1 Facebook in a manner that Facebook knew or should have known would create an unreasonable 2 risk to Plaintiff and the Class. 3 177. Because (1) the persecution of the Rohingya by the military government was 4 widely known before Facebook launched its product in Burma and (2) Facebook was repeatedly 5 warned after the launch that hate speech and misinformation on the system was likely to result in 6 ethnic violence, Facebook knew and had reason to expect that the proliferation of such content 7 on its system could incite and facilitate violence and atrocities by the Myanmar military and non- 8 Rohingya civilians against Plaintiff and the Class. 9 178. Moreover, the kind of harm resulting from the ethnic violence committed by the 10 Myanmar military and their non-Rohingya supporters is precisely the kind of harm that could 11 have been reasonably expected from Facebook’s negligent propagation and prioritization of anti- 12 Rohingya hate speech and misinformation on its system—e.g., wrongful death, personal injury, 13 pain and suffering, emotional distress, and property loss. 14 179. Facebook’s acts and omissions in breach of its duty of care were a proximate 15 cause of the persecution of and ethnic violence against—and resulting injuries to—Plaintiff and 16 the Class. 17 18 19 180. Plaintiff and the Class are entitled to actual damages proximately caused by Facebook’s negligence of its algorithms and product. 181. Plaintiff and the Class are further entitled to punitive damages caused by 20 Facebook’s failure to correct or withdraw its algorithms and system after Facebook knew about 21 their defects. 22 23 24 25 PRAYER FOR RELIEF WHEREFORE, Plaintiff Jane Doe, on behalf of herself and the Class, respectfully requests that this Court enter an Order: A. Certifying the case as a class action on behalf of the Class, as defined above, 26 appointing Plaintiff Jane Doe as representative of the Class, and appointing her counsel as Class 27 Counsel; 28 CLASS ACTION COMPLAINT 69 Case No. __________________