CASE Document 33 Filed 09/19/17 Page 1 of 3 UNITED STATES DISTRICT COURT DISTRICT or MINNESOTA UNITED STATES OF AMERICA, SUPERSEDING INDICTMENT Plaintiff, 18 U.S.C. 1030(a)(5)(A) Oil n40 PSSIDTS v. CHRISTOPHER VICTOR GRUPE, Defendant. THE UNITED STATES GRAND JURY CHARGES THAT: 1. At all times relevant to this Indictment, defendant CHRISTOPHER VICTOR GRUPE was a resident of the State of Minnesota. From in or about September 2013 until on or about December .15, 2015, defendant was employed as an IT professional working for Canadian Paci?c Railway in Minnesota. 2. On or about December 3, 2015, GRUPE was suspended for insubordination by Canadian Paci?c after getting into a verbal altercation with his supervisor. 3. On December 15, 2015, GRUPE was noti?ed by Canadian Paci?c that he was going to be ?red. At request, he was permitted to resign. GRUPE submitted a letter to Canadian Paci?c via email on December 15, 2015 indicating that he was resigning and that his resignation was effective that same day. In his letter, GRUPE . indicated that he would return all company property to the Canadian Paci?c of?ce in Minneapolis, Minnesota. 4. On December 17, 2015, before returning his company-issued laptop computer, GRUPE used the laptop to access Canadian Paci?c?s computer network. Once SEP 1 9 20!? us. DISTRIQTGOLI - CASE Document 33 Filed 09/19/17 Page 2 of 3 United States v. Christopher Victor Grune. Criminal File No. 11-90 on the network, GRUPE deleted data, including! deleting some system administrator accounts entirely and changing passwords for other system administrator accounts. GRUPE also attempted to delete logging information on the Canadian Paci?c computer network that would have revealed his activity. 5. Later in the day on December 17, 2015, GRUPE returned the company? issued lapt0p computer to canadian Paci?c. Before returning the computer, GRUPE wiped all data from the hard-drive. 6. On or about January 6, 2016, Canadian Paci?c began experiencing network problems, which Canadian Paci?c IT staff attempted to correct. Because GRUPE had deleted some system administrator-accounts and changed passwords to other system administrator accounts, no one at Canadian Paci?c was able to access a critical portion of the network. Canadian Paci?c began an incident investigation, which included hiring an outside computer security company to assist in identifying and correcting the problem. On January 7, 2016, Canadian Paci?c was able to restore the system administrator accounts through a process that resulted in a network outage and thereafter regained system administrator access to the computer network. A subsequent investigation by Canadian Paci?c IT staff and the outside computer security company hired by Canadian Paci?c concluded that GRUPE had deleted system administrator accounts, changed passwords for system administrator accounts, and wiped network logs that recorded his activities. CASE Document 33 Filed 09/19/17 Page 3 of 3 United States v. Christopher Victor Gruoe. Criminal File No. 11-90 (Intentional Damage to a Protected Computer) On or about December 17, 2015, in the State and District of Minnesota, the - defendant, CHRISTOPHER VICTOR GRUPE, did knowingly and without authorization cause the transmission of programs, code, and commands, and as a result of such conduct, intentionally caused damage to protected computers, and as a result Iof such conduct, the defendant caused loss to Canadian Paci?c during the period from December 17, 2015 to December 17, 2016, of an aggregate. value of more than $5,000.00, all in violation of Title 18, United States Code, Sections 1030(a)(5)(A) and A TRUE BILL ACTING UNITED STATES ATTORNEY FOREPERSON