1 that users see when opening up the app or entering the site and “the center of the Facebook 2 experience”—is driven by engagement. Posts with higher engagement scores are included and 3 prioritized in the News Feed, while posts with lower scores are buried or excluded altogether. 4 “[T]he Feed’s … logics can be understood through a design decision to elevate and amplify 5 ‘engaging’ content…. [T]he core logic of engagement remains baked into the design of the Feed 6 at a deep level.”15 7 39. Facebook engineers and data scientists meet regularly to assess the billions of 8 likes, comments and clicks Facebook users make every day to “divine ways to make us like, 9 comment and click more,” so that users will keep coming back and seeing more ads from the 10 company’s 2 million advertisers. Engineers are continually running experiments with a small 11 share of Facebook users to boost engagement. 16 Thus, Facebook’s design was the “result of 12 particular decisions made over time…. Every area has undergone meticulous scrutiny … by 13 teams of developers and designers…. [Facebook] has evolved through conscious decisions in 14 response to a particular set of priorities.”17 15 40. Facebook has consistently promoted and rewarded employees who contribute to 16 the company’s growth through a relentless focus on increased engagement of Facebook users; 17 employees who raise ethical and safety concerns tend to be ignored and marginalized and, 18 eventually, left the company.18 19 20 21 22 23 24 25 26 27 28 15 Luke Munn, Angry by design: toxic communication and technical architectures, HUMANIT SOC SCI COMMUN 7 (July 30, 2020), https://www.nature.com/articles/s41599-02000550-7. 16 Victor Luckerson, Here’s How Facebook’s News Feed Actually Works, TIME (July 9, 2015), https://time.com/collection-post/3950525/facebook-news-feed-algorithm/. 17 Luke Munn, Angry by design: toxic communication and technical architectures, HUMANIT SOC SCI COMMUN 7 (July 30, 2020), https://www.nature.com/articles/s41599-02000550-7. 18 Katie Canales, ‘Increasingly gaslit’: See the messages concerned Facebook employees wrote as they left the company, BUSINESS INSIDER (Oct. 28, 2021), https://www.businessinsider.com/facebook-papers-employee-departure-badge-post-gaslitburned-out-2021-10 (“[t]he employee said Facebook's infamous growth-first approach leads to rolling out ‘risky features.’ If employees propose reversing that risk, they’re seen as being ‘growth-negative, and veto’d by decision makers on those grounds,’ they said. They also said it’s difficult to establish ‘win/wins,’ or to roll out features that promote both safety and growth”). CLASS ACTION COMPLAINT 13 Case No. __________________