1 on September 28, 2021, three social media researchers testified about Facebook’s attempts to 2 block their access to the data they needed: 3 • Laura Edelson of New York University testified: “this summer, Facebook cut off my team’s access to their data. We used that very data to support the finding in our recent study that posts from misinformation sources on Facebook got six times more engagement than factual news during the 2020 elections, to identify multiple security and privacy vulnerabilities that we have reported to Facebook, and to audit Facebook’s own, public-facing Ad Library for political ads.”32 • Alan Mislove, a Professor of Computer Sciences at Northeastern University, testified: “Facebook recently criticized a study on misinformation by saying it focused on who engages with content and not who sees it—but that’s only true because Facebook does not make such impression data available to researchers.”33 • Kevin T. Leicht, a Professor of Sociology at University of Illinois Urbana-Champaign testified: “there are limited amounts of social media data available due to company restrictions placed on that data. Many researchers fear litigation that may result from analyzing and publishing results from these data.”34 4 5 6 7 8 9 10 11 12 13 57. On October 5, 2021, Haugen testified before Congress: 14 [N]o one truly understands the destructive choices made by Facebook except Facebook…. 15 16 A company with such frightening influence over so many people, over their deepest thoughts, feelings, and behavior, needs real oversight. But Facebook’s closed design means it has no real oversight. Only Facebook knows how it personalizes your Feed for you. 17 18 19 20 32 21 22 23 24 25 Hearing on The Disinformation Black Box: Researching Social Media Data before the Subcomm. on Oversight, 117th Cong. (2021) (testimony of Laura Edelson, NYU Cybersecurity for Democracy), https://www.congress.gov/117/meeting/house/114064/witnesses/HHRG-117SY21-Wstate-EdelsonL-20210928.pdf. 33 Hearing on The Disinformation Black Box: Researching Social Media Data before the Subcomm. on Oversight, 117th Cong. (2021) (testimony of Alan Mislove, Professor of Computer Sciences at Northeastern University), https://www.congress.gov/117/meeting/house/114064/witnesses/HHRG-117-SY21-WstateMisloveA-20210928.pdf. 34 26 27 28 Hearing on The Disinformation Black Box: Researching Social Media Data before the Subcomm. on Oversight, 117th Cong. (2021) (testimony of Kevin T. Leicht, a Professor of Sociology at University of Illinois Urbana-Champaign), https://www.congress.gov/117/meeting/house/114064/witnesses/HHRG-117-SY21-WstateLeichtK-20210928.pdf. CLASS ACTION COMPLAINT 21 Case No. __________________

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