Case 1:20-cv-03590-JEB Document 75-1 Filed 08/19/21 Page 1 of 80
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF COLUMBIA
`
`FEDERAL TRADE COMMISSION
`600 Pennsylvania Avenue, N.W.
`Washington, DC 20580
`
`Plaintiff,
`
`v.
`
`FACEBOOK, INC.
`1601 Willow Road
`Menlo Park, CA 94025
`
` Defendant.
`
`Case No.: 1:20-cv-03590-JEB
`
`PUBLIC REDACTED VERSION OF
`DOCUMENT FILED UNDER SEAL
`
`FIRST AMENDED COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE
`RELIEF
`
`Plaintiff, the Federal Trade Commission (“FTC”), by its designated attorneys, petitions this
`
`Court pursuant to Section 13(b) of the Federal Trade Commission Act (“FTC Act”), 15 U.S.C.
`
`§ 53(b), for a permanent injunction and other equitable relief against Defendant Facebook, Inc.
`
`(“Facebook”), to remedy and prevent its anticompetitive conduct and unfair methods of
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`competition in or affecting commerce in violation of Section 5(a) of the FTC Act, 15 U.S.C.
`
`§ 45(a).
`
`I. NATURE OF THE CASE
`
`1.
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`Facebook is the world’s dominant online social network, with a purported three
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`billion-plus regular users. Facebook has maintained its monopoly position in significant part by
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`pursuing Chief Executive Officer (“CEO”) Mark Zuckerberg’s strategy, expressed in 2008: “it is
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`better to buy than compete.” True to that maxim, Facebook has systematically tracked potential
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`rivals and acquired companies that it viewed as serious competitive threats. Facebook
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`supplemented this anticompetitive acquisition strategy with anticompetitive conditional dealing
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`policies, designed to erect or maintain entry barriers and to neutralize perceived competitive
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`threats.
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`2.
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`Facebook holds monopoly power in the market for personal social networking
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`services (“personal social networking” or “personal social networking services”) in the United
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`States, primarily due to its control of two of the largest and most profitable social networks in the
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`world, Facebook and Instagram. The Facebook social network is known internally at Facebook as
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`“Facebook Blue” and has more than
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` monthly users in the United States. Instagram
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`attracts more than
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` monthly users. No other personal social networking provider in the
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`United States remotely approaches Facebook’s scale. Snapchat is the next-largest provider of
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`personal social networking services, but its user base pales in comparison: Snapchat has tens of
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`millions fewer monthly users than either Facebook Blue or Instagram.
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`3.
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`Facebook’s dominant position provides it with staggering profits. Facebook
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`monetizes its personal social networking monopoly principally by selling surveillance-based
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`advertising. Facebook collects data on users both on its platform and across the internet and
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`exploits this deep trove of data about users’ activities, interests, and affiliations to sell behavioral
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`advertisements. Last year alone, Facebook generated revenues of more than $85 billion and profits
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`of more than $29 billion.
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`4.
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`As Facebook has long recognized, its personal social networking monopoly is
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`protected by high barriers to entry, including strong network effects. In particular, because a
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`personal social network is more valuable to a user when more of that user’s friends and family are
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`already members, a new entrant faces significant difficulties in attracting a sufficient user base to
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`compete with Facebook. Facebook’s internal documents confirm that it is very difficult to win
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`users with a social networking product built around a particular social “mechanic” (i.e., a particular
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`way to connect and interact with others, such as photo-sharing) that is already being used by an
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`incumbent with dominant scale. Oftentimes, even an entrant with a superior product cannot
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`succeed against the overwhelming network effects enjoyed by an incumbent personal social
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`network.
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`5.
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`Strong network effects can insulate a dominant personal social networking provider
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`from competitive threats until a disruptive or innovative technology emerges to open up new ways
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`for users to connect. In a competitive environment, Facebook’s success would depend on its ability
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`to anticipate and adapt to periods of technological transition by developing innovative tools that
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`create value for the company’s social network. But in navigating its own transition from small
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`startup to business behemoth, Facebook’s leadership came to the realization—after several
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`expensive failures—that it lacked the business talent required to maintain its dominance amid
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`changing conditions. Unable to maintain its monopoly by fairly competing, the company’s
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`executives addressed the existential threat by buying up new innovators that were succeeding
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`where Facebook failed. The company supplemented this anticompetitive spending spree with an
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`opened-first-closed-later scheme that helped cement its monopoly by further thwarting nascent
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`rivals.
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`6.
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`A critical transition period in the history of the internet, and in Facebook’s history,
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`was the emergence of smartphones and the mobile internet in the 2010s. The emergence of these
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`technologies fundamentally disrupted the digital economy by allowing people to connect on the
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`go. As users increasingly shifted online activities to the mobile internet, opportunities arose for
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`innovative, upstart companies to challenge Facebook and other giants that had grown dominant in
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`the desktop age. Venture capital and other funding flowed to startups like Instagram, which
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`allowed users to connect through photo sharing, and WhatsApp, which provided messaging
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`services. These upstarts became popular quickly.
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`7.
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`Facebook recognized that the transition to mobile posed an existential challenge—
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`and that Facebook had a brief window of time to stymie emerging mobile threats. Facebook’s
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`CEO, Mr. Zuckerberg, described the period as a
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`
`
`
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` Failing to compete on business talent, Facebook developed a plan to maintain its
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`dominant position by acquiring companies that could emerge as or aid competitive threats. By
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`buying up these companies, Facebook eliminated the possibility that rivals might harness the
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`power of the mobile internet to challenge Facebook’s dominance.
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`8.
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`Facebook buttressed its acquisition strategy by implementing and enforcing a series
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`of anticompetitive conditional dealing policies that pulled the rug out from under firms perceived
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`as competitive threats. Facebook included these policies in agreements with third-party developers
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`of software apps that ran on or connected to Facebook’s platform. Beginning in 2007, Facebook
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`actively invited app developers onto its platform, granting them open access to critical application
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`programming interfaces (“APIs”) and tools needed to interconnect with Facebook. This open
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`access policy drove developer and user engagement with Facebook, which in turn helped to fuel
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`Facebook’s massive advertising profits. But as developers expanded popular offerings, Facebook
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`came to view them as a threat, recognizing that some could aid emerging rivals or even challenge
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`Facebook directly. In response, Facebook retooled its API policies into an anticompetitive
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`weapon: developers could only access Facebook’s platform if they agreed (i) not to compete with
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`Facebook’s core services and (ii) not to facilitate the growth of potential rivals to Facebook. App
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`developers or websites that stayed loyal to Facebook by adhering to these conditions were given
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`access to valuable Facebook platform interconnections. In contrast, app developers that worked
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`with or themselves emerged as potential competitive threats to Facebook lost access to those
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`interconnections, forcing some out of business. But for the restrictions imposed by Facebook’s
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`anticompetitive conditional dealing policies, developers could promote competitive threats to
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`Facebook or become threats themselves. By preventing them from doing so, Facebook reduced
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`the opportunities available to nascent threats. In other words, Facebook beat competitors not by
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`improving its own product, but instead by imposing anticompetitive restrictions on developers.
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`This conduct is no less anticompetitive than if Facebook had paid off these nascent competitive
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`threats to cease competing.
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`9.
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`Through these actions, Facebook implemented an anticompetitive scheme that
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`prevented differentiated and innovative firms from gaining scale, thus enabling Facebook to
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`maintain its dominance. Facebook’s course of conduct has eliminated nascent rivals and
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`extinguished the possibility that such rivals’ independent existence might allow other internet
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`platforms to overcome the substantial barriers to entry that protect Facebook’s monopoly position.
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`In doing so, Facebook deprives personal social networking users in the United States of the benefits
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`of competition, including increased choice, quality, and innovation.
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`10.
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`By interfering with the emergence and growth of personal social networking rivals,
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`Facebook also suppresses meaningful competition for the sale of advertising. Many personal
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`social networking providers monetize their platforms through the sale of advertising; thus, more
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`competition in personal social networking is also likely to mean more competition in the provision
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`of advertising. By monopolizing personal social networking, Facebook thereby also deprives
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`advertisers of the benefits of competition, such as lower advertising prices and increased choice,
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`quality, and innovation related to advertising.
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`11.
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`Facebook’s unlawful course of conduct to maintain its monopoly continues today
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`and must be enjoined. Facebook continues to hold and operate the assets it acquired unlawfully
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`and continues to keep them positioned to provide a protective “moat” around its personal social
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`networking monopoly. Moreover, Facebook continues to monitor competitive threats and will
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`seek to acquire or kneecap them unless enjoined.
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`II. JURISDICTION AND VENUE
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`A. Jurisdiction
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`12.
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`This Court has subject matter jurisdiction over this action pursuant to Sections 5(a)
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`and 13(b) of the FTC Act, 15 U.S.C. §§ 45(a) and 53(b), and 28 U.S.C. §§ 1331, 1137(a), and
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`1345. This is a civil action arising under Acts of Congress protecting trade and commerce against
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`restraints and monopolies, and is brought by an agency of the United States authorized by an Act
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`of Congress to bring this action.
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`13.
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`This Court has personal jurisdiction over Facebook because Facebook has the
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`requisite constitutional contacts with the United States of America pursuant to 15 U.S.C. § 53(b).
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`14.
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`Facebook’s general business practices, and the unfair methods of competition
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`alleged herein, are “in or affecting commerce” within the meaning of Section 5 of the FTC Act,
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`15 U.S.C. § 45.
`
`15.
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`Facebook is, and at all relevant times has been, a corporation, as the term
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`“corporation” is defined in Section 4 of the FTC Act, 15 U.S.C. § 44.
`
`B. Venue
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`16.
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`Venue in this district is proper under 15 U.S.C. § 22, 28 U.S.C. § 1391(b)(1), and
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`15 U.S.C. § 53(b). Facebook resides, transacts business, and is found in this district.
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`III. THE PARTIES
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`17.
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`Plaintiff FTC is an administrative agency of the United States government,
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`established, organized, and existing pursuant to the FTC Act, 15 U.S.C. §§ 41 et seq., with its
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`principal offices in the District of Columbia. The Commission is vested with authority and
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`responsibility for enforcing, among other things, Section 5 of the FTC Act, 15 U.S.C. § 45, and is
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`authorized under Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), to initiate court proceedings to
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`enjoin violations of any law the FTC enforces and to seek equitable remedies.
`
`18.
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`The FTC is authorized to bring this case in federal court because it has reason to
`
`believe that Defendant Facebook is violating or is about to violate a provision of law enforced by
`
`the FTC, and this is a proper case for permanent injunctive relief within the meaning of Section
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`13(b) of the FTC Act, 15 U.S.C. § 53(b).
`
`19.
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`Defendant Facebook is a publicly traded, for-profit company, incorporated in
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`Delaware and with its principal place of business at 1601 Willow Road, Menlo Park, CA 94025.
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`Facebook’s principal businesses are in technologies that facilitate digital interactions and
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`communications, including Facebook Blue, which provides personal social networking;
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`Instagram, which provides personal social networking; Facebook Messenger, which provides
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`mobile messaging services; and WhatsApp, which provides mobile messaging services.
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`IV. INDUSTRY BACKGROUND
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`
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`A. The Rise of Personal Social Networking and Facebook’s Beginnings
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`20.
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`In the early 2000s, the widespread use of personal computers and internet
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`connectivity enabled a new way of connecting and communicating with other people: online social
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`networking with friends and family. In contrast to the limited functionality of email and text
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`messaging, personal social networking gained popularity by providing a distinct way for people to
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`maintain personal connections. Personal social networking enables people to stay up to date and
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`share personal content with friends and family. It is now an integral part of the daily lives of
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`millions of Americans.
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`21.
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`Through an account on a personal social network, people can post content about
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`their own lives and interests, and view content that personal connections have posted. Because
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`many people use personal social networking to engage with personal connections, the presence of
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`a critical mass of people on a particular personal social network both attracts new users and keeps
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`existing users on the network. In this sense, social networks share features of telephone systems,
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`operating systems, and other services characterized by strong network effects: the value of the
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`service to individual consumers increases with the number of other consumers that use the service.
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`Internal Facebook investor call talking points expressed this phenomenon crisply:
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`
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`22.
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`Friendster, launched in March 2002, was one of the first personal social networks
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`to gain significant popularity, and Myspace followed the next year.
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`23.
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`Subsequently, in February 2004, Mr. Zuckerberg and his college classmates
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`launched Facebook (then styled “TheFacebook”). They first launched the product on their school
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`campus, and then quickly expanded to other college campuses. Following rapid uptake in
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`university settings, Facebook became widely available to members of the general public in 2006.
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`Facebook’s rapid initial growth led to substantial private investment in the company, which in turn
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`fueled more growth.
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`B. Facebook Launched Facebook Platform, and Provided Access to Critical Interfaces,
`to Induce App Developers to Interoperate with Facebook Blue
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`24.
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`The early, rapid growth of Facebook’s user base was of critical importance to the
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`company. Facebook needed to add users rapidly not only to sell itself to investors, but also to
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`achieve a critical mass of users that could allow it to establish and benefit from network effects:
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`As more users actively and regularly engaged with Facebook’s offerings, users would be more
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`likely to stay with Facebook and attract yet more users—and leave potential competitors with little
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`room to maneuver. Facebook therefore sought to quickly expand its offerings to users.
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`25.
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`In furtherance of this goal, Facebook in 2007 launched “Facebook Platform.” The
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`Platform initiative leveraged Facebook’s control over its rapidly expanding user base to encourage
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`software developers to build an entire ecosystem of apps and tools—ranging from games and page
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`design tools to video-sharing tools and e-marketing apps—that interoperate with Facebook Blue.
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`Facebook aimed to turn Facebook Blue into a dominant platform for apps: If Facebook could
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`induce developers to use Facebook Blue to promote and distribute innovative apps that appealed
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`to users, Facebook would benefit from increased user engagement, yielding greater and more
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`granular data about its users and their online activities, and cementing network effects to insulate
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`itself from competition.
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`26. When it launched Platform, Facebook explicitly “welcome[d] developers with
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`competing applications” to build on Platform, representing that it had “designed Facebook
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`Platform so that applications from third-party developers are on a level playing field with
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`applications built by Facebook.”
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`27.
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`Facebook’s Platform initiative allowed it to conserve its own resources and
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`leverage the creativity of third parties to ensure that engagement continued on Facebook. Without
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`Platform, Facebook itself would be required to build apps that increased the value of its network—
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`meaning that Facebook would have to try to predict what apps users wanted; design, code, and
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`scale those apps across its user base and network; and bear the risk and resource drain of guessing
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`wrong and making mistakes.
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`28.
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`Platform allowed Facebook to avoid these risks and costs—and to reap the benefits
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`derived from the efforts of third-party app developers. Facebook would not need to spend
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`significant resources to develop new apps or test new business models—third parties would do
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`that instead. Facebook could merely wait for an app built for Platform to gain widespread
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`adoption, then either build a competing app or reap the benefits of that popular app’s user
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`engagement, including valuable new social data for Facebook. The potential to extract profits
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`from the work of these developers—including from the apps these developers built and the users
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`they attracted—led Facebook to actively seek out and invite developers to build apps on Platform.
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`29.
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`Facebook rolled out Facebook Platform as a program that would provide all app
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`developers with the freedom to design apps. When Facebook introduced Facebook Platform,
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`Mr. Zuckerberg stated, “[u]ntil now, social networks have been closed platforms. Today, we’re
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`going to end that. With this evolution of Facebook Platform, any developer worldwide can
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`build full social applications on top of the social graph, inside of Facebook.”
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`30.
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`Facebook marketed Facebook Platform as a way to empower all app developers
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`because it recognized that doing so would be critical to its business. In a 2007 press release,
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`Mr. Zuckerberg stated, “[Facebook Platform] is good for us because if developers build great
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`applications then they’re providing a service to our users and strengthening the social graph.
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`This is a big opportunity. We provide the integration and distribution and developers provide
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`the applications. We help users share more information and together we benefit.”
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`31. Mr. Zuckerberg and Facebook continued to repeat the message that Facebook
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`benefited from an “open” Facebook Platform that allowed any social app developer to
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`interoperate. In 2008, Mr. Zuckerberg observed that
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` In early 2012, a Facebook Initial Public Offering
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`document stated that “[t]he success of our Platform developers and the vibrancy of our Platform
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`ecosystem are key to increasing user engagement [on Facebook Blue]. We continue to invest in
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`tools and APIs that enhance the ability of Platform developers to deliver products that are more
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`social and personalized and better engage users on Facebook [Blue], across the web, and on
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`mobile devices.”
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`32.
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`Facebook’s open platform was designed to attract not only new developers, but
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`also (i) new Facebook users attracted by the developers that interoperated with Facebook’s
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`Platform; and (ii) greater engagement from existing Facebook users as they enjoyed new
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`functionality on the platform. In each case, Facebook’s Platform was designed to create and
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`leverage the network effects that come with an increased user base and engagement. And each
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`drove the other: more users meant more developers, and more developers meant more users.
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`Both were good for Facebook.
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`33.
`
`Following the 2007 launch of Platform, Facebook frequently added new tools for
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`developers to use, usually at its semi-annual “f8” developers conference. For example, in 2008,
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`Facebook launched Facebook Connect, a tool that enabled developers to let their users log into
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`the developer’s websites or apps using their Facebook credentials, “bring their Facebook
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`account information, friends and privacy” to the developer’s service, and share content back to
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`Facebook. Use of Facebook Connect by developers benefitted Facebook by increasing the
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`amount of engaging content on Facebook Blue and making Facebook more ubiquitous across
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`the internet.
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`34.
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`Facebook continued to add functionalities to Platform, including APIs that allowed
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`third-party apps access to Facebook user data. An API is a structured way for different pieces of
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`software to communicate and share data or functionality with one another. APIs are used widely
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`online to facilitate communication among businesses and other entities, integration or
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`interoperation between products and services, and the development of new products built “on top
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`of” the features or data of others.
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`35.
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`By providing an API, businesses can enable third-party developers to
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`programmatically interact with certain data or functionality from the API provider. This is a
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`common pattern for businesses that wish to enable the development of products that are
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`complementary or adjacent to their own products without building those products themselves.
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`In these situations, the API provider makes available to third-party developers the data and
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`functionality needed to interoperate with the provider. By providing critical interoperability,
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`many APIs effectively serve as a means of distribution for third-party developers in digital
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`markets.
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`36.
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`Facebook Platform comprises access to many different APIs, and many have
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`changed over time. Graph API, launched in 2010, is one of the core Facebook Platform
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`APIs. Although it, too, has changed over the years, its general purpose has been to facilitate the
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`exchange of a multitude of different types of information and data between Facebook’s social
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`graph and other apps, including both Facebook and third-party products. After Facebook grants a
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`third-party developer access to particular endpoints of Graph API, that developer can use Graph
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`API to retrieve and/or create those particular types of information within Facebook’s social
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`graph. For example, Graph API can be used to retrieve the photos that a user has uploaded to
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`Facebook Blue, or to publish a video to a user’s Facebook Blue timeline. The data available
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`through Graph API can provide developers with an important means to achieve distribution and
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`grow their user bases.
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`37.
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`In 2010, Facebook provided third-party apps with access to critical APIs through
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`Graph API, including the Find Friends API (providing information about a user’s Facebook
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`friends) and other APIs used to access user content from Facebook Blue. The Find Friends API,
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`in particular, was a valuable growth tool for third-party apps because it enabled users of such apps
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`to find their Facebook Blue friends who also used the third-party app and to invite those friends
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`who did not.
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`38.
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`In 2010, Facebook also added the Open Graph and Social Plugins to Facebook
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`Platform, which enabled third-party apps and websites to add features such as the Facebook “Like”
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`button to their own services. Using the Like button, Facebook Blue users could like and share
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`their interest in the third-party app. Third-party apps were motivated to install the Like button and
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`encourage its use, as a “Like” would be shared on the user’s news feed and profile on Facebook
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`Blue, which could attract additional users to the third-party app.
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`39.
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`Open access to Facebook Platform was important to developers from the time that
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`Facebook introduced it for at least three primary reasons. First, Facebook Platform offered
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`developers a unique distribution channel for their products and services, promising to allow
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`developers to exploit Facebook’s massive social graph to “spur mass distribution.” Second, tools
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`like Graph API, Social Plugins, and Open Graph provided developers with the ability to engage
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`their users through personalized experiences: “For example, if you like a band on [the music
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`service] Pandora, that information can become part of the graph so that later if you visit a concert
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`site, the site can tell you when the band you like is coming to your area.” Third, Facebook Platform
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`enabled developers to advertise their products and conduct in-app transactions. With these benefits
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`on offer, and the company’s active encouragement, developers were induced to rely on Facebook’s
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`open access policies and invested in developing compatible products.
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`40.
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`Usage of Open Graph grew rapidly. One week after the introduction of Open
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`Graph, over 50,000 websites had installed Open Graph plug-ins. Those sites realized the
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`immediate benefits of a massive new distribution channel. By July 2008, one year after it
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`launched, more than 400,000 developers were already using Facebook Platform. By April 2010,
`
`over
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` developers were using Facebook Platform. By July 2012, Open Graph was being
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`used to share nearly one billion pieces of social data each day to Facebook Blue, giving Facebook
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`substantially greater and more granular information about its users and their online activities.
`
`41.
`
`This strategy not only integrated users’ online activities more fully into Facebook
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`Blue, but also drove profits for Facebook. As a Facebook executive summarized in a May 2012
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`email to Facebook Chief Operating Officer (“COO”) Sheryl Sandberg: “Because we have this
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`critical mass of people, that attracts new people to sign up, it attracts developers who want to find
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`customers for their apps and websites, and it attracts advertisers [who] want to reach the
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`audience[.]” The executive explained that Facebook had “[r]eached a size now where you can
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`imagine as a developer that most of your current and future users/customers are on Facebook[,]”
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`noting that “[7] of the top 10 apps in the Apple App store are Facebook enabled[.]”
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`42.
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`Further, third-party apps helped Facebook grow through Facebook plug-ins and by
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`directing social data, such as “Likes,” back to Facebook Blue. These interactions also provided
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`Facebook with critical information about the extent to which users interacted with third-party apps
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`and enabled it to closely track and identify usage trends in their incipiency.
`
`C.
`
`43.
`
`Facebook Surpassed Early Competitors to Become the Dominant Social
`Network
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`Facebook grew rapidly following its 2006 expansion beyond schools to the general
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`public. According to ordinary course documents, between May 2007 and May 2008, Facebook’s
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`monthly active users grew
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`, while those of Myspace—its primary competitor—grew just
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` over the same period. By 2009, Facebook had surpassed Myspace and established
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`itself as the most popular personal social networking provider in the United States and the world.
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`In October 2011, according to internally circulated figures, Facebook had 156 million unique users
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`in the United States averaging 441 minutes per visitor on the service. At the same time, Myspace
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`had just twenty-seven million users in the United States averaging merely ten minutes per visitor.
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`By 2011, Facebook was touting to its advertising clients that “Facebook is now 95% of all social
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`media in the US.”
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`44.
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`Facebook’s Platform policies helped to fuel its growth. After launching its
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`Facebook Platform and Open Graph initiatives, Facebook grew significantly, adding an average
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`of more than ten million monthly active users in the United States each year from 2010 to 2018.
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`D. Facebook’s Business Model: Selling Advertising Based on Detailed User Data
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`
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`45. While there are several ways in which personal social networking could be
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`monetized, Facebook has chosen to monetize its product by mining the personal data of its users
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`and selling behavioral advertising.
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`46.
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`This practice has been highly profitable for Facebook. Advertisers now pay
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`billions—approximately $84 billion in 2020—to display their ads to specific sets of Facebook Blue
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`and Instagram users. Facebook serves up these “audiences” using proprietary algorithms that
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`analyze the vast quantity of data the company collects on its users. This allows advertisers to
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`target different campaigns and messages to different groups of users. Ads displayed by Facebook
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`are interspersed with—and can be similar in appearance to—user-generated content.
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`47.
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`Facebook recognizes the unique characteristics of the advertising that a personal
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`social network can offer (“social advertising”). For example, in earnings calls, Facebook COO
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`Sheryl Sandberg described Facebook Blue as the “world’s first global platform that lets marketers
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`Case 1:20-cv-03590-JEB Document 75-1 Filed 08/19/21 Page 16 of 80
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`personalize their messages at unprecedented scale,” and called Facebook Blue and Instagram the
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`“two most important mobile advertising platforms” in the world.
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`48.
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`Social advertising is distinct from other forms of advertising, including other forms
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`of display advertising, search advertising, and “offline” advertising (e.g., television, radio, and
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`print).
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`49.
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`Social advertising is a distinct form of display advertising. Display advertising
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`refers to the display of advertisements—in the form of images, text, or videos—on websites or
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`apps when a user visits or uses them. Display advertising is distinct from “offline” advertising,
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`such as television, radio, and print advertising, because it offers the ability to reach consumers
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`during their online activity (including during their use of mobile devices like smartphones and
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`tablets), allows for interactive ads, and permits rich ad targeting to users using personal data
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`generated and collected through their online activity. Display advertising is also distinct from
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`search advertising, which is a form of digital advertising that is shown to a person when he or she
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`enters a specific search term in an online search engine, like Google or Bing. Advertisers buy
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`search advertising to target consumers who are actively inquiring about a particular type of product
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`or service. By contrast, display advertising reaches consumers who are not actively querying a
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`search engine, including consumers who may be further from making a specific purchase decision.
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`50.
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`Social advertising is a type of display advertising, but it is distinct in several ways
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`from the non-social display advertising found on websites and apps that are not personal social
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`networks. For example, in part because users must log in to a personal social network with unique
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`user credentials, social advertising enables advertisers to target users based on personalized data
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`regarding users’ personal connections, activities, identity, demographics, interests, and hobbies.
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`Also, in contrast to display advertising on other websites and apps, social advertising leverages
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`high eng