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conducted by NIMH scientist Elisabeth Murray. As part of this campaign, PETA employees and members have sought to advocate for the end of primate testing on the NIH's social media pages. 2. Plaintiff [J who resides in Oakland, Califomia, is a former animal research technician tuned animal rights advocate. [J operates an Instagram account under the handle GME. 20d I maintains a Facebook profile under the name J HE BR 22 long advocated for the end of animal testing in laboratories. As a student at the University of Wisconsin, [BB studied zoology and worked as a student primate caretaker at the Harlow Center for Biological Psychology. [ij firsthand experience with primate testing led[fffJ to conclude that animal testing is immoral and compelled[ffMJ to publicly share the details of her experiences. EE secks to contribute to the public discourse on animal testing in part by drawing attention to the NIH's funding of National Primate Research Centers. One way HE <<< to bring attention to the NIH's involvement in animal testing is by commenting on the NIH's social media posts. 3. Plaintiff [BM . who resides in Madison, Wisconsin, is an engineer in the digital health field. [JJ operates an Instagram account under the handle GE. 204 [lj maintains a Facebook profile under the name I [EEE opposition to animal testing stems from 2018. That year, [JJ moved to Madison and started passing the Wisconsin National Primate Research Center ("WNPRC") on[fffJ way to work. (IY began to leam more about the WNPRC through videos on Facebook and PETA campaigns. At one point. J saw a video EE posted describing her past work at the Harlow Center and JJ goal of shutting down the lab. [EEE reached out tof to connect and offer his assistance. 4. Defendant Francis S. Collins is the Director of the National Institutes of Health (NIM), The NIH is a medical research center and is one of the eight health agencies of the Public