AO 91 (Rev.

11/11) Criminal Complaint
AUSA William E. Ridgway (312) 469-6233
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

UNITED STATES OF AMERICA

v.

TIMOTHY JUSTIN FRENCH,
also known as “Orbit,” “@Orbit_g1rl,”
“crysis,” “rootcrysis,” and “c0rps3”

CASE NUMBER:
Hon. Daniel G. Martin



UNDER SEAL

CRIMINAL COMPLAINT

I, the complainant in this case, state that the following is true to the best of my knowledge
and belief.
Beginning no later than in or around July 2013, and continuing until at least in or about
May 2014, in the Northern District of Illinois, Eastern Division, and elsewhere, the defendant,
TIMOTHY JUSTIN FRENCH, also known as “Orbit,” “@Orbit_g1rl,” “crysis,” “rootcrysis,” and
“c0rps3,” violated:
Code Section Offense Description
Title 18, United States Code, Sections
1030(a)(5)(A), 1030(b), and
1030(c)(4)(B)(i)
Conspiring to knowingly cause the transmission of a
program, information, code, or command, and as a
result of such conduct, intentionally causing damage
without authorization to a protected computer, which
offense caused a loss aggregating at least $5,000 in
value to one or more persons during a one-year period

This criminal complaint is based upon these facts:
X Continued on the attached sheet.

Patrick M. Geahan
Special Agent, Federal Bureau of Investigation

Sworn to before me and signed in my presence.

Date: June 3, 2014



Judge’s signature

City and state: Chicago, Illinois Daniel G. Martin, U.S. Magistrate Judge
Printed name and Title
1


UNITED STATES DISTRICT COURT )
)
NORTHERN DISTRICT OF ILLINOIS )

AFFIDAVIT

Introduction and Agent Background
I, Patrick M. Geahan, being duly sworn, state as follows:

1. I am a Special Agent of the Federal Bureau of Investigation and
am assigned to the Chicago Field Office. I have been employed as a Special
Agent with the FBI since 2004. As a Special Agent, I am charged with
investigating possible violations of federal criminal law, including computer
crimes, in violation of 18 U.S.C. § 1030 (the Computer Fraud and Abuse Act).
I have received specialized training in those areas. In particular, I hold a
Bachelor of Science degree in Computer Science from Michigan Technological
University, as well as a Certified Information Systems Security Professional
certification from the International Information Systems Security
Certification Consortium. I have attended multiple FBI and private sector
training sessions and conferences on computer intrusion, network analysis,
and electronic evidence recovery.
2. This affidavit is submitted in support of a criminal complaint
alleging that Timothy Justin French, also known as “Orbit,” “@Orbit_g1rl,”
“crysis,” “rootcrysis,” and “c0rps3,” and others have conspired to knowingly
2

cause the transmission of a program, information, code, or command, and as
a result of such conduct, intentionally causing damage without authorization,
to a protected computer, which offense caused a loss aggregating at least
$5,000 in value to one or more persons during a one-year period, in violation
of Title 18, United States Code, Sections 1030(a)(5)(A), 1030(b), and
1030(c)(4)(B)(i). Because this affidavit is being submitted for the limited
purpose of establishing probable cause in support of a criminal complaint, I
have not included each and every fact known to me concerning this
investigation. I have set forth only the facts that I believe are necessary to
establish probable cause to believe that the defendant committed the offense
alleged in the complaint.
3. This affidavit is based on my personal knowledge, information
provided to me by other law enforcement agents and from other persons with
knowledge regarding relevant facts. Moreover, throughout this affidavit in
footnotes and in brackets I provide definitions and explanations for certain
terms and phrases. Those definitions are based on my training and
experience in the area of computers and my experience investigating the
unauthorized access of computer systems, also known as computer hacking.
Definitions
4. I know from my training and experience that the following
definitions apply to the activity discussed in this affidavit:
3

a. IP Address: The Internet Protocol address (or simply “IP”
address) is a unique numeric address used by computers on the Internet. An
IP address looks like a series of four numbers, each in the range 0-255,
separated by periods (e.g., 121.56.97.178). Every computer attached to the
Internet must be assigned an IP address so that Internet traffic to and from
that computer may be properly directed from its source to its destination.
b. Server: A server is a computer that provides services to
other computers. Examples include web servers which provide content to web
browsers and e-mail servers which act as a post office to send and receive e-
mail messages.
c. VPN: A Virtual Private Network (“VPN”) is an encrypted
connection between two or more computer resources over a public computer
network, such as the Internet, which enables access to a shared network
between those resources. A common example is an individual who purchases
access to a VPN service from a VPN service provider. A VPN service provider
may also be a server hosting provider or may be a customer of a server
hosting provider that is using servers hosted by the server hosting provider
for the VPN service. The individual would connect from the individual’s
computer to the VPN service at the VPN service provider over the Internet.
Once connected to the VPN, the individual’s subsequent computer network
communications, including access to websites, would be routed through the
4

VPN connection from the individual’s computer to the VPN service at the
VPN service provider, and then from the VPN service provider on to the
destination website. The response from the destination website is sent back
to the VPN service at the VPN service provider and then finally routed via
the VPN connection to the individual’s computer. In this scenario, the IP
address which accesses the third party website is actually associated with the
VPN service and is not the actual IP address of the individual’s computer.
Overview
5. The FBI has been investigating “NullCrew,” a collection of
individuals who have claimed responsibility for many high-profile computer
attacks against corporations, educational institutions, and government
agencies. Individuals associated with NullCrew include “Orbit,” whom the
FBI has identified as Timothy Justin French (who also uses the aliases
“@Orbit_g1rl,” “crysis,” “rootcrysis,” and “c0rps3”), and “Null,” whom the FBI
has identified as Individual A.
6. One of the ways that NullCrew publicizes its attacks is through
the online social networking and microblogging service Twitter, including via
the accounts @OfficialNull and @NullCrew_FTS. Since mid-2012, NullCrew
has announced dozens of attacks against various victims. For example:
a. On or about July 13, 2012, NullCrew, through the account
@OfficialNull, reported hacking websites of two organizations. That
6

c. On or about November 5, 2012, NullCrew, through the
account @OfficialNull, announced an attack on a foreign government’s
ministry of defense, releasing over 3,000 usernames, email addresses, and
passwords purportedly belonging to members of the ministry of defense.
7. As part of the investigation, the FBI has been working with a
confidential witness (“CW”),
3
who was invited to join online chats with
members of NullCrew. During those chats, NullCrew members discussed
past, present, and future computer hacks; shared current computer
vulnerabilities and planned targets; and discussed releases of their victim’s
information. These chats occurred through Skype, Twitter, and CryptoCat.
4

8. On many occasions during these chats, NullCrew members
discussed tactics for avoiding law enforcement. One of those tactics was to
launch its computer attacks through an intermediary computer server, either
a VPN or a compromised server, i.e., a computer server to which an outsider
has obtained unauthorized access. As further described below, during part of
the investigation, members of NullCrew used a computer server in Chicago
from which to launch computer attacks (the “Chicago computer server”). As

3
This CW has experience in information security and has assisted with the
investigation primarily in an effort to help the FBI.
4
CryptoCat is communications software program that allows for real-time online
chat. CryptoCat advertises itself as encrypted and unreadable by third parties. A
user creates a new username each time the user logs into the program, which exists
only for the particular session.
7

further described below, the FBI has obtained records from the Chicago
computer server relating to NullCrew’s hacking activities.
9. For reasons discussed in ¶¶32-39, the investigation has identified
Timothy Justin French as “Orbit,” who also operates under the usernames
“@Orbit_g1rl,” “crysis,” “rootcrysis,” and “c0rps3.”
5

Summary of the Evidence
Cyber Attack Against University A
10. On or about July 19, 2013, “0rbit” chatted with the CW via Skype
about an attack on University A, a large public university. During that
conversation, 0rbit wrote: “Working on rooting
6
[University A].edu.” When
the CW offered assistance, 0rbit replied, “Yeah, I already got a shell
7
up; I’m
just rooting it” and sent the CW a link to a file called “gny.php” on a server at
ifa.[University A].edu.
11. On or about July 19, 2013, FBI communicated with a system
administrator from University A, who reported that one of its computer
servers had been compromised, meaning someone had gained unauthorized

5
As reflected in this affidavit, French sometimes spells the username name “Orbit”
with a “0,” i.e., “0rbit.”
6
“Rooting” describes an attack on a computer server that is intended to result in full
administrative, or “root” privileges. Such privileges allow the user to access all
commands and files.
7
A “shell” is command-line level access to a computer, meaning an individual is
given direct access to run commands on the system. When used as a verb in this
context, “to shell” means to get the computer to give you a shell through
unauthorized means.
8

access to the server. That system administrator further recovered the
“gny.php” file. The administrator reviewed the file, determined that it had
not been installed by University A, and advised that it was likely malicious
software, i.e., software that could be used to obtain unauthorized access to
University A’s computer systems. The FBI received log files
8
from University
A for the compromised computer server. An analysis of the log files showed
multiple connections to the program gny.php between June 18, 2013, to
June 21, 2013, consistent with the chat described above. During that time
period, the attacker appeared to view different directories (i.e., folders on the
server) and attempted to run commands on the local database.
Cyber Attack Against Company A
12. On or about January 28, 2014, the CW engaged in an online chat
with “crisis” via CryptoCat regarding Company A, a large Canadian
telecommunications company. During this chat, crysis wrote “We’ve also been
working on that [Company A] server again.. but, the problem is: If theres as
much data as Null says, in that server.. then, how I’ve been doing it manually
would take forever.” Later, crysis wrote, “I tried running [Company A

8
A log file (or simply log) for a computer server is a record of activity on that server,
such as requests from information, including the source IP address, date and time,
and information requested.
9

website] through SQLMap,
9
for quicker rates; it kept erroring me, we couldn’t
figure out why.. especially when I was using all flags correctly, with the right
parameters.”
13. On or about February 1, 2014, NullCrew, through the Twitter
account @NullCrew_FTS, announced a computer attack on Company A. In
particular, the message stated: “Whelp, let’s start things off properly -
nullcrew.org/[Company A].txt . . . hacked by #NullCrew.” On or about
February 2, 2014, the Twitter account provided a link to a post on
Cryptobin.
10
I have reviewed the documents that were linked in these
messages and they appear to be copies of database tables and credentials for
one of Company A’s computer servers. The materials on Cryptobin included a
section marked “tblCredentials,” containing a series of 12,000 username and
password pairs, which appeared to be a list of Company A customer
credentials.
14. On or about February 2, 2014, the CW chatted with “rootcrysis”
via CryptoCat. The CW praised rootcrysis about the Company A data breach,
to which rootcrysis replied “Yup LOL. Gained ALOTTTTTTT of attention.

9
“SQLMap” is a program used to probe SQL database servers for vulnerabilities.
“SQL,” which stands for “Structured Query Language,” refers to a special-purpose
programming language designed for managing data held in certain types of
databases.
10
“Cryptobin” is an Internet website that allows any party to upload text files for
others to view.
10

I’ve done like four interviews.” As rootcrysis continued, “I released it like two
days ago, it would’ve been released sooner if manual wasn’t a bitch and had
to wait for you and null to help me with the sqlmap response.” The CW
asked, “Why did we even target [Company A] to being with?” In response,
rootcrysis wrote, “Good question, Null just gave me the exploit since he lost
the data; told me to go to town, that it was for NC [NullCrew].”
15. On or about February 2, 2014, a blog that provides news online
about data breaches (databreaches.net) posted a story about the Company A
data breach. As part of that story, a purported NullCrew member was
interviewed and provided a screenshot of a chat that the purported member
had with a Company A employee. The screenshot showed a conversation in
which the employee of Company A was warned of an attack against the
company’s server. During the February 2, 2014 chat referenced above, the
CW inquired about this interview, asking if “Null” did “the screen shot.”
Rootcrysis responded, “Nah, I did rofl [rolling on the floor laughing]. I got on
chat after ripping [copying] data, told them [Company A], and screened [took
a screen shot of] their response.”
16. I have reviewed records from the Chicago computer server
referenced above. According to those records, on or about January 26, 2014, a
folder was created titled “protectionmanagement.[Company A].” This folder
contained a log file indicating that the program “SQLMap” was run against a
11

SQL installation on protectionmanagement.[Company A]. The log file
indicated that SQLMap located five separate SQL injection points.
11
These
records further indicate that multiple executions of the SQLMap program
were made against protectionmanagement.[Company A], beginning on or
about January 22, 2014. The Chicago computer server also contained a set of
data from a database that appears to be associated with Company A, which is
nearly identical to the usernames and passwords released on February 1,
2014.
Cyber Attack Against University B
17. On or about January 30, 2014, during an online chat with the CW
via CryptoCat, crysis discussed University B, a large public university, and
asked “have you taken a look at the system() backdoor
12
on [University B]?”
The CW asked crysis for further information; crysis provided the CW with a
link and instructions about how to access the vulnerability. As crysis
explained, “I’ve been looking around in it for a while, theres some interesting

11
“SQL Injection” or “sqli” refers to an attack launched on a database server in
which a user attempts to send SQL commands in an area in which they are not
normally allowed.
12
“Backdoor” refers to gaining access to a system through a normal, but hidden,
authentication mechanism. Unlike a vulnerability (or “vuln”), which is an error, a
backdoor is an intentional entry which gets misused.
12

shit.” The CW was also told by crysis to try running the command
“cmd=whoami”
13
on the system.
18. On or about April 15, 2014, an FBI undercover employee (“UCE”),
using the CW’s username with the CW’s permission, had online
communications with rootcrysis. During those communications, rootcrysis
provided a copy of information NullCrew planned to release on April 20,
2014. In this document, data from University B was presented for release.
19. On or about April 20, 2014, the UCE engaged in an online chat
with rootcrysis and Individual A. During the chat, Individual A stated he had
a “code-execution vuln
14
” and provided the link, which is associated with the
University B systems. Individual A then provided rootcrysis a command that
could be used to find all files in existence on a server in a specified directory.
Individual A further requested that the results be uploaded to a place where
it could be accessed. In response, rootcrysis wrote, “Doing so now. Taking a
while lol.” Later in the conversation, rootcrysis stated, “Welcome back, and
I’mma up [upload] that file now. I’ll put it on mega and send it to you.”
Individual A asked about the size of the file, to which rootcrysis responded,

13
A successful execution of this command would indicate that the user has the
ability to run system commands on the server.
14
“Vuln,” short for “vulnerabilities,” refers to errors in computer software that allow
an attacker to gain unauthorized access.
14

about January 30, 2014, to on or about February 2, 2014, from an IP address
belonging to the Chicago computer server. Those logs further reflect that on
January 30, 2014, an individual attempted twice to run the same command
referenced by “crisis” on January 30, 2014, in the chat with the CW described
above in ¶17. That command was executed from the IP address
24.151.249.146.
22. I have reviewed files and logs stored on the Chicago computer
server. Those files reflect that on or about February 5, 2014, a user operating
under the name “Orbit” created a directory entitled “[University B]” on the
Chicago computer server. Within this directory were several files detailing
configurations and directories on server computers in the University B
domain. On April 20, 2014, at approximately 1:39 pm, a file named
“[University B]_files.txt” was created, in the home directory for Orbit’s
account. That file, based on my review, is substantially the same as the file
posted to mega.co.nz, referenced above. A review of the logs of the Chicago
computer server during that time period reflects that Orbit logged into the
server from IP address 24.151.249.146.
Cyber Attack Against Company B
23. On or about April 15, 2014, the UCE had an online chat with
rootcrysis via CryptoCat. During that discussion, rootcrysis provided the
UCE a link to information NullCrew planned to release on April 20, 2014.
15

That release contained hardware data, WordPress configuration data, and
user information for Company B, a company based in California.
24. FBI later interviewed an IT employee at Company B, who
confirmed that there was unauthorized access to the company’s computer
servers. The IT employee also provided logs for Company B. Those logs
reflected that, between January 17, 2014, and January 21, 2014, the IP
address 24.151.249.146 accessed Company B’s servers approximately 209
times, approximately 123 of which were to a file entitled “test.php.” Based on
my analysis of the usage of this file, it appears to be a malicious PHP
16
file
that allows an attacker shell-type access to the system.
25. During an online chat with the UCE on or about April 20, 2014,
rootcrysis stated “I’mma laugh when we’ve caused that web-developer of
[Company B] to lose his job LOL.”
26. A review of the Chicago computer server reflects that on or about
February 5, 2014, a folder entitled “Targets/[Company B]” was created in
Orbit’s home directory on the Chicago computer server. In that folder was a
file entitled “Exfil.txt,”
17
modified on or about January 21, 2014. That file
contained the information that was released by NullCrew on or about April

16
PHP is a programming language, commonly used to provide functionality on
websites.
17
“Exfil” or “exfiltration” is used in data security to refer to “data theft” or
information acquired through the unauthorized access of a computer system or
network.
16

20, 2014. An analysis of login records for the Chicago computer server for
that day show that user “Orbit” logged in on multiple occasions from the IP
address 24.151.249.146.
Cyber Attack Against Company C
27. On or about February 5, 2014, rootcrysis chatted with the CW via
CryptoCat about Company C, a large mass media communications company.
During the chat, rootcrysis provided a URL
18
to a server at Company C,
stating that it was the “Current target” and that the vulnerability was “LFI
19

in Zimbra.”
20
The CW asked what the goal was and rootcrysis responded,
“Pretty much, get anything interesting we can; goal is to get a shell [i.e., shell
access].” Later, rootcrysis and the CW discussed the fact that they had
exploited the LFI vulnerability and, as a result, had obtained data from the
server that included credentials for other system services. According to
rootcrysis, he had uploaded the material onto a computer server (later
identified as the Chicago computer server). Also, during the chat, rootcrysis
provided the CW a certain command to run, which was designed to exploit a
second vulnerability in Zimbra.

18
A “URL,” or uniform resource locator, is a specific character string that
constitutes a reference to a resource, which is commonly used for webpages.
19
“LFI,” or local file inclusion, refers to a vulnerability in webservers.
20
Zimbra is a collaboration program, installed in a client-server model, intended to
allow people to share data.
17

28. On or about February 5, 2014, NullCrew, through its Twitter
account @NullCrew_FTS, announced an attack on Company C, and posted a
link to a document located on Pastebin. The document, which I have
reviewed, listed thirty-three Company C servers, and stated that they all run
a software package called “Zimbra.” One of the servers was the same as the
one mentioned by rootcrysis in the chat with the CW and the vulnerable URL
was the same as the one rootcrysis provided to the CW, as referenced above.
The document also states that Zimbra is vulnerable to a technique known as
LFI, and posts several critical files from the server as proof. The files include
credentials for several system services.
29. A review of records on the Chicago server shows logins to user
“Orbit” on February 5, 2014, from IP address 24.151.249.146. During these
logins, a directory entitled “Targets/[Company C]” was created in the home
directory for user Orbit. This directory contained a file named “vuln.txt,”
which contained the same URL sent to CW above. Additionally, a file named
“subdomains.txt” contained a list of Company C servers, which included the
list of vulnerable servers from the release. Finally, a series of files in the
“Exfil” subdirectory contained username and password combinations that
were duplicated in the release.
30. A review of records on the Chicago server for user Orbit shows
that on or about February 5, 2014, the user ran two commands that are
18

substantially similar to the ones discussed in the chat above. These
commands targeted the same server discussed in the chat above.
31. Based on my training and experience, and based on my
knowledge of the investigation and conversations with employees of the
victim companies and universities in this case, I believe that the victims in
incurred costs that, in aggregate, exceed $5,000, including costs responding to
the computer intrusion, conducting a damage assessment, and restoring the
computer systems.
Identification of “Orbit,” “Orbit_g1rl,” “Rootcrysis,” and “Crysis”
as Timothy Justin French

32. During group chats on Skype among NullCrew members in early
2013, which the CW provided to the FBI, another NullCrew member stated
that “Orbit” also uses the nickname “c0rps3,” which Orbit confirmed in that
chat.
33. During a group Skype chat on or about January 29, 2013,
NullCrew members were discussing a “dox”
21
that was posted about 0rbit.
0rbit responded stating, “my name is Timothy, I’ve told everyone that.” Later
in that same chat, 0rbit stated, “My location in TN is different then what
they thought” and also “Timothy Story = Not even a real name, I set that up.”

21
“Dox” or “doxxing” refers to the acquisition and release of personal information
about an individual. These terms are often used in reference to identifying someone
previously only know by a pseudonym.
19

34. On or about December 22, 2011, a search warrant was executed
by FBI agents at a residence in Talbott, Tennessee, in relation to an attack
on computers at a community college.
22
Agents believed that Timothy Justin
French was responsible for the attack. Following the search, French was
located and interviewed at a residence in Morristown, Tennessee, owned by
one of French’s family members (“the Morristown address”). That is the
residence which is listed on French’s driver’s license, as of on or about March
25, 2014. During the interview, French admitted using the online nickname
“c0rps3.” French also stated that he used the name “Timothy Story” on the
Internet.
35. During a Skype chat with the CW on or about February 8, 2013,
0rbit wrote “four hours ago I was in a bad car wreck.” When the CW asked
what 0rbit was driving, 0rbit responded “It’s a 1996 camaro, automatic; v6
305 engine.” A search of public records reflects under French’s name a vehicle
accident on February 7, 2013, involving a 1996 Chevrolet Camaro/RS.
According to driving records, French was cited for “Failure to Yield Right of
Way” and “Violation of Seat Belt Law as Driver” on February 7, 2013.

22
The residence in Talbott, Tennessee, is owned by French’s father.
20

36. During multiple conversations via Skype, 0rbit used the Skype
username “orbit.girl.”
23
Records from Skype reflect that username orbit.girl
was registered on October 23, 2012, from the IP address 75.136.47.7. Records
from Charter Communications reflect that this IP address was assigned to an
individual at the Morristown address between June 8, 2012, and October 24,
2012.
37. On or about February 3, 2014, the CW participated in a chat with
“rootcrysis” via CryptoCat. During that chat, rootcrysis provided a password
“to the nc [NullCrew] twitter.” The CW was able to use that password to log
into the Twitter account @NullCrew_FTS. Records from Twitter regarding
the account @NullCrew_FTS reflect that the IP address 24.151.249.146
logged into this account between February 3, 2014, and February 5, 2014.
Records from Comcast reflect that the IP address was assigned to the
Morristown address during that time period.
38. During each of the attacks involving the Chicago computer
server, described above, a user was logged into the Chicago computer server
under the name “Orbit” from the IP address 24.151.249.146. Records
obtained from Charter Communications reflect that, during this time period,
the IP address 24.151.249.146 was assigned to the Morristown address.

23
Though the account username was “orbit.girl,” during the investigation, the
“display name” to the CW and UCE was “0rbit.”
21

39. As described above, on multiple occasions, an individual accessed
victim servers directly from IP addresses that resolve to the Morristown
address or accessed the Chicago computer server in connection with this
activity from an IP address that resolves to the Morristown address. For
example:
a. Records obtained from University A regarding the attack
on their servers (described above in ¶¶10-11) show connections to the file
gny.php by IP address 75.136.44.71 on multiple occasions between June 18,
2013, and June 21, 2013. Additionally, multiple accesses were seen from IP
address 24.151.251.118 on July 19, 2013, at or around the same time that
“0rbit” was discussing an attack with CW. Records obtained from Charter
Communications show that 75.136.44.71 and 24.151.251.118 were both
assigned to the Morristown address during their respective time periods.
b. Records obtained from University B regarding the attack
on their servers (described above in ¶¶17-22) show accesses to the vulnerable
link described in ¶19 from IP address 24.151.249.146 on January 30, 2014.
Additionally, those records show access to the posted vulnerable link, and
another vulnerable link, from the Chicago computer server on January 30,
2014, and February 2, 2014. During this time, user “Orbit” was logged into
the Chicago server from IP address 24.151.249.146. Additionally, as
referenced above, University B files were uploaded to the Chicago server on
22

April 20, 2014, also from IP address 24.151.249.146. Records obtained from
Charter Communications show that IP address 24.151.249.146 was assigned
to the Morristown address during that entire time period.
c. Records obtained from Company B regarding the attack on
its servers (described in ¶¶23-26) show 209 accesses to a file called “test.php,”
which Company B deemed malicious. These accesses, from IP address
24.151.249.146, all occurred between January 17, 2014, and January 21,
2014. Additionally, on or about February 5, 2014, a file was created on the
Chicago computer server, containing Company B information. During the
creation of this file, user “Orbit” was logged in from IP address
24.151.249.146. Records obtained from Charter Communications show that
IP address 24.151.249.146 was assigned to the Morristown address at all
times during that period.

23

Conclusion
40. Based on the above information, I respectfully submit that there
is probable cause that beginning no later than in or around July 2013, and
continuing until at least in or about May 2014, Timothy Justin French and
others have conspired to knowingly cause the transmission of a program,
information, code, or command, and as a result of such conduct, intentionally
causing damage without authorization, to a protected computer, which
offense caused a loss aggregating at least $5,000 in value to one or more
persons during a one-year period, in violation of Title 18, United States Code,
Sections 1030(a)(5)(A), 1030(b), and 1030(c)(4)(B)(i).

FURTHER AFFIANT SAYETH NOT.



Patrick M. Geahan
Special Agent, FBI



SUBSCRIBED AND SWORN to before me on June 3, 2014.



Daniel G. Martin
United States Magistrate Judge

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