1 II. 2 The Introduction of Facebook Led to a Crisis of Digital Literacy in Burma 77. In addition to high engagement, continued user growth was critical to Facebook’s 3 success. “If we fail to retain existing users or add new users, … our revenue, financial results, 4 and business may be significantly harmed.” 57 By 2012, Facebook reported 1.06 billion monthly 5 active users (“MAUs”) with 84% of those accessing Facebook from outside the United States, 6 meaning that there were already about 170 million MAUs in the United States—equal to more 7 than half the U.S. population. 58 To ensure continued growth, Facebook would have to gain users 8 in developing countries, many of whom had no previous access to the Internet. 9 78. Prior to 2011, in an atmosphere of extreme censorship, only about 1% of the 10 Burmese population had cell phones. That percentage grew dramatically with the liberalization 11 that began in 2011.59 In 2013, when two foreign telecom companies were permitted to enter the 12 market, the cost of a SIM card fell from more than $200 to as little as $2, and by 2016, nearly 13 half the population had mobile phone subscriptions, most with Internet access. 60 14 79. Facebook took active steps to ensure that it would have a dominant position in the 15 emerging Burmese market. “Entering the country in 2010, Facebook initially allowed its app to 16 be used without incurring data charges, so it gained rapid popularity. It would come pre-loaded 17 on phones bought at mobile shops….”61 18 19 80. Facebook would eventually pursue a similar strategy for penetrating other developing markets, as reflected in its “Free Basics” product. Free Basics was “a Facebook- 20 21 22 23 24 25 26 27 28 57 Facebook 2012 10-K, at 13, https://www.sec.gov/Archives/edgar/data/1326801/000132680113000003/fb12312012x10k.htm#s5D6A63A4BB6B6A7AD01CD7A5A25638E4. 58 Id. at 8. 59 Report of the detailed findings of the Independent International Fact-Finding Mission on Myanmar, UNITED NATIONS HUMAN RIGHTS COUNCIL (Sept. 17, 2018), https://digitallibrary.un.org/record/1643079/files/A_HRC_39_CRP-2-EN.pdf (“UNHRC Report”) ¶ 1343. 60 Steve Stecklow, Why Facebook is losing the war on hate speech in Myanmar, REUTERS (Aug. 15, 2018), https://www.reuters.com/investigates/special-report/myanmar-facebook-hate/. 61 Saira Asher, Myanmar coup: How Facebook became the ‘digital tea shop,’ BBC NEWS (Feb. 4, 2021), https://www.bbc.com/news/world-asia-55929654. CLASS ACTION COMPLAINT 29 Case No. __________________