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It is alleged in this complaint that Facebook made misleading and false statements to the market. Facebook misled the market in regard to its user growth. Facebook knew or should have known that a considerable portion of its purported growth originated from duplicate accounts represented, and failed to disclose the implications of duplicate accounts on its revenue growth and business. Facebook failed to maintain a fair platform for all users, including protecting high-profile users with the “Cross Check/XCheck” system. Facebook failed to take effective action against bad actors on its platform such as human traffickers, drug cartels, and violent criminals. Facebook’s public statements were materially misleading and false, based on these facts. Investors suffered damages when the market learned the truth about Facebook.