and event that urged people in Kenosha … to carry weapons amid protests.”52 1 • 2 3 4 5 6 75. “In the days leading up to [the January 6, 2021] march on the Capitol, supporters of President Trump promoted it extensively on Facebook and Facebook-owned Instagram and used the services to organize bus trips to Washington. More than 100,000 users posted hashtags affiliated with the movement prompted by baseless claims of election fraud, including #StopTheSteal and #FightForTrump.”53 Prior to Facebook’s entry into Burma, as described below, Facebook was on 7 notice of the manner in which its service could influence political conflict and be used to fuel 8 real-world violence. For example, during a 2010 conflict in Kyrgyzstan, highly divisive and at 9 times violent content spread widely on Facebook, inclusive of substantial misinformation related 10 to the source and cause for ongoing violence. 54 Likewise, even in examples where Facebook has 11 been credited with supporting protests for positive political change before 2012, the consistent 12 result is that the same governments and militant groups that were opposed by the protests, 13 eventually utilized Facebook to help put down those uprisings through widespread 14 misinformation campaigns.55 15 76. Facebook was on notice very early on in its existence that “that liberty isn't the 16 only end toward which these tools can be turned.”56 And it is with that knowledge in hand that it 17 launched in the extremely volatile environment present in Burma. 18 19 Madeleine Carlisle, Mark Zuckerberg Says Facebook’s Decision to Not Take Down Kenosha Militia Page Was a Mistake, TIME (Aug. 29, 2020), https://time.com/5884804/markzuckerberg-facebook-kenosha-shooting-jacob-blake/. 53 Elizabeth Dwoskin, Facebook’s Sandberg deflected blame for Capitol riot, but new evidence shows how platform played role, WASHINGTON POST (Jan. 13, 2021), https://www.washingtonpost.com/technology/2021/01/13/facebook-role-in-capitol-protest/. 54 Neil Melvin and Tolkun Umaraliev, New Social Media and Conflict in Kyrgyzstan, SIPRI (Aug. 2011), https://www.sipri.org/sites/default/files/files/insight/SIPRIInsight1101.pdf. 55 Nariman El-Mofty, Social Media Made the Arab Spring, But Couldn't Save It, WIRED (Jan. 26, 2016), https://www.wired.com/2016/01/social-media-made-the-arab-spring-but-couldntsave-it/ (“These governments have also become adept at using those same channels to spread misinformation. ‘You can now create a narrative saying a democracy activist was a traitor and a pedophile,’ … ‘The possibility of creating an alternative narrative is one people didn’t consider, and it turns out people in authoritarian regimes are quite good at it.’”) 56 Id. 52 20 21 22 23 24 25 26 27 28 CLASS ACTION COMPLAINT 28 Case No. __________________