832 HASTINGS LAW JOURNAL [Vol. 71:813 content on its platform, Facebook acts less like a non-engaging bystander and more like an active participant in the promulgation of inciteful speech. IV. CASE EXAMPLE: MYANMAR For many years, Myanmar heavily restricted its citizens’ access to the Internet.145 According to the United Nations agency, International Telecommunication Union, only 1.1% of the population used the Internet in 2012.146 In 2014, a quasi-civilian government loosened restrictions and the use of mobile technology exploded as Subscriber Identification Module (SIM) cards became more affordable.147 Each smartphone came preinstalled with Facebook, leading Facebook to “become sort of the de facto internet for Myanmar.”148 Myanmar’s mobile phone operators also began offering an appealing deal: use Facebook without paying any data charges.149 While many individuals became quickly connected to Facebook, these users did not know how to navigate the wider Internet.150 This quickly led to an increased reliance on Facebook as the primary source of news and information.151 The combination of increased Internet access and the growing hate campaign proved devastating to the Rohingya.152 The Rohingya, a majority Muslim group, for years, have been subject to severe religious persecution in Myanmar, a primarily Buddhist country.153 Facebook, as the “de facto Internet” of Myanmar, became a useful tool for the Tatmadaw military and Buddhist nationalists to incite violence and hatred against the Rohingya.154 Reuters News and the Human Rights Center of the University of California Berkeley School of Law found more than 1000 examples of posts, comments, images, and videos attacking Myanmar’s Muslim population.155 Various posts called for Rohingya citizens to be shot, set on fire, and fed to pigs.156 One user posted a restaurant advertisement featuring Rohingya-style food, claiming: “We must fight them the 145. Steve Stecklow, Why Facebook Is Losing the War on Hate Speech in Myanmar, REUTERS (Aug. 15, 2018, 3:00 PM), https://www.reuters.com/investigates/special-report/myanmar-facebook-hate/. 146. Id. 147. Id.; see also Mozur, supra note 38. 148. Megan Specia & Paul Mozur, A War of Words Puts Facebook at the Center of Myanmar’s Rohingya Crisis, N.Y. TIMES (Oct. 27, 2017), https://www.nytimes.com/2017/10/27/world/asia/myanmar-governmentfacebook-rohingya.html. 149. See Stecklow, supra note 145. 150. See Specia and Mozur, supra note 148. 151. Id. 152. Stecklow, supra note 145. 153. Id. 154. See Specia and Mozur, supra note 148. 155. Olivia Solon, Facebook Struggles to End Hate Speech in Myanmar, Investigation Finds, GUARDIAN (Aug. 15, 2018, 9:32 PM), https://www.theguardian.com/technology/2018/aug/15/facebook-myanmarrohingya-hate-speech-investigation. 156. Myanmar Rohingya: Facebook “Still Hosts Hate Speech,” BBC NEWS (Aug. 15, 2018), https://www.bbc.com/news/technology-45196167.