1 than ten thousand Rohingya men, women, and children died by shooting, stabbing, burning, or 2 drowning. Thousands of others were tortured, maimed, and raped. Whole villages were burned to 3 the ground. More than 700,000 Rohingya eventually fled to squalid, overcrowded refugee camps 4 in Bangladesh. 5 25. Not until 2018—after the damage had been done—did Facebook executives, 6 including CEO Mark Zuckerberg and COO Sheryl Sandberg, meekly admit that Facebook 7 should and could have done more to prevent what the United Nations has called “genocide” and 8 a “human rights catastrophe.” Facebook’s underwhelming response failed to capture even a 9 scintilla of the gravity of what it had done and the role it played, stating “we weren’t doing 10 enough to help prevent our platform from being used to foment division and incite offline 11 violence. We agree that we can and should do more.”7 12 26. The second part of its efforts to “do more” was to launch the virtual reality centric 13 “Metaverse” to further force themselves into the lives of billions. As noted by prominent 14 political commentor Dan Pfeiffer, 15 Facebook is one of the least liked, least trusted companies on the planet. They are in the middle of a massive scandal about their involvement in genocide, human trafficking, and disinformation. And their next move is to say: “What if you could live inside Facebook?”8 16 17 27. 18 Still, years after their initial tepid admission of negligence, former Facebook 19 employee and now prolific whistleblower, Frances Haugen, stated “[t]he company’s leadership 20 knows how to make Facebook and Instagram safer but won’t make the necessary changes 21 because they have put their astronomical profits before people.” 9 Notably, in litigation pending 22 7 23 24 25 Alex Warofka, An Independent Assessment of the Human Rights Impact of Facebook in Myanmar, FACEBOOK NEWSROOM (Nov. 5, 2018), https://about.fb.com/news/2018/11/myanmarhria/. 8 See @DanPfeiffer, TWITTER (Oct. 28, 2021, 3:24 PM) https://twitter.com/danpfeiffer/status/1453819894487674899. Abram Brown, Facebook ‘Puts Astronomical Profits Over People,’ Whistle-Blower Tells Congress, FORBES (Oct. 5, 2021), https://www.forbes.com/sites/abrambrown/2021/10/05/facebook-will-likely-resume-work-oninstagram-for-kids-whistleblower-tells-congress/?sh=7385d0f74cda. 9 26 27 28 CLASS ACTION COMPLAINT 9 Case No. __________________