Case Western Reserve Journal of International Law 52 (2020) Crime as Cognitive Constraint Pre-2011, a mobile SIM card cost around US $1,500-2,000; by 2011, it cost US $1.50. 46 Mobile phones became affordable and broadband subscriptions increased. 47 Thus, the country woke up from five decades of military rule greeted by smartphones; this was the populace’s “first experience with any form of telephony.” 48 Social media platforms gained more users as access to the Internet became easier. 49 Facebook currently enjoys an estimated 20 million active users 50 of the country’s 54 million demographic. 51 Unsurprisingly, hate speech flourished on the platform. 52 Facebook posts helped 46. Jason Motlagh, When a SIM Card Goes From $2000 to $1.50: Myanmar opens its wireless market, cuing a frenzy, BLOOMBERG (Sept. 29, 2014), https://www.bloomberg.com/news/articles/2014-09-29/myanmar-opensits-mobile-phone-market-cuing-carrier-frenzy [https://perma.cc/F6U7Y72U]. 47. Myanmar’s mobile revolution, BANGKOK POST (Jun. 20, 2016), https://www.bangkokpost.com/world/1015225/myanmars-mobilerevolution [https://perma.cc/WUR6-4TY2]; Detailed Findings of the FFM, supra note 7, ¶ 1342; Michelle J. Foster, The Business Environment for News Media in Myanmar: 2018, INTERNEWS (2018), https://internews.org/resource/business-environment-news-mediamyanmar-2018 [https://perma.cc/V2BQ-59TU] (finding that mobile phone penetration has exceeded 100% as of 2018). 48. Lorian Leong, Mobile Myanmar: The Development of a Mobile App Culture in Yangon, 5 MOBILE MEDIA & COMMUNICATION 139, 140 (2017) (stating that Huawei and Android dominated the market as of 2014). 49. Detailed Findings of the FFM, supra note 7, ¶ 1344, n.2975 (“It is suggested that Facebook enjoys more than 90 per cent share among social media platforms in Myanmar, and that this has been so since 2012.”). As of August 2019, Facebook enjoys almost 95% market share in the country. Social Media Stats in Myanmar - February 2020, STATCOUNTER GLOBALSTATS, http://gs.statcounter.com/social-mediastats/all/myanmar [https://perma.cc/2BV2-37JM]; Catherine Trautwein, Facebook Racks Up 10m Myanmar Users, MYANMAR TIMES (June 13, 2016), https://www.mmtimes.com/business/technology/20816facebook-racks-up-10m-myanmar-users.html. For an anecdotal account, see Craig Mod, The Facebook-Loving Farmers of Myanmar, THE ATLANTIC (Jan. 21, 2016), https://www.theatlantic.com/technology/archive/2016/01/the-facebookloving-farmers-of-myanmar/424812/. See also Leong, supra note 48, at 11-12 (discussing how mobile shop-keepers acted as “warm gatekeepers” for mobile users who were not digitally literate, by installing apps in mobile phones remarkably without receiving any financial incentive from app companies) 50. Detailed Findings of the FFM, supra note 9, ¶ 1344. 51. POPULATION REV., Myanmar Population 2020, WORLD http://worldpopulationreview.com/countries/myanmar-population/ [https://perma.cc/NN4P-TE6L]. 52. See Sticks and Stones: Hate Speech Narratives and Facilitators in C4ADS (2016), Myanmar, https://static1.squarespace.com/static/566ef8b4d8af107232d5358a/t/56b 153