Randall and her Chief of Staff, Jeanine Arnett, share administrative control over the Chair’s Facebook Page, although Randall almost exclusively controls the page’s content. On her campaign page, Randall characterized the Chair’s Facebook Page as her “county Facebook page” stating: I really want to hear from ANY Loudoun citizen on ANY issues, request, criticism, complement or just your thoughts. However, I really try to keep back and forth conversations (as opposed to one time information items such as road closures) on my county Facebook page (Chair Phyllis J. Randall) or County email (Phyllis.randall@loudoun.gov). Having back and forth constituent conversations are Foiable ([Freedom of Information Act]) so if you could reach out to me on these mediums that would be appreciated. J.A. 455 (emphasis added). The Chair’s Facebook Page includes three columns. The left column, which is topped by a picture of Randall, includes several links to allow visitors to quickly navigate the contents of the Chair’s Facebook Page. The middle column, which is organized in reverse chronological order similar to a personal profile’s News Feed, is composed of posts by Randall and comments by Facebook users on those posts. Randall’s posts are almost always directed to “Loudoun,” see, e.g., J.A. 408–10, and deal with numerous aspects of Randall’s official responsibilities. For example, Randall used the Chair’s Facebook Page to notify the public about upcoming Loudoun Board meetings, and the subjects to be discussed during those meetings. Randall also used the page to inform Loudoun County residents about significant public safety issues. See, e.g., J.A. 412 (stating that Loudoun Board had “been informed by the Sheriff’s Office about the non-legitimate threat made on social 5

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