Case 1:15-cr-00115-PB Document 42 Filed 07/27/16 Page 1 of 30

UNITED STATES DISTRICT COURT
DISTRICT OF NEW HAMPSHIRE
UNITED STATES OF AMERICA

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v.

1:15-cr-00115-01-PB

RYAN J. VALLEE
____________________________________

SECOND SUPERSEDING INDICTMENT
The Grand Jury charges:
Background
1. At all times relevant to this indictment, defendant RYAN JUSTIN VALLEE, using
aliases that included “Seth,” “Seth Williams,” “Stephanie Williams,” “James,” and
“James McRow,” resided in the District of New Hampshire.
2. Yahoo! Inc. (“Yahoo!”) provided electronic mail (“e-mail”) and other electronic
communications services to users all over the world.
3. Google, Inc. (“Google”) provided electronic mail (“e-mail”) and other electronic
communications services to users all over the world.
4. AOL, Inc. (“AOL”) provided electronic mail (“e-mail”) and other electronic
communications services to users all over the world.
5. Facebook, Inc. (“Facebook”) provided social networking and other electronic
communications services to users all over the world.
6. Instagram, Inc. (“Instagram”) provided photograph sharing and other electronic
communications services to users all over the world.
7. Skype, Inc. (“Skype”) provided text, voice, and video communications to users all over
the world.
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8. Amazon, Inc. (“Amazon”) provided online merchant services to users all over the world.
Users stored in their Amazon account personally identifiable information that included
their name, address, and payment card information.
9. Pinger, Inc. (“Pinger”), which is based in California, provided free
“spoofing”/anonymizer text messaging services to users all over the world. By using
Pinger’s “textfree” messaging service, a user could select a different telephone number
and then send text messages, as well as photographs, that appeared to originate from that
“spoofed” number. This in turn allowed the user to disguise his true identity when
communicating with others. Using “textfree,” users can send text messages over the
internet to and from any internet-connected device, such as a laptop computer, iPod, or
cell phone. At all times relevant to this indictment, Pinger’s computer servers were
located in California and all of Pinger’s customers’ “textfree” communications traveled
through Pinger’s California-based servers.
10. At all times relevant to this indictment, persons whose identities are known to the Grand
Jury and known to the defendant but are identified herein as “Jane Doe A” through “Jane
Doe K,” were females, ranging in ages from approximately 15- to 19 years-old, who
resided in the District of New Hampshire, whereas beginning in or about 2012, Jane Doe
J moved out of New Hampshire and resided outside of the District of New Hampshire.
11. From in or about 2011 through in or about March 2016, VALLEE engaged in a computer
hacking and “sextortion” campaign designed to force numerous teenaged females, to
provide him with sexually explicit photographs of themselves. VALLEE employed a
variety of techniques to force the victims he targeted to comply with his “sextortionate”
demands. For example, VALLEE repeatedly accessed, without authorization (“hacked”

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into), and took control over, the victims’ online accounts. Once inside those hacked
accounts, VALLEE locked the victims out of their own accounts, he sometimes defaced
the contents of the accounts, and he sometimes used their stored payment account data to
purchase, without authorization, products of a sexual nature. In some instances,
VALLEE also obtained sexually explicit photographs of the victims and their friends and
distributed the sexually explicit photographs to others. With this backdrop, VALLEE,
disguising his true identity and using various aliases, repeatedly sent threatening
electronic communications to the victims, telling them that, unless they gave him
sexually explicit photographs of themselves, he would continue with the above-described
conduct. When most of the victims refused to comply with VALLEE’s demands and
begged him to leave them alone, VALLEE responded with threats to inflict additional
harm.
Hacking Into Online Accounts
12. From in or about 2011 through in or about March 2016, VALLEE repeatedly accessed,
without authorization (“hacked”), numerous teenaged females’ online accounts, including
their accounts with Facebook, Instagram, Yahoo!, Google, AOL, and Amazon.com. He
typically did this by guessing the answers to the security questions on these accounts,
which is a way for users to reset a forgotten password, and then changing the account
passwords.
13. Once VALLEE had hacked into the victims’ accounts, he took control over their
accounts, changed the passwords to their accounts, and prevented the victims from
accessing their own accounts. In several instances, VALLEE defaced their social
networking account pages by, for example, publishing embarrassing photographs and text

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on their Facebook pages. He also used the hacked accounts to communicate with other
victims.
Stealing Payment Card Information and Making Unauthorized Purchases of SexRelated Products
14. In one or more instances, from in or about 2012 through in or about November 2013,
VALLEE hacked into one or more victims’ accounts with the online merchant
Amazon.com, which stored the victims’ payment card information and shipping address.
15. VALLEE then used the victim’s payment card information stored on their Amazon.com
accounts to make unauthorized purchases of sex-related products, which he then had
shipped to the victims’ home addresses.
Sending Threatening Online Communications and Sexually Explicit Images
16. Beginning in or about 2010, VALLEE created accounts with one or more text message
“spoofing”/anonymizer services, including Pinger’s “textfree” service. VALLEE then
used Pinger’s “textfree” service and similar services to send text messages, and
photograph attachments, from “spoofed” phone numbers generated by those services, so
that the recipients would not know VALLEE’s true phone number or identity.
17. VALLEE also created accounts with Facebook, using aliases that included “Seth
Williams” and others, and used these Facebook accounts to send Facebook messages, and
photographic attachments, so that the recipients would not know VALLEE’s true
identity.
18. From approximately 2012-March 2016, using the “textfree” text message “spoofing”
services, his and his hacked victims’ Facebook accounts, and other methods of online

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communication, VALLEE sent multiple communications to numerous victims, which
travelled in interstate commerce.
19. In these communications, VALLEE, using various aliases, threatened the victims in an
attempt to force them to provide him with sexually explicit photographs of themselves.
20. For example, VALLEE notified the victims that he had hacked into their various online
accounts. He then demanded that they provide him with sexually explicit photographs of
themselves in order to regain access to and control of their hacked accounts. In some
cases, he threatened to continue hacking, to delete, and to deface their hacked accounts
unless the victims provided him with sexually explicit photographs of themselves. If the
hacked account was with the online merchant Amazon.com, VALLEE threatened to
make unauthorized purchases from the account unless the victim provided him with
sexually explicit photographs of themselves.
21. In multiple instances, VALLEE, again using various aliases, notified the victims that he
had obtained sexually explicit photographs of them and of their classmates. He then
threatened to distribute these sexually explicit photographs to others unless the victims
provided him with sexually explicit photographs of themselves. As proof that he could
carry out his threats, VALLEE sent the victims sexually explicit photographs of
themselves and their classmates, who were also teenaged females.
Jane Doe A
22. In or about August 2012, VALLEE hacked into the Facebook account and Google e-mail
account belonging to Jane Doe A, took control of the accounts, and locked Jane Doe A
out of her accounts.

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23. In or about August 2012, VALLEE sent multiple texts to Jane Doe A telling her that he
had obtained one or more sexually explicit photographs of her and had hacked her
accounts. As proof, VALLEE sent Jane Doe A one or more sexually explicit
photographs of Jane Doe A. VALLEE threatened Jane Doe A that he would distribute
the photograph(s) of Jane Doe A widely on the internet and continue hacking her
accounts unless she sent him additional sexually explicit photographs of herself.
24. For example, in a series of texts that VALLEE sent to Jane Doe A in or about August 2,
2012, VALLEE stated, “If you don’t want me to set that as your profile picture on
Facebook take your bra off . . . You have 15 minutes . . . I hacked your Facebook [sic] if
you don’t show me your tits I will set this as your profile picture [sic] nice pussy too girl.
You don’t have a choice. If I don’t see your tits by ten everyone will see your pussy.
Don’t make me do this [Jane Doe A’s first name]. I hacked you once I can hack you
again.”
25. In or about August 2012, VALLEE sent a text message to Jane Doe A’s sister, who was
also a teenaged female, which had as an attachment the same sexually explicit
photograph of Jane Doe A that VALLEE had previously sent to Jane Doe A.
26. In or about August 2012, VALLEE defaced Jane Doe A’s Facebook account, changing
her Facebook “profile” photograph to a photograph of Jane Doe A wearing a bikini.
27. In or about August 2012, VALLEE, having taken over Jane Doe A’s Facebook account,
used Jane Doe A’s Facebook identification to communicate online with others. Posing as
Jane Doe A, VALLEE sent Facebook messages to several of Jane Doe A’s Facebook
“friends.” VALLEE attempted to elicit personally identifiable information from her
friends.

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Jane Doe B
28. In or about July and August 2012, VALLEE hacked into the Facebook account and
Google e-mail account belonging to Jane Doe B, took control of the accounts, and locked
Jane Doe B out of her accounts.
29. In or about July and August July 2012, VALLEE sent Jane Doe B multiple texts
notifying her that he had hacked into her accounts and threatening to delete her accounts
unless she sent him compromising photographs of herself. He further warned Jane Doe B
that each day she delayed, he would demand that she remove an additional layer of
clothing. He stated that he would give her access to her online accounts only if she
complied with his demands.
30. For example, in a series of texts VALLEE sent to Jane Doe B on or about July 25-26,
2012, VALLEE stated, “Put jeans on and take a picture of how your butt fills them or
Facebook will be deleted [sic] don’t tell anyone! I am waiting. I am waiting. Do this or
I delete facebook. You have ten minutes. I hacked your Facebook and emails [sic] do
this or they will be deleted. Three minutes left. ONE MINUTE. Time is up. I read your
emails . . . I want a picture of your butt in jeans . . . I won’t stop until you do this [sic]
okay I have all of your email adresses [sic] hacked as well. Do we have a deal [sic].”
When Jane Doe B refused, VALLEE warned her, “Each day you procrastinate sending
this one layer of clothes will need to be removed.” VALLEE continued, “You need your
email for college. You have been hacked again. Hacked gmail again hehehe.”
VALLEE then stated, “Do you enjoy anal [sic]. I want to lick your pussy.”
31. For example, in a series of texts VALLEE sent to Jane Doe B on or about July 27, 2012,
VALLEE stated, “if you need your passwords to get back into your emails just text me

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for them. I was planning on getting naked photos of you and [first name of classmate of
Jane Doe B] but it is wrong to force someone to do this I repent for these crimes against
you . . . I regret doing this to all those other girls . . . it is wrong.” He later continued to
demand that Jane Doe B answer personal questions about herself and asked her, “Can
you tell [first and last name of Jane Doe G] to text me I want to give her password to her .
. . I have had her Facebook for three weeks.”
32. For example, in a series of texts VALLEE sent to Jane Doe B on or about July 28-29,
2012, after Jane Doe B asked him, “Are you trying to get on my facebook again,” he
responded, “I have to check something it will take two minutes I promise.” He repeated,
“To check something it will be real fast I will even tell you password . . . . Will you help
me? . . . Got in. If you corporated [sic] I would have been done but you were a bitch so
I locked you out. Do you want it back [sic] . . . Your password is . . . ” . . . .
33. For example, in a series of texts VALLEE sent to Jane Doe B on or about July 30, 2012,
VALLEE stated, “Talk to me. Have a conversation or I hack you . . . Have a
conversation with me,” and proceeded to ask her a series of personal questions. He
continued, “Just talk to me . . . or I will hack you . . . Don’t make me hack you toots . .
.” and again asked her personal questions, again stating, “Don’t make me hack you . . . I
will lock you out. Tell me . . . what color panties you have on . . . What color panties do
you have on? What color panties do you have on? What color panties do you have on?
What color panties do you have on? What color panties do you have on? How good
would that feel inside you. Hahah you are probably fingering yourself to it. I was a little
bit drunk and that is not my penis I googled it.”

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34. In or about July 30, 2012, VALLEE sent via text to Jane Doe B a sexually explicit
photograph that depicted a male’s genitals.
35. For example, in a series of texts VALLEE sent to Jane Doe B on or about August 1,
2012, VALLEE stated, “I want to date you. [First name of Jane Doe B] I want to date
you. I’m going to hack you again okay?” When Jane Doe B threatened to go to the
police, VALLEE responded, “I am not afraid of police [sic] they have been looking for
me for over a year,” and then demanded that Jane Doe B provided him with the cell
phone number of one of her classmates. VALLEE stated, “Look her up I need her
number. Will you help me. Do not make me hack you.”
36. In or about August 3, 2012, VALLEE sent via text to Jane Doe B a sexually explicit
photograph of Jane Doe A, with the message, “Guess who [sic] photo that is [sic]. I scare
myself. This is her. This could be yours.”
Jane Doe C
37. In or about April 2012, VALLEE hacked into the Facebook account and Yahoo! e-mail
account belonging to Jane Doe C, took control of the accounts, and locked Jane Doe C
out of her accounts.
38. In or about April 2012, in or about September 2012, and in or about January 2013,
VALLEE sent Jane Doe C multiple texts and other electronic communications
demanding that she send him sexually explicit photographs of herself.
39. In or about April 2012, September 2012, and January 2013, VALLEE sent Jane Doe C
multiple texts and other electronic communications telling her that he had one or more
photographs of her of a sexual nature. He threatened to distribute the photograph(s)
widely on the internet unless she sent him additional sexually explicit photographs of

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herself. As proof, VALLEE sent Jane Doe C a photograph that showed Jane Doe C’s
naked buttocks.
40. In or about April 2012, September 2012, and January 2013, VALLEE sent Jane Doe C a
series of texts and other electronic communications in which he notified Jane Doe C that
he had hacked into her Facebook and Yahoo! e-mail accounts and would give her access
to her online accounts only if she complied with his demands.
41. For example, in a series of texts VALLEE sent to Jane Doe C on or about April 16, 2012,
VALLEE stated “I need a naked pic of you.” When she refused, VALLEE stated, “I’m
just going to show your ass shots to [first name of a classmate of Jane Doe C’s]. Send me
a picture. Your friends did. [First and last names of four of Jane Doe C’s classmates,
including Jane Doe E and Jane Doe H] and more . . . If you don’t send me a nude by 8,
Im [sic] sending this picture to people and uploading them to Facebook.” When Jane Doe
C again refused, VALLEE stated, “Now take a naked picture. Okay fine. Im [sic]
uploading your ass pix to your facebook.” Jane Doe C then warned him that she would
contact the police and that he would go to jail for “kid pornography,” and VALLEE
responded, “Ha ha, calling the cops won't stop your friends from seeing. . . They can't
find me. I already went through this with [first and last name of Jane Doe C’s classmate,
Jane Doe H].” When Jane Doe C threatened to tell her mother, VALLEE responded,
“Trust me, I made sure I am untraceable. Just one picture [first name of Jane Doe C] and
I will end this. Send it . . . I just want one full frontal nude . . . Same deal I made with
[first name of Jane Doe H]. I will leave you alone after. . . Just one picture.” When Jane
Doe C begged him to “get off my FB [Facebook page],” he responded, “Send me a naked

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picture . . . As soon as I get a nude of you. Take your clothes off. Get fucking naked on
camera. . . . I’m going to have fun fucking you this summer.”
42. For example, in a series of Facebook messages that VALLEE sent to Jane Doe C on or
about September 24, 2012, VALLEE stated, “Im [sic] going to add [first name of Jane
Doe C’s mother] if you don’t talk to me. Im [sic] showing them your nude photos . . . .
[Im] sending friend requests to your friends . . . Last chance to talk to me before I add
your mommy . . . Do I have to add [first name of Jane Doe C’s mother].” VALLEE
continued, “I sent your ass pictures to a few people don’t make me show more. [First
name of Jane Doe C’s mother’s] is next. Show me those breasts.” VALLEE stated, “Get
naked. Do you want this to end. Show me. I am currently in New Hampshire [sic] I
know you live [inserting details about where Jane Doe C lived] and you work at
[company name of Jane Doe C’s employer]. Show me your nipples. [First name of Jane
Doe C] show me now to end this or I will never leave you alone . . . Don’t make this hard
on your self [sic]. I just sent your mom a friend request.”
43. For example, in a series of texts that VALLEE sent to Jane Doe C on or about January
19, 2013, VALLEE stated, “Send me the photo you promised and I shall return facebook
and yahoo too [sic] you . . . Do you want facebook and yahoo back? [First name of Jane
Doe C.] Send me my photo and you can have everything back . . . Your password is
fuckmehard69. Send me the promised photo and this will end.”
Jane Doe D
44. In or about April 2012, VALLEE hacked into the Facebook account belonging to Jane
Doe D, took control of the account, and locked Jane Doe D out of her account.

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45. In or about April 2012, VALLEE sent Jane Doe D multiple texts demanding that she send
him one or more sexually explicit photographs of herself. He threatened to post one or
more compromising photographs of Jane Doe D on her hacked Facebook page unless she
sent him the sexually explicit photograph. He also threatened to distribute a sexually
explicit photograph of Jane Doe D’s classmate, Jane Doe H. As proof, VALLEE then
sent Jane Doe D a sexually explicit photograph of a classmate of Jane Doe D, Jane Doe
H, who was also a teenaged female.
46. For example, in a series of texts VALLEE sent to Jane Doe D on or about April 23, 2012,
VALLEE stated “Not until I see [you] naked. What if I set this sexy g string picture as
[your] facebook profile picture. You have ten minutes. If I don’t have a naked picture of
you by 12:10 everyone will see this [an attachment that contained one or more sexually
explicit photographs of Jane Doe D’s classmate, Jane Doe H].”
Jane Doe E
47. In or about 2012, Jane Doe E was locked out of, and unable to access, her accounts with
her cell phone service provider and with her e-mail provider Google.
48. In or about April 2012, VALLEE sent multiple texts to Jane Doe E, demanding that she
provide him with a copy of a text she had recently received and notifying Jane Doe E that
he had obtained one or more sexually explicit photographs of her. VALLEE threatened
to send the sexually explicit photographs to others unless Jane Doe E sent him the text
message and sent him additional sexually explicit photographs of herself. VALLEE also
demanded that she perform specified sex acts for him while he listened over the phone.
49. For example, in a series of texts VALLEE sent to Jane Doe E on or about April 29, 2012,
VALLEE stated, “[first name of Jane Doe E] what is the text you just got . . . answer me

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or I will spread your nudes . . . Show me your boobs one last time . . . Keep ignoring me
and I will spread these nudes . . . Don’t make me spread these.” He continued, “Do this
and I will leave you alone forever.” VALLEE further stated, “Okay [first name of Jane
Doe E] look I am calling you so finger yourself on the phone or I sen . . . [sic] . . . Make
sure your phone is on speaker beside your head . . . I will stop after you do this . . . Only
if you finger yourself on the phone . . . Will you finger yourself . . . Answer me”
50. As proof, VALLEE sent via text to Jane Doe E one or more sexually explicit photographs
of Jane Doe E.
Jane Doe F
51. In or about January 2013, VALLEE hacked into the Amazon.com account and Facebook
account belonging to Jane Doe F, took control of her Facebook account, and locked Jane
Doe F out of her Facebook account.
52. In or about January 2013, after hacking into Jane Doe F’s Amazon.com account,
VALLEE used, without authorization, Jane Doe F’s payment card information that was
electronically stored in her Amazon.com account. He purchased, and shipped to Jane
Doe F’s home address, merchandise of a sexual nature. This included items called a
“remote rick vibrating dildo” and “California exotics waterproof delights blue jelly.”
VALLEE also purchased from Jane Doe F’s Amazon.com account several adult
entertainment videos, available to download or watch on demand.
53. In or about January 2013, VALLEE sent Jane Doe F a series of texts in which he notified
Jane Doe F that he had hacked into her Facebook account, and he would give her access
to her account only if she sent him sexually explicit photographs of herself. He also
stated that knew her payment card number and would buy items of a sexual nature from

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her account unless she sent him sexually explicit photographs of herself. As proof, he
sent her a text containing the last four digits of her payment card number.
54. For example, in a series of texts VALLEE sent to Jane Doe F on or about January 22,
2013, VALLEE stated, “I want a nude photo . . . I will trade you your facebook for nude
photo. I will leave your facebook alone if you send me a nude photo. Do we have a
deal? [Jane Doe F’s first name] send me the photo and you can have facebook back.”
VALLEE continued, “trade photo for facebook . . . a nude photo [sic] photo for facebook.
Deal? Send photo. The sooner you show me the sooner facebook will be yours.”
VALLEE then stated, “Do you want your facebook [sic]. Do you want your facebook.
[sic]. Are you going to take the photo? Send nude photo get facebook back. Don’t send
nude photo debit card is charged. Ends in 8123. Amazon. Send the photo. $200 will be
charged if photo is not sent by 10:30. Thirty dollars was just spent [sic] you have until
10:30. You have one minute. I am charging your debit card now. Send a naked photo
and I won’t [sic] hope you enjoy vibrators you’re getting alot [sic]” VALLEE continued,
“Send me a nude photo [sic] I will cancel the orders I made and return facebook . . . Get
Naked.”
55. In or about January 2013, VALLEE, having hacked into and taken control over Jane Doe
F’s Facebook account, posted onto Jane Doe F’s Facebook page a receipt from
Amazon.com that indicated that Jane Doe F had purchased a vibrator for herself.
VALLEE, using Jane Doe F’s Facebook account and posing as Jane Doe F, also sent
Facebook messages to Jane Doe F’s Facebook “friends” that stated that Jane Doe F
purchased a vibrator.
Jane Doe G

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56. In or about October 2011, VALLEE sent Jane Doe G numerous Facebook messages
stating, “show me your tits,” and informing Jane Doe G that he masturbated to her
photographs, that her “ass made [his] dick hard,” and that “[his] hobbie [sic] is
masturbating [sic] im [sic] addicted.”
57. In or about July 2012, VALLEE hacked into the Facebook account and Google e-mail
account belonging to Jane Doe G, took control of the accounts, and locked Jane Doe G
out of her accounts.
58. In or about July 2012, VALLEE sent multiple texts to Jane Doe G telling her that he
would delete her Facebook account unless she told him the phone number of one of her
friends. VALLEE then demanded that Jane Doe G send him a suggestive photograph of
herself, and, in exchange, he would return access to her various online accounts.
59. For example, in a series of texts that VALLEE sent to Jane Doe G on or about July 9,
2012, VALLEE stated “What is [Jane Doe G’s female friend’s first and last name]
number . . . Tell me her number or I will delete your facebook.” VALLEE demanded,
“Okay show butt and I tell you passwords for all of your online accounts. Will you do
that [sic].” When Jane Doe G begged him to leave her alone, VALLEE responded, “Now
show me. . . . I will delete your facebook. Sorry this is the only way. Will you show me
[sic]. What will you do [sic]. Make a list of what you’re willing to do.”
60. At this point during the texting exchange, Jane Doe G provided her cell phone to a law
enforcement officer and consented to allow the law enforcement officer to assume Jane
Doe G’s identity and continue to communicate with VALLEE to gather more
information.
Jane Doe H

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61. Over the course of several months in or about 2011-2012, VALLEE sent multiple texts
and other electronic communications to Jane Doe H, demanding that she send him
sexually explicit photographs of herself and warning her that he would not leave her
alone until she did so.
62. On or about March 9, 2012, Jane Doe H complied with VALLEE’s repeated demands
and sent him via text a sexually explicit photograph of herself, along with the attached
text message: “have a nice life douchebag. I hate you.”
63. In or about September 2012, VALLEE created a Facebook page, using a Facebook
account name that was virtually identical to Jane Doe H’s real Facebook account name,
with one difference: Jane Doe H’s last name had one letter misspelled. On the fake Jane
Doe H Facebook page that VALLEE created, VALLEE posted sexually explicit
photographs of Jane Doe H.
64. In or about September 2012, VALLEE sent multiple texts to Jane Doe H, demanding that
she provide him with her e-mail address, notifying her that he had obtained sexually
explicit photographs of her, and notifying her that he had set up a fake Facebook page for
her. He threatened to send the sexually explicit photographs to others unless she
complied with his demands. VALLEE then sent Jane Doe H one or more sexually
explicit photographs of Jane Doe H. He also sent Jane Doe H the account name of the
fake Facebook page that VALLEE had created.
65. For example, in a series of texts VALLEE sent to Jane Doe H on or about September 2930, 2012, VALLEE stated, “[nickname of Jane Doe H] tell me your email I leave you
alone. [inserting link with one or more sexually explicit photographs of Jane Doe H].
Perhaps I will send these photos to [first name of male acquaintance of Jane Doe H’s] if

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you don’t answer. Do you want this to end . . . Search for [first name and last name of
Jane Doe H, with one letter of last name misspelled] on facebook. I sent your boyfriend a
friend request with it. Hegehe. Tell me your email I will delete this fake profile.
Perhaps I shall add your teachers. [First name and last name of acquaintance of Jane Doe
J’s] accepted your friend request. Do you want me to take it down [sic].”
66. For example, in or about March 20, 2013, VALLEE sent a series of Facebook messages
to Jane Doe H, with attachments containing sexually explicit photographs of Jane Doe H.
VALLEE stated, “I am posting these around bathrooms and locker room if you don’t
skype. I am sending to [first name of male acquaintance of Jane Doe H] right now. I
know you are reading these messages. Do I have to send your photos to everyone? Go
on skype . . . You showed me your tits. Show me on skype and I will stop. Okay no
more talking to you, no showing people. Show me on skype [first name of Jane Doe H]
Please.”
Jane Doe I
67. In or about March 2011, VALLEE sent multiple Facebook messages to Jane Doe I
asking her to send him sexually explicit photographs of herself.
68. In or about March and April 2012, VALLEE sent multiple texts to Jane Doe I, notifying
her that he had obtained sexually explicit photographs of several of her friends and
offering to send them to Jane Doe I in exchange for sexually explicit photographs of Jane
Doe I. As proof, VALLEE sent one or more texts to Jane Doe I containing dozens of
sexually explicit photographs of other teenaged females.
69. For example, in a series of texts VALLEE sent to Jane Doe I on or about March 28, 2012,
VALLEE stated “[First name of Jane Doe I,] if I give you alott [sic] of naked pictures of

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[first names of Jane Doe A, Jane Doe E, and two other classmates of Jane Doe I] can I
have 4 or 5 of you? Do we have a deal [first name of Jane Doe I]? That picture is just a
sample I have alot [sic] more.” As proof, VALLEE texted to Jane Doe I a suggestive
photograph of Jane Doe E.
70. For example, in a series of texts VALLEE sent to Jane Doe I on or about April 16, 2012,
VALLEE claimed to be Jane Doe C, who was a classmate of Jane Doe I’s. When Jane
Doe I stated that she did not believe that he was Jane Doe E, VALLEE continued,
“Sending dirty pics. Now do you believe me.” He continued, “Your turn to send nudes
of yourself. Omg! [First name of Jane Doe I]!!!! Your [sic] so hot!! Can I have a naked
pic gurl [sic]. Sex me.”
71. On or about April 16, 2012, VALLEE texted to Jane Doe I approximately 30-40 sexually
explicit photographs of other teenaged females, including Jane Doe E, many of whom
were classmates of Jane Doe I.
Jane Doe J
72. In or about March-April 2012, VALLEE hacked into the Facebook account, Google email account, AIM instant messaging account, and Sprint cell phone account belonging to
Jane Doe J, took control of the accounts, and locked Jane Doe J out of her accounts.
73. In or about March 2012-March 2016, while Jane Doe J resided outside of the state of
New Hampshire, VALLEE sent multiple texts and other online communications to Jane
Doe J, notifying her that he had hacked into her accounts and stating that he would give
her access to the accounts only if she gave him sexually explicit photographs of herself.
VALLEE also notified Jane Doe J that he had obtained sexually explicit photographs of
her and of her classmates, demanded that Jane Doe J send him sexually explicit

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photographs of herself, and threatened to distribute the sexually explicit photographs to
others if Jane Doe J did not comply. As proof, VALLEE sent Jane Doe J a semi-nude
photograph of Jane Doe J and one or more sexually explicit photographs of Jane Doe J’s
classmates, many of whom were teenaged females.
74. For example, in a series of text messages VALLEE sent to Jane Doe J in or about April
2012, VALLEE stated, “I want that picture. I’ll trade you your Facebook for a picture . .
. send some sexy pics to email . . . I just want to see you from the front . . . ” When Jane
Doe J threatened to go to the police, VALLEE responded, “It’s a text free number it is an
app. I piggyback off of peoples [sic] wifi.” VALLEE continued, “I will give [your
accounts] back to you just pleaseee [sic] let me see your boobs . . . Please [nickname of
Jane Doe J] if you show me I will give you all of your accounts back . . . I want to see the
front please . . . if it’s in your Inbox tomorrow morning you will have your accounts back
. . . I just want one picture [nickname of Jane Doe J] then you will have your accounts
back . . . im [sic] desperate to see . . . you will have all 3 accounts back . . . [confirming
her Facebook and email accounts] and aim. And sprint so 4 actually.” VALLEE
continued, “Just send one. [Nickname of Jane Doe J] this is the only way . . . If you don’t
send one you will never get these back . . . Just take a picture of your tits to end this
otherwise I might upload this as your profile pic on fb [Facebook]. Just show me the
front. If you send the new pic to your email you have til 6:30. . . . Just let me look at your
nipples . . . at least I’m not fucking you I just want it to help me masturbate.” When Jane
Doe J continued to refuse, to beg him to leave her alone, and to threaten to inform the
police, VALLEE responded, “Well everyone on Facebook will see this sexy photo then
because I only want to see you . . . Just show me your tits and your life won’t have to get

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ruined I want to study your nipples . . . just get nakeddd [sic] There’s no need to let your
life be destroyed when you can save everything by letting me check out your nips . . .
please send me a naked picture . . . You will let me see if you want your bills paid, want
to talk to your friends etc. . . I will go online and have your phone disconnected [listing
Jane Doe J’s account password to her cell phone account] . . .”
75. For example, on or about June 21, 2013, having hacked into the Facebook account of one
of Jane Doe J’s friends, Jane Doe K, VALLEE sent a series of Facebook messages from
the hacked account to Jane Doe J. VALLEE stated, “[nickname of Jane Doe J] I have
just hacked another facebook profile. This is your last chance, show me your tits or I
shall spread all of these nude photos all over the internet. Only you can stop me. The
only way is to show me those boobs. How many people need to suffer because you
won’t do this simple task? Show me now and I will stop. Do I need to send more?
Don’t ruin there [sic] lives for what you wont [sic] do . . . You have until midnight.”
76. Along with these Facebook messages, VALLEE then sent to Jane Doe J a semi-nude
photograph of Jane Doe J, and sexually explicit photographs of three of her classmates,
Jane Doe A, Jane Doe E, and Jane Doe H, who were also teenaged females.
77. For example, on or about February 12-13, 2016, VALLEE, after again hacking into the
Facebook account of Jane Doe K, sent a series of Facebook messages from the hacked
account to Jane Doe J that stated, “Can I lose my virginity to you [sic] Remember we
talked on here along [sic] time ago.” VALLE asked to meet Jane Doe J in person, and
said, “If I tell you who I am would you consider letting me lose my virginity to you?”
When Jane Doe J reminded him that “you’ve threatened me, on a number of occasions,”

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VALLEE stated, “I’m so sorry [nickname of Jane Doe J] I will never hurt you. I know I
said horrible things to you im so sorry Will you give me one kiss?”
78. On or about March 12-16, 2016, VALLEE, again using the same hacked Facebook
account of Jane Doe K, sent a series of Facebook messages from the hacked account to
an undercover law enforcement agent. The undercover agent, acting with Jane Doe J’s
permission, was posing as Jane Doe J and using her Facebook account to communicate
with VALLEE. In the messages to the undercover agent, who VALLEE believed to be
Jane Doe J, VALLEE admitted that he had previously hacked into Jane Doe J’s accounts
“a few years ago.” VALLEE then offered to reveal his name “if you show me your butt
one last time to prove your [sic] not having cops look at this right now. I still have the
one you sent me before . . . What if I tell you my name . . . and you show me your butt as
a reward? Deal? . . . Would you be willing to finally let me see you butt with no panties
if I do?” VALLEE, whose middle name is Justin, also told the undercover agent that he
had graduated from Belmont High School in 2012, lived in New Hampshire, and his
name was “Justin.”
Jane Doe K
79. In or about June 2013-March 16, 2016, VALLEE repeatedly hacked into the Facebook
account belonging to Jane Doe K. He obtained information from that account, including
access to non-public portions of Jane Doe K’s Facebook account and information about
Jane Doe K and her friends and acquaintances. VALLEE repeatedly used Jane Doe K’s
hacked Facebook account to send threatening communications and sexually explicit
photographs to other victims and to an undercover law enforcement agent posing as a
victim.

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 Case 1:15-cr-00115-PB Document 42 Filed 07/27/16 Page 22 of 30

COUNTS ONE THROUGH THIRTEEN
18 USC § 875(d)
(Interstate Threats as to Jane Doe A, Jane Doe B
Jane Doe C, Jane Doe D, Jane Doe E, Jane Doe F, Jane Doe G, Jane Doe H, and Jane
Doe J)
80. The Grand Jury re-alleges and incorporates by reference paragraphs 1-79 of this
Indictment and further charges that:
On or about the dates set forth below, in the District of New Hampshire and elsewhere,
defendant
RYAN J. VALLEE,
with intent to extort from any person, namely Jane Doe A, Jane Doe B, Jane Doe C, Jane
Doe D, Jane Doe E, Jane Doe F, Jane Doe G, Jane Doe H, and Jane Doe J, as set forth
below, a thing of value, namely, sexually explicit images of Jane Doe A, Jane Doe B,
Jane Doe C, Jane Doe D, Jane Doe E, Jane Doe F, Jane Doe G, Jane Doe H, and Jane
Doe J, transmitted in interstate commerce a communication containing a threat to injure
the property, namely, to delete, deface, or make purchases from their online accounts, and
to injure the reputation of the addressee and of another, namely, to widely distribute
sexually explicit photographs of the addressee and of another.
All in violation of Title 18, United States Code, Section 875(d).
Count
Number
1

Victim’s Name
Jane Doe A

Type and Approximate Date(s) of
Electronic Communications Transmitted
Texts on August 2, 2012

2

Jane Doe B

Texts on July 25, 2012

3

Jane Doe C

Texts on April 16, 2012

4

Jane Doe C

Facebook messages on September 24, 2012

5

Jane Doe C

Texts on January 19, 2013

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6

Jane Doe D

Texts on April 23, 2012

7

Jane Doe E

Texts on April 29, 2012

8

Jane Doe F

Texts on January 22, 2013

9

Jane Doe G

Texts on July 9, 2012

10

Jane Doe H

Texts on September 29, 2012

11

Jane Doe H

Facebook messages on March 20, 2013

12

Jane Doe J

Texts in March-April 2012

13

Jane Doe J

Facebook messages on June 21, 2013

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 Case 1:15-cr-00115-PB Document 42 Filed 07/27/16 Page 24 of 30

COUNT FOURTEEN
18 USC §§ 1030 (a)(2)(C), (c)(2)(B)
(Computer Fraud and Abuse as to Jane Doe F)
81. The Grand Jury re-alleges and incorporates by reference paragraphs 1-79 of this
Indictment and further charges that:
On or about January 22, 2013, in the District of New Hampshire and elsewhere,
defendant
RYAN J. VALLEE,
intentionally accessed a computer, namely Amazon’s computer associated with Jane Doe
F’sAmazon.com online account, without authorization and exceeded authorized access,
and thereby obtained information from any protected computer, namely a server of
Amazon, and the offense was committed in furtherance of any criminal and tortious act in
violation of the laws of the United States and any State, namely wire fraud in violation of
18 U.S.C. § 1343 and interstate threats in violation of 18 U.S.C. § 875.
All in violation of Title 18, United States Code, Section 1030(a)(2)(C), (c)(2)(B).

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COUNTS FIFTEEN THROUGH TWENTY-TWO
18 USC § 1030(a)(7)
(Computer Fraud and Abuse as to Jane Doe A, Jane Doe B,
Jane Doe C, Jane Doe D, Jane Doe F, Jane Doe G, and Jane Doe J)
82. The Grand Jury re-alleges and incorporates by reference paragraphs 1-79 of this
Indictment and further charges that:
On or about the dates set forth below, in the District of New Hampshire and elsewhere,
defendant
RYAN J. VALLEE,
with intent to extort from any person a thing of value, namely, sexually explicit images,
transmitted in interstate commerce a communication containing a threat to cause damage
to a protected computer; a threat to obtain information from a protected computer without
authorization and in excess of authorization and to impair the confidentiality of
information obtained from a protected computer without authorization and by exceeding
authorized access; and a demand and request for a thing of value, namely sexually
explicit images, in relation to damage to a protected computer, where such damage was
caused to facilitate the extortion.
All in violation of Title 18, United States Code, Section 1030(a)(7).
Count
Number

Account
Holder
Victim Name

Service Provider Account(s)
Threatened

Jane Doe A

Type and Approximate
Date of Electronic
Communication
Transmitted
Texts on August 2, 2012

15
16

Jane Doe B

Texts on July 25, 2012

17

Jane Doe C

Texts on April 16, 2012

Facebook account and
Google account
Facebook account

18

Jane Doe C

Texts on January 19, 2013

25

Facebook account

Facebook account and Yahoo!
account

 Case 1:15-cr-00115-PB Document 42 Filed 07/27/16 Page 26 of 30

19

Jane Doe D

Texts on April 23, 2012

Facebook account

20

Jane Doe F

Texts on January 22, 2013

21

Jane Doe G

Texts on July 9, 2012

Amazon account and
Facebook account
Facebook account

22

Jane Doe J

Texts in March-April 2012

26

Facebook account, AIM
account, Google account, and
Sprint account

 Case 1:15-cr-00115-PB Document 42 Filed 07/27/16 Page 27 of 30

COUNTS TWENTY-THREE THROUGH THIRTY
18 USC § 1028A
(Aggravated Identity Theft as to Jane Doe A, Jane Doe B,
Jane Doe C, Jane Doe D, Jane Doe F, Jane Doe G, Jane Doe J)
83. The Grand Jury re-alleges and incorporates by reference paragraphs 1-79 of this
Indictment and further charges that:
On or about the dates set forth below, in the District of New Hampshire and elsewhere,
defendant
RYAN J. VALLEE,
during and in relation to a felony violation enumerated in 18 U.S.C. § 1030 as charged
above in Counts 14 through 22 knowingly transferred, possessed, and used, without
lawful authority, a means of identification of another person, namely, the account log-in
credentials of the individuals described below, as well as the account log-in credentials
and the payment card information of the individual described as Jane Doe F below,
All in violation of Title 18, United States Code, Section 1028A(1).

Count
Number

Account
Holder
Victim
Name

Related to Unauthorized
Access to Service Provider
Account

Related
Count

Jane Doe A

Approximate
Date of
Possession and
Use of Victim’s
Means of
Identification
August 2, 2012

23

Facebook account

15

24

Jane Doe B

July 25, 2012

16

25

Jane Doe C

April 16-24, 2012

Facebook account and
Google account
Facebook account

26

Jane Doe C

January 19, 2013

Facebook account and Yahoo!
account

18

27

17

 Case 1:15-cr-00115-PB Document 42 Filed 07/27/16 Page 28 of 30

27

Jane Doe D

April 23, 2012

Facebook account

19

28

Jane Doe F

January 22, 2013

14, 20

29

Jane Doe G

July 9, 2012

Facebook account and
Amazon account
Facebook account

30

Jane Doe J

March-April 2012

Facebook account, AIM
account, Google account, and
Sprint account

22

28

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 Case 1:15-cr-00115-PB Document 42 Filed 07/27/16 Page 29 of 30

COUNT THIRTY-ONE
18 USC § 2261A(2)(B)
(Cyberstalking as to Jane Doe J)
84. The Grand Jury re-alleges and incorporates by reference paragraphs 1-79 of this
Indictment and further charges that:
On or about March 2012-March 2016, in the District of New Hampshire and elsewhere,
defendant
RYAN J. VALLEE,
with the intent to harass and intimidate, used an interactive computer service and an
electronic communications service and electronic communication system of interstate
commerce, and any other facility of interstate and foreign commerce, specifically text
message and Facebook message, to engage in a course of conduct that caused, attempted
to cause, and would be reasonably expected to cause substantial emotional distress to
Jane Doe J, in violation of Title 18, United States Code, Section 2261A(2)(B).

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Dated: July 27, 2016
TRUE BILL
/s/ Foreperson
Grand Jury Foreperson
EMILY GRAY RICE
United States Attorney
By: /s/ Arnold H. Huftalen
Arnold H. Huftalen
Assistant U.S. Attorney
/s/ Mona Sedky
Mona Sedky
Senior Trial Attorney
U.S. Department of Justice

30