Rita Shreffler Declaration Re
Summary
The Declaration of Rita Shreffler, Director of Communications for Children's Health Defense, filed June 7, 2021 as Document 103-1 in Children's Health Defense v. Facebook, Inc., et al., Case No. 3:20-cv-05787-SI, in the U.S. District Court for the Northern District of California. It supports the plaintiff's Motion to File a Rule 15(d) Supplement to the Second Amended Complaint and Request for In Camera Inspection. The declaration attaches as Exhibit 1 the plaintiff's Second Proposed Supplement to its Second Amended Complaint, which alleges that Facebook removed vaccine-related content regardless of whether it was false and cites emails between Mark Zuckerberg and Dr. Anthony Fauci from March 2020. Exhibit 2 is described as documents on Facebook's Global Operations Primer on Health Misinformation, and Exhibit 3 as redacted emails. The filing is 38 pages.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Full text
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 1 of 38
1 ROGER I. TEICH
California State Bar No. 147076
2 290 Nevada Street
San Francisco, CA 94110
3 Telephone: (415) 948-0045
E-Mail Address: rteich@juno.com
4
ROBERT F. KENNEDY, JR.
5 MARY HOLLAND
6 Children’s Health Defense
1227 North Peachtree Parkway, Suite 202
7 Peachtree City, GA 30269
Telephone: (917) 743-3868
8 E-Mail Address: mary.holland@childrenshealthdefense.org
(Subject to pro hac vice admission)
9
Attorneys for Plaintiff
10 CHILDREN’S HEALTH DEFENSE
11 UNITED STATES DISTRICT COURT
12 NORTHERN DISTRICT OF CALIFORNIA
13 SAN FRANCISCO DIVISION
14
15
16 CHILDREN’S HEALTH DEFENSE,
17 Plaintiff,
18 Case No. 20-cv-05787-SI
v.
19 DECLARATION OF RITA SHREFFLER
FACEBOOK, INC., et al.,
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21 Defendants.
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28 1 RITA SHREFFLER DECLARATION RE:
RULE 15(d) MOTION AND OTHER RELIEF
CHD v. Facebook et al.; Case No. 3:20-cv-05787-Si
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 2 of 38
1 DECLARATION OF RITA SHREFFLER
2 I, Rita Shreffler, declare as follows:
3 1. I am the Director of Communications for Children’s Health Defense (“CHD”),
4 which is the plaintiff organization in this action, Children’s Health Defense v. Facebook, Inc.,
5 et al., 3:20-cv-05787-SI, currently pending in the United States District Court for the Northern
6 District of California. This declaration is made in support of Plaintiff CHD’s Motion to File a
7 Rule 15(d) Supplement to the Second Amended Complaint and Request for In Camera
8 Inspection. If called as a witness, I could and would testify competently to the facts herein,
9 except as to those matters stated on information and belief.
10 2. Attached hereto as Exhibit “1” is a true and correct copy of the Second
11 Supplement to Plaintiff’s Second Amended Complaint which CHD seeks leave to file in this
12 case.
13 3. On information and belief, attached hereto as Exhibit “2” are true and correct
14 copies of the Project Veritas Facebook whistleblower’s documents with respect to Facebook’s
15 Global Operations Primer on Health Misinformation, available at https://assets.ctfassets.net/
16 syq3snmxclc9/5m5WDtHyHDYsB7D6qu6Qg3/3a2a12c32ee5606d0fd5f81f3
17 08f8df1/Global_Operations_Primer_-_Health_Misinformation_WATERMARKED.pdf and
18 Vaccine Hesitancy Comment Demotion available at https://assets.ctfassets.net/syq3snmxclc9/
19 7zG8FPh0cBk3qh28dY90iB/10771f24b25cf9994c08bf69e74056d5/Vaccine_Hesitancy_Com
20 ment_Demotion_WATERMARKED.pdf.
21 4. On information and belief, attached hereto as Exhibit “3” are true and correct
22 copies of (redacted) emails between Mark Zuckerberg, Dr. Anthony Fauci, and Courtney
23 Billet, NIAID Director of Office of Communications and Government Relations (OCGR),
24 purportedly from February and March, 2020, which are available at:
25 https://www.documentcloud.org/documents/20793561-leopold-nih-foia-anthony-fauci-emails,
26 and are linked here: https://www.buzzfeednews.com/article/nataliebettendorf/fauci-emails-
27 covid-response.
28 2 RITA SHREFFLER DECLARATION RE:
RULE 15(d) MOTION AND OTHER RELIEF
CHD v. Facebook et al.; Case No. 3:20-cv-05787-Si
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 3 of 38
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I declare under penalty of perjury under the laws of the United States that the foregoing
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is true and correct to the best of my knowledge and that this declaration was executed in
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Nixa, Missouri, on June 7, 2021.
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6 RITA SHREFFLER
7 Communications Director
Children’s Health Defense
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28 3 RITA SHREFFLER DECLARATION RE:
RULE 15(d) MOTION AND OTHER RELIEF
CHD v. Facebook et al.; Case No. 3:20-cv-05787-Si
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 4 of 38
EXHIBIT 1
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 5 of 38
1 ROGER I. TEICH
California State Bar No. 147076
2 290 Nevada Street
San Francisco, CA 94110
3 Telephone: (415) 948-0045
E-Mail Address: rteich@juno.com
4
ROBERT F. KENNEDY, JR.
5 MARY HOLLAND
Children’s Health Defense
6 1227 North Peachtree Parkway, Suite 202
Peachtree City, GA 30269
7 Telephone: (917) 743-3868
E-Mail Address: mary.holland@childrenshealthdefense.org
8
Attorneys for Plaintiff
9 CHILDREN’S HEALTH DEFENSE
10 UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
11 SAN FRANCISCO DIVISION
12
CHILDREN’S HEALTH DEFENSE,
13
Case No. 3:20-cv-05787-SI
14 Plaintiff,
SECOND PROPOSED SUPPLEMENT TO
15 v. PLAINTIFF’S SECOND AMENDED
16 FACEBOOK, INC., et al., COMPLAINT
17
Defendants.
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PLAINTIFF’S SECOND PROPOSED SUPPLEMENT
20 TO ITS SECOND AMENDED COMPLAINT
21 Plaintiff Children’s Health Defense (“CHD”), by and through its undersigned attorneys, hereby
22 supplements its Second Amendment Complaint (“SAC”) against Defendants Facebook, Inc., Mark
23 Zuckerberg, Science Feedback, Poynter Institute, Politifact, and Does 1-20, with the following
24 allegations made on personal information as to itself and on information and belief as to all other things.
25 1. On or about May 10, 2021, a high-ranking Facebook officer expressly admitted that,
26 contrary to Facebook’s official COVID-19 and Vaccine Updates & Policy,
27 www.facebook.com/help/230764881494641, which asserts that Facebook removes COVID- and
28 vaccine-related content only when such content is “false,” Facebook was actually removing content
1 Plaintiff’s Proposed Second
Supplemental Pleading
CHD v. Facebook et al.; Case No. 3:20-cv-05787-SI
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 6 of 38
1 critical of or simply questioning the safety of the COVID vaccines regardless of whether that content
2 was true or false.
3 2. Specifically, according to a Facebook vice president, the company is “removing groups,
4 pages and accounts that deliberately discourage people from taking vaccines, regardless of whether the
5 information can be verified as false or not.” BBC News, The volunteers using “honeypot” groups to
6 fight anti-vax propaganda, May 10, 2021, https://www.bbc.com/news/blogs-trending-57051691
7 (emphasis added). “Some of the groups that fall under the new policy may include material that’s true,
8 or unverifiable, but are not outright falsehoods.” Id. (emphasis added).
9 3. On or about May 24, 2021, a Facebook whistleblower (subsequently fired) went public
10 with internal Facebook documents showing that, notwithstanding the company’s public declarations that
11 it censored only “false” vaccine-related claims, Facebook was in fact systematically and covertly
12 censoring true vaccine-related content, as well as mere expressions of opinion, provided such content
13 was deemed capable of leading to “vaccine hesitancy”—i.e., to concerns about, or reluctance to take, the
14 COVID vaccines. See Project Veritas, BREAKING: Facebook Whistleblowers Expose LEAKED
15 INTERNAL DOCS Detailing New Effort to Secretly Censor Vaccine Concerns on a Global Scale, May
16 24, 2021, https://www.projectveritas.com/news/breaking-facebook-whistleblowers-expose-leaked-
17 internal-docs-detailing-new.
18 4. On or about June 3-4, 2021, Defendant Zuckerberg and Facebook Vice-President Heidi
19 Swarz admitted in a video that the whistleblower leaked documents were authentic Facebook
20 documents. https://www.youtube.com/watch?v=2S3246XJBOI. Neither denied the existence of
21 Facebook’s massive “vaccine hesitancy” censorship program, in which content, including completely
22 true information and/or expression of opinion, is blocked or restricted if it criticizes or questions the
23 safety, efficacy, or necessity of the COVID vaccines. Id.
24 5. On information and belief, Zuckerberg was personally and individually involved in
25 devising and approving this “vaccine hesitancy” censorship campaign.
26 6. In late May and early June 2021, a large number of previously undisclosed emails by or
27 to Dr. Anthony Fauci, Director of the U.S. National Institute of Allergy and Infectious Diseases and
28 Chief Medical Adviser to the President, was released as a result of Freedom of Information Act requests.
2 Plaintiff’s Proposed Second
Supplemental Pleading
CHD v. Facebook et al.; Case No. 3:20-cv-05787-SI
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 7 of 38
1 7. One such email, dated March 15, 2020, was written to Fauci by Defendant Zuckerberg,
2 proposing a collaboration related to COVID- and vaccine-related information. The email discloses to
3 Fauci not-yet-public Facebook plans to launch a COVID information “hub” that would be visible to all
4 of Facebook’s billions of users and proposes collaboration on that “hub” to help “get your message out.”
5 Id. The full extent of the proposed collaboration is, however, unknown because four critical lines have
6 been redacted. Id.
7 8. The following is a copy of that email (Bates #: NIH-000468):
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3 Plaintiff’s Proposed Second
Supplemental Pleading
CHD v. Facebook et al.; Case No. 3:20-cv-05787-SI
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 8 of 38
1 9. In response to Zuckerberg’s March 15, 2020 email to Fauci, National Institutes of Health
2 communications director Courtney Billet sent Fauci an email (also just disclosed, but also partially
3 redacted) the next day, March 16, 2020, saying: “But an even bigger deal is his [Zuckerberg’s] offer
4 [CONTENT REDACTED]. The sooner we get that offer up the food chain the better. I gave Bill a
5 heads-up and he is standing by to discuss this with HHS and WH comms, but I didn’t want him to do
6 anything without you being aware of the offer. Is it OK if I hand this aspect off to Bill to determine who
7 the best point of contact would be so the Administration can take advantage of this offer, soonest? Do
8 you plan to call MZ? His cell number is in his message below.”
9 10. The following is a copy or screenshot of Billet’s email:
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23 11. Fauci responded by email to Billet the following day, March 17, 2020, writing: “I will
24 write to or call Mark and tell him that I am interested in doing this. I will then tell him that you will get
25 for him the name of the USG [United States Government?] point of contact.”
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4 Plaintiff’s Proposed Second
Supplemental Pleading
CHD v. Facebook et al.; Case No. 3:20-cv-05787-SI
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 9 of 38
1 12. The following is a copy or screenshot of Fauci’s email to Billet:
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9 13. Fauci also responded by email to Zuckerberg that same day, March 17, 2020: “Your idea
10 and proposal sound terrific. I would be happy to do a video for your hub. . . . Also, your idea about
11 [REDACTED] is very exciting. I am . . . copying the Director of my Communications and Government
12 Relations Group. She can put your people in touch with the best person who could be the US
13 Government point of contact for [REDACTED.]”
14 14. The following is a copy or screenshot of Fauci’s email to Zuckerberg:
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27 15. All the redactions referred to in the above emails are notated “(b)(4)” (as the legal basis
28 for the redaction), indicating “trade secrets and commercial or financial information.” See 5 U.S.C.
5 Plaintiff’s Proposed Second
Supplemental Pleading
CHD v. Facebook et al.; Case No. 3:20-cv-05787-SI
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 10 of 38
1 § 552(b)(4).
2 16. Given the timing of Zuckerberg’s redacted proposal to Fauci, the subject matter of the
3 email, the legal basis offered for the redactions, the importance attributed to Zuckerberg’s “offer” by
4 Billet, and the alacrity with which they responded, it is plausible to believe that: (a) the offer was acted
5 upon; and (b) that it concerned working together on Facebook’s efforts to censor COVID-related
6 content.
7 17. The email’s timing is especially indicative of this conclusion. In March of 2020, the
8 month when Zuckerberg sent this email, Facebook was then intensely engaged in its early effort to
9 devise methods to “suppress misinformation about the coronavirus.” Jeff Horwitz, Facebook Fights
10 Hoaxes and Hysteria in Its Virus-Themed Groups, WALL ST. J., Mar. 6, 2020, https://www.wsj.com/
11 articles/facebook-fights-hoaxes-and-hysteria-in-its-virus-themed-groups-11583505221.
12 18. As alleged in the SAC, the next month, April, 2020, Facebook would begin what became
13 a concerted, massive, system-wide program of monitoring COVID-related content and suppressing posts
14 deemed by Facebook to be “misinformation.”
15 19. As further alleged in the SAC, Facebook would later admit that in determining what
16 COVID-related content counted as misinformation, Facebook was “advised” by “public health
17 authorities.”
18 20. It is therefore plausible to believe that Facebook, as part of this effort, was seeking
19 assistance from and collaboration with federal health organizations such as the CDC, HHS, or the NIH,
20 and that Zuckerberg was proposing such a collaboration to Fauci.
21 21. This conclusion would also explain the legal basis offered for the redaction—that the
22 redacted content was a “trade secret”—because Facebook was then and is even today attempting to keep
23 secret its various, massive “vaccine-misinformation” surveillance and censorship program.
24 22. On or about May 25, 2021, Facebook reversed its ban on content suggesting that COVID
25 was “manmade or manufactured.” Cristiano Lima, Facebook no longer treating 'man-made' Covid as a
26 crackpot idea, POLITICO, May 25, 2021, https://www.politico.com/news/2021/05/26/facebook-ban-
27 covid-man-made-491053.
28 23. This abrupt reversal followed on the heels of Chief Medical Adviser to the President Dr.
6 Plaintiff’s Proposed Second
Supplemental Pleading
CHD v. Facebook et al.; Case No. 3:20-cv-05787-SI
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 11 of 38
1 Anthony Fauci’s similar backtracking from earlier dismissals of the hypothesis that COVID originated
2 in a Wuhan laboratory. See Jonathan Turley, Facebook says mentions of COVID-19’s possible origins
3 in Wuhan are now allowed. How generous, FOX NEWS, May 27, 2021, https://www.foxnews.com/
4 opinion/facebook-covid-19-origins-wuhan-jonathan-turley (“Now, however, President Joe Biden’s chief
5 medical adviser Dr. Anthony Fauci, and others have acknowledged that there is a basis for suspect[ing]
6 the lab as the origin of the outbreak. So now Facebook will allow you to talk about it.”).
7 24. Facebook’s about-face on this issue confirms, further evidences, and makes more
8 plausible CHD’s allegation that Facebook is acting as censor for the federal government, willfully
9 participating in joint activity with federal officials to decide what speech will be permitted on its
10 platforms, banning information when federal officials want it banned and permitting information when
11 federal officials change their minds.
12 25. As of this filing, CHD is substantially and increasingly self-censoring the content it posts
13 to Facebook.
14 26. Because of Facebook’s deplatforming of Mr. Kennedy, and because of the company’s
15 ramped-up “vaccine-hesitancy” programs, CHD increasingly chooses not to post on Facebook valuable,
16 accurate information and opinions on COVID- and vaccine-related matters—matters of the utmost
17 public importance—out of fear that its account will be terminated if it does so.
18 Dated: June 7, 2021 Respectfully submitted,
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ROBERT F. KENNEDY, JR.
21 Founder and Chairman, Children’s Health Defense
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23 MARY S. HOLLAND
General Counsel, Children’s Health Defense
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26 ROGER I. TEICH
27 Counsel for Plaintiff
28 Children’s Health Defense
7 Plaintiff’s Proposed Second
Supplemental Pleading
CHD v. Facebook et al.; Case No. 3:20-cv-05787-SI
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 12 of 38
EXHIBIT 2
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 13 of 38
Global Operations Primer - Health Misinformation
NB: This is intended to provide a high-level overview of the Global Operations organization, but tailored to context for cross-
functional partners involved in COVID Defense efforts on Misinformation. Our support for COVID Defense is continuously
changing, and so we will work to keep this document up to date. Please reach out to @Alexis Link or @Cristina Cepero-
Novoa with any questions or feedback on how to improve this or if you need to make edits.
Last Updated: April 12th
Organizational Structure and Purpose
The mission of Global Operations (GO) is to:
Build and run world-class processes at a global scale
that minimize harm to people and society, and
maximize success and well-being of our ecosystem of
people, community, business, and partners.
To achieve this mission, the organization is split into three key pillars under GO’s leader, John DeVine.
Very broadly speaking, Trust and Safety is responsible for demand (or what work our reviewers do), and Scaled Ops is
responsible for supply (the people who do that work). Functional Operations covers Risk and Response and houses the
GO Central Analytics team and GO Engineering teams. These three functions are very different in their scope,
responsibilities, and requirements.
As a general rule, all scaled review—or enforcement done by our outsourced review teams across many languages and
at high volume—is operationalized by someone within Trust and Safety, partnering with Scaled Ops to successfully
launch. These flows are almost always in SRT. On the other hand, escalations-only or specialized flows are owned by
Risk and Response teams (Functional Ops) or Market FTEs (Scaled Ops), and may or may not be in SRT.
What? Reviewers Tools
1 Scaled Review High volume review across all supported Outsourced Reps SRT
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 14 of 38
1 Scaled Review Outsourced Reps SRT
languages
Escalations Small-volume review on particular high- FTEs, sometimes SRT, Centra, Tasks,
2 priority areas and escalations-only
Only Contractors other
policies
Trust and Safety is made up of a number of separate teams depending on the function of the business:
1. Community Operations (CO) covers enforcement, measurement, and labeling for the Implementation
Standards (internal-facing guidelines for how to enforce the Community Standards) for organic content; the
Misinformation Process team sits within CO
2. Product Data Operations (PDO) lives within Product Support Ops and covers Product Policy, or the guidelines
dictating how people can actually use our products (e.g. Groups or Live policies, platform policy, etc.). Product
Policy is policy that applies to a particular experience or product experience (for example Fundraisers or Dating)
to address risks that are unique to those surfaces which can't be addressed through Community Standards or
product controls.
3. Business Integrity (BI) covers enforcement for ads policies
4. Commerce Ops is responsible for connections between businesses and users
5. Risk and Payments (R&P) protects the community from financial abuse and provides payments support
6. Legal and Premier Partner Operations supports rights holders, media partners, and their content
Though the focus areas differ for each of the Trust and Safety teams, their responsibilities are generally similar.
Health Misinformation Support
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 15 of 38
Health Misinformation scaled review is supported by both CO and PDO:
1. PDO is labeling to train Barriers to Vaccination (B2V) classifiers;
2. CO outsourced reviewers are enforcing on Misinformation and Harm (M&H), Widely Debunked Hoaxes (WDH),
and Repeatedly Fact-Checked Hoaxes (RFH), conducting prevalence labeling, supporting appeals, and conducting
quality reviews
CO scaled review is done by ring fenced reviewers—meaning these reviewers are only working in the health space. This
is due to the extremely complex nature of misinformation policies and current challenges in accuracy. However, this
limits flexibility of the workforce; we can’t simply add more work to the reviewers as all new work must tradeoff on
other health work. We are actively exploring avenues to break the ring fencing model; this comes with other challenges,
and is unlikely to happen before the end of Q3 at the absolute earliest.*
This scaled review is currently in 10 languages covering 90% of MAP: English, Spanish, Portuguese, Hindi, Bengali,
French, Arabic, Thai, Indonesian, Tagalog, Italian, Burmese, Dutch, German, Malay, Polish, Turkish, Ukrainian,
Vietnamese
This scaled review only covers simple objects—meaning posts, comments, photos, videos, etc. We are planning to
expand coverage to complex objects (pages, groups, events, IG profiles, FB profiles) in late Q3.* Complex Object review
is significantly more resource-intensive than simple objects, and therefore reviewers get through fewer per hour.
Further, all enqueued content is proactively detected—we do not have user reporting today for misinformation.
* Breaking the ring fenced model and expanding to complex objects will take until at least Q3. This is due to a number of
factors, including but not limited to challenges in hiring due to COVID affecting cross-border work, complexity of
misinformation policies, current accuracy, reviewers using an “Info First” review tree versus standard three-step labeling tree,
and developing new tooling.
Non-Scaled Support
Markets
We also have support from our Market FTE teams. An important note is that these FTEs are not an enforcement
workforce. Unlike our CO outsourced reviewers, who spend ~24.5 hours per week on content moderation, Market FTEs
only spend a part of their time doing content review.
Each week, we have Market FTEs enforce for a few hours in the following languages: Amharic, Georgian, German,
Malay, Persian, Turkish, Russian, Albanian, Croatian, Czech, Hungarian, Kurdish, Maghreb, Slovak, Afrikaans, Finnish,
Nepali, Norwegian, and Zulu. We are also requesting regular support for the languages supported at outsourcing to
help on complex objects (or entities). Further, Market FTEs across all markets staff X-Check queues and escalations that
come in.
Unlike CO outsourced reviewers, FTEs can enforce on all policies—including escalations-only policies. This covers M&H,
WDH, RFH, B2V tiers 1 and 2, and Dedicated Vaccine Discouraging Entities (DVDE). They primarily enforce on simple
objects which are sourced from Health Integrity managed classifiers and GO Markets managed CIRD pipelines, but, by
covering the DVDE policy, will also begin to support complex objects.
Within the Markets team sits the Civic Incubator team. This is made up of FTEs from the North America market. This
team covers COIL (Complex Objects Integrity Lab), formerly known as HEROCO, which is an SRT flow allowing for in-
depth review of English Groups (and soon Pages and IG Profiles) against all policies. Today, this review process takes
about 10 minutes per Group reviewed. In addition, this group will soon start review and enforcement of escalated
COVID Top 100 content and entities.
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 16 of 38
Finally, we have Market FTEs and contractors who work on HERO. HERO reviewers cover the predicted top 1000 posts
in the US by VPVs daily. These reviewers apply neutral inform treatments, or NITs, within the HERO flow. They also
temporarily supported COVID Top 100 post review for one week.
Appeals from Markets work outside of COIL currently route to normal CO scaled review. As a result, the reviewers for
appeals are not trained in all policies. We are discussing a proposal to prevent appeals for complex objects (entities) for
reviews done by Market FTEs.
Risk and Response
There are two risk teams and six escalation teams within Risk and Response. The three key ones for Misinformation
enforcement are CO-PREsc, Early Response Escalations, and Regulation Escalations (the teams that enforce on organic
content). These three teams are responsible for enforcement as escalated by internal staff, governments and NGOs, M-
Team, and the Media. They enforce on every surface and product within the Facebook ecosystem, with the exception
of WhatsApp. These teams are responsible for all Implementation Standards, including the 60+ escalations-only
policies and MisInformation policies. Beyond enforcement, these teams are lead crisis managers (e.g. Capitol Riots). In
addition to staffing all L2+ L3 IPOCs, senior members of these teams serve as IPOC Crew Leads, responsible for IPOC
effectiveness and communications. As a result, these teams have very little bandwidth for additional support.
These teams have global presence, which facilitates 24/7 coverage. That said, they are relatively small teams (5-15 per
region per team) with a dynamic workflow, meant to pivot into and out of crisis, and only support English content.
Response teams work in Centra instead of SRT, use Cases as their case management tool (as opposed to tasks), and
have access to most tooling available (including BAT, MMS, CET, BH, and XCheck).
Escalation teams are organized by escalated content source, i.e. government/NGO escalations, media, Oops, or book of
business partner. The teams are not trained in B2V tiers 3 and 4, as these will be automated only. In addition, they will
enforce on COVID-topic Top 100 FB and IG pages, groups, IG profiles, and comments flagged by First Responders until
this flow is passed off to Civic Incubator. We do not offer appeals for decisions made by PREsc.
First Responders are a contractor team under PREsc. They will be filtering through some Top 100 content and entities
to be escalated to PREsc or Civic Incubator.
Outside of enforcement, the Community Risk Assessment team is responsible for the Dynamic Risk Assessment (DRA)
shared weekly, proactive risk investigations (PRIs), and the weekly incident review.
Health Misinformation Enforcement Summary
Workforce Ops POC Employee Type Policies Review Type Languages Job Types Scale
1 PDO @Fiona Yee Outsourcing B2V Labeling Many Content High
@Reshama Enforcement,
2 CO Ring Fenced Deshmukh Outsourcing M&H, WDH, RFH Measurement 19 Content High
M&H, WDH, RFH,
3 Markets - General @Orla Power FTE DVDE, B2V 1/2, CH Enforcement ~25 Content, Entities Medium
B2V (Inform
4 HERO @Dylan FTE, treatments only), Enforcement, Inform ~25 Posts Medium
Ackerman Contractor M&H, RFH, WDH Treatments
COIL (owned by M&H, WDH, RFH,
5
Civic Incubator) @John Shea FTE DVDE, B2V 1/2, CH Enforcement English Groups Medium
M&H, WDH, RFH,
6 Civic Incubator @Tori Manlove FTE DVDE, B2V 1/2, CH Enforcement English Content, Entities Medium
@Caroline M&H, WDH, RFH,
7 PREsc Nichols FTE DVDE, B2V 1/2, CH Enforcement English Content, Entities Low
M&H, WDH, RFH,
8 Early Response @Zach Gerasin FTE DVDE, B2V 1/2, CH Enforcement English Content, Entities Low
@Caroline M&H, WDH, RFH, Enforcement,
9 Fi t R d C t t E li h C t t E titi L
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 17 of 38
@Ca o e & , , , o ce e t,
9 First Responders Nichols Contractor DVDE, B2V 1/2, CH Labeling English Content, Entities Low
Policies Glossary
1. M&H: Misinformation and Harm
2. WDH: Widely-Debunked Hoaxes
3. RFH: Repeatedly Fact-Checked Hoaxes
4. CH: Coordinating Harm
5. DVDE: Dedicated Vaccine Discouraging Entities
6. B2V: Barriers to Vaccination
7. VH: Vaccine Hesitancy
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 18 of 38
Vaccine Hesitancy Comment Demotion
Credits
● Author List: @Joo Ho Yeo, @Nick Gibian, @Hendrick Townley, @Amit Bahl, @Matt Gilles
● Thanks:
Executive Summary
● What's your goal?
○ Drastically reduce user exposure to vaccine hesitancy (VH) in comments
● What is the product change?
○ Utilize the existing v1 VH classifier (English) to demote comments on ranked comments, meaning that they
are filtered from ‘most relevant’ but are still visible in other tabs (ex ‘most recent’)
● What are the benefits of this launch?
○ VPVs on Vaccine post English comments vh p80: -10.6±2.1%
■ Projected launch impact: -934.8K±194.4K vpvs
■ Authoritative vh p80 comment vpvs: -26.7 (±4.1)%
□ Projected launch impact: -402.4K±71.3K
○ CEP on Vaccine post English comments vh p80: —11.1 (±1.8)%
■ Authoritative vh p80 comments CEP: -26.1±3.0%
○ Decrease in other engagement of VH comments including create, likes, reports, replies
■ Scuba grouped by VH
● What are the costs of this launch?
○ No significant cost is observed.
● Risks of this launch
○ Not all comments are actually vaccine hesitancy, but we’d aligned with Health Policy on this risk in the COVID
Lockdown Decisions meeting 2 weeks ago — https://docs.google.com/presentation/d/1Qo35TGq75yf70-
VkOAY61g0offjYaOB2o2dF6SUry44/edit#slide=id.gca2fb195a7_11_0
● How could this be made more aggressive?
○ Use lower thresholds for interventions
● How could this be made more conservative?
○ Use higher Thresholds for interventions
Background
Experiment Launch Post
Comments are a major surface relevant to our B2V efforts. We estimate that the prevalence of VH comments in
Authoritative Health Pages is 25.3% and for other pages 19.42%. Now that the v1 Vaccine Hesitancy classifier has
been cleared for this usecase, reducing the visibility of these comments represents another significant opportunity for
us to remove barriers to vaccination that users on the platform may potentially encounter.
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 19 of 38
We do not expect user controls to resolve this issue, although teams have recently shipped tools to give people the
ability to choose who can
comment. https://docs.google.com/presentation/d/1xIn5T1pg8kCy9JEeX_Ehevh4tndhQYMiwL1zsuzwIl4/edit#slide=id
.gbafc05fce7_10_6
This is a Break The Glass lever that we’ll replace with higher quality detection comes online. For now, we do not have
other tools for remediating the high prevalence of vaccine hesitancy in Health comments
● More context from COVID Lockdown Decisions, where this was
approved https://docs.google.com/presentation/d/1Qo35TGq75yf70-
VkOAY61g0offjYaOB2o2dF6SUry44/edit#slide=id.gca2fb195a7_11_0
Classifier
We utilized a text-only version of the VH classifier that Amit Bahl developed to score English-language comments on
vaccine posts. We then performed a hand-labeling exercise to evaluate the model output.
Use of classifier approved by pxfn (L1076303PRV) and bwc.
Threshold Selection
VPV-weighted precision and recall on thresholds (weighted resevoir sampling) and label based on the latest policy
approved VH labeling guidelines.
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 20 of 38
Notebook: https://www.internalfb.com/intern/anp/view/?id=495202
Post: https://fb.workplace.com/notes/3942483092467702
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 21 of 38
Classifier-based prevalence
● Of the non-null results, 168.775 K comments are under vaccine posts, which is 0.499% (33.625 M are not):
https://fburl.com/scuba/ranked_comment_actions/ezd40b5u
● Since the vaccine hesitancy classifier only covers english comments size greater than 5, comments with a Vaccine
hesitancy score is 48.355K. Of those 2.235 K are eligible for demotion:
https://fburl.com/scuba/ranked_comment_actions/p2fcyml5
Among english vaccine post comments the classifier-based prevalence (with the p58 threshold 0.75):
● 4.3% of comment VPVs
● 4.3% of comment creates
● 6.4% of comment likes
(When adjusted for precision and recall, the prevalence is estimated to be 20~30% vpv)
Source: https://fburl.com/scuba/ranked_comment_actions/tlkb18sm
VH Comment Examples
A B C
1
vaccine_hesit
ancy_score comment_id comment_text
2 0.87189 261957062286503 So what are you spraying over north edmonton over residential homes, poison
3
Only if you want to travel.. won't be forced...but can't go anywhere unless you have it. \n\nSo yes it
0.8623 193117605957898 will be forced
4
0.9141 10158579572293271 Better headline: "Vaccine thought to be 98% effective turns out to be 99.992% effective."
5
Exclusive: Former Pfizer VP to AFLDS: 'Entirely possible this will be used for massive-scale
0.8663 281743050286949 depopulation'
6
I've written to him and others. Either they dont read , dont research or just want to push the killer
0.95312 1731887923657815 vaccines
7
@[100000552011150:2048:Kim Chrest] there’s a 99.2% that you won’t. That is far above the
0.85873 10159016877751830 95% effective rate that we were told in the beginning.
8
I’m in a group whose families have had the “Jab”.\nDoesn’t matter which you have, all are causing
0.85002 10158210334681728 terrible side effects and many dying.\n
9
The vaccine is not fda approved but rather approved for emergency use only. Legally employers
0.85447 304527971035699 and others can not make it mandatory.
10
In other words, the Namibia human rights advocate, is calling for suspension of the rights of health
0.94851 4498348683527934 workers and pushing for forced vaccinations.
11 0.85625 293217805580344 didn't work for the boarder worker....had both vaccines and still got covid again.....
12
@[100002882938982:2048:Eifz O'Hare] how many have died from covid? How many have died
0.87042 10158393963727183 from vaccine?
13
@[796927924:2048:Dave Harvey] A year ago we didn't know how successful any anti-COVID
0.96451 10159572429229015 vaccine, let alone mRNA vaccines, would be in the field.
14
Not really joking... Day b4 yesterday my uncle died few days after vaccination in Washington due
0.89849 1200292507059482 to clotting .. aged 71 .. Diagnosed COVID19
15
Vaccines r not suitable for evey one many of them r having side effects also after getting
0.91939 2943603365923180 vaccinated ppl r getting corona positive
16 0.86973 10159665959084604 @[579026291:2048:Harry Fogarty] feel free to have it my as well, might help you ..
17
@[100000411263327:2048:Heather Keedy Bateman] \nToo bad they aren’t reporting all the
0.86931 10159080434066026 deaths and serious adverse effects to the public!
18
@[100000814050919:2048:Lisa Sanders] 71 out of 1.4 million fully vaccinated people in Missourri
0.87968 10159566195034228 isnt too bad in my opinion. .000005%
19
Leave the elderly alone & the rest of us-we don't want your poison.You are completely ignoring the
0.95139 10158211115291728 deaths & severe reactions caused by this crap
20 0.93852 757768611577136 Vaccine kill him from the very moment he got the shot in March he became ill
It was a daft question Annette! All old people who got vax WILL DIE so if they died within 6 weeks..
21
0.88215 183299193612702 would vax be blamed?
Experiment
QE: https://www.internalfb.com/intern/qe2/cref_v5_universe/vh_v1_en_demotion_v2/setup/config
QE is set up with a control group and the following test groups. Demotion is done to read time score at level -1:
● demote comments with v1 vaccine hesitancy classifier score of 0.75 (p58) or above with demotion strength of
0.01
● demote comments with v1 vaccine hesitancy classifier score of 0.75 (p58) or above with demotion strength of
0.001
● demote comments with v1 vaccine hesitancy classifier score of 0.8 (p68) or above with demotion strength of 0.01
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 22 of 38
● demote comments with v1 vaccine hesitancy classifier score of 0.8 (p68) or above with demotion strength of
0.001
Ranking Changes
https://www.internalfb.com/intern/configerator/edit/?
path=comment_ranking%2Fcomment_ranking_configs%2Fvh_v1_en_demotion_p58_001.cconf
demote_vh_en =>
{
"signals": {
"vh_score": 871
},
"signal_defaults": {
"vh_score": 0
},
"phase": 1,
"signal_blender": "if(gte($vh_score, 0.75), 0.001, 1)",
"signal_rules": []
}
experiment_read_time_score =>
{
"signal_blender": "mul($read_time_score, $demote_vh_en)",
"phase": -1,
"signals": [],
"signal_rules": [
"read_time_score",
"demote_vh_en"
],
"signal_defaults": {
"read_time_score": 1,
"demote_vh_en": 1
}
}
Demotion Example
https://www.facebook.com/CDC/photos/a.184668026025/10159076965856026
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 23 of 38
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 24 of 38
Prod
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 25 of 38
Test
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 26 of 38
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 27 of 38
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 28 of 38
Results
Analyzing the p58 and demotion strength 0.01 (though all results are similar)
Deltoid
Vaccine Heistancy Prevalence Metrics
https://fburl.com/deltoid3/754nhd0z
● CEP on Vaccine post English comments vh p80: —11.1 (±1.8)%
○ Authoritative vh p80 comments CEP: -26.1±3.0%
○ Non-authoritative vh p80 comments CEP:-9.9±2.3%
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 29 of 38
● VPVs on Vaccine post English comments vh p80: -10.6±2.1%
○ Projected launch impact:-934.8K±194.4K vpvs
○ Authoritative vh p80 comment vpvs: -26.7 (±4.1)%
■ Projected launch impact: -402.4K±71.3K
○ Non-authoritative vh p80 comment vpvs: -9.0±2.7%
■ Projected launch impact: -526.5K±163.4K
Other Signals:
● No detectable difference in misinfo frx:
○ https://fburl.com/daiquery/a1yg0xhx
● No detectable difference in high or low quality comment VPVs:
○ https://fburl.com/scuba/ranked_comment_actions/itgnv6zs,
○ https://fburl.com/scuba/ranked_comment_actions/r5z2koh3
● No detectable difference in FRX overall of any type:
○ https://fburl.com/deltoid3/1h64b6oi
Overall Engagement
https://fburl.com/deltoid3/iitnq125
Grouped by Reply
https://fburl.com/deltoid3/o4hnqgsd
Grouped by Reply time series
https://fburl.com/deltoid3/h9snr3uy
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 30 of 38
Grouped by High.Low Relevance
https://fburl.com/deltoid3/xxi2mu5c
Grouped by Is bullying
https://fburl.com/deltoid3/jlyfs4c5
Grouped by is hate speech
https://fburl.com/deltoid3/vaa6rzzf
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 31 of 38
Scuba grouped by VH
https://fburl.com/scuba/ranked_comment_actions/5zbwxfo9
● -75.6% create
● -42.5% like
● -34.2% report
● -32.6% vpv
● -88.6% replies
Next Steps
● Team holdout
● Live videos? Other surfaces?
Follow Up Question Answers:
1. What is the percentage of vaccine
a. Of the non-null results, 168.775 K comments are under vaccine posts, which is 0.499% (33.625 M are not):
https://fburl.com/scuba/ranked_comment_actions/ezd40b5u
i. This aligns with the vaccine post vpvs / all post vpvs which is ~0.5%
1. https://fburl.com/daiquery/grmcvdqx
b. Since the vaccine hesitancy classifier only covers english comments size greater than 5, comments with a
Vaccine hesitancy score is 48.355K. Of those 2.235 K are eligible for demotion:
https://fburl.com/scuba/ranked_comment_actions/p2fcyml5
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 32 of 38
i. So the final eligible comments for demotion are 0.00661% of ranked comments
c. Since the number of eligible comments for demotion are relatively small, it is likely that the like regression is
noise
2. Change in “likes“
a. For the vaccine hesitant comments we are demoting, we are reducing -2.64K likes (-42.5%), which would be
176K likes since the test size is 1.5%
i. https://fburl.com/scuba/ranked_comment_actions/oldlnwjv
b. Grouped by is_repy, time series:
i. https://fburl.com/deltoid3/xturut3g
c. Grouped by survey_high, survey_low
i. https://fburl.com/deltoid3/3a2ijqyw
* https://fb.workplace.com/groups/health.integrity/permalink/875731499946842
**https://fb.workplace.com/groups/health.integrity/permalink/505046790348650
***https://fb.workplace.com/groups/health.integrity/permalink/505046790348650
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 33 of 38
EXHIBIT 3
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 34 of 38
From: Fauci, Anthony (NIH/ NIAIO) [E)
Sent: Fri, 28 Feb 2020 00:4 7:19 +0000
To : Mar k Zuckerberg
Subject: RE:
Mark:
Thanks for the note . If we start in April ( ~6-7 weeks from now ) with a phase 1
trial of 45 subjects, it will take another 3-4 months to determ ine safety and some
immunogenicity . The next step is phase 2 for efficacy . We may need help with
resources for the phase 2 tria l if we do not get our requested budget
supplement. I believe that we will be OK. If thi s goes off track, I will contact
you. Many thanks for t he offer . Much app reciated .
Best regard s,
Tony
Anthony S. Fauci , MD
Director
National Institute of Allergy and Infectious Diseases
Build ing 31, Room 7A-03
31 Center Drive, MSC 2520
National Institutes of Hea lth
Bethesda , MD 20892-2520
Phone : (b)(6)
FAX : (301 496-4409
E-mail : (b)(6)
The information in this e-mail and any of its attachments is confidential and may contain sensitive
information . It should not be used by anyone who is not the original intended recipient . If you
have rece ived this e-mail in error please inform the sender and delete it from your mailbox or any
other storage devices . The National Institute of Allergy and Infectious Diseases (NIAID) shall not
accept liability for any statements made that are the sender 's own and not expressly made on
behalf of the NIAID by one of its representatives .
From: Mar k Zuckerberg Cb)(6)
Sent : Thur sday, Febru ary 27, 2020 7: 16 PM
To: Fauci, Anth ony (NIH/ NIAID) [E]_______
------~= _.
(b)(6)>
Subject :
Tony :
I was glad to hear your statement that the covid -19 vaccine w ill be ready for human trials in six weeks.
Are there any resources o ur found ation can help provide to pot ent ially acceler ate t his or at least make
sure it stays on track ?
Mark
NIH-001245
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 35 of 38
From: Fauci, Anthony (NIH/NIAIO) [E)
Sent: Tue, 17 Mar 2020 00:23:16 +0000
To : Billet, Courtney (NIH/NIAID) [E]
Cc: Folkers, Greg (NIH/NIAID) [E];Conrad, Patricia (NIH/NIAID) [E];Stover, Kathy
(NIH/NIAID) [E];Routh, Jennifer (NIH/NIAID) [E]
Subject: RE:offer from Mark Zuckerberg
I will write to or call Mark and tell him that I am interested in doing this. I will then tell him
that you will get for him the name of the USG point of contact. I agree it shou ld be Bill Hall
who could then turf to the White House Com ms if he wishes
From: Billet, Courtney (NIH/NIAID) [E] (bH >
Sent: M onday, March 16, 2020 6:53 PM
To: Fauci, Anthony (NIH/NIAID) [E] -----~~ (b)(6)>
Cc: Folkers, Greg (NIH/NIAID) [El (bH ; Conrad, Patricia (NIH/NIAID) [El
(b)(6); Stover, Kathy (NIH/NIAID) [E) (bH >; Routh, Jennifer
"'.'"
( N
- 1-H/- N
:--
-IA l':""):--:
- D [':""
El:-===::::::...-____;-= (b')(=
"'"" >
Subject: ASF: offer from Mark Zuckerberg
Per email below, Mark Zuckerberg has extended a few offers to do videos with you that we would be
happy to seek clearance on for you to do, if you are amenable. These would have the weight and impact
of television - really, more so. Please advise if you want to do and we will seek clearance with VP office
and work with Patty to sort out the logistics.
But an even bigger deal is his offer (b)(4)
- The sooner we get that offer up the food-chain the better. I gave Bill Hall a heads-up about this
opportunity and he is standing by to discuss this with HHS and WH comms, but I didn't want him to do
anything without you being aware of the offer. Is it OK if I hand this aspect off to Bill to determine who
the best point of contact would be so the Administration can take advantage of this offer, soonest?
Do you plan to call MZ? His cell number is in his message below.
From: Mark Zuckerberg (b)(6)
Sent: Sunday, March 15, 2020 12:18 PM
------
To: Fauci, Anthony (NIH/NIAID) [E]
Subject: Thanks and ideas -------- ..-.-,= (b)(6J>
Tony:
I wanted to send a note of thanks for your leadership and everything you're doing to make our country's
response to this outbreak as effect ive as possible. I also wanted to share a few ideas of ways we could
help you get your message out, but I understan d you 're incredibly busy, so don't feel a need to reply
unless these seem interest ing.
This isn't public yet, but we 're building a Coronavirus Information Hub that we're going to put at the top
of Facebook for everyone (200+ million Americans, 2.5 billion peop le worldwide) with two goals: (1)
NIH-000468
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 36 of 38
make sure people can get authoritative information from reliable sources and (2) encourage people to
practice social distance and give people ideas for doing this using internet tools. This will be live within
the next 48 hours.
As a central part of this hub, I think it would be useful to include a video from you because people trust
and want to hear from experts rather than just a bunch of agencies and political leaders. This could be
done in a number of formats if you're open to it. Probably best would be recording a Q&A where you
answer people's top questions , but we'd be open to other fo rmats too.
I'm also doing a series of livest reamed Q&As with health experts to try to use my large following on the
platform {100 million followers) to get authoritative information out as well. I'd love to have you do one
of these Q&As. This could be the video we put in the Coronavirus Hub or it could be a different thing
that we distribute separately, but I think it could be effective as well.
Again, I know you're incredibly busy, so don't feel t he need to respond if this doesn't seem helpful. If it 's
easy to talk live, give me a call anytime on my mobile phone: (b) (6) .
Thanks again for everything you're doing .
Mark
NIH-000469
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 37 of 38
From: Fauci, Anthony (NIH/N IAID) [E)
Sent : Tue, 17 Mar 2020 00:22:45 +0000
To: Mark Zuckerberg
Cc: Conrad, Patricia (NIH/NIAID) [E);Billet, Courtney (NIH/ NIAID) [E];Barasch,
Kimberly (NIH/NIAID) [CJ
Subject: RE:Thanksand ideas
Mark:
Thank you for your kind note. I tried to cal l you, but got voice mai l. FYI, my cell phone
number is (b)(6) Your idea and proposal sound te rr ific. I would be happy to do a
video for your hub. We need to reach as many people as possible and convince them to take
mitigation strateg ies seriously or th ings will get much , much worse. Also, your id ea about (b)(4 )
is vey exciting. I am copying my Special Assist ant, Patty Conrad. Her office numbe r is (b)(6)
----- Cb)( • Please have your people contac t her to arrange for the video. I am also copy in g the
Director of my Communications and Governmen t Relations gro up . She can put your people in
contact with the best person who cou ld be the US Government poin t of con tact for (b)(4).
Best regards,
Tony
From: Mar k Zuckerberg (b)(6)>
Sent : Sunday, Marc h 15, 2020 12:18 PM
To: Fauci, Anthony {NIH/NIAID) [E] ------~~ (b)(6)>
Subject: Thanks and ideas
--------
Tony :
I wanted to send a note of thanks for your leadership and everything you 're doing to make our country's
response to this outbreak as effective as possible. I also wanted to share a few ideas of ways we could
help you get your message out, but I understand you're incredibly busy, so don't feel a need to reply
unless these seem interesting .
This isn't public yet, but we're building a Coronavirus Information Hub that we're going to put at the top
of Facebook for everyone (200+ million Americans, 2.5 billion people worldwide ) with two goals: (1)
make sure people can get author itative information from reliable sources and {2) encourage people to
practice social distance and give people ideas for doing this using internet tools. This will be live wit hin
t he next 48 hours.
As a centra l part of this hub, I think it would be useful to include a video from you because people trust
and want to hear from experts rather than just a bunch of agencies and politi cal leaders. This could be
done in a number of fo rmats if you're open to it . Probably best would be recording a Q&A where you
answer people's top questions, but we'd be open to other fo rmats too.
I'm also doing a series of livest reamed Q&As with health experts to try to use my large following on th e
platform (100 million followers) to get authoritative information out as well. I'd love to have you do one
NIH-000470
Case 3:20-cv-05787-SI Document 103-1 Filed 06/07/21 Page 38 of 38
of these Q&As. This could be the video we put in the Coronavirus Hub or it could be a different thing
that we distribute separately, but I think it could be effective as well.
Again, I know you're incredibly busy, so don't feel the need to respond if this doesn't seem helpful. If it 's
easy to talk live, give me a call anytime on my mobile phone: (b)( 6)
Thanks again for everything you're doing.
Mark
NIH-00047 1
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