to align—often unconsciously—with extremists and authoritarians to the detriment of democracy around the world. 42 1 2 67. Facebook had the ability to detect and deactivate counterfeit accounts used by 3 authoritarian politicians and regimes to generate “fake engagement” but devoted minimal 4 resources to that task. In April 2021, Sophie Zhang, a data scientist whom Facebook had fired a 5 year earlier, spoke out about having “found multiple blatant attempts by foreign national 6 governments to abuse our platform on vast scales to mislead their own citizenry….” For 7 example, “[o]ver one six-week period from June to July 2018, [the president of Honduras]’s 8 Facebook posts received likes from 59,100 users, more than 78% of which were not real people.” 9 Such “fake engagement can influence how that content performs in the all-important news feed 10 algorithm; it is a kind of counterfeit currency in Facebook’s attention marketplace.” 43 11 68. It took Facebook almost a year to remove fake accounts associated with 12 “domestic-focused coordinated inauthentic activity in Honduras” and, when Zhang “found that 13 the Honduras network was reconstituting … there was little appetite from [Facebook] to take it 14 down again.” Before she was fired, Zhang alerted Facebook to networks of fake Pages 15 supporting political leaders in Albania, Azerbaijan, Mexico, Argentina, Italy, the Philippines, 16 Afghanistan, South Korea, Bolivia, Ecuador, Iraq, Tunisia, Turkey, Taiwan, Paraguay, El 17 Salvador, India, the Dominican Republic, Indonesia, Ukraine, Poland, and Mongolia. Some of 18 these networks were investigated while others “languish[ed] for months without action.” 44 19 20 69. Zhang gave one example that was especially reminiscent of the situation in Burma: 21 Of all the cases of inauthentic behavior that Zhang uncovered, the one that most concerned her—and that took the longest to take down—was in Azerbaijan. It was one of the largest she had seen, 22 23 24 25 26 27 28 42 Roger McNamee, Zucked: Waking Up to the Facebook Catastrophe, at 232-33 (Penguin 2020 ed.). 43 Julia Carrie Wong, How Facebook let fake engagement distort global politics: a whistleblower’s account, THE GUARDIAN (Apr. 12, 2021), https://theguardian.com/technology/2021/apr/12/facebook-fake-engagement-whistleblowersophie-zhang. 44 Id. CLASS ACTION COMPLAINT 25 Case No. __________________