1 Burma market, Facebook would still be worth $1 trillion, Mark Zuckerberg would still be one of 2 the top ten richest people in the world, and its stock price would still be at astronomical levels. 3 30. In the end, there was so little for Facebook to gain from its continued presence in 4 Burma, and the consequences for the Rohingya people could not have been more dire. Yet, in the 5 face of this knowledge, and possessing the tools to stop it, it simply kept marching forward. 12 6 That is because, once Facebook struck the Faustian Bargain that launched the company, it has 7 had blinders on to any real calculation of the benefits to itself compared to the negative impacts 8 it has on anyone else. Facebook is like a robot programed with a singular mission: to grow. And 9 the undeniable reality is that Facebook’s growth, fueled by hate, division, and misinformation, 10 has left hundreds of thousands of devastated Rohingya lives in its wake. 11 PARTIES 12 31. 13 resides in Illinois. 14 32. Plaintiff Jane Doe is a natural person and a Rohingya Muslim refugee. Plaintiff Meta Platforms, Inc. is a corporation organized and existing under the laws of the 15 State of Delaware, with its principal place of business at 1 Hacker Way, Menlo Park, California 16 94025. Until October 2021, Defendant Meta was known as Facebook, Inc. Meta Platforms does 17 business in this County, the State of California, and across the United States. 18 JURISDICTION AND VENUE 19 20 33. This Court has jurisdiction over this action pursuant to Article VI, Section 10, of the California Constitution and Cal. Code Civ. Proc. § 410.10. 21 22 Angshuman Choudhury, How Facebook Is Complicit in Myanmar’s Attacks on Minorities, THE DIPLOMAT (Aug. 25, 2020), https://www.thediplomat.com/2020/08/howfacebook-is-complicit-in-myanmars-attacks-on-minorities/ (“why would Facebook favor the regime in Myanmar? For the same reason it would do so in India: to protect business interests in a domestic market that it currently dominates by a wide margin. Imposing bans on governmentor military-linked accounts could dilute this monopoly by drawing the ire of state regulators.”) In 2020, Facebook similarly bowed to the demands of the Communist Vietnamese government to “censor posts with anti-state language rather than risk losing an estimated $1 billion in annual revenue from the country.” Peter Wade, Facebook Bowed to Vietnam Government’s Censorship Demands: Report, ROLLING STONE (Oct. 25, 2021), https://www.rollingstone.com/politics/politics-news/facebook-vietnam-censorship-1247323/. 12 23 24 25 26 27 28 CLASS ACTION COMPLAINT 11 Case No. __________________