Facebook Page principally addressed her official responsibilities, a few posts addressed topics less closely related to her official activities such as her affection for the German language or pride in becoming an organ donor. Members of the public, including Davison, “liked” 1 or commented on several of Randall’s posts on the Chair’s Facebook Page. Each “like” or comment identified the name of the personal profile or Page of the authoring party. Many of the comments thanked Randall and the Loudoun Board for representing the public’s interests. Other posts by members of the public offered feedback on various issues faced by Randall and the Loudoun Board. E.g., J.A. 427 (stating that “[p]utting recreation in a flood plain is not a good idea”); J.A. 448 (stating that “more needs to be done with the explosion of Lyme disease in Loudoun”). And other comments dealt with constituent-specific issues. E.g., J.A. 415 (constituent stating, in response to post by Randall regarding visit to Loudoun County’s “Sister City” in Germany, that constituent’s “daughter is interested in exchange programs”); J.A. 454 (stating that “there [we]re no [snow] plows to be seen” in a particular neighborhood). Finally, several comments, including a number authored by Davison, criticized the Loudoun Board, generally, and Randall, in particular, for actions taken in their official capacities. E.g., J.A. 429–30 (Davison criticizing public school system budget and expenditures); J.A. 438–39 (member of public criticizing governmental entity’s inspection of farm, claiming it failed to uncover animal abuse); 1 “‘Liking’ on Facebook is a way for Facebook users to share information with each other.” Bland v. Roberts, 730 F.3d 368, 385 (4th Cir. 2013). 7

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