Victim Advocates International (VAI) is providing technical assistance to the groups in notifying the complaint. VAI is a membership organisation for victims of serious international crimes, including war crimes, crimes against humanity, and genocide. VAI has obtained powers-of-attorney from each of these Complainants, and has Memorandums of Understanding (MOUs) with each of the groups they represent. Together, these groups represent thousands of Rohingya within the camps in Cox’s Bazar Bangladesh. This complaint is the result of a culmination of efforts by the complainant groups to directly engage Facebook in negotiations, which Facebook ultimately rejected. Please direct all correspondence to: - Clare Brown, Deputy Director (Victim c.brown@victimadvocatesinternational.org). 2.2. Advocates International, Whether the issue is material and substantiated The facts underlying this specific instance relate to human rights violations suffered by the Complainants when on the 24th and 25th of August 2017, the Burmese military (“the Tatmadaw”) together with local police and other actors launched a ‘clearance operation’ in Myanmar’s Rakhine state resulting in the deportation of 750,000 Rohingya into neighbouring Bangladesh. The IIFFMM concluded that the 2017 operations gave rise to numerous human rights violations guaranteed under the UN Charter, through the UDHR, as well as treaties to which Myanmar was a state party. The rights violations were as follows: - the right to life – it is conservatively estimated that 10,000 Rohingya were killed during the operations.20 - the right to security of the person, and the right to be protected from torture and illtreatment – endemic rapes and sexual violence against women, girls, men and boys, giving rise to these violations.21 - the right to liberty and security of the person which were violated as a result of the arbitrary arrests and enforced disappearances of the Rohingya.22 - the rights to adequate housing, food, and the right to highest attainable physical and mental health that resulted from the obliteration of their homes and villages, and concomitant violence – it is estimated that 750,000 Rohingya were displaced as a result of the operations.23 The IIFFMM found the role of social media to be “significant”, noting that “Facebook has been a useful instrument for those seeking to spread hate, in a context where, for most users, Facebook is the Internet.” They concluded that Facebook posts and messages had led to realworld discrimination and violence, and that the response by Facebook had been “slow and ineffective.”24 The 2017 operations were the culmination of decades of persecution and state 20 Report of the Independent International Fact-Finding Mission on Myanmar (“IIFFMM”) (A/HRC/39/64), para 1275, viewed 30 June 2021, <https://www.ohchr.org/Documents/HRBodies/HRCouncil/FFM-Myanmar/A_HRC_39_CRP.2.pdf>. [accessed 29 September 2021] 21 Ibid., para 1276. 22 Ibid., para 1277. 23 Ibid., paras 1278-1282. 24 Ibid., para 1351. 7