AO 91 (Rev.

11/11) Criminal Complaint

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA
CASE NUMBER:
UNDER SEAL

v.
ZACHARY BUCHTA,
also known as “pein,” “@fbiarelosers,”
“@xotehpoodle,” and “lizard,” and
BRADLEY JAN WILLEM VAN ROOY,
also known as “Uchiha,” “@UchihaLS,”
“dragon,” and “fox”

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 November 2015, and continuing at least until in or
around September 2016, in the Northern District of Illinois, Eastern Division, and elsewhere, the
defendants 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 caused 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.
ERIC T. BRELSFORD
Special Agent, Federal Bureau of Investigation
(FBI)

Sworn to before me and signed in my presence.
Date: September 23, 2016
Judge’s signature
City and state: Chicago, Illinois

MARY M. ROWLAND, U.S. Magistrate Judge
Printed name and Title

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS

)
)
)

AFFIDAVIT
I.

INTRODUCTION AND AGENT BACKGROUND
I, Eric T. Brelsford, 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 May 2003 and have specialized in cybercrime investigations for the
duration of my employment. As a Special Agent, I am charged with investigating
possible violations of federal criminal law, including violations of 18 U.S.C. §§ 1030
(computer crime), 1029 (access device fraud), 875(c) (interstate transmission of
threats), and 2261A(2) (cyberstalking). I have received specialized training in the
investigation of cybercrime. In particular, I hold a bachelor’s degree in Computer
Studies

and

have

current

cybersecurity-related

certifications

from

Global

Information Assurance Certification in the fields of incident handling, web
application penetration testing, and computer forensics. 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 Zachary Buchta, also known as “pein,” “@fbiarelosers,” “@xotehpoodle,” and
“lizard,” and Bradley Jan Willem van Rooy, also known as “Uchiha,” “@UchihaLS,”
“dragon,” and “fox,” have conspired with each other and others to knowingly cause
the transmission of a program, information, code, or command, and as a result of such

conduct, intentionally caused 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) (the “Subject Offense”).
3.
following

This affidavit is also submitted in support of seizure warrants for the
domain

names:

shenron.lizardsquad.org

(Subject

Domain

1),

lizardsquad.org (Subject Domain 2), stresser.poodlecorp.org (Subject Domain 3),
and poodlecorp.org (Subject Domain 4) (collectively, the “Subject Domains”).
Domains ending in “.org” are ultimately controlled by Public Interest Registry, 1775
Wiehle Avenue, Suite 200, Reston, Virginia 20190
4.

The statements in this affidavit are based on my personal knowledge

and from 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. Because this affidavit is being
submitted for the limited purpose of securing a search warrant, I have not included
each and every fact known to me concerning this investigation. I have set forth only
those facts that I believe are sufficient to establish probable cause.
5.

I know from my training and experience that the following definitions

apply to the activity discussed in this affidavit:
2

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 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
3

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.
d.

Whois: A “Whois” search provides publicly available information

as to which entity is responsible for a particular IP address. A Whois record for a
particular IP address will list a range of IP addresses that that IP address falls within
and the entity responsible for that IP address range. For example, a Whois record for
the IP address 10.147.53.25 might list an IP address range of 10.147.53.0 –
10.147.53.255 and list Company ABC as the responsible entity. In this example,
Company ABC would be responsible for the IP addresses 10.147.53.0 through
10.147.53.255.
e.

Domain Name: A domain name is a simple, easy-to-remember

way to identify computers on the Internet, using a series of characters (e.g., letters,
numbers, or other characters) that correspond with a particular IP address. For
example, “usdoj.gov” is a domain name.
f.

Domain

Name

System:

IP

addresses

generally

have

corresponding domain names. The Domain Name System (DNS) is, among other
things, a hierarchical convention for domain names. Domain names are composed of
one or more parts, or “labels,” that are delimited by periods, such as
4

“www.example.com.” The hierarchy of domains descends from right to left; each label
specifies a subdivision, or subdomain, of the domain on the right. The right-most level
conveys the “top-level” domain. For example, the domain name “www.example.com”
means that the computer assigned that name is in the “.com” top-level domain, the
“example” second-level domain, and the web server. For each top-level domain, there
is a single entity, called a “registry,” that determines which second-level domain
resolves. Certain top-level domains have been assigned to specific countries. For
example, “.de” is a top-level domain for Germany, “.mx” is a top-level domain for
Mexico, and “.me” is a top-level domain for Montenegro.
g.

Registrar & Registrant: Domain names may be purchased

through a registrar, which acts as the intermediary between the registry and the
purchaser of the domain name. The individual or business that purchases, or
registers, a domain name is called a “registrant.” Registrants control the IP address,
and thus the computer, to which their domain name resolves. Thus, a registrant may
easily move a domain name to another computer anywhere in the world. Registrars
typically maintain customer, billing, and contact information about the registrants
who used their domain name registration services.
h.

Distributed Denial-of-service attack (DDOS): Based on my

training and experience, I am aware that a “distributed denial-of-service” attack
involves making computing or computer network resources unavailable to legitimate
users. I am aware that these attacks are commonly carried out by directing large
5

amounts of computer network traffic to a target causing that target’s available
resources to be consumed by the attack resulting in no or few resources left to
accommodate legitimate users.
II.

FACTS ESTABLISHING PROBABLE CAUSE IN SUPPORT OF THE CRIMINAL
COMPLAINT AND THE SEIZURE WARRANT
A.

Overview

6.

The FBI has been investigating computer crimes perpetrated by

members of the computer hacking groups “Lizard Squad” and “PoodleCorp.” These
crimes include extensive denial-of-service attacks, the trafficking of stolen payment
card account information, and online account takeovers, in violation of the Subject
Offense. Individuals associated with Lizard Squad and/or PoodleCorp include “pein,”
whom the FBI has identified as Zachary Buchta (who also uses the aliases
“@fbiarelosers,” “@xotehpoodle,” and “lizard”), “Uchiha,” whom the FBI has identified
as Bradley Jan Willem van Rooy (who also uses the aliases “@UchihaLS,” “dragon,”
and “fox”), “@chippyshell,” whom the FBI has identified as Individual A, and
“AppleJ4ck,” whom the FBI has identified as Individual B.
7.

As further described below, Zachary Buchta, Bradley Jan Willem van

Rooy, Individual A, Individual B, and others have conspired to launch destructive
cyber attacks against companies and individuals around the world. They have done
so first by promoting and operating the websites “shenron.lizardsquad.org” (Subject
Domain 1) and “stresser.ru” (hereinafter, “Shenron”), through which they provided
a cyber-attack-for-hire service and trafficked stolen payment card account
6

B.

Phonebomber.net

9.

This investigation began in response to the launch of the website

phonebomber.net, a site that enabled paying customers to select victims to receive
repeated harassing and threatening phone calls from spoofed phone numbers. During
October and November 2015, two Twitter accounts identified as belonging to
members of Lizard Squad—@LizardLands and @UchihaLS (i.e., van Rooy)—were
used to disseminate information about phonebomber.net.
10.

On or about October 27, 2015, I accessed the website phonebomber.net

and observed a webpage titled “Phone Bomber” that stated:
phonebomber.net (phonebombermlyerhx.onion) is a no-registration
phone bombing service. We will call your target once per hour with one
of our pre-recorded messages for $20 a month. Since our calls come from
random numbers, your target will be unable to block our calls. Your
target will be left with only 3 options: Change their number, Bend to
your whim, Deal with a ringing phone for the length of our attack :\
For the extortionists amongst us we’ve added an option to cancel the
calls at the click of a button, giving you complete control over the length
of the attack. . . .
Since there is no registration, all purchases are untraceable. The only
data a hacker / feds would be able to exfiltrate from our database are the
phone numbers currently being called, and the last 30 days of targets.
Rest assured your privacy is respected here and purchase in confidence.
11.

On or about October 23, 2015, @LizardLands announced that Victim O,

a resident of the Northern District of Illinois, was the “first victim” of the service.
Upon reviewing the hyperlink that @LizardLands tweeted and having received
information from Victim O, Victim O’s phone number received a phone call every hour
for thirty days with the following audio recording:
8

When you walk the fucking streets, Motherfucker, you better look over
your fucking back because I don’t flying fuck if we have to burn your
fucking house down, if we have to fucking track your goddamned family
down, we will fuck your shit up motherfuck.
C.

Denial-of-Service Attack against Victim A

12.

Soon after the launch of phonebomber.net, members of Lizard Squad

began denial-of-service attacks against various victims and boasted about their
attacks on Twitter. In particular, during November and December 2015, the Twitter
accounts @LizardLands, @fbiarelosers (i.e., Buchta), and @chippyshell (i.e.,
Individual A) were used to coordinate and announce a denial-of-service attack
committed against Victim A, an international digital media company. For example:
a.

On or about December 3, 2015, I reviewed Twitter account

@LizardLands and observed a retweet2 of a tweet made by @chippyshell with a
timestamp of November 27, 2015, at 7:33 AM PST, which stated: “[Victim A online
service] #OFFLINE #CHIPPY #LIZARDSQUAD.”
b.

On or about December 7, 2015, I reviewed the account

@chippyshell and the account description stated: “Founder of Lizard Squad /
@fbiarelosers is my partner in cyber crime.” I also observed the following tweets with
associated timestamps:
Tweet #1, November 27, 2015 6:40 AM PST: “put on ur fucking water boots itz
bouta rain packets3 kid”

2

A “retweet” is the re-posting of a tweet made by another Twitter account.

3

Based on my training and experience, I am aware that a “packet” is the terminology utilized
for a unit of data that is being transmitted via digital networks. I am also aware that denial-

9

11/28/15 5:32 AM
D.

@UchihaLS

[Victim A online service] is back
offline c:

The Shenron Website
1.

16.

@fbiarelosers

Launching of the Shenron Denial-of-Service Website

In or about February 2016, members of Lizard Squad, using the Twitter

accounts @LizardLands, @UchihaLS (i.e., van Rooy), @fbiarelosers (i.e., Buchta), and
@chippyshell (i.e., Individual A) advertised a new website named Shenron, which
enabled paying customers to issue denial-of-service attacks with the click of a button
against victims of their choosing.
17.

On or about February 4, 2016, I reviewed the @fbiarelosers account,

which had the display name “Pein,” and observed a tweet dated February 4, 2016,
which stated: “sitting here enjoying shenron! #LizardSquad.” Also included with the
tweet was a screenshot (as reflected below) of a webpage titled “SHENRON,” which
included a heading that invited users to “[l]aunch an attack with the Shenron
Stresser.” The webpage also had text boxes referring to the length, number and power
of the attack (with the power reflected in gigabits per second or “Gpbs”). The webpage
included a pop-up box titled, “Launch Attack.”6 The logged in user account visible in

This screenshot appears to be of a website for a “stresser service.” I am aware from my
training and experience that stresser services, which are sometimes referred to as “booter
services,” typically provide denial-of-service attack capabilities on a pay-per-usage or
subscription basis. Based on my training and experience, I believe “376 Gbps TOTAL
POWER” refers to the maximum attack size of the service in terms of the amount of network
traffic that could be directed at a target.
6

12

February 20, 2016 1:03 PM PST: “PayPal Payments are now being
accepted on shenron.lizardsquad.org [Subject Domain 1], limited
time!”
February 20, 2016 1:41 PM PST: “@DominicAero1 Its a monthly
subscription with unlimited attacks.” This tweet was observed to have
been sent in response to the following tweet by @DominicAero1:
“@LizardLands Do we have to add 20$ and get the 20$ package to be
able to ddos [distributed denial-of-service] or can we add 2$ and do 1
attack?”
20.

On or about February 20, 2016, I reviewed the @fbiarelosers account and

observed a tweet with a timestamp of February 20, 2016, at 12:10 PM PST, which
stated: “shenron.lizardsquad.org,” i.e., Subject Domain 1.
21.

On or about February 21, 2016, I reviewed the @chippyshell account and

observed a tweet with a timestamp of February 20, 2016, at 6:01 pm PST, which
stated “shenron.lizardsquad.org,” i.e., Subject Domain 1.
22.

On or about March 1, 2016, I accessed the website Subject Domain 1.

After creating a user account, I was presented with a webpage (as reflected below)
titled “Dashboard: An overview of Shenron,” which had text boxes reflecting the user
balance, the maximum power of an attack, the number of users online, and the
percentage of time the website was available.

15

has provided the FBI a copy of the results of the testing, including the Simple
Network Management Protocol (“SNMP”) attack, which I have reviewed.
25.

The SNMP attack was found to be composed of approximately 6,000

unique IP addresses, each of which was transmitting SNMP responses to the targeted
IP address and port. Based on my training and experience, this attack traffic
appeared to be consistent with an SNMP amplification attack.9
26.

I reviewed the IP addresses reflected in the logs as sending the SNMP

responses and identified one of these as an IP address associated with Company T
(“Company T IP address”). Company T is located in Arlington Heights, Illinois, and
the Company T IP address was assigned to a computer network device running the
SNMP service from a location in Arlington Heights.
27.

On or about March 17, 2016, Company T provided consent for the FBI

to monitor computer trespasser traffic to and from the Company T IP address, which
commenced on or about March 22, 2016, and continued until on or about May 31,
2016. The monitoring reflected hundreds of instances in which a single IP address
appeared to issue large numbers of SNMP requests to the Company T IP address,
resulting in the Company T IP address sending SNMP responses to the IP address

I am aware from my training and experience that an SNMP amplification attack is a type
of denial-of-service attack in which the attacker sends SNMP requests to Internet-accessible
devices running SNMP, with the source IP address in the request being falsified (also known
as “spoofed”) to appear to be the IP address of the target of the denial-of-service attack. This
results in the SNMP responses from these Internet accessible devices to be directed to that
target IP address instead of back to the IP address of the attacker that sent the request. The
size of the SNMP response is typically much larger than the size of the request resulting in
the “amplified” size of the attack.
9

18

that appeared to be submitting the requests.10 Based on my training and experience,
I found this to be consistent with an SNMP amplification attack in which the attack
“spoofs” the source IP address in the SNMP request to cause the responses to be
directed to the intended target IP address.
3.
28.

Further Investigation of the Shenron Website

On or about March 4, 2016, I reviewed the publicly accessible portion of

@LizardLands and observed a tweet explaining that Shenron had a “new domain,”
which was listed as “stresser.ru.”
29.

On or about March 4, 2016, I accessed the website “stresser.ru” and it

appeared to be the same website previously accessed via Subject Domain 1, offering
identical denial-of-service attack packages. I also was able to successfully login to the
website using the username and password combination for the account I had created
on March 1, 2016, when accessing Subject Domain 1.
30.

On or about April 12, 2016, I reviewed the @LizardLands and

@fbiarelosers accounts and observed a tweet by @LizardLands dated April 11, 2016,
which advertised stresser.ru. For the @fbiarelosers account, the “bio” section stated
that the user was a “Leader of Lizard Squad” and that one may direct message (or
“DM”) the account about obtaining the services of a “5 star botnet.”11

10

There were some instances in which the Company T IP address received SNMP requests,
but for an unknown reason did not send the corresponding SNMP responses.
A “botnet” refers to a collection of computers or other Internet-connected devices that have
been compromised, typically with malicious software, enabling an attacker to exercise some
11

19

31.

I re-reviewed the Shenron website via “stresser.ru” approximately eight

times between on or about March 11, 2016, and May 16, 2016, and observed that it
continued to offer denial-of-service attack packages for purchase. The maximum
denial-of-service attack size advertised during this time was “Up to 500 Gbps” for
packages that cost $999.99 a month.
32.

On or about May 24, 2016, I accessed the Shenron website via

“stresser.ru” and found that in addition to offering denial-of-service attack packages,
the website also contained a section named “CC Shop” that offered for sale credit card
information. The section had a comment that stated:
Welcome to the newest addition to the shenron family: the card shop!
We have uploaded a very small batch for testing purposes. The valid rate
is 60-80%. Please note it’s still under development so expect issues. If
you have any questions submit a ticket. More coming soon. ~ shenron
team.
The “CC Shop” section contained what appeared to be approximately 347 pages of
payment card data available for purchase with each page appearing to contain
approximately ten records per page.

degree of control over these compromised devices. I am aware from my training and
experience that botnets are commonly utilized to conduct denial-of-service attacks.

20

34.

I have re-reviewed the Shenron website via “stresser.ru” approximately

ten times between on or about June 27, 2016, and or about September 15, 2016, and
have observed that it has continued to offer payment cards for sale during each of
these instances.
35.

On or about September 15, 2016, I also reviewed the website

lizardsquad.org, i.e., Subject Domain 2, which displayed the title “Lizard Squad
Hub” with the only additional text on the page stating: “If you were looking for the
lizard squad twitter click [https://twitter.com/lizardlands] Stresser: [Subject
Domain 1].” I then accessed Subject Domain 1 and logged in with the same account
I used to access Shenron via “stresser.ru.” I found that it displayed the same
information I observed during my September 15, 2016 review via “stresser.ru.”
36.

I reviewed the IP addresses associated with both Subject Domain 1

and stresser.ru and found them to be associated with the U.S.-based website proxy
service provider CloudFlare, Inc.12
37.

Records provided from CloudFlare reflected that it was providing proxy

services to access the websites Subject Domain 1 and stresser.ru and that the actual

12

CloudFlare is a U.S.-based internet service company that provides proxy services for its
customers’ websites which results in internet traffic destined for those websites to be routed
through CloudFlare’s network. As a result, the publicly listed IP addresses associated with a
CloudFlare customer’s website would be a CloudFlare controlled IP address. CloudFlare
maintains records of the true IP address on which the corresponding website is actually
hosted in order to properly route the traffic to and from that website via CloudFlare’s
network.

22

IP address associated with both Subject Domain 1 and stresser.ru was an IP
address ending in 247.
38.

I performed a Whois search for the IP address ending in 247 and found

it was allocated to an internet service provider in the Netherlands.
4.
39.

Court-Authorized Wiretap of the Shenron Website

Pursuant to both a mutual legal assistance request from the United

States and a parallel investigation initiated by Dutch authorities, a court in the
Netherlands authorized a wiretap of the computer assigned to the IP address ending
in 247, which began on or about May 24, 2016. United States authorities received a
copy of the wiretap data covering the period of approximately on or about May 24,
2016, through approximately on or about June 8, 2016, and I have reviewed that data.
The data reflects, among other things, that during that time period:
a.

Users of the Shenron website purchased over 100 payment cards.

b.

Over 600 apparent denial-of-service attacks were initiated by

users of the Shenron website, including SNMP denial-of-service attacks.
40.

The payment card data purchased via the Shenron website included

card data for Victim E13 and F, both of whom are residents of the Northern District
of Illinois. Victim E and F were both interviewed by the FBI and they confirmed that
they had not authorized anyone to sell their payment card information.

13

The card data for Victim E was associated with the previously described FBI purchase on
or about May 27, 2016.

23

41.

The wiretap data reflected that several purchases of payment card data

were made by a Shenron user whose connection to the Shenron website was routed
through a CloudFlare data center associated with the identifier “ORD.”14 These
included purchases from on or about May 27, 2016, through on or about June 2, 2016,
of payment card information for Victims G through J. Victims G, H, and I have been
interviewed by the FBI. Victims G and H and each confirmed that they had not
authorized anyone to sell their payment card information. Victim I confirmed that
he/she was aware that his/her card information had been compromised without
his/her authorization.
42.

I compared the SNMP denial-of-service attacks reflected in the wiretap

data with the SNMP requests that were identified by the computer trespasser
monitoring of the Company T IP address. The first SNMP denial-of-service attack
reflected in the wiretap had a date of on or about May 23, 2016, at 8:52 AM UTC.15
The wiretap data reflected approximately 62 SNMP denial-of-service attacks
initiated between this date and time, and on or about May 31, 2016.16
43.

Based on my review, 32 of the 62 SNMP denial-of-service attacks had

corresponding matches in the computer trespasser monitoring of the Company T IP
14

Information provided by CloudFlare reflects that the data center associated with “ORD” is
physically located in Chicago, Illinois.
15

Based on an analysis of the wiretap data, it appears that Shenron displays recent attack
history to a user. As a result, I was able to obtain information on some attacks performed via
the site prior to the start of the wiretap.
16

As stated previously, the computer trespasser monitoring of the Company T IP address
ended on or about May 31, 2016.

24

7:09 PM PDT: “EU [Victim B] #Offline – [Victim B game #1] #Offline,
[Victim B game #2] #Offline, [Victim B game #3] #Offline, [Victim B
game #4] #Offline @fbiarelosers @AppleJ4ckxoxo”
7:20 PM PDT: “Arrest us.”
7:55 PM PDT: “More to come.”
46.

On or about April 14, 2016, I reviewed the @fbiarelosers account and

observed the bio section stated mentioned “PEiN” and that the user was a “Member
of @LizardLands.” I also observed that @fbiarelosers had retweeted the April 13,
2016, 7:09 PM PDT @LizardLands tweet which stated: “EU [Victim B] #Offline –
[Victim B game #1] #Offline, [Victim B game #2] #Offline, [Victim B game #3]
#Offline, [Victim B game #4] #Offline @fbiarelosers @AppleJ4ckxoxo”
47.

On or about April 14, 2016, I reviewed the @UchihaLS account and

observed the following tweet made by @UchihaLS on April 14, 2016 at 3:54 AM PDT:
“You can’t arrest a lizard.”
48.

Victim B is a U.S.-based company that produces video games, among

other things. Representatives of Victim B confirmed that Victim B sustained
significant denial-of-service attacks on or about April 13, 2016, which targeted both
its United States and European region online gaming platforms. The denial-of-service
attack against Victim B’s United States region online gaming platform specifically
targeted a particular IP address, Victim B IP address #1. This IP address is
associated with the authentication servers for Victim B’s United States region and is
used to allow players to access Victim B’s online games. The representatives
26

4/13/16 6:54 PM

4/13/16 6:59 PM

4/13/16 6:59 PM
4/13/16 6:59 PM
4/13/16 6:59 PM
4/13/16 7:00 PM
4/13/16 7:04 PM
4/13/16 7:04 PM
4/13/16 7:04 PM
4/13/16 7:50 PM
4/13/16 7:50 PM
4/13/16 7:50 PM
4/13/16 7:50 PM
4/13/16 7:50 PM
4/13/16 7:50 PM
50.

@fbiarelosers

@AppleJ4ckxoxo going bac on
this is weird last time we
hit [Victim B] [Twitter
shortened URL which
@fbiarelosers
@AppleJ4ckxoxo
resolved to Victim B's
gaming platform website]
went offline
@fbiarelosers
@AppleJ4ckxoxo now its not offline
@fbiarelosers
@AppleJ4ckxoxo but [Victim B] is offline
@fbiarelosers
@AppleJ4ckxoxo odd
[Twitter shortened URL
which resolved to a
@fbiarelosers
@AppleJ4ckxoxo
Twitter.com search for
“[Victim B]CS”]
@AppleJ4ckxoxo @fbiarelosers
done
@AppleJ4ckxoxo @fbiarelosers
EU down as well
@fbiarelosers
@AppleJ4ckxoxo ok
@fbiarelosers
@AppleJ4ckxoxo ay
@fbiarelosers
@AppleJ4ckxoxo ay
@fbiarelosers
@AppleJ4ckxoxo ay
@fbiarelosers
@AppleJ4ckxoxo ay
@fbiarelosers
@AppleJ4ckxoxo u done?
@AppleJ4ckxoxo @fbiarelosers
Yep

I have reviewed the IP addresses identified by Victim B as participating

in the denial-of-service attacks and many of them have service addresses located in
the Northern District of Illinois.
F.

PoodleCorp

51.

Beginning in or about June 2016, a new computer hacking group

operating under the name “PoodleCorp” emerged, which, as further described below,
involved individuals associated with the group Lizard Squad. The “official” Twitter
account for this group as identified on the group’s website, poodlecorp.org (Subject
Domain 4), used the screen name @PoodleCorp.
28

52.
personnel

Between approximately or about June 29, 2016, and July 6, 2016, FBI
reviewed

the

publicly-accessible

content

of

@LizardLands

and

@PoodleCorp, and observed the following tweets:
a.

A tweet by @PoodleCorp on or about June 23, 2016, at 2:15 AM

UTC, which stated “Soon ;) #PoodleCorp #Summer2016”;
b.

A retweet by @LizardLands of the preceding tweet by

@PoodleCorp.
c.

A tweet by @LizardLands on or about June 28, 2016, at 5:35 AM

UTC, which stated “Lizards and Poodles. #Summer2016”;
d.

A tweet by @LizardLands on or about June 30, 2016, at 5:14 AM

UTC, which stated “[Subject Domain 2] & [Subject Domain 4] #Summer2016”;
and
e.

A tweet by @PoodleCorp on or about July 4, 2016, at 7:45 AM

UTC, which stated “poodlecorp.org,” i.e., Subject Domain 4.
1.
53.

Review of Subject Domain 4

On or about July 6, 2016, I reviewed Subject Domain 4 and observed

that it contained a section titled “Members,” which listed six monikers and a
corresponding hyperlink to the associated Twitter account. These included in part,
the moniker “xo” with a hyperlink to twitter.com/xotehpoodle (“@xotehpoodle”), the
moniker

“shadowpoodle”

(“@shadowpoodle”),

and

with
the

a

hyperlink

moniker

to

“appleJ4ck”

twitter.com/shadowpoodle
with

a

hyperlink

to

twitter.com/applej4ckxoxo. The website also contained a section titled “Used &
29

Abused,” which listed seven entries corresponding to a purported victim of a cyberattack from PoodleCorp and the date for that attack, including an entry for an attack
on Victim C on June 26, 2016, and on Victim B on June 28, 2016. Victim C is also a
U.S.-based

company

that

produces,

among

other

things,

video

games.

Representatives from Victim C and Victim B have confirmed that their company each
sustained a denial-of-service attack on June 26 and 28, 2016, respectively, and that
the attack had an impact on their company’s online gaming platform, blocking online
access for tens of thousands of customers.
54.

The “Used & Abused” section described in the previous paragraph also

included an entry for Victim S and a link to a YouTube channel operated by Victim S.
55.

On or about September 1, 2016, I reviewed the publicly-accessible

portion of the YouTube channel for Victim S. The channel had over 12 million listed
subscribers. I also reviewed the Twitter account for Victim S and located a tweet
dated June 22, 2016, which stated: “We are aware of the hack on our youtube channel
and we’re working with YouTube to fix the changes.”
56.

On or about September 1, 2016, I performed an internet search for the

Victim S YouTube channel compromise and located a video posted on a separate
YouTube channel documenting the compromise of Victim S. All of the posted videos
visible in Victim S’s channel were observed to have the title “HACKED BY
OBNOXIOUS AND PEIN twitter.com/poodlecorp.” The video also displayed a tweet

30

from Victim S’s Twitter account made on June 22, 2016, which stated “HACKED BY
@fbiarelosers and @BLADER.”
2.
57.

Launch of the PoodleStresser Service

Between approximately July 6, 2016, and July 31, 2016, FBI personnel

reviewed the @PoodleCorp and @xotehpoodle (i.e., Buchta) accounts and observed the
following tweets regarding “PoodleStresser”:
a.
PDT,

which

A tweet by @PoodleCorp on or about July 19, 2016, at 6:08 PM
stated

“Going

to

be

doing

a

giveaway

for

PoodleStresser

(stresser.poodlecorp.org [Subject Domain 3]) soon. RT to be eligible.”;
b.

A retweet by @xotehpoodle of the July 19, 2016, 6:08 PM PDT

tweet by @PoodleCorp; and
c.

A tweet by @xotehpoodle on or about July 19, 2016, at 6:36 PM

PDT, which stated “All user boots hit minimum of 10Gbps and the gold package does
20Gbps+ Also the botnet packages both hit at least 400Gbps at any time.”
58.

On or about July 22, 2016, an FBI employee accessed Subject Domain

3, and after creating a user account, was presented with a dashboard view web page
(as reflected below), which stated “361 Total Attacks” and “1776 Total Users.” The
website also contained a section titled “Purchase,” which listed eight options for
purchase which included in part the following choices:
- 1 Month Bronze; $19.99 for 30 days; 1200 Max Boot Time, 1 Concurrents
- 1 Month Silver; $29.99 for 30 days; 2400 Max Boot Time, 1 Concurrents;
- 1 Month Gold; $49.99 for 30 days; 3600 Max Boot Time, 2 Concurrents;
31

60.

On or about August 10, 2016, a confidential source (“Source B”)19

provided the FBI a copy of what is believed to be the leaked Poodle Stresser
database.20 I have reviewed the contents of this database and found it to contain
several database tables including those named “users” which appeared to reflect
usernames, encrypted passwords, and email addresses, “loginlogs” which appeared to
reflect user account login activity, “logs” which appeared to reflect attacks carried
out, and “payments” which appeared to reflect payment details. To corroborate the
authenticity of this information, I observed that the “loginlogs” table contained a login
from the test account created by the FBI on July 22, 2016. I made the following
observations during the review of these tables:
a.

The first two accounts listed in the “users” table were “test123”

and “admin.” There were in excess of 1,500 user accounts overall listed in this table.
b.

The “payments” table reflected sixteen entries with each entry

listing in part an email address, a paid amount, an apparent PayPal transaction ID,
and an apparent payment method. The first entry listed in the table had a listed
email address of ThomasTaylor0707@hotmail.com (discussed later) and an apparent
PayPal transaction ID of 8AF147362X797261U.

Source B is in direct online communications with individuals involved in computer hacking
activities. Source B has provided information to the FBI since 2012 as part of multiple
computer hacking related investigations. Source B has a prior conviction for reckless driving.
Source B has received approximately $6,000 from the FBI in return for assistance in this and
other investigations.
19

20

Source B obtained the database from a third party individual with whom Source B was in
online communication.

33

users, 0 total global attacks launched, and 3 users listed as “Upgraded” with the subdescription “users that have active plan.” A section of the website titled “upgrade”
was found to allow individuals to purchase attack packages. This section stated in
part: “All packages are delivered instantly upon payment confirmation – for obvious
reasons we do not accept PayPal! However you can exchange PayPal to BitCoin via
LocalBitcoins.” This section also stated “Available Attack Methods: DNS, SSyN,
Home, xSyn, TCP-FIN, TCP-RST, TCP-ACK, TCP-AMP, VSE, Dominate.”21 Six
different attack packages were observed to be listed for purchase. These included in
part the following:
- 1 Month Bronze: $19.99 for 1 month; 10Gbps+ Power; 1200 Boot Time;
1 Concurrents;
- 1 Month Silver: $29.99 for 1 month; 10 Gbps+ Power, 2400 Boot Time;
1 Concurrents;
- 1 Month Gold; $39.99 for 1 month; 20Gbps+ Power; 3600 Boot Time; 2
Concurrents;

21

Based on my training and experience, I am aware that the “attack methods” listed (“DNS,”
“SSyN,” etc.) refer to different types of denial-of-service attacks.

35

G.

August 2016 Denial-of-Service Attack Against Victim B

66.

Beginning on or about August 4, 2016, FBI personnel reviewed the

account @PoodleCorp and observed the following Twitter activity pertaining to a
denial-of-service attack against Victim B:
a.

A tweet by @PoodleCorp on or about August 2, 2016, at

approximately 4:33 PM PDT, which stated “(US) [Victim B] #Offline #PoodleCorp
#Lubed”; and
b.

A tweet by @PoodleCorp on or about August 2, 2016, at

approximately 5:20 PM PDT, which stated “(EU & US) [Victim B] #Offline
#PoodleCorp @[Victim B]CS @Gh0stPoodle @PoodlesInBlack.”
67.

A representative of Victim B confirmed to the FBI that Victim B

sustained a denial-of-service attack on or about August 2, 2016, which had an impact
on its online gaming platform.
H.

August 2016 Denial-of-Service Attack Against Victim D

68.

Victim D is a U.S.-based company that produces video games, among

other things.
69.

Beginning on or about September 1, 2016, I reviewed the publicly-

accessible contents of @PoodleCorp and observed the following Twitter activity
pertaining to a denial-of-service attack against Victim D:
a.
AM

PDT,

A tweet by @PoodleCorp on or about August 31, 2016, at 11:58
which

stated:

“The

upcoming

attacks

stresser.poodlecorp.org [Subject Domain 3] #PoodleCorp”; and
37

are

powered

by

b.

A tweet by @PoodleCorp on or about August 31, 2016, at 12:33

PM PDT which stated: “We are responsible for the downtime of @[Victim D] &
@[Victim D game]#PoodleCorp.”
70.

A representative of Victim D has confirmed that a significant denial-of-

service attack was experienced by Victim D beginning on or about August 31, 2016 at
approximately 11:00 AM PDT, which had an impact on Victim D’s operations and
caused damages well in excess of $5,000.
5.
71.

Common access between @fbiarelosers, @PoodleCorp, and
@xotehpoodle accounts

Records from Twitter, collected through a search warrant, subpoenas,

and pen register data, reflect times in which Twitter accounts @fbiarelosers,
@PoodleCorp, and @xotehpoodle were accessed from a common IP address in close
time proximity. Specifically:
a.

There were eight instances between on or about June 24, 2016,

and on or about June 27, 2016, in which @fbiarelosers, @PoodleCorp, and
@xotehpoodle were all logged into from the same IP address within three hours or
less. This occurred on four different days and involved six different IP addresses used
to log into all three accounts. A review of these IP addresses found them to be
associated with the Tor network.22

22

Tor (or The Onion Router) is an international software project to anonymize Internet traffic
that allows individuals to use software to encrypt their communications and route them
through a series of computers before they reach their destination thereby concealing the true
origin point of the communication.

38

b.

There were thirty-three instances between on or about June 24,

2016, and on or about September 2, 2016, in which @PoodleCorp and @xotehpoodle
were logged into from the same IP address within three hours or less.
I.

Identification of Zachary Buchta as User of @fbiarelosers and as
an Operator of the Shenron and PoodleCorp Websites

72.

As described below, the FBI first identified Buchta in this investigation

based in part on text messages he appeared to exchange with @chippyshell near the
time of the November 27, 2015, denial-of-service attack against Victim A (which
attack is mentioned in ¶12). This led the FBI to identify and monitor Buchta’s
internet traffic and compare that to traffic accessing the @fbiarelosers account and
the Shenron and PoodleCorp websites. As further described below, it appears that
Buchta frequently accessed the @fbiarelosers account and the Shenron and
PoodleCorp websites, often through an intermediary Virtual Private Network (VPN)
based overseas.
73.

Regarding the text messages, records obtained from Twitter reflect that

@chippyshell had a telephone number ending in 1065 listed as a registered device for
this account as of July 31, 2015, at 5:08 AM UTC. The records list the service carrier
for this telephone number as “us.googlevoice.” Records obtained from Google reflect
that telephone number ending in 1065 was a Google Voice telephone number and that
the underlying telephone number associated with the account was a number ending
in 7297.

39

74.

Records obtained from AT&T for the number ending in 7297 reflect a

total of four SMS text messages sent between the number ending in 7297 and a Sprint
telephone number ending in 9229 between November 27, 2015, at 4:28 PM UTC, and
November 28, 2015, at 5:24 AM UTC, i.e., near the time of the denial-of-service attack
against Victim A. Records from Sprint for telephone number ending in 9229 reflect
that it is associated with mobile telephone service and that on November 27, 2015,
the subscriber had a billing address in Fallston Maryland, where Zachary Buchta
resides (the “Buchta Residence”).
75.

Comcast records obtained February 9, 2016, reflect that Comcast

account number 0951967050805 (the “Buchta Comcast Account”) is associated with
Internet service provided to the Buchta Residence.
1.
76.

Internet Usage of the Buchta Comcast Account

On or about February 12, 2016, a pen register order for the Buchta

Comcast Account was issued in the Northern District of Illinois, and thereafter
renewed three times. The pen register collection reflected extensive communications
between the Buchta Comcast Account and IP addresses ending in 218, 194, 138, 235,
58, and 42, all through UDP 443 and/or TCP port 22.23 There were also extensive
communications between the Buchta Comcast Account and the IP address ending in

As described below, connections to these particular IP addresses and ports were determined
to be consistent with usage of a particular VPN service based overseas.
23

40

92 through TCP port 3389.24 In particular, the table below reflects the IP address,
date range, days of communications between the IP address and the Buchta Comcast
Account, and the cumulative size of data transmitted in gigabytes:
IP
*218
*194
*138
*235
*58
*42
*92
77.

Date Range
2/24/16 – 6/22/16
4/1/16 – 9/5/16
4/2/16 – 9/5/16
2/25/16 – 5/30/16
5/23/16 – 5/24/16
7/4/16 – 9/3/16
7/4/16 – 8/29/16

Days
63
83
93
37
2
18
25

Size
150 GB
300 GB
400 GB
100 GB
10 GB
30 GB
1 GB

I performed Internet searches for the IP addresses above and found

references indicating that, other than the *92 address, they were associated with a
particular VPN service based overseas.
78.

On or about June 30, 2016, I tested that VPN service observed that it

supports establishing remote VPN sessions via UDP to port 443 and via TCP to port
22. I used the software to connect with servers identified as being located in the
United States. Upon successful connection, the VPN service provided information
about the connection, including the entry IP address and exit IP address, as well as
the “Protocol” and “Port.” I repeated this process again on or about September 20,
2016, and found that each VPN server had a consistent IP address when connecting

24

These communications went to destination port TCP 3389. I am aware from my training
and experience that Remote Desktop Protocol (“RDP”) is a form of remote computer
administration that allows an individual to establish a connection to a remote computer and
have the equivalent of desktop access on the remote computer. I am also aware that RDP
typically operates on TCP port 3389.

41

the login records for @fbiarelosers reflect logins from the *92 IP address, which was
also accessed extensively from the Buchta Comcast Account.
81.

Indeed, there are many instances in which the Buchta Comcast Account

was communicating with one of the Entry IP Addresses at the same time that
@fbiarelosers was accessed from the corresponding Exit IP Address. For example:
a.

On or about April 14, 2016 at 2:48 AM UTC, Exit IP Address 4

logged into @fbiarelosers. The Buchta Comcast Account was communicating with
Entry IP Address 4 at the same time.
b.

On or about April 17, 2016 at 6:59 AM UTC, Exit IP Address 2

logged into @fbiarelosers. The Buchta Comcast Account was communicating with
Entry IP Address 2 at the same time.
c.

On or about April 17, 2016 at 10:31 PM UTC, Exit IP Address 4

logged into @fbiarelosers. The Buchta Comcast Account was communicating with
Entry IP Address 4 at the same time.
d.

On or about April 27, 2016 at 3:56 AM UTC, Exit IP Address 4

logged into @fbiarelosers. The Buchta Comcast Account was communicating with
Entry IP Address 4 at the same time.
e.

On or about May 14, 2016 at 5:53 AM UTC, Exit IP Address 1

logged into @fbiarelosers. The Buchta Comcast Account was communicating with
Entry IP Address 1 at the same time.

43

82.

Moreover, records indicate that the Buchta Comcast Account was used

to access @fbiarelosers when that account was used to discuss the ongoing denial-ofservice attack against Victim B, as described in ¶49. In particular, Twitter records
reflect a login to @fbiarelosers from Exit IP Address 4 on or about April 13, 2016, at
7:48 PM PDT. The pen register for the Buchta Comcast Account reflects that the
account was communicating with Entry IP Address 4 at the same time.
3.
83.

Access to the Shenron Website from VPN Servers With
Corresponding Access from the Buchta Comcast Account

The wiretap data also reflected that the exit IP addresses for the VPN

service were used to operate and use the Shenron website, such as reviewing and
handling customer support tickets, initiating denial-of-service attacks, and
purchasing a payment card. The wiretap data reflected that two different user
accounts, “support” and “lizard,” were used to perform this activity.
84.

There are many instances in which the Buchta Comcast Account was

communicating with entry IP address for the VPN service at the same time that the
Shenron website was accessed from the corresponding exit IP addresses. For
example:
a.

On or about May 24, 2016, from 2:04 PM UTC to 2:06 PM UTC,

Exit IP Address 5 accessed the Shenron website using the account “support”26 and
proceeded to review and close open support tickets (i.e., handle customer complaints

26

At the time of this access, the user appears to have already been logged into the “support”
account as there was no corresponding login reflected in the wiretap data.

44

or issues). The Buchta Comcast Account was communicating with Entry IP Address
5 at the same time.
b.

On or about May 24, 2016, from 8:54 PM UTC to 9:02 PM UTC,

Exit IP Address 1 accessed the Shenron website using the already logged in account
“support” and proceeded to purchase a payment card and review the open support
tickets. The Buchta Comcast Account was communicating with the corresponding
Entry IP Address 1 at the same time.
c.

On or about May 25, 2016, from 1:16 PM UTC to 1:18 PM UTC,

Exit IP Address 1 accessed the Shenron website using the already logged in account
“support” and proceeded to initiate two denial-of-service attacks with a specified
duration of 7,500 seconds each. The Buchta Comcast Account was communicating
with Entry IP Address 1 at the same time.
d.

On or about May 25, 2016, from 2:32 PM UTC to 2:33 PM UTC,

Exit IP Address 1 accessed the Shenron website and logged into the “lizard” account
using a twenty-two-character password. The account balance was listed as $86,233.57
and the maximum power available to the “lizard” account was listed as 500 Gbps.27
The “lizard” user then initiated a denial-of-service attack against a particular IP
address with a specified duration of 18,000 seconds. The Buchta Comcast Account
was communicating with Entry IP Address 1 at the same time.

27

As previously stated, the prior reviews of the Shenron website identified the largest
advertised attack size as “up to 500 Gbps” for a package which cost $999.99 per month.

45

e.

On or about May 25, 2016, at 11:01 PM UTC, Exit IP Address 1

accessed the Shenron website and logged into the “support” account. The “support”
user then reviewed and closed a support ticket. The Buchta Comcast Account was
communicating with Entry IP Address 1 at the same time.
f.

On or about May 26, 2016, at 9:32 AM UTC, Exit IP Address 1

accessed the Shenron website using the already logged in account “support” and
reviewed a support ticket. The Buchta Comcast Account was communicating with
Entry IP Address 1 at the same time.
g.

On or about May 29, 2016, from 9:36 PM UTC to 9:37 PM UTC,

Exit IP Address 4 accessed the Shenron website using the already logged in account
“support” and reviewed support tickets. The Buchta Comcast Account was
communicating with Entry IP Address 4 at the same time.
h.

On or about June 3, 2016, from 4:45 PM UTC to 4:50 PM UTC,

Exit IP Address 1 accessed the Shenron website, logged into the “support” account,
and accessed the support tickets. The Buchta Comcast Account was communicating
with Entry IP Address 1 at the same time.
i.

On or about June 3, 2016, from 6:24 PM UTC to 6:25 PM UTC,

Exit IP Address 3 accessed the Shenron website using the already logged in account
“support” and reviewed an open support ticket. The Buchta Comcast Account was
communicating with Entry IP Address 3 at the same time.

46

j.

On or about June 4, 2016, at 12:15 AM UTC, Exit IP Address 2

accessed the Shenron website using the already logged in account “support” and
accessed the support tickets. The Buchta Comcast Account was communicating with
the Entry IP Address 2 at the same time.
k.

On or about June 4, 2016, from 1:29 PM UTC to 1:33 PM UTC,

Exit IP Address 1 accessed the Shenron website and logged into the “lizard” account.
The account user then changed the “lizard” account password. The Buchta Comcast
Account was communicating with Entry IP Address 1 at the same time.
l.

On or about June 5, 2016, at 12:45 PM UTC, Exit IP Address 1

accessed the Shenron website using the already logged in account “lizard.” The
“lizard” user then initiated a denial-of-service attack with a specified duration of
18,000 seconds. The Buchta Comcast Account was communicating with Entry IP
Address 1 at the same time.
m.

On or about June 6, 2016, from 4:39 PM UTC to 4:40 PM UTC,

Exit IP Address 2 accessed the Shenron website, logged into the “support” account,
and accessed the support tickets. The Buchta Comcast Account was communicating
with Exit IP Address 2 at the same time.
4.
85.

Access to the PoodleCorp Website from VPN Servers With
Corresponding Access from the Buchta Comcast Account

As described above, I reviewed the leaked PoodleCorp database. With

respect to the “loginlogs” table entries reflecting logins to the accounts “test123” and
“admin,” I identified many instances in which the Buchta Comcast Account was
47

communicating with an entry IP address for the VPN service at the same time there
was access to the “admin” account for the PoodleCorp website with a corresponding
exit IP addresses. For example:
a.

Exit IP Address 2 was listed for twenty-two logins to the “admin”

account and five logins to the “test123” account between on or about July 21, 2016 at
10:28 AM UTC, and on or about July 24, 2016 at 7:21 PM UTC. The Buchta Comcast
Account was communicating with Entry IP Address 2 during the times listed for each
of these twenty-seven combined logins.
b.

Exit IP Address 6 was listed for three logins to the “admin”

account and two logins to the “test123” account on or about July 24, 2016, between
approximately 10:01 AM UTC and 8:01 PM UTC. The Buchta Comcast Account was
communicating with Entry IP Address 6 during the times listed for each of these five
combined logins.
c.

Exit IP Address 3 was listed for five logins to the “admin” account

on or about July 25, 2016, between 9:48 AM UTC and 5:13 PM UTC. The Buchta
Comcast Account was communicating with Entry IP Address 3 during the times listed
for each of these five logins.
86.

With respect to the “payments” table for the PoodleCorp database,

PayPal records were obtained for the accounts associated with the transaction ID
8AF147362X797261U, which was the first transaction listed in the table. These
records show that PayPal transaction 8AF147362X797261U occurred on July 20,
48

2016, at 12:08 AM UTC and was a $1.00 payment from the PayPal account associated
with the email address ThomasTaylor0707@hotmail.com (which was reflected in the
leaked database, see ¶60(b)) made to the PayPal account associated with the email
address 495081505855@protonmail.com. The subject of the payment was “1 Month
Bronze.”
87.

PayPal records for the account associated with the email address

495081505855@protonmail.com reflected the following information:
a.

The account holder is listed as Zachary Buchta, along with his

date of birth. The Buchta Residence is listed as an address for the account, and a
mobile telephone number ending in 9229 is listed for the account.28 A bank account
held at Aberdeen Proving Ground Federal Credit Union with an account number
ending in 7176 was also associated with the account.
b.

The records reflect 69 logins to the account, including:
i.

Twenty-five logins to the account from the Buchta Comcast

Account between April 9, 2016, and July 30, 2016.
ii.

Fifteen logins to the account from Exit IP Address 2

between June 16, 2016, and July 28, 2016.
iii.

Fifteen logins to the account from Exit IP Address 3

between April 7, 2016, and July 20, 2016.

28

The telephone number associated with this PayPal account was the same telephone
number previously described in this affidavit as exchanging text messages with the AT&T
telephone number ending in 7297, and which had a billing address of the Buchta Residence.

49

iv.

Two logins to the account from Exit IP Address 1 between

June 8, 2016, and June 14, 2016.
88.

PayPal records for the account associated with the email address

ThomasTaylor0707@hotmail.com reflected the following information:
a.

The account received sixteen payments between July 19, 2016,

and July 20, 2016 with values of $19.99, $29.99, or $39.99 with corresponding
descriptions of “1 Month Bronze,” “1 Month Silver,” and “1 Month Gold.”
b.

The records showed sixty-nine logins to the account between July

6, 2016, and July 28, 2016 which included:
i.

Two logins to the account from Exit IP Address 3 on July

ii.

Two logins to the account from Exit IP Address 2 on July

19, 2016.

20, 2016
89.

Aberdeen Proving Ground Federal Credit Union records reflect that the

account holder of the account ending in 7176 is Zachary Buchta with the Buchta
Residence listed as the account holder address.
5.
90.

Previous Interview of Buchta

As part of a separate FBI investigation into a denial-of-service attack,

on or about July 17, 2014, Buchta was interviewed by FBI agents at the Buchta
Residence. During the interview, Buchta provided his mobile telephone number as
the same telephone number ending in 9229 as has been previously described. The
interview was prompted by a report received by the FBI alleging that an individual
50

named “Zach” residing at the Buchta Residence had been involved in a denial-ofservice attack. During the interview, Buchta denied any involvement with denial-ofservice attacks, and stated that he had been chatting online with a group of
individuals, but that Buchta eventually stopped associating with them.
91.

As part of a separate FBI investigation into swatting calls,29 on or about

November 5, 2015, Individual C30 was interviewed by the FBI in connection with
Individual A’s alleged involvement in making swatting calls. Individual A stated that
“Zach Buchta” was his/her friend and also responsible for making swatting calls.
Individual C stated that Zach Buchta lived at the Buchta Residence, and that Buchta
utilized the Twitter account @fbiarelosers and the moniker “Pein.” Individual C also
stated that Buchta was the “co-leader” of Lizard Squad. Individual C also stated that
a Facebook account he/she was questioned about was also used by an individual with
the moniker “vamp.”
92.

During the review of the search warrant results for @fbiarelosers, I

observed Twitter direct messages sent on or about November 6, 2015, at 5:56 AM
UTC from @fbiarelosers to another Twitter user which stated, “oh I also found out I
got snitched on by vamp so I cant have anything illegal or do anything illegal.”

The term “swatting” refers to false emergency calls placed to law enforcement agencies
typically alleging scenarios such as an active shooter at a residence. The purpose of the
“swatting” call is to incite a law enforcement response, often times a SWAT team, to the
targeted address.
29

30

Individual C was a minor at the time this interview was conducted.

51

J.

Identification of Bradley Jan Willem van Rooy as the User of
Uchiha and as an Operator of the Shenron Website

93.

According to records from Twitter, collected through subpoenas and a

search warrant, there were extensive logins to both @LizardLands and @UchihaLS
from the same IP address 86.89.127.163 (“the ‘163 IP Address”).31 The records also
reflected that the @LizardLands account was registered on or about January 28, 2015
from the ‘163 IP address. The records reflected that from on or about February 3,
2013, through on or about April 12, 2015, the email address associated with the
@UchihaLS account was lil_jon@hotmail.nl. On or about April 12, 2015, the email
address was changed to uchihals@mail.ru.
94.

The Twitter records also reflect the following direct communications by

@LizardLands in which the user indicated that he lived near a police station:
Date/Time (UTC)

From

To

2/1/15 10:47:57 PM

Twitter User #5

@LizardLands

2/1/15 10:48:09 PM

Twitter User

@LizardLands

2/1/15 10:50:08 PM

Twitter User #5

@LizardLands

2/1/15 10:50:37 PM

@LizardLands

Twitter User #5

2/1/15 10:50:51 PM

Twitter User #5

@LizardLands

2/1/15 10:50:55 PM

@LizardLands

Twitter User #5

2/1/15 10:51:17 PM

Twitter User #5

LizardLands

31

Direct Message
Feds lurkin, be careful
bro.
I could be an
informant
You make me wanna
start harassing twitch
streamers again
God etc follow you you
aint shit bruh
Lmao
Once the feds over
here ill throw my
laptop off my balcony
l0l
Eat the hard drive

Whois records reflected the IP address 86.89.127.163 to be associated with KPN, an
internet service provider located in the Netherlands.

52

2/1/15 10:51:19 PM

@LizardLands

Twitter User #5

2/1/15 10:51:32 PM

Twitter User #5

LizardLands

2/1/15 10:51:37 PM

@LizardLands

Twitter User #5

2/1/15 10:51:48 PM

@LizardLands

Twitter User #5

2/1/15 10:52:00 PM

Twitter User #5

@LizardLands

2/1/15 10:52:08 PM

@LizardLands

Twitter User #5

2/1/15 10:52:50 PM

@LizardLands

Twitter User #5

2/1/15 10:52:50 PM

Twitter User #5

@LizardLands

2/1/15 10:52:57 PM

@LizardLands

Twitter User #5

2/1/15 10:53:12 PM

Twitter User #5

@LizardLands

2/1/15 10:53:37 PM

@LizardLands

Twitter User #5

95.

Wouldn’t be the best
idea on second
thoughts
Just magnet it
Well there's a small
problem
Nearest fed to me atm
[at the moment] is
approx 50 meters l0l
LOL
Living above a police
station, they'll never
swat/raid me l0l
Even if they would
trace down my shit,
they’d leave the
address cuz of that
reason ^^
Lmao
they won’t take it
serious lol
ik they would think it
was a hoax
Yeah but if i look
outside my window
right now i can see
undercover cars etc
lmao

The Twitter records also reflect the following direct communications by

@UchihaLS:
Date/Time (UTC)

From

To

4/15/2015 10:41:06 AM

@UchihaLS

Twitter User #6

4/15/2015 10:41:11 AM

@UchihaLS

Twitter User #6

53

Direct Message
[photo sent via direct
message – see Figure 8]
Feds

Figure 8 – April 15, 2015 direct message photo from @UchihaLS

96.

Pursuant a mutual legal assistance request from the United States,

subscriber records obtained from the Netherlands for the ‘163 IP address reflect the
subscriber is an individual with the last name Van Rooy with a service address listing
a residence located in Leiden, the Netherlands (“the Leiden Address”).
97.

Netherlands authorities have confirmed that the Leiden Address backs

up to the parking lot of a police station. I have personally been in the parking lot of

54

this police station and found it to be the parking lot and building depicted in the above
photograph.
98.

According to records from Microsoft, collected through subpoena and a

search warrant, the lil_jon@hotmail.nl email account was logged into over 400 times
from the ‘163 IP address between November 2014 and November 2015. These records
also reflect an email message sent on or about August 2, 2015, from lil_jon@hotmail.nl
to lil_jon@hotmail.nl, which contained the photo of a Netherlands passport for
Bradley Jan Willem van Rooy. The same email also contained a photo of a bank
statement from Rabobank for a bank account ending in account number 4264 with
what appears to be an abbreviation of the Leiden Address listed for the account
address.
1.
99.

Investigation of PayPal Payments to Shenron

As previously stated, on or about February 20, 2016, at approximately

1:03 PM PST, @LizardLands tweeted: “PayPal Payments are now being accepted on
shenron.lizardsquad.org [Subject Domain 1], limited time!”
100.

PayPal records for an account associated with the email address

uchihals@mail.ru reflected that:
a.

The account was registered on or about May 22, 2015, from the

‘163 IP address, and the account holder is listed as Bradley van Rooy with the Leiden
Address listed as an address and an associated bank account at Rabobank with the
account number ending in 4264.

55

b.

There were over 400 logins to the account from the ‘163 IP address

between on or about May 22, 2015, and on or about March 4, 2016.
c.

The records also reflect a series of login and account

administration activity that occurred on or about February 20, 2016, immediately
preceding the @LizardLands tweet announcing the acceptance of PayPal payments
at 1:03 PM PST. This included an event at 12:46 PM PST in which the ‘163 IP address
was used to remove the Leiden Address from the account.
d.

On or about February 20, 2016, at approximately 1:01 PM PST

(two minutes prior to the tweet announcing the acceptance of PayPal), there was a
$1.00 payment made to the uchihals@mail.ru PayPal account from a PayPal account
associated with the email address JackMarrowz@outlook.com. PayPal records for the
JackMarrowz@outlook.com account reflect that it was logged into from the ‘163 IP
Address on or about February 20, 2016, at approximately 12:56 PM PST, and the
uchihaLS@mail.ru PayPal was logged into from the ‘163 IP Address on February 20,
2016 at approximately 12:58 PM PST.
e.

On or about February 20, 2016, at approximately 1:09 PM PST, a

payment of $19.99 was received with a description of “Add funds – 19.99 USD.”
Between the time of this payment, and on or about March 1, 2016, there were a total
of 46 additional payments received with a total value of approximately $1,046. The
majority of the payment amounts were observed to be consistent with the prices for
the packages listed on the Shenron website.
56

2.
101.

Access to the Shenron Website from ‘163 IP Address

The wiretap data also reflected that the ‘163 IP Address was used to

access the Shenron website and perform a variety of functions, including in part
reviewing customer support tickets and purchasing payment cards. The wiretap data
reflected that three different user accounts, “support” and “fox,” and “dragon,” were
used by the ‘163 IP Address. For example:
a.

On or about May 24, 2016, at 9:39 PM UTC, the ‘163 IP Address

accessed the Shenron website and logged into the account “dragon” and proceeded to
review an already purchased payment card.
b.

On or about May 24, 2016, at 9:40 PM UTC, the ‘163 IP Address

accessed the Shenron website and logged into the account “fox” and proceeded to
purchase a payment card. The account balance for “fox” was listed as $89,999.
c.

On or about May 27, 2016, between 7:58 PM UTC and 8:57 PM

UTC, the ‘163 IP Address accessed the Shenron website using the already logged in
account “fox” and proceeded to purchase approximately five payment cards.
d.

On or about May 29, 2016, at 2:54 AM UTC, the ‘163 IP Address

accessed the Shenron website using the already logged in “fox” account and proceed
to review the current stresser package for this account. The current package was
listed as having a twelve-month duration from April 2, 2016 through April 2, 2017
with a cost of $9,999. The listed attack length for the package was 18,000 seconds.

57

e.

On or about June 2, 2016, at 2:15 PM UTC, the ‘163 IP Address

accessed the Shenron website and logged into the account “support” and proceeded to
review and respond to open support tickets.
III.

SEIZURE OF THE DOMAIN NAMES
A.

Statutory Basis

102.

Title 18, United States Code, Sections 1030(i)(1)(A) and 1030(j) provides,

in relevant part, that any property used, or intended to be used, to commit or facilitate
an offense under Title 18, United States Code, Section 1030, is subject to criminal
forfeiture to the United States government. Section 1030(i)(2) further provides that
the “forfeiture of property under this section, any seizure and disposition thereof, and
any judicial proceeding in relation thereto, shall be governed by [21 U.S.C. § 853],
except for subsection (d) of that section.”
103.

To protect the ability of the United States to exercise its right of

forfeiture, Title 21, United States Code, Section 853(e), empowers courts to enter
restraining orders and injunctions to preserve the availability of property that is
subject to forfeiture under Section 853(a). However, if there is probable cause to
believe that the property to be seized is subject to forfeiture and that an order
pursuant to Section 853(e) may not be sufficient to assure its availability for
forfeiture, a district court may issue a warrant authorizing the seizure of such
property. 21 U.S.C. § 853(f). Section 853(f) provides that:
The Government may request the issuance of a warrant authorizing the
seizure of property subject to forfeiture under this section in the same
manner as provided for a search warrant. If the court determines that
58

there is probable cause to believe that the property to be seized would,
in the event of conviction, be subject to forfeiture and that an order
under subsection (e) may not be sufficient to assure the availability of
the property for forfeiture, the court shall issue a warrant authorizing
the seizure of such property.
B.

The Subject Domains

104.

There exists probable cause that the Subject Domains are property

used or intended to be used to commit or facilitate violations of Title 18, United States
Code, Section 1030(a)(5)(A). Moreover, given the nature of the Subject Domains and
the fact that they have been used to facilitate ongoing violations of the Subject
Offense by third parties, neither a restraining order nor an injunction is sufficient
to guarantee the availability of the Subject Domains for forfeiture and prevent
ongoing criminal activity. By seizing and locking the Subject Domains, the United
States will prevent third parties from using the Subject Domains to commit
additional crimes.
C.

Seizure Procedure

105.

Upon execution of the seizure warrants for the Subject Domains,

Public Interest Registry, the registry for the “.org” top-level domain, shall be directed
to restrain and lock the domains or otherwise suspend the Subject Domains,
pending transfer of all right, title, and interest in the domains to the United States
upon completion of forfeiture proceedings, to ensure that changes to those domains
cannot be made absent court order or, if forfeited to the United States, without prior
consultation by FBI.

59

IV.

CONCLUSION
106. Based on the above information, I respectfully submit that there is

probable cause to believe that Zachary Buchta, also known as “pein,” “@fbiarelosers,”
“@xotehpoodle,” and “lizard,” and Bradley Jan Willem van Rooy, also known as
“Uchiha,” “@UchihaLS,” “dragon,” and “fox,” have committed the Subject Offense
and that the Subject Domains constitute personal property used or intended to be
used to commit or facilitate the Subject Offense and are therefore subject to
seizure.
FURTHER AFFIANT SAYETH NOT.

____________________________
Eric T. Brelsford
Special Agent
Federal Bureau of Investigation

Subscribed and sworn
before me on September 23, 2016

Honorable Mary M. Rowland
United States Magistrate Judge

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