In almost all of our work, we have to answer hard questions about what we believe. We have to justify the metrics and make sure they aren’t losing out on a bigger picture. But connecting people. That’s our imperative. Because that’s what we do. We connect people.4 1 2 3 4 14. In short, Facebook sees itself, at best, as an amoral actor on the world stage, with 5 the sole objective of growth, regardless of how it impacts its users or the world more generally. 6 To be clear, the last five years, and in fact just the last five months, have made it abundantly 7 clear that Facebook’s path to promote the very worst of humanity was not the result of a bug, but 8 rather a carefully designed feature. 5 9 15. The manifestation of this can be seen in nearly everything Facebook does. For 10 example: 11 • Before and after the 2020 election, it failed to stop mass publication and reposting of misinformation about the legitimacy of the election and the subsequent calls for violence that culminated in the January 6th attack on our nation’s Capitol; • Facebook has known about human traffickers using its system for years, but only after “[i]t got so bad that in 2019”, and Apple threatened to pull Facebook and Instagram’s access to the App Store, did “Facebook employees rush[] to take down problematic content and make emergency policy changes avoid what they described as a ‘potentially severe’ consequence for the business.”6; • In another ongoing example, throughout the COVID-19 global pandemic, Facebook has been a constant vehicle for the mass distribution of misinformation on COVID, masks, and vaccines; and 12 13 14 15 16 17 18 19 20 4 21 22 23 24 25 26 Ryan Mac, Growth At Any Cost: Top Facebook Executive Defended Data Collection In 2016 Memo — And Warned That Facebook Could Get People Killed, BUZZFEED https://www.buzzfeednews.com/article/ryanmac/growth-at-any-cost-top-facebook-executivedefended-data (emphasis added). 5 In most companies, the total disregard shown for the human toll of corporate action would have been met with termination; here, however, Andrew Bosworth not only stayed employed, but was in fact placed in charge of (and became a chief spokesman for) arguably the company’s largest and most aggressive expansion ever: the “Metaverse.” See Kurt Wagner, Who’s Building Facebook’s Metaverse? Meet CTO Andrew Bosworth, BLOOMBERG (Oct. 27, 2021), https://www.bloomberg.com/news/articles/2021-10-27/facebook-fb-new-cto-andrewbosworth-is-the-man-building-the-metaverse. 6 27 28 Clare Duffy, Facebook has known it has a human trafficking problem for years. It still hasn’t fully fixed it, CNN (Oct. 25, 2021), https://www.cnn.com/2021/10/25/tech/facebookinstagram-app-store-ban-human-trafficking/index.html. CLASS ACTION COMPLAINT 6 Case No. __________________