1 170. Moreover, the kind of harm resulting from the ethnic violence committed by the 2 Myanmar military and their non-Rohingya supporters is precisely the kind of harm that could 3 have been reasonably expected from Facebook’s propagation and prioritization of anti-Rohingya 4 hate speech and misinformation on its system—e.g., wrongful death, personal injury, pain and 5 suffering, emotional distress, and property loss. 6 7 8 9 10 171. The dangers inherent in the design of Facebook’s algorithms and product outweigh the benefits, if any, afforded by that design. 172. Plaintiff and the Class are entitled to actual damages proximately caused by the defective design of Facebook’s algorithms and system. 173. Plaintiff and the Class are further entitled to punitive damages caused by 11 Facebook’s failure to correct or withdraw its algorithms and product after Facebook knew about 12 their defects. 13 SECOND CAUSE OF ACTION 14 NEGLIGENCE 15 174. Plaintiff incorporates the foregoing allegations as if fully set forth herein. 16 175. When operating in Burma—as everywhere—Facebook had a duty to use 17 18 reasonable care to avoid injuring others. 176. Facebook breached this duty by—among other things—negligently designing its 19 algorithms to fill Burmese users’ News Feeds (especially users particularly susceptible to such 20 content) with disproportionate amounts of hate speech, misinformation, and other content 21 dangerous to Plaintiff and the Class; negligently contributing to the creation of hate speech, 22 misinformation, and other content dangerous to Plaintiff and the Class by rewarding (and thus 23 encouraging) users to post ever more extreme content; negligently failing to remove such 24 dangerous content from its system after having been repeatedly warned of the potential for such 25 content to incite violence; negligently making connections between and among violent 26 extremists and susceptible potential violent actors; and negligently allowing users to use 27 28 CLASS ACTION COMPLAINT 68 Case No. __________________