and it was clearly being used to prop up an authoritarian regime with an egregious record on human rights. 1 2 The Azerbaijani network used the same tactic that was seen in Honduras—thousands of Facebook Pages set up to look like user accounts—but instead of creating fake likes, the Pages were used to harass. Over one 90-day period in 2019, it produced approximately 2.1m negative, harassing comments on the Facebook Pages of opposition leaders and independent media outlets, accusing them of being traitors and praising the country’s autocratic leader, President Ilham Aliyev, and his ruling party, the YAP. 3 4 5 6 7 Facebook did not employ a dedicated policy staffer or market specialist for Azerbaijan, and neither its eastern European nor Middle Eastern policy teams took responsibility for it. Eventually Zhang discovered that the Turkey policy team was supposed to cover the former Soviet republic, but none of them spoke Azeri or had expertise in the country. As of August 2020, Facebook did not have any full-time or contract operations employees who were known to speak Azeri, leaving staff to use Google Translate to try to understand the nature of the abuse. 8 9 10 11 12 Facebook did not take down those fake accounts or Pages until more than a year after Zhang 13 reported them.45 14 E. Facebook’s Algorithm Has Successfully Radicalized Its Users 15 70. By prioritizing hate speech and misinformation in users’ News Feeds, training 16 users to produce ever more extreme and outraged content, recommending extremist groups, and 17 allowing its product to be exploited by autocrats, Facebook radicalizes users and incites them to 18 violence. 19 71. As Chamath Palihapitiya, Facebook’s former vice president for user growth, told 20 an audience at Stanford Business School: “I think we have created tools that are ripping apart the 21 social fabric of how society works … [t]he short-term, dopamine-driven feedback loops we’ve 22 created are destroying how society works … No civil discourse, no cooperation[,] 23 misinformation, mistruth. And it’s not an American problem…” 46 24 25 26 45 Id. 46 27 28 James Vincent, Former Facebook exec says social media is ripping apart society, THE VERGE (Dec. 11, 2017), https://www.theverge.com/2017/12/11/16761016/former-facebookexec-ripping-apart-society. CLASS ACTION COMPLAINT 26 Case No. __________________