1 DETERMINING FOREIGN LAW - NOTICE 2 Plaintiff hereby gives notice that, to the extent Defendant Meta Platforms raises the 3 Communications Decency Act, 47 U.S.C. § 230, as a defense to the claims asserted below, and 4 to the extent that the Court were to find that the Communications Decency Act conflicts with 5 Burmese law, Burmese law applies. Burmese law does not immunize social media companies for 6 their role in inciting violence and contributing to genocide. 7 INTRODUCTION 8 9 1. The Rohingya people, a Muslim minority historically living in present-day Burma (internally renamed Myanmar following a military coup),2 number over 1 million and are the 10 largest stateless population in the world. While the Rohingya have long been the victims of 11 discrimination and persecution, the scope and violent nature of that persecution changed 12 dramatically in the last decade, turning from human rights abuses and sporadic violence into 13 terrorism and mass genocide. 14 2. A key inflection point for that change was the introduction of Facebook into 15 Burma in 2011, which materially contributed to the development and widespread dissemination 16 of anti-Rohingya hate speech, misinformation, and incitement of violence—which together 17 amounted to a substantial cause, and perpetuation of, the eventual Rohingya genocide. A 18 stunning declaration of a former Facebook employee now turned whistleblower, states 19 “Facebook executives were fully aware that posts ordering hits by the Myanmar government on 20 the minority Muslim Rohingya were spreading wildly on Facebook…”, and that “…the issue of 21 the Rohingya being targeted on Facebook was well known inside the company for years.” This 22 23 24 25 Throughout this Complaint, “Myanmar” will be used in reference the ruling military government, while “Burma” will be used to refer to the country itself. See U.S. Relations With Burma, US STATE DEPARTMENT, https://www.state.gov/u-s-relations-with-burma/ (“The military government changed the country’s name to ‘Myanmar’ in 1989. The United States government continues to use the name ‘Burma.’”) 2 26 27 28 CLASS ACTION COMPLAINT 2 Case No. __________________