1 misinformation. In addition, beginning in 2013, Facebook was repeatedly alerted to hate speech 2 on its system: 3 • In 2013, a new civil society organization called Panzagar, meaning “flower speech,” was formed in Myanmar. 158 The group spoke out locally about anti-Muslim hate speech directed at the Rohingya minority that was proliferating on Facebook. One of the group’s awareness-raising methods was to put flowers in their mouths to symbolize speaking messages of peace versus hate. Panzagar reported instances of hate speech to Facebook. 159 • In November 2013, Aela Callan, an Australian documentary filmmaker, “met at Facebook’s California headquarters with Elliott Schrage, vice president of communications and public policy” to discuss a project she had begun regarding “hate speech and false reports that had spread online during conflicts between Buddhists and Rohingya Muslims the prior year…. I was trying to alert him to the problems she said….” But “[h]e didn’t connect me with anyone inside Facebook who could deal with the actual problem….” 160 • “On March 3, 2014, Matt Schissler [an American aid worker working in Myanmar], was invited to join a call with Facebook on the subject of dangerous speech online…. Toward the end of the meeting, Schissler gave a stark recounting of how Facebook was hosting dangerous Islamophobia. He detailed the dehumanizing and disturbing language people were using in posts and the doctored photos and misinformation being spread widely.”161 • By June 14, 2014, Al Jazeera had published an article entitled “Facebook in Myanmar: Amplifying Hate Speech?” In that article, a civil society activist was quoted as saying: “Since the violence in Rakhine state began, we can see that online hate speech is spreading and becoming more and more critical and dangerous…. I think Facebook is the most effective way of spreading hate speech. It’s already very widespread, infecting the hearts of people.” The article cited Facebook posts reading: “We should kill every Muslim. No Muslims should be in Myanmar”; “Why can’t we kick out the 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 158 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. 159 Mary Michener Oye, Using ‘flower speech’ and new Facebook tools, Myanmar fights online hate speech, THE WASHINGTON POST, https://www.washingtonpost.com/national/religion/using-flower-speech-and-new-facebooktools-myanmar-fights-online-hate-speech/2014/12/24/3bff458c-8ba9-11e4-ace947de1af4c3eb_story.html. 160 Steve Stecklow, Why Facebook is losing the war on hate speech in Myanmar, REUTERS (Aug. 15, 2018), https://www.reuters.com/investigates/special-report/myanmar-facebook-hate/. 161 Sheera Frenkel and Cecilia Kang, An Ugly Truth: Inside Facebook’s Battle for Domination, at 177 (HarperCollins 2021). CLASS ACTION COMPLAINT 51 Case No. __________________