1 developed mobile app that gives users access to a small selection of data-light websites and 2 services … [t]o deliver the service, … Facebook partners with local mobile operators … [who] 3 agree to ‘zero-rate’ the data consumed by the app, making it free, while Facebook does the 4 technical heavy lifting to ensure that they can do this as cheaply as possible. Each version is 5 localized, offering a slightly different set of up to 150 sites and services…. There are no other 6 social networking sites apart from Facebook and no email provider.” 62 7 81. One reason why Facebook gained immense traction in Burma is that “[t]he 8 website … handles Myanmar fonts well compared to other social media like Twitter.” 63 After 9 citizens bought an inexpensive phone and a cheap SIM card, “there was one app that everybody 10 in [Burma] wanted: Facebook. The reason? Google and some of the other big online portals 11 didn’t support Burmese text, but Facebook did.” 64 12 82. For the majority of Burma’s 20 million Internet-connected citizen’s, “Facebook is 13 the internet…. [M]ost mobile phones sold in the country come preloaded with Facebook…. 14 There are equal numbers of internet users and Facebook users in [Burma]. As a result, many 15 people use Facebook as their main source of information….” 65 16 83. A report commissioned by Facebook in 2018 described how the rapid transition of 17 Burma from a society without modern communications infrastructure to an Internet-connected 18 society caused “a crisis of digital literacy: A large population of internet users lacks basic 19 understanding of how to … make judgments on online content.… Digital literacy is generally 20 low across the country, and many people find it difficult to verify or differentiate content (for 21 22 23 24 25 26 Olivia Solon, ‘It’s digital colonialism’: how Facebook’s free internet service has failed its users, THE GUARDIAN (July 27, 2017), https://www.theguardian.com/technology/2017/jul/27/facebook-free-basics-developing-markets. 63 Hereward Holland, Facebook in Myanmar: Amplifying Hate Speech?, AL JAZEERA (Jun. 14, 2014), https://www.aljazeera.com/features/2014/6/14/facebook-in-myanmaramplifying-hate-speech. 62 64 Anisa Sudebar, The country where Facebook posts whipped up hate, BBC TRENDING (Sept. 12, 2018), https://www.bbc.com/news/blogs-trending-45449938. Human Rights Impact Assessment: Facebook in Myanmar, BSR (Oct. 2018) (“BSR Report”) at 12-13, https://about.fb.com/wp-content/uploads/2018/11/bsr-facebook-myanmarhria_final.pdf. 65 27 28 CLASS ACTION COMPLAINT 30 Case No. __________________