1 this opportunity, prioritizing divisive and polarizing content, including hate speech and 2 misinformation about targeted groups, when delivering content to users and recommending that 3 users make new connections or join new groups. 4 12. Facebook participates in and contributes to the development and creation of 5 divisive content, including hate speech and misinformation. By ensuring that more users see and 6 respond—in the form of “likes,” “shares,” and comments—to such toxic content, Facebook’s 7 algorithms train users to post more hate speech and misinformation in order to garner more 8 attention online. 9 13. This “growth at all costs” view of Facebook’s business is not speculative, or, for 10 that matter, inconsistent with Facebook’s view of itself. Facebook’s Borg-like march toward 11 further growth was best captured by one of its highest-ranking executives, Andrew Bosworth, in 12 an internal memo circulated after a shooting death in the Chicago was stunningly live streamed 13 on Facebook. It stated, in part: 14 We connect people. 15 16 That can be good if they make it positive. Maybe someone finds love. Maybe it even saves the life of someone on the brink of suicide. 17 So we connect more people. 18 19 That can be bad if they make it negative. Maybe it costs a life by exposing someone to bullies. Maybe someone dies in a terrorist attack coordinated on our tools. 20 And still we connect people. 21 The ugly truth is that we believe in connecting people so deeply that anything that allows us to connect more people more often is *de facto* good… 22 23 24 25 26 27 28 That’s why all the work we do in growth is justified. All the questionable contact importing practices. All the subtle language that helps people stay searchable by friends. All of the work we do to bring more communication in. The work we will likely have to do in China some day. All of it. The natural state of the world is not connected. It is not unified. It is fragmented by borders, languages, and increasingly by different products. The best products don’t win. The ones everyone use win. CLASS ACTION COMPLAINT 5 Case No. __________________

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