1 Buddhists have their own Facebooks and are really inciting a lot of violence and a lot of hatred 2 against the Rohingya or other ethnic minorities.” 149 3 D. Civilian Participation in the 2017 “Clearance Operations” 4 120. The radicalization of the Burmese population, to which Facebook materially 5 contributed, did not merely ensure tolerance of and support for the military’s campaign of 6 genocide against the Rohingya, it also allowed the military to recruit, equip, and train “civilian 7 death squads” that would actively participate in the atrocities. 150 8 9 10 121. The U.N. Mission drew a connection between anti-Rohingya reporting and hate speech, ethnic tension, and the ability of the military to recruit non-Rohingya civilians to perpetrate violence against the Rohingya, finding: 11 • “The inflammatory nature of much of this reporting [on activities of Rohingya militants], often characterizing Rohingya as ‘Bengali terrorists,’ coupled with rising vitriolic discourse and hate speech against the Rohingya, fuelled an already volatile situation.”151 • “[The reports] deepened inter-communal suspicion and fear. They were likely a factor in a notable breakdown in the relationship between the communities, particularly in the weeks leading up to 25 August 2017.”152 • “During this period [beginning in late 2016], the Myanmar authorities made increasing efforts to recruit ethnic Rakhine as members of the security apparatus…. Moreover, the recruitment of non-Rohingya to Government supported militias … continued throughout this period in Rakhine State.”153 12 13 14 15 16 17 18 19 20 21 22 23 24 25 149 Libby Hogan, Michael Safi, Revealed: Facebook hate speech exploded in Myanmar during Rohingya crisis, THE GUARDIAN (Apr. 2, 2018), https://www.theguardian.com/world/2018/apr/03/revealed-facebook-hate-speech-exploded-inmyanmar-during-rohingya-crisis; see Tom Miles, U.N. investigators cite Facebook role in Myanmar crisis, REUTERS (Mar. 12, 2018), https://www.reuters.com/article/us-myanmarrohingya-facebook-idUKKCN1GO2PN. 150 Jason Motlagh, The Survivors of the Rohingya Genocide, ROLLING STONE (Aug. 9, 2018), https://www.rollingstone.com/politics/politics-features/rohingya-genocide-myanmar-701354/. 151 26 27 28 UNHRC Report, ¶ 1134, https://digitallibrary.un.org/record/1643079/files/A_HRC_39_CRP-2-EN.pdf. 152 Id. ¶ 1135. 153 Id. ¶ 1143-44. CLASS ACTION COMPLAINT 49 Case No. __________________

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