Muslim dogs?”; and “all terrorists are Muslim … they kill innocent men and women so peace and Islam are not related.” 162 1 2 • On August 18, 2014, PRI’s “The World” program published a story entitled “In newly liberated Myanmar, hatred spreads on Facebook.” After describing several false rumors that led to violence, the article reported: “The pattern repeats in towns and villages across Myanmar. Rumors rip through communities, fueled by seething racism and embellishments. Graphic images of violence are shared virally through social media platforms like Facebook, which has become one of the most popular websites in the country….”163 • After the March 2014 call with Schissler, “a handful of Facebook employees started an informal working group to connect Facebook employees in Menlo Park with activists in Myanmar.”164 Schissler said that “between March and December 2014, he held [a series] of discussions with Facebook officials…. He told them how the platform was being used to spread hate speech and false rumors in Myanmar, he said, including via fake accounts.” 165 • “In March 2015, Schissler gave a talk at Facebook’s California headquarters about new media, particularly Facebook, and antiMuslim violence in Myanmar.”166 “In a small conference room where roughly a dozen Facebook employees had gathered, with others joining by video-conference, he shared a PowerPoint presentation that documented the seriousness of what was happening in Myanmar: hate speech on Facebook was leading to real-world violence in the country, and it was getting people killed.”167 One Facebook employee asked whether Schissler thought genocide could happen in Myanmar: “‘Absolutely’ he answered. If Myanmar continued on its current path, and the anti-Muslim hate speech grew unabated, a genocide was possible. No one followed up on the question.”168 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 162 20 21 22 23 24 25 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 (emphasis added). 163 Bridget DiCerto, In newly liberated Myanmar, hatred spreads on Facebook, THE WORLD (Aug 8, 2014), https://www.pri.org/stories/2014-08-08/newly-liberated-myanmar-hatredspreads-facebook. 164 Sheera Frenkel and Cecilia Kang, An Ugly Truth: Inside Facebook’s Battle for Domination, at 178 (HarperCollins 2021). 165 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/. 166 26 27 28 Id. Sheera Frenkel and Cecilia Kang, An Ugly Truth: Inside Facebook’s Battle for Domination, at 181 (HarperCollins 2021). 168 Id. at 181-82. 167 CLASS ACTION COMPLAINT 52 Case No. __________________