1 • “[I]n a 21 September 2017 post on Facebook … [the Tatmadaw] Commander-in-Chief … states that, ‘the Bengali population exploded and the aliens tried to seize the land of the local ethnics….’”144 • “[O]n 11 October 2017 the Commander-in-Chief … posted: ‘there is exaggeration to say that the number of Bengali fleeing to Bangladesh is very large.’ At the time more than 600,000 Rohingya had fled … Myanmar in a period of six weeks.”145 • “On 27 October 2017, in another Facebook post entitled ‘every citizen has the duty to safeguard race, religion, cultural identities and national interest,’ [the] Commander-in-Chief stated that ‘all must … preserve the excellent characteristics of the country …’”146 2 3 4 5 6 7 8 9 118. Rolling Stone reported that “[m]ore shocking was how [the military’s] bigoted 10 doctrine was parroted by Aung San Suu Kyi, the Nobel Peace Prize-winning human-rights icon 11 and de facto leader of Myanmar…. When she finally broke her silence, on Facebook, nearly two 12 weeks after the 2017 attacks began, it was in cold defense of the same military that kept her 13 under house arrest for 15 years when she was the country’s leading dissident. Suu Kyi blamed 14 ‘terrorists’ for promoting a ‘huge iceberg of misinformation’ about the violence engulfing 15 Rakhine. She made no mention of the Rohingya exodus.”147 16 119. The U.N. additionally found that there was “no doubt that the prevalence of hate 17 speech in Myanmar significantly contributed to increased tension and a climate in which 18 individuals and groups may become more receptive to incitement and calls for violence. This 19 also applies to hate speech on Facebook.”148 In early 2018, U.N. investigator Yanghee Lee 20 warned that “Facebook has become a beast,” and that “we know that the ultra-nationalist 21 22 23 24 144 145 146 25 26 27 28 Id. ¶ 1338. Id. ¶ 1339. Id. ¶ 1341. 147 Jason Motlagh, The Survivors of the Rohingya Genocide, ROLLING STONE (Aug. 9, 2018), https://www.rollingstone.com/politics/politics-features/rohingya-genocide-myanmar-701354/ (emphasis added). 148 UNHRC Report, ¶ 1354, https://digitallibrary.un.org/record/1643079/files/A_HRC_39_CRP-2-EN.pdf (emphasis added). CLASS ACTION COMPLAINT 48 Case No. __________________