Case Western Reserve Journal of International Law 52 (2020) Crime as Cognitive Constraint all Rohingya, including civilians and children, as “ARSA terrorists”76 continues to maintain a Facebook presence. 77 It is unclear as to how Facebook interprets its Community Standards definition of “dangerous organizations” 78 to justify the ban of one account while allowing others to stand. Other Facebook services were also used. In a notable example, two versions of a chain message were distributed through Facebook messenger in September 2017. 79 One version called on Buddhists to “unite” against the common enemy in light of a supposedly planned jihad attack by Muslims on September 11 of that year. 80 Another version contained the same message but with the actors reversed; Muslims were warned of a supposed impending attack by the MaBaTha and other ultranationalists on the same date. 81 In an interview with Vox in April 2018, Mark Zuckerberg shared that Facebook’s “systems” were able to detect this Facebook Messenger scam. 82 Myanmar civil society organizations pushed back in an open letter addressed to Zuckerberg, arguing that the effective “systems” that he was describing were, in fact, the very same organizations that were alerting Facebook on the matter days after the fake content had already been widely shared. 83 For years, civil society groups served as de facto monitors, flagging problematic content to Facebook officials. 84 This underscored 76. Id. ¶ 1335. 77. The page has over 90,000 followers as of February 2020. The Global New Light of Myanmar (@TheGNLM), FACEBOOK, (Feb. 18, 2020), https://www.facebook.com/TheGNLM/. 78. See Banning More Dangerous Organizations from Facebook in Myanmar, (Feb. 5, 2019), FACEBOOK https://about.fb.com/news/2019/02/dangerous-organizations-inmyanmar/. 79. Detailed Findings of the FFM, supra note 7, ¶ 1348. 80. Id. 81. Id.; John Reed, Hate speech, Atrocities, and Fake News: The Crisis of Democracy in Myanmar, FINANCIAL TIMES (Feb. 22, 2018), https://www.ft.com/content/2003d54e-169a-11e8-9376-4a6390addb4. 82. Jen Kirby, Mark Zuckerberg on Facebook’s Role in Ethnic Cleansing in Myanmar: ‘It’s a Real Issue,’ Vox (Apr. 2, 2018), https://www.vox.com/2018/4/2/17183836/mark-zuckerberg-facebookmyanmar-rohingya-ethnic-cleansing-genocide. 83. Open letter from Myanmar civil society organizations, to Mark Zuckerberg, CEO of Facebook (Apr. 5, 2018), https://drive.google.com/file/d/1Rs02G96Y9w5dpX0Vf1LjWp6B9mp32 VY-/view. 84. Steve Stecklow, Why Facebook is Losing the War on Hate Speech in (Aug. 15, 2018), Myanmar, REUTERS https://www.reuters.com/investigates/special-report/myanmarfacebook-hate/. At one point, members of Myanmar civil society would 157