842 HASTINGS LAW JOURNAL [Vol. 71:813 CONCLUSION As Zuckerberg admitted, Facebook has a responsibility to uphold human rights.236 This responsibility may also include legal responsibility under the theory of corporate criminal complicity. Issues remain outstanding with regard to jurisdiction and evidentiary proof, as shown in the Myanmar case study. However, based on the legal theories of corporate criminal complicity, Facebook could be held criminally liable for its operation of a platform used by authoritarian regimes to commit human rights abuses. To address the obstacles of jurisdiction and evidentiary proof, the international community could propose and establish an international criminal tribunal with jurisdiction over corporations. This would certainly solve the jurisdiction issue. Furthermore, the creation of an international criminal tribunal would also address the evidentiary proof issues. Because the potential defendant, Facebook, is effectively holding the data that may furnish potential criminal liability, an international tribunal with appropriate jurisdiction could subpoena such data to investigate Facebook’s involvement. While Facebook can be held accountable through other means such as reputational costs, shareholder and employee activism, it appears not to have learned its lesson with Myanmar. In fact, Facebook is continuously entering markets where its platform can easily be weaponized.237 As part of its vision to connect the entire world to the Internet within the next five to ten years, Facebook has set up free Internet hotspots called “Express Wi-fi” in India, Indonesia, Kenya, Nigeria, and Tanzania.238 There are no reports on whether Facebook has assessed the potential impact its platform may have on human rights in those five countries. While Facebook’s efforts may be beneficial to these countries, its lack of transparency with data collection and reporting remain significant problems. Facebook is currently the ultimate regulator of content on its platform, a task it performs with little to no accountability. The threat of liability in international criminal law may encourage corporations to act more swiftly in response to human rights abuses by authoritarian regimes. As observed with the Myanmar case study, civil society organizations played a large role in alerting Facebook to potential misuses of its platform in Myanmar. Facebook would be wise to rely more heavily on these organizations to uphold human rights. War crimes and crimes against humanity rank as some of the worst crimes in the international framework. Although corporate criminal liability is currently theoretical, civil society organizations’ and governments’ increasing calls for liability may eventually lead to a future where social media corporations are held accountable for their operations, and where victims can seek relief without being dismissed on purely jurisdictional and evidentiary grounds. Exploring the 236. See Transcript, supra note 1. 237. Nitasha Tiku, After Troubles in Myanmar, Facebook Charges Ahead in Africa, WIRED (Oct. 7, 2018, 7:00 AM), https://www.wired.com/story/after-troubles-myanmar-facebook-charges-ahead-africa/. 238. Id.