1 161. Commonality and Predominance. There are many questions of law and fact 2 common to the claims of Plaintiff and the Class and those questions predominate over any 3 questions that may affect individual members of the Class. These common questions of law and 4 fact include: 5 • Whether Facebook (the product) contains design defects that harmed Rohingya Muslims, and, if so, whether Facebook (the company) is strictly liable for them; • Whether Facebook owed a duty of care to Rohingya Muslims when entering the Burmese market; • Whether Facebook breached any duty of care to Rohingya Muslims in the way it operated in Burma; and • Whether Facebook’s Burmese operations caused harm to Rohingya Muslims. 6 7 8 9 10 11 12 162. Typicality. Plaintiff’s claims are typical of the claims of all members of the 13 Class. Plaintiff and the other Class members sustained damages as a result of Defendant’s 14 uniform wrongful conduct. 15 163. Adequacy. Plaintiff will fairly and adequately protect the interests of the Class. 16 Plaintiff has retained counsel with substantial experience in prosecuting complex class actions 17 and particular expertise in litigation involving social media. Plaintiff and her counsel are 18 committed to vigorously prosecuting the action on behalf of the Class and have the resources to 19 do so. Neither the Plaintiff nor her counsel have any interests adverse to those of the other 20 members of the Class. Defendant has no defenses unique to Plaintiff. 21 164. Superiority. A class action is superior to all other available methods for the fair 22 and efficient adjudication of this controversy and joinder of all members of the Class is 23 impracticable. The members of the proposed Class are, by definition, recent immigrants and lack 24 the tangible resources, language skills, and cultural sophistication to access and participate 25 effectively in the prosecution of individual lawsuits in any forum having jurisdiction over 26 Defendant. A class action in which the interests of the Class are advanced by representative 27 parties therefore provides the greatest chance for individual Class members to obtain relief. 28 CLASS ACTION COMPLAINT 66 Case No. __________________