1 McNamee likewise explained how the design of Facebook’s algorithms and 72. 2 system lead to real-world violence: “The design of Facebook trained users to unlock their 3 emotions, to react without critical thought…. at Facebook’s scale it enables emotional contagion, 4 where emotions overwhelm reason…. Left unchecked, hate speech leads to violence, 5 disinformation undermines democracy.”47 6 As Dipayan Ghosh, a former Facebook privacy expert, noted, “[w]e have set 73. 7 ethical red lines in society, but when you have a machine that prioritizes engagement, it will 8 always be incentivized to cross those lines.”48 9 10 Facebook’s tendency to cause real-world violence by radicalizing users online has 74. been demonstrated time and time again. A few recent examples include: 11 • In March 2019, a gunman killed 51 people at two mosques in Christchurch, New Zealand, while live-streaming the event on Facebook.49 For two years prior to the shooting, the gunman had been active on the Facebook group of the Lads Society, an Australian extremist white nationalist group. 50 • In August 2020, “[h]ours before a 17-year-old white man allegedly killed two people and injured a third at protests over a police shooting in Kenosha, Wisconsin, a local militia group posted a call on Facebook: ‘Any patriots willing to take up arms and defend our city tonight from evil thugs?’”51 Later, Mark Zuckerberg said that “the social media giant made a mistake by not removing a page 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 47 Roger McNamee, Zucked: Waking Up to the Facebook Catastrophe, at 98, 233 (Penguin 2020 ed.). 48 Sheera Frenkel and Cecilia Kang, An Ugly Truth: Inside Facebook’s Battle for Domination, at 185 (HarperCollins 2021). 49 Charlotte Grahan-McLay, Austin Ramzy, and Daniel Victor, Christchurch Mosque Shootings Were Partly Streamed on Facebook, NEW YORK TIMES (Mar. 14, 2019), https://www.nytimes.com/2019/03/14/world/asia/christchurch-shooting-new-zealand.html. 50 Royal Commission of Inquiry into the Terrorist Attack on Christchurch Mosques on 15 March 2019 § 4.6, https://christchurchattack.royalcommission.nz/the-report/firearmslicensing/general-life-in-new-zealand/; Michael McGowan, Australian white nationalists reveal plans to recruit ‘disgruntled, white male population’, THE GUARDIAN (Nov. 11, 2019), https://www.theguardian.com/australia-news/2019/nov/12/australian-white-nationalists-revealplans-to-recruit-disgruntled-white-male-population. 51 27 28 Adam Mahoney, Lois Beckett, Julia Carrie Wong, Victoria Bekiempis, Armed white men patrolling Kenosha protests organized on Facebook, THE GUARDIAN (Aug. 26, 2020), https://www.theguardian.com/us-news/2020/aug/26/kenosha-militia-protest-shooting-facebook. CLASS ACTION COMPLAINT 27 Case No. __________________