1 • Disturbingly, whistleblower Frances Haugen shed light on Facebook’s knowledge that its websites, including both Facebook and Instagram, led to mental health and body-image issues, and in some cases, eating disorders and suicidal thoughts, in teens. Yet, Facebook’s own internal research also showed that the more that teenagers had these thoughts and emotions, the more they used the app. So, it did nothing to protect the millions of children viewing its content daily and maintained the status quo. 16. The clear underlying message of the Bosworth memo above, as well as these 2 3 4 5 6 examples, is one of sacrifice: that the victims of a terrorist attack can be sacrificed for 7 Facebook’s growth; that an innocent child who takes her own life because she is bullied can be 8 sacrificed for Facebook’s growth; that democracy can be sacrificed for Facebook’s growth; that 9 the mental and physical health of children can be sacrificed for Facebook’s growth; that the 10 prevention of a global pandemic can be scarified for Facebook’s growth; and, as will be fully 11 described here, that an entire ethnic population can be sacrificed for Facebook’s relentless 12 growth. 13 17. Because Facebook’s algorithms recommend that susceptible users join extremist 14 groups, where users are conditioned to post even more inflammatory and divisive content, it is 15 naturally open to exploitation by autocratic politicians and regimes. By using large numbers of 16 fake accounts (that Facebook not only fails to police but actually likes because they inflate the 17 user data Facebook presents to the financial markets), these regimes can repeatedly post, like, 18 share, and comment on content attacking ethnic minorities or political opponents. Because that 19 content appears to generate high engagement, Facebook’s algorithms prioritize it in the News 20 Feeds of real users. 21 18. As such, Facebook’s arrival in Burma provided exactly what the military and its 22 civilian terrorists were praying for. Beginning around 2011, Facebook arranged for tens of 23 millions of Burmese to gain access to the Internet for the first time, exclusively through 24 Facebook. This resulted in a “crisis of digital literacy,” leaving these new users blind to the 25 prevalence of false information online. Facebook did nothing, however, to warn its Burmese 26 users about the dangers of misinformation and fake accounts on its system or take any steps to 27 the restrict its vicious spread. 28 CLASS ACTION COMPLAINT 7 Case No. __________________