Attachment

"PETA" is no longer an NIH Facebook keyword filter as of December 3, 2021. A copy of [i HE <ounmeents is attached hereto as Exhibit [X]. 62. PETA employees have occasionally advocated for animal rights in comments posted to the NIH Facebook page by modifying the spelling of certain words or by replacing filtered words with words conveying similar meanings. For example, on October 16, 2020. HE 0% comments on an NIH Facebook Live video about COVID-19 treatment, including: "Francis Collins, thank you for your hard work finding a vaccine for COVID-19. In light of the urgency of devoting resources to find a vaccine and the ineffectiveness of experiments on anlmals, will you please end the fright xpts on macaques of Elisabeth Murray?" and "Francis Collins, please end Elisabeth Murray's fright expts on macaques. People with mental health disorders deserve better, actually effective research." These comments were not hidden or filtered, and were viewable by the public. A copy of JENN) comments is attached hereto as Exhibit [X]. 63. I PETA employees wish to continue posting comments about animal testing on the NIH's Facebook page that may contain terms subject to NIH's current Facebook keyword filters. 64. Plaintiff PETA also wishes to engage with and read the comments of other animal rights advocates on the NIH Facebook page. PETA, by and through several of its employees, follows the NIH Facebook page. I 65. On April 29, 2021. IY commented on an NIH Instagram post about a study on Alzheimer's disease treatment that was conducted on mice. EEE wrote. "It's pretty messed up that you block conversation about animal testing." This comment contains NIH 'Commented [A3]: Note that "experiments" is not a filtered keyword. Author