1 19. The brutal and repressive Myanmar military regime employed hundreds of 2 people, some posing as celebrities, to operate fake Facebook accounts and to generate hateful 3 and dehumanizing content about the Rohingya. 4 20. Anti-Rohingya content thereafter proliferated throughout the Facebook product 5 for years. Human rights and civil society groups have collected thousands of examples of 6 Facebook posts likening the Rohingya to animals, calling for Rohingya to be killed, describing 7 the Rohingya as foreign invaders, and falsely accusing Rohingya of heinous crimes. 8 9 21. It was clearly foreseeable, and indeed known to Facebook, that, by prioritizing and rewarding users for posting dangerous and harmful content online—as well as by 10 recommending extremist groups and allowing fake accounts created by autocrats to flourish on 11 its system—Facebook would radicalize users in Burma, causing them to then support or engage 12 in dangerous or harmful conduct in the offline world. 13 22. Despite having been repeatedly alerted between 2013 and 2017 to the vast 14 quantities of anti-Rohingya hate speech and misinformation on its system, and the violent 15 manifestation of that content against the Rohingya people, Facebook barely reacted and devoted 16 scant resources to addressing the issue. 17 23. The resulting Facebook-fueled anti-Rohingya sentiment motivated and enabled 18 the military government of Myanmar to engage in a campaign of ethnic cleansing against the 19 Rohingya. To justify and strengthen its hold on power, the government cast, by and through 20 Facebook, the Rohingya as foreign invaders from which the military was protecting the Burmese 21 people. Widespread anger toward, and fear of, the Rohingya made it possible for the government 22 to enhance its own popularity by persecuting the Rohingya. Meanwhile, few Burmese civilians 23 objected to the attendant human rights abuses and eventual acts of genocide; indeed, as described 24 herein, many civilians actively participated in atrocities committed against the Rohingya. 25 24. With the way cleared by Facebook, the military’s campaign of ethnic cleansing 26 culminated with “clearance operations” that began in August 2017. Security forces, accompanied 27 by civilian death squads armed with long swords, attacked dozens of Rohingya villages. More 28 CLASS ACTION COMPLAINT 8 Case No. __________________