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Daphne Keller & Paddy Leerssen

complaint form was less visible on their website compared to YouTube or
Twitter. Yet Facebook’s Community Guideline removals in the same period
numbered in the millions and were not included in the NetzDG report. On July
2, 2019, Germany’s Federal Ofﬁce of Justice ﬁned Facebook €2 million for
incomplete reporting, claiming that, because it was unclear which complaints
based on Community Guidelines had in fact identiﬁed unlawful material, “the
number of received complaints about unlawful content is incomplete,” and the
reports therefore created a “distorted picture” (Bundesamt für Justiz 2019).
This raises the question whether NetzDG also requires platforms to assess and
report on the lawfulness of content decisions that are not referred to them under
the NetzDG framework.
Social_Media_and_Democracy