Burma and should have done more in that 15 regard. On April 10, 2018, Zuckerberg testified before the U.S. Senate: 16 SEN. PATRICK LEAHY: ... [S]ix months ago, I asked your general counsel about Facebook’s role as a breeding ground for hate speech against Rohingya refugees. Recently, U.N. investigators blamed Facebook for playing a role in inciting possible genocide in Myanmar. And there has been genocide there…. 17 18 19 This is the type of content I’m referring to. It calls for the death of a Muslim journalist. Now, that threat went straight through your detection system, it spread very quickly, and then it took attempt after attempt after attempt, and the involvement of civil society groups, to get you to remove it. 20 21 22 Why couldn’t it be removed within 24 hours? 23 ZUCKERBERG: Senator, what’s happening in Myanmar is a terrible tragedy, and we need to do more.... 24 25 26 27 28 Sheera Frenkel and Cecilia Kang, An Ugly Truth: Inside Facebook’s Battle for Domination, at 185-86 (HarperCollins 2021). 180 Id. at 186-87. 179 CLASS ACTION COMPLAINT 57 Case No. __________________