Dublin office.15 A Global Market specialist at Facebook’s Dublin office wrote that he “led policy changes to Facebook's Community Standards to better protect our users.”16 Facebook has in the past used additional holding companies in Ireland. These were subsequently shut down as a result of a lawsuit by the US Internal Revenue Services that alleged Facebook used these holding companies to avoid payment of more than 9 billion USD in tax owed to the US government.17 In 2018, Facebook International holding company 1, incorporated in Ireland, recorded revenue of 30 billion USD, which was more than half of Facebook’s total global turnover of 56 billion.18 The same holding company recorded pre-tax profits of 13 billion USD in 2017, the year in which the operations against the Rohingya took place.19 2.1.2. Identity of the notifier This complaint is being filed on behalf of sixteen victims of the 2017 clearance operations in Myanmar, who represent six community-based organisations in Cox’s Bazar refugee camp in Bangladesh, as well as youth and women leaders. • Mohamed Nowkim is a Technician at the Arakan Rohingya Society for Peace and Human Rights (ARSPH), and a human rights activist in the camp. ARSPH is the largest camp-based civil society organisation in Cox’s Bazar refugee camp, which has a presence in all the camps, and representation amongst youth communities, women and elders. • Mr Abdu Rohim is the Vice Chair of ARSPH. • Mr Mohammed Jubayer is the Secretary of ARSPH. • Mr Roshie Dullah is the Logistics Officer of ARSPH. • Mr Mohammed Shoaibe is a teacher in ARSPH. • Mr Mohammed Ayas is a teacher in ARSPH. • Mr Mohamed Samin is a teacher in ARSPH. • Ms Yasmin Ara is the founder of Rohingya Women Development Forum. • Ms Omme Salma is a women’s leader within the camp. • Ms Shaykotura is a women’s leader within the camp. • Mr Mohamed Sadekis a teacher in ARSPH. • Mr Yarsor Arfat is the co-founder of Rohingya Student Unity Rights. • Ms Chekufa Ra is the founder of Rohingya Women Empowerment and Advocacy Network. • Mr Mohamed Shah is a youth leader in the camp. • Mr Junide is a youth leader in the camp. • Mr Sayedollah is a youth leader in the camp. 15 These communications are confidential but can be provided upon request. 17 Julia Kollewe, ‘Facebook to close Irish holding companies at centre of tax dispute’, The Guardian, 28 December 2020, viewed 28 May 2021, <https://www.theguardian.com/technology/2020/dec/27/facebook-toclose-controversial-irish-holding-companies>. [accessed 24 April 2021] 18 Ibid. 19 Paul O’Donaghue, ‘Irish Facebook Branch Pays 1 per cent Global Tax’, The Irish Times, 24 December 2019, < https://www.thetimes.co.uk/article/irish-facebook-branch-pays-1-per-cent-tax-02ztgstdq> [accessed 29 November 2021] 6