At other large tech companies like Google, any independent researcher can download from the Internet the company’s search results and write papers about what they find. And they do. But Facebook hides behind walls that keeps researchers and regulators from understanding the true dynamics of their system….35 1 2 3 4 58. Nevertheless, it is now clear that, by modifying the design of its algorithms and 5 system, Facebook can influence and manipulate the quantity, substance, and emotional tone of 6 the content its users produce. Through its dopamine-based incentive structure of social rewards 7 and cues, as well as its algorithmic promotion of hate speech and misinformation, Facebook 8 contributes to and participates in the development and creation of outraged, extreme, and 9 divisive content. 10 59. It’s obviously not in Facebook’s favor—especially its bottom line—to curb the 11 spread of negative content and adjust its algorithm to promote positive content. One designer and 12 technologist proposed four different interventions to address the “problems of polarization, 13 dehumanization, and outrage, three of the most dangerous byproducts” of tools such as 14 Facebook. The four interventions described in the article include “Give Humanizing Prompts,” 15 “Picking out unhealthy content with better metrics,” “Filter unhealthy content by default,” and 16 “Give users feed control.” Facebook had not implemented any such interventions, undoubtedly 17 because, as the author admitted, the interventions “will all likely result in short-term reductions 18 in engagement and ad revenue.”36 19 60. Facebook has options for moderating its algorithms’ tendency to promote hate 20 speech and misinformation, but it rejects those options because the production of more engaging 21 content takes precedence. In a September 2021 article, based on recently leaked internal 22 documents, the Wall Street Journal described how Facebook had modified its News Feed 23 24 25 26 35 Facebook Whistleblower Frances Haugen Testifies on Children & Social Media Use: Full Senate Hearing Transcript, REV (Oct. 5, 2021), https://www.rev.com/blog/transcripts/facebook-whistleblower-frances-haugen-testifies-onchildren-social-media-use-full-senate-hearing-transcript. Tobias Rose-Stockwell, Facebook’s problems can be solved with design, QUARTZ (Apr. 30, 2018) (emphases in original), https://qz.com/1264547/facebooks-problems-can-be-solvedwith-design/. 36 27 28 CLASS ACTION COMPLAINT 22 Case No. __________________