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Case 8:20-cv-00585-MSS-CPT Document 1-1 Filed 03/12/20 Page 1 of 33 PageID 10
`Filing # 104496395 E-Filed 03/06/2020 03:50:49 PM
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`IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
`IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
`CIRCUIT CIVIL DIVISION
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`DEBRYNNA GARRETT, ALEXANDER C. ROBERTS,
`TIMOTHY DIXON, JR., KONICA RITCHIE,
`JESSICA YOUNG, LAMOND RICHARDSON,
`ANGELA CANSINO, JOHNNY OLDEN,
`KATRINA EVANS, DANIEL WALKER,
`TODD ALEXANDER, ELTON GOULD,
`LAMEKA DOTSON, NICHOLAS COLLINS,
`REMEAL EUBANKS, TANIA PAUL,
`GABRIELLE MURRELL, COURTNEY NELSON,
`individually and on behalf of all others similarly situated,
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`Plaintiffs,
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`v.
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` Case No.: 20-CA-001146
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`FACEBOOK, INC., and COGNIZANT
`TECHNOLOGY SOLUTIONS U.S. CORPORATION,
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`Defendants.
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`_______________________________________________/
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`AMENDED CLASS ACTION COMPLAINT AND DEMAND FOR JURY TRIAL
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`
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`Plaintiffs DEBRYNNA GARRETT, ALEXANDER C. ROBERTS, TIMOTHY DIXON,
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`JR., KONICA RITCHIE, JESSICA YOUNG, LAMOND RICHARDSON, ANGELA CANSINO,
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`JOHNNY OLDEN, KATRINA EVANS, DANIEL WALKER, TODD ALEXANDER, ELTON
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`GOULD, LAMEKA DOTSON, NICHOLAS COLLINS, REMEAL EUBANKS, TANIA PAUL,
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`GABRIELLE MURRELL and COURTNEY NELSON (“Plaintiffs”) hereby sue the Defendants,
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`FACEBOOK, INC. (“Facebook”), and COGNIZANT TECHNOLOGY SOLUTIONS U.S.
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`CORPORATION (“Cognizant”) (collectively, “Defendants”) to protect themselves and all others
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`similarly situated from the dangers of psychological trauma resulting from Defendants’ failure to
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`provide a safe workplace for the thousands of “content moderators” who are entrusted to provide
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`the safest environment possible for Facebook users.
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`
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`· LECHNER LAW ·
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`Case 8:20-cv-00585-MSS-CPT Document 1-1 Filed 03/12/20 Page 2 of 33 PageID 11
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`BACKGROUND
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`1.
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`Every day, Facebook users post millions of videos, images, and livestreamed
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`broadcasts of child sexual abuse, rape, torture, bestiality, beheadings, suicide, racist violence and
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`murder. To maintain a sanitized platform, maximize its already vast profits, and cultivate its public
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`image, Facebook relies on people like Plaintiffs – known as “content moderators” – to view those
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`posts and remove any that violate the corporation’s terms of use.
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`2.
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`From their cubicles during the overnight shift in Cognizant’s Tampa and Phoenix
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`offices, Plaintiffs witnessed thousands of acts of extreme and graphic violence. As another
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`Facebook content moderator recently told the Guardian, “You’d go into work …, turn on your
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`computer and watch someone have their head cut off. Every day, every minute, that’s what you
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`see. Heads being cut off.”
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`3.
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`As a result of constant and unmitigated exposure to highly toxic and extremely
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`disturbing images through Facebook’s content review systems, Plaintiffs and other class members
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`developed and suffer from significant psychological trauma and/or post-traumatic stress disorder
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`(“PTSD”).
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`4.
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`In an effort to cultivate its image, Facebook helped draft workplace safety standards
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`to protect content moderators like Plaintiffs and the proposed class from workplace trauma and
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`associated adverse consequences, which include pre-hiring psychological screening; providing
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`moderators with robust and mandatory counseling and mental health support; altering the
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`resolution, audio, size, and color of trauma-inducing images; and training moderators to recognize
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`the physical and psychological symptoms of PTSD.
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`5.
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`Other recommended safety standards include: having content moderators work in
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`pairs or teams rather than alone; improving working conditions by not focusing solely on
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`efficiency and productivity; and providing additional breaks or “wellness time” during periods of
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`extraordinary stress. In addition, Cognizant employees requested to change their queues. For
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`example, several content moderators asked the company to change which queues they were
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`assigned, whereby Workforce Management could periodically place a moderator in less graphic
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`queues, such as regulated goods. Defendants failed to implement any of these safety standards.
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`6.
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`But Defendants ignore the very workplace safety standards they helped create.
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`Instead, the multibillion-dollar corporations affirmatively require their content moderators to work
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`under conditions known to cause and exacerbate psychological trauma.
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`7.
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`Facebook contracts with companies like Cognizant to serve as its agent responsible
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`for finding, hiring and employing the moderators, and then laying them off when the contract
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`expires, thereby attempting to absolve Defendants of accountability for the mental health of
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`(offering no psychological support to) their workers after they are laid off. In fact, Cognizant has
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`shut down its Tampa and Phoenix offices in February 2020, laying off its workforce and leaving
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`content moderators, including Plaintiffs, with no means of obtaining requisite ongoing medical
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`monitoring, screening, diagnosis, or adequate treatment after suffering psychological trauma
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`during their employment.
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`8.
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`By requiring their content moderators to work in dangerous conditions that cause
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`debilitating physical and psychological harm and then laying them off when the contract expires
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`in order to absolve themselves of accountability for their mental health issues, Defendants violate
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`Florida and Arizona law.
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`9. Without this Court’s intervention, Defendants will continue to breach the duties
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`they owe to the content moderators who review content on Facebook’s platforms.
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`10. Content moderators are essentially the first responders of the internet, performing
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`Case 8:20-cv-00585-MSS-CPT Document 1-1 Filed 03/12/20 Page 4 of 33 PageID 13
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`a critical function on a platform with billions of users. Many times, moderators are the first to see
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`emergency situations and report them to Facebook to report to local authorities. Plaintiffs were
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`specifically referred to as “first responders,” and Facebook compiles statistics about how
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`moderators assist law enforcement. Plaintiffs and the other content moderators, at a minimum,
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`deserve
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`the same protections as other
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`first
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`responders, which
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`includes workers’
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`compensation/health coverage for the PTSD caused by the working conditions.
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`11. On behalf of themselves and all others similarly situated, Plaintiffs bring this action
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`(1) to ensure that Defendants cease to engage in these unlawful and unsafe workplace practices
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`and instead provide content moderators with safe tools, systems, and mandatory ongoing mental
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`health support, (2) to establish a medical monitoring fund for testing and providing mental health
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`treatment to the thousands of current and former content moderators affected by Defendants’
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`unlawful practices, and (3) to provide monetary compensation to the thousands of current and
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`former content moderators for the lost wages and medical and mental health expenses incurred as
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`a result of the Defendants’ unlawful practices.
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`JURISDICTION AND VENUE
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`12. This is an action for damages in excess of $30,000.00, exclusive of interest, costs,
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`and equitable relief.
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`13. Venue is proper in this Court because the unlawful conduct giving rise to the claims
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`herein occurred within this judicial district, and at least one Defendant is located in this judicial
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`district.
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`14. This Court has personal jurisdiction over Cognizant because the corporation
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`operates, conducts, engages in, and carries on a business venture in this state and has an office in
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`this judicial circuit, at 7725 Woodland Center Blvd., Tampa, FL 33614, and regularly conducts
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`Case 8:20-cv-00585-MSS-CPT Document 1-1 Filed 03/12/20 Page 5 of 33 PageID 14
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`substantial business there, committed a tortious act within Florida, and engages in substantial and
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`not isolated activity within Florida.
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`15.
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`This Court has personal jurisdiction over Facebook because the corporation
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`operates, conducts, engages in, and carries on a business venture in this state and has an office in
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`this state, located at 701 Brickell Ave., Miami, Florida 33131, and regularly conducts substantial
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`business there and throughout the state, committed a tortious act within Florida, and engages in
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`substantial and not isolated activity within Florida.
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`PARTIES
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`16.
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`Plaintiffs Garrett, Roberts, Dixon, Ritchie, Young, Richardson, Cansino, Olden,
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`Evans, Walker, Alexander, Dotson, Collins, Eubanks, Paul, Murrell and Nelson are residents of
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`Hillsborough County, Florida. Plaintiff Gould is a resident of Pasco County, Florida. Plaintiff
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`Roberts is a citizen of Arizona.
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`17. Defendant Facebook provides “products that enable people to connect and share
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`with friends and family through mobile devices, personal computers, and other surface” or “to
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`share their opinions, ideas, photos and videos, and other activities with audiences ranging from
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`their closest friends to the public at large.” Facebook is a publicly traded corporation incorporated
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`under the laws of Delaware, with its headquarters located at 1601 Willow Road, Menlo Park,
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`California, 94025.
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`18. Defendant Cognizant
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`is a professional services vendor
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`that employed
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`approximately 800 workers at its Facebook content moderation site in Tampa. Cognizant is a
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`publicly traded corporation incorporated under the laws of Delaware, with its headquarters located
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`at 211 Quality Circle, College Station, TX 77845.
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`Case 8:20-cv-00585-MSS-CPT Document 1-1 Filed 03/12/20 Page 6 of 33 PageID 15
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`FACTUAL ALLEGATIONS
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`A. Content moderators watch and remove some of the most depraved images on the
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`internet to protect users of Facebook’s products from trauma-inducing content.
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`19. Content moderation is the practice of removing online material that violates the
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`terms of use for social networking sites or applications like Facebook.com and Instagram.
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`20.
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`Instead of scrutinizing content before it is published to its users, Facebook primarily
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`relies on users to report inappropriate content. Facebook receives more than one million user
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`reports of potentially objectionable content on its social media sites and applications every day.
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`Human moderators review the reported content – sometimes thousands of videos and images every
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`shift – and remove those that violate Facebook’s terms of use.
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`21. After content is flagged, Facebook’s algorithms direct it to a content moderator,
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`who then reviews it using a platform developed by Facebook.
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`22.
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`Facebook asks content moderators to review more than 10 million potentially rule-
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`breaking posts per week via its review platforms. Facebook seeks to ensure all user-reported
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`content is reviewed within 24 hours of a report and with an overall error rate of less than one
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`percent.
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`23. Facebook has developed and continually revises hundreds of rules that content
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`moderators use to determine whether flagged content – i.e., posts, comments, messages, images,
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`videos, advertisements, etc. – violates Facebook’s policies.
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`24. Facebook has also developed expectations for the amount of time a content
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`moderator should need to review different types of flagged content.
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`25. According to Monika Bickert, head of global policy management at Facebook,
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`Facebook conducts weekly audits of every content moderator’s work to ensure that its content
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`rules are being followed consistently.
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`Case 8:20-cv-00585-MSS-CPT Document 1-1 Filed 03/12/20 Page 7 of 33 PageID 16
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`26.
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`In August 2015, Facebook rolled out Facebook Live, a feature that allows users to
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`broadcast live video streams on their Facebook pages. Mark Zuckerberg, Facebook’s chief
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`executive officer, considers Facebook Live to be instrumental to the corporation’s growth. Mr.
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`Zuckerberg has been a prolific user of the feature, periodically “going live” on his own Facebook
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`page to answer questions from users.
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`27. But Facebook Live also provides a platform for users to livestream murder,
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`beheadings, torture, and even their own suicides, including the following:
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`● In late April 2017, a father killed his 11-month-old daughter and livestreamed it before
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`hanging himself. Six days later, Naika Venant, a 14-year-old who lived in a foster home,
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`tied a scarf to a shower’s glass doorframe and hung herself. She streamed the whole suicide
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`in real time on Facebook Live. Then in early May, a Georgia teenager took pills and placed
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`a bag over her head in a suicide attempt. She livestreamed the attempt on Facebook and
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`survived only because viewers watching the event unfold called police, allowing them to
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`arrive before she died.
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`● On March 15, 2019, the horrific mass shooting in Christchurch, New Zealand, which killed
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`50 people at two mosques, was livestreamed on Facebook as the shooter pulled up to a
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`mosque in Christchurch, New Zealand, grabbed guns out of his vehicle and stormed inside,
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`opening fire on worshipers. By the time Facebook removed the 17-minute video, it had
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`been viewed roughly 4,000 times, the company said.
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`28. Facebook understands the dangers associated with a person watching this kind of
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`imagery.
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`29.
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`In the context of protecting users from this kind of content, Mr. Zuckerberg
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`announced on May 3, 2017:
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`Case 8:20-cv-00585-MSS-CPT Document 1-1 Filed 03/12/20 Page 8 of 33 PageID 17
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`“Over the last few weeks, we’ve seen people hurting themselves and others on
`Facebook—either live or in video posted later. Over the next year, we’ll be adding
`3,000 people to our community operations team around the world – on top of the
`4,500 we have today – to review the millions of reports we get every week, and
`improve the process for doing it quickly.
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`These reviewers will also help us get better at removing things we don’t allow on
`Facebook like hate speech and child exploitation. And we’ll keep working with
`local community groups and law enforcement who are in the best position to help
`someone if they need it – either because they’re about to harm themselves, or
`because they’re in danger from someone else.”
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`30. According to Sheryl Sandberg, Facebook’s chief operating officer, “Keeping
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`people safe is our top priority. We won’t stop until we get it right.”
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`31. Today, approximately 15,000 content moderators around the world review content
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`via Facebook’s review platforms.
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`32. Most of these 15,000 content moderators, like Plaintiffs and the proposed class
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`here, are employed by third-party vendors of Facebook and are not Facebook employees.
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`33. For many reasons, including short-term contracts and the trauma associated with
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`the work, most content moderators – like Plaintiffs – remain in the position for short periods of
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`time. When the contractors’ contracts expire, the content moderators are laid off and abandoned
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`by Defendants, with no access to adequate or ongoing mental health services or psychological
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`support.
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`B. Repeated exposure to graphic imagery can cause devastating psychological trauma,
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`including PTSD.
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`34.
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`It is well known that exposure to images of graphic violence can cause debilitating
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`injuries, including PTSD.
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`35.
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`In a study conducted by the National Crime Squad in the United Kingdom, 76
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`percent of law enforcement officers surveyed reported feeling emotional distress in response to
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`exposure to child abuse on the internet. The same study, which was co-sponsored by the United
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`Kingdom’s Association of Chief Police Officers, recommended that law enforcement agencies
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`implement employee support programs to help officers manage the traumatic effects of exposure
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`to child pornography.
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`36.
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`In a study of 600 employees of the Department of Justice’s Internet Crimes Against
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`Children task force, the U.S. Marshals Service found that a quarter of the cybercrime investigators
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`surveyed displayed symptoms related to psychological trauma, including from secondary
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`traumatic stress.
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`37. Another study of cybercrime investigators from 2010 found that “greater exposure
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`to disturbing media was related to higher levels of . . . secondary traumatic stress” and that
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`“substantial percentages” of investigators exposed to disturbing media “reported poor
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`psychological well-being.”
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`38. The Eyewitness Media Hub has also studied the effects of viewing videos of
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`graphic violence, including suicide bombing, and found that“40 percent of survey respondents said
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`that viewing distressing eyewitness media has had a negative impact on their personal lives.”
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`39. Whereas viewing or hearing about another person’s traumatic event used to be
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`considered “secondary traumatic stress,” the current Diagnostic and Statistical Manual of Mental
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`Disorders (American Psychiatric Association, 5th ed. 2013) (“DSM-5”) recognizes that secondary
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`or indirect exposure to trauma, such as repeated or extreme exposure to aversive details of trauma
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`through work-related media, meets the first diagnostic criterion for PTSD.
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`40.
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`It is well established that stressful work conditions, such as especially demanding
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`job requirements or a lack of social support, reduce resilience in the face of trauma exposure and
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`increase the risk of developing debilitating psychological symptoms.
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`41. Depending on many factors, individuals who have experienced psychological
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`trauma may develop a range of subtle to significant physical and psychological symptoms,
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`including extreme fatigue, disassociation, difficulty sleeping, excessive weight gain, anxiety,
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`nausea, and other digestive issues.
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`42. Trauma exposure and PTSD are also associated with increased risk of chronic
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`health problems including cardiovascular problems, strokes, pain syndromes, diabetes, epilepsy,
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`and dementia.
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`43. There is growing evidence that early identification and treatment of PTSD is
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`important from a physical health perspective, as a number of meta-analyses have shown increased
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`risk of cardiovascular, metabolic, and musculoskeletal disorders among patients with long-term
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`PTSD.
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`44. Psychological trauma and/or PTSD are also often associated with the onset or
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`worsening of substance use disorders. Epidemiologic studies indicate that one-third to one-half of
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`individuals with PTSD also have a substance use disorder. Compared to individuals without PTSD,
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`those with PTSD have been shown to be more than twice as likely to meet the diagnostic criteria
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`for alcohol abuse or dependence; individuals with PTSD are also three to four times more likely
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`to meet the diagnostic criteria for drug abuse or dependence.
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`45. PTSD symptoms may manifest soon after the traumatic experiences, or they may
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`manifest later in life, sometimes months or years after trauma exposure.
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`46. An individual’s risk of developing PTSD or associated symptoms may be reduced
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`through prevention measures, which include primary, secondary, or tertiary interventions. Primary
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`interventions are designed to increase resilience and lower the risk of future PTSD among the
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`general population. Secondary interventions are designed to lower the risk of PTSD among
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`individuals who have been exposed to trauma, even if they are not yet showing symptoms of
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`Case 8:20-cv-00585-MSS-CPT Document 1-1 Filed 03/12/20 Page 11 of 33 PageID 20
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`traumatic stress. Finally, tertiary interventions are designed to prevent the worsening of symptoms
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`and improve functioning in individuals who are already displaying symptoms of traumatic stress,
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`or have been diagnosed with PTSD.
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`47.
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`Individuals who develop PTSD or other mental health conditions following
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`traumatic exposure require not only preventative measures but also treatment. Unlike prevention,
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`treatment measures are aimed at symptom resolution and recovery from the condition.
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`48. Preliminary screening is necessary to determine which types of prevention or
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`treatment measures are most appropriate for an individual.
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`C.
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`Facebook helped craft industry standards for minimizing harm to content
`moderators but failed to implement the very standards it helped create.
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`49.
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`In 2006, Facebook helped create the Technology Coalition, a collaboration of
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`internet companies aiming “to develop technology solutions to disrupt the ability to use the Internet
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`to exploit children or distribute child pornography.”
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`50. Facebook was a member of the Technology Coalition at all times relevant to the
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`allegations herein.
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`51.
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`In January 2015, the Technology Coalition published an “Employee Resilience
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`Guidebook for Handling Child Sex Abuse Images” (the “Guidebook”).
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`52. According to the Guidebook, the technology industry “must support those
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`employees who are the front line of this battle.”
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`53. The Guidebook recommends that internet companies implement a robust, formal
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`“resilience” program to support content moderators’ well-being and mitigate the effects of
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`exposure to trauma-inducing imagery.
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`54. With respect to hiring content moderators, the Guidebook recommends:
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`a.
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`In an informational interview, “[u]se industry terms like ‘child sexual abuse
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`imagery’ and ‘online child sexual exploitation’ to describe subject matter.”
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`b.
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`In an informational interview, “[e]ncourage candidate to go to websites
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`[like the National Center for Missing and Exploited Children] to learn about
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`the problem.”
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`c.
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`In follow-up interviews, “[d]iscuss candidate’s previous experience/
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`knowledge with this type of content.”
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`d.
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`In follow-up interviews, “[d]iscuss candidate’s current level of comfort
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`after learning more about the subject.”
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`e.
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`In follow-up interviews, “[a]llow candidate to talk with employees who
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`handle content about their experience, coping methods, etc.”
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`f.
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`In follow-up interviews, “[b]e sure to discuss any voluntary and/or
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`mandatory counseling programs that will be provided if candidate is hired.”
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`55. With respect to safety on the job, the Guidebook recommends:
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`a.
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`Limiting the amount of time an employee is exposed to child sexual abuse
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`imagery;
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`b.
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`Teaching moderators how to assess their own reaction to the images;
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`c.
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`Performing a controlled content exposure during the first week of
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`employment with a seasoned team member and providing follow up
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`counseling sessions to the new employee;
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`d.
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`Providing mandatory group and individual counseling sessions
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`administered by a professional with specialized training in trauma
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`intervention; and
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`e.
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`Permitting moderators to “opt-out” from viewing child sexual abuse
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`imagery.
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`56. The Technology Coalition also recommends the following practices for minimizing
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`exposure to graphic content:
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`a.
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`Limiting time spent viewing disturbing media to “no more than four
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`consecutive hours;”
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`b.
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`“Encouraging switching to other projects, which will allow professionals to
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`get relief from viewing images and comeback recharged and refreshed;”
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`c.
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`Using “industry-shared hashes to more easily detect and report [content]
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`and in turn, limit employee exposure to these images. Hash technology
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`allows for identification of exactly the same image previously seen and
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`identified as objectionable;”
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`d.
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`Prohibiting moderators from viewing child pornography one hour before
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`the individuals leave work; and
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`e.
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`Permitting moderators to take time off as a response to trauma.
`
`57. According to the Technology Coalition, if a company contracts with a third-party
`
`vendor to perform duties that may bring vendor employees in contact with graphic content, the
`
`company should clearly outline procedures to limit unnecessary exposure and should perform an
`
`initial audit of the independent contractor’s wellness procedures for its employees.
`
`
`
`58. The National Center for Missing and Exploited Children (“NCMEC”) also
`
`promulgates guidelines for protecting content moderators from psychological trauma. For
`
`instance, NCMEC recommends changing the color or resolution of the image, superimposing a
`
`grid over the image, changing the direction of the image, blurring portions of the image, reducing
`
`the size of the image, and muting audio.
`
`
`
`13
`
`

`

`Case 8:20-cv-00585-MSS-CPT Document 1-1 Filed 03/12/20 Page 14 of 33 PageID 23
`
`
`
`59. Based on these industry standards, some internet companies take steps to minimize
`
`harm to content moderators. However, Defendants do not take any of the mitigating set forth
`
`above. Cognizant did not even conduct any psychological evaluations on new employees,
`
`including Plaintiffs, to determine if they were a good fit for the job. Although there are counselors
`
`on staff, they do not provide any real counseling services. In fact, management was told to monitor
`
`how much time employees spent with counselors in order to discourage use of counseling services.
`
`
`
`60. Content moderators review thousands of traumatic images each day through
`
`Facebook’s review platforms without the benefit of these known safeguards and with little training
`
`on how to handle the resulting distress.
`
`
`
`61.
`
`In addition, Facebook sets overarching standards relating to the timeframe for and
`
`accuracy of review.
`
`
`
`62.
`
`Plaintiffs and other content moderators at the Tampa and Phoenix Cognizant
`
`facilities faced relentless pressure from their bosses to better enforce Facebook’s community
`
`standards, which receive near-daily updates that leave its contractor workforce in a perpetual state
`
`of uncertainty. The Tampa site, which has been accurately referred to in the press as a
`
`“sweatshop,” has routinely failed to meet the 98 percent “accuracy” target set by Facebook. With
`
`a score hovering around 92, it has been Facebook’s worst-performing site in North America.
`
`
`
`63.
`
`In mid-2019, a “Wellness Summit” was held, where Facebook displayed the
`
`productivity statistics for its content moderator contractors. Cognizant was on the bottom of the
`
`list. After this Summit, Cognizant issued directives to begin writing up employees for lack of
`
`production and taking too much “wellness” time.
`
`
`
`64. Following the Wellness Summit, employees, including Plaintiffs, were being
`
`pushed hard. Employees were expected to review 300 pieces of content per day. Employees were
`
`
`
`14
`
`

`

`Case 8:20-cv-00585-MSS-CPT Document 1-1 Filed 03/12/20 Page 15 of 33 PageID 24
`
`being written up for lack of production and taking too much “wellness” time (e.g. time to
`
`“decompress” during a shift). These write ups were based on a directive from Cognizant, which
`
`originally came from Facebook
`
`
`
`65.
`
`Facebook understands that its standards impose intense pressure and stress on
`
`content moderators, and that such stress contributes to and exacerbates content moderators’ risk of
`
`developing psychological trauma.
`
`
`
`66. As one moderator described the job:
`
`“[The moderator] in the queue (production line) receives the tickets (reports)
`randomly. Texts, pictures, videos keep on flowing. There is no possibility to know
`beforehand what will pop up on the screen. The content is very diverse. No time is
`left for a mental transition. It is entirely impossible to prepare oneself
`psychologically. One never knows what s/he will run into. It takes sometimes a few
`seconds to understand what a post is about. The agent is in a continual situation of
`stress. The speed reduces the complex analytical process to a succession of
`automatisms. The moderator reacts. An endless repetition. It becomes difficult to
`disconnect at the end of the eight-hour shift.”
`
`67. Facebook also demands that its content moderation vendors, including Cognizant,
`
`
`
`require their employees to sign sweeping Non-Disclosure Agreements (“NDAs”). Facebook
`
`further requires its vendors to provide Facebook-developed training to all content moderators to
`
`instruct the moderators not to speak about the content or workplace conditions to anyone outside
`
`of their review team. By prohibiting content moderators from discussing their work or seeking
`
`outside social support, Facebook impedes the development of resiliency and increases the risk that
`
`moderators will develop psychological trauma.
`
`
`
`68.
`
`The results of an in-depth investigation into the dangerous working conditions at
`
`Cognizant’s Tampa facility and some of the psychological harm suffered by the content
`
`moderators employed there was published in The Verge in June 2019. For further background
`
`information, please visit: https://www.theverge.com/2019/6/19/18681845/facebook-moderator-
`
`
`
`15
`
`

`

`Case 8:20-cv-00585-MSS-CPT Document 1-1 Filed 03/12/20 Page 16 of 33 PageID 25
`
`interviews-video-trauma-ptsd-cognizant-tampa and https://www.cnn.com/videos/business/2019/
`
`06/23/former-facebook-moderator-blows-the-whistle.cnn.
`
`E.
`
`Plaintiffs Garrett’s individual allegations.
`
`
`
`69.
`
`From approximately July 2018 until the present, Plaintiff Garrett worked as a
`
`Process Executive (a/k/a Facebook Content Moderator) at Cognizant’s offices at 7725 Woodland
`
`Center Blvd., Tampa, FL 33614.
`
`
`
`70. During this period, Plaintiff Garrett was employed by Cognizant.
`
`
`
`71. At all times relevant to this complaint, Cognizant was an independent contractor of
`
`Facebook.
`
`
`
`
`
`72. Cognizant directly oversaw all human resources matters concerning Ms. Garrett.
`
`73. Ms. Garrett has never been employed by Facebook in any capacity and never
`
`received any wages or employee benefits package (e.g., wellness benefits, paid time off, parental
`
`financial assistance) from Facebook.
`
`
`
`74. During her employment as a content moderator, Ms. Garrett was exposed to
`
`thousands of images, videos, and livestreamed broadcasts of graphic violence, including
`
`beheadings, mutilations, terrorist killings and torture, rapes and murders.
`
`
`
`75. On the night of March 9, 2018, Mr. Roberts’s coworker, Keith Utley, had a heart
`
`attack and died at his desk during Mr. Roberts’s shift. Management came in and instructed
`
`everyone that they could not speak about it with anyone. Cognizant never disclosed what Mr.
`
`Utley was watching when he died, nor did it taking any apparent mitigating steps to ensure this
`
`does not happen again to other content moderators.
`
`
`
`76. Ms. Garrett and other content moderators in Tampa and Phoenix receive two 15-
`
`minute breaks and a 30-minute lunch each day, along with nine minutes per day of “wellness” time
`
`
`
`16
`
`

`

`Case 8:20-cv-00585-MSS-CPT Document 1-1 Filed 03/12/20 Page 17 of 33 PageID 26
`
`that they purportedly can use when they feel overwhelmed by the emotional toll of the job.
`
`
`
`77. On March 15, 2019, two consecutive terrorist shooting attacks occurred at mosques
`
`in Christchurch, New Zealand, killing 51 people and injuring 49. The gunman, a white
`
`supremacist, live-streamed the first 17 minutes of this attack on Facebook Live. Cognizant
`
`employees, including Ms. Garrett, were forced to watch these horrific images over and over again
`
`due to its viral nature. Defendants Facebook and Cognizant did not provide support after this event
`
`and failed to have trauma counselors on site.
`
`
`
`78. As a result of the extreme working conditions and unrelenting pressure, in Fall
`
`2018, Ms. Garrett was diagnosed with PTSD. As a result of these impairments, Ms. Garrett went
`
`out on a leave of absence in or about September 2019.
`
`E.
`
`Plaintiffs Roberts’ individual allegations.
`
`
`
`79. From approximately November 2017 until January 19, 2020, Plaintiff Robe

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