1 Moreover, duplicative individual litigation of the complex legal and factual controversies 2 presented in this Complaint would increase the delay and expense to all parties and impose a 3 tremendous burden on the courts. By contrast, a class action would reduce the burden of case 4 management and advance the interests of judicial economy, speedy justice, and uniformity of 5 decisions. 6 FIRST CAUSE OF ACTION 7 STRICT PRODUCT LIABILITY 8 165. Plaintiff incorporates the foregoing allegations as if fully set forth herein. 9 166. Facebook makes its social media product widely available to users around the 167. Facebook designed its system and the underlying algorithms and in a manner that 10 world. 11 12 rewarded users for posting, and thereby encouraged and trained them to post, increasingly 13 extreme and outrageous hate speech, misinformation, and conspiracy theories attacking 14 particular groups. 15 168. The design of Facebook’s algorithms and product resulted in the proliferation and 16 intensification of hate speech, misinformation, and conspiracy theories attacking the Rohingya in 17 Burma, radicalizing users, causing injury to Plaintiff and the Class, as described above. 18 Accordingly, through the design of its algorithms and product, Facebook (1) contributed to the 19 development and creation of such hate speech and misinformation and (2) radicalized users, 20 causing them to tolerate, support, and even participate in the persecution of and ethnic violence 21 against Plaintiff and the Class. 22 169. Because (1) the persecution of the Rohingya by the military government was 23 widely known before Facebook launched its product in Burma and (2) Facebook was repeatedly 24 warned after the launch that hate speech and misinformation on the system was likely to result in 25 ethnic violence, Facebook knew and had reason to expect that the Myanmar military and non- 26 Rohingya civilians would engage in violence and commit atrocities against Plaintiff and the 27 Class. 28 CLASS ACTION COMPLAINT 67 Case No. __________________