Case Western Reserve Journal of International Law 52 (2020) Crime as Cognitive Constraint the platform’s own inadequate controls. 85 In the open letter, Myanmar civil society expressed their frustration with Facebook’s “over-reliance on third parties, a lack of a proper mechanism for emergency escalation, a reticence to engage local stakeholders around systemic solutions and a lack of transparency.” Zuckerberg issued an apology soon after. 86 As I have discussed elsewhere, 87 Facebook’s user base in Myanmar involves both the ordinary citizen and the state. The official Facebook pages of Myanmar officials and government agencies demonstrate the reliance of state actors on the platform in carrying out official duty. To an extent, this move is not different from US President Donald Trump’s use of Twitter to appeal directly to his political base. 88 However, what appears to set apart Myanmar from other contexts is the broader speech landscape in which narratives are spun and gain traction. Myanmar’s transitional phase to democracy cannot be discounted. Although prepublication censorship was abolished, 89 journalists and dissenters are bring up posts in a private messaging group that included both Myanmar civil society and Facebook employees such as Mia Garlick, then-policy director for Facebook for Asia-Pacific. Id. Garlick has since been reassigned to serve as Director of Policy for Australia and New Zealand. ONLINE SAFETY INSTITUTE, See Mia Garlick, FAMILY https://www.fosi.org/people/mia-garlick/ (last visited March 25, 2020). 85. Removing Myanmar Military Officials From Facebook, supra note 70. See also Detailed Findings of the FFM, supra note 7, ¶ 1352 n.2991 (quoting a statement by Mark Zuckerberg before the United States Congress: “We’ve been too slow to deal with the hate and violence in places like Myanmar […]. The challenges we face in a country that has fast come online are very different than those in other parts of the world, and we are investing in people, technology, and programs to help address them as effectively as possible.”). 86. Kevin Roose and Paul Mozur, Zuckerberg Was Called out Over Myanmar Violence. Here’s His Apology, N.Y. TIMES (Apr. 9, 2018), https://www.nytimes.com/2018/04/09/business/facebook-myanmarzuckerberg.html. 87. Jenny Domino, How Myanmar’s Incitement Landscape Can Inform Platform Regulation in Situations of Mass Atrocity, OPINIO JURIS (Jan. 2, 2020), http://opiniojuris.org/2020/01/02/how-myanmars-incitementlandscape-can-inform-platform-regulation-in-situations-of-mass-atrocity/; Jenny Domino, How Facebook is Reconfiguring Speech in Situations of Mass Atrocity: Lessons from Myanmar and the Philippines, OPINIO JURIS (Jan. 1, 2019), http://opiniojuris.org/2019/01/01/how-facebook-isreconfiguring-freedom-of-speech-in-situations-of-mass-atrocity-lessonsfrom-myanmar-and-the-philippines/. 88. See Michael D. Shear et al., How Trump Reshaped the Presidency in Over (Nov. 2, 2019), 11,000 Tweets, N.Y. TIMES https://www.nytimes.com/interactive/2019/11/02/us/politics/trumptwitter-presidency.html. 89. Aung Hla Tun, Censorship, Myanmar REUTERS Government Abolishes Direct (Aug. 20, 158 Media 2012),