1 and interactions on the [Facebook] platform as did trustworthy news sources, such as CNN or the 2 World Health Organization.”24 3 48. In testimony before Congress in September 2020, Tim Kendall, Facebook’s first 4 Director of Monetization—likening Facebook’s business model to that of Big Tobacco— 5 explained how such content makes Facebook addictive: 6 At Facebook, I believe we sought to mine as much human attention as possible and turn it into historically unprecedented profits. To do this, we didn’t simply create something useful and fun; we took a page from Big Tobacco’s playbook, working to make our offering addictive at the outset…. 7 8 9 The next page in Big Tobacco’s playbook was to add bronchodilators to cigarettes. This allowed the smoke to get in contact with more surface area of the lungs. Allowing for misinformation, conspiracy theories, and fake news to flourish were Facebook’s bronchodilators. 10 11 12 But that incendiary content wasn’t enough. Tobacco companies then added ammonia to cigarettes to increase the speed with which nicotine traveled to the brain. Facebook’s ability to deliver this incendiary content to the right person, at the right time, in the exact right way—through their algorithms—that is their ammonia. And we now know it fosters tribalism and division. 13 14 15 Social media preys on the most primal parts of your brain; it provokes, it shocks, and it enrages…. 16 17 Facebook and their cohorts worship at the altar of engagement and cast other concerns aside, raising the voices of division, anger, hate, and misinformation to drown out the voices of truth, justice, morality, and peace.25 18 19 49. Content attacking opposing groups is particularly engaging. Zeynep Tufekci, a 20 sociologist at University of North Carolina, has written that: 21 the new, algorithmic gatekeepers aren’t merely (as they like to believe) neutral conduits for both truth and falsehood. They make their money by keeping people on their sites and apps; that aligns their incentives closely with those who stoke outrage, spread 22 23 24 25 26 24 Elizabeth Dwoskin, Misinformation on Facebook got six times more clicks than factual news during the 2020 election, study says, WASHINGTON POST (Sept. 4, 2021), https://www.washingtonpost.com/technology/2021/09/03/facebook-misinformation-nyu-study/. Mainstreaming Extremism: Social Media’s Role in Radicalizing America: Hearing Before the House Subcommittee on Consumer Protection and Commerce, 116th Congress (Sept. 24, 2020) (statement of Timothy Kendall). 25 27 28 CLASS ACTION COMPLAINT 17 Case No. __________________