Plaintiff Tamara Fields (“Plaintiff”), by and through her attorneys, allege the following against Defendant Twitter, Inc. (“Twitter” or “Defendant”):...For years, Twitter has knowingly permitted the terrorist group ISIS to use its social network as a tool for spreading extremist propaganda, raising funds and attracting new recruits.  This material support has been instrumental to the rise of ISIS and has enabled it to carry out numerous terrorist attacks, including the November 9, 2015 shooting attack in Amman, Jordan in which Lloyd “Carl” Fields, Jr. was killed…ISIS “has exploited social media, most notoriously Twitter, to send its propaganda and messaging out to the world and to draw in people vulnerable to radicalization.”…The services and support that Defendant purposefully, knowingly or with willful blindness provided to ISIS constitute material support to the preparation and carrying out of acts of international terrorism, including the attack in which Lloyd Fields, Jr. was killed… Defendant’s provision of material support to ISIS was a proximate cause of the injury inflicted on Plaintiff...The services and support that Defendant purposefully, knowingly or with willful blindness provided to ISIS constitute material support to a Foreign Terrorist Organization…