Case 1:17-cr-20648-RNS Document 1 Entered on FLSD Docket 09/01/2017 Page 1 of 17 UN ITED STA TE S D ISTR ICT CO UR T SO U TH ER N D ISTR ICT O F FL O RID A No. /p-r)'-/Jz:/-Ty UN ITED STA TE S O F A M ER ICA V. GM uV AL LE RIU S, a/k/a, FRAN CISC O R .M A D ERA L A SSISTA N T UN ITED STATES A TTORN EY Fla.Bar.N o.41481 99 N .E.4th Street M iam i,Florida 33132-211l TEL (305)961-9159 FAX (305)530-7976 francisco.maderal@ usdoj.gov Case 1:17-cr-20648-RNS Document 1 Entered on FLSD Docket 09/01/2017 Page 2 of 17 AO 91(Rev.08/09) CriminalComplaint U NITED STATESD ISTRICT C OURT forthe Southern DistrictofFlorida United StatesofAmerica ) ) V. GALVALLERIUS,a/k/a,''OXYM O NSTER,'' . ) casexo. j)-my-o5p//-rp ) ) C RIM IN A L CO M PLA IN T 1,thecomplainantin thiscase,statethatthefollowing istruetothebestofmy knowledgeandbelief. Onoraboutthedatets)of Southern Districtof 3/2015-8/2017 inthecountyof Florida ,thedefendantts)violated: Code Section Title 21,United StatesCode, Miami-Dade inthe OffenseDescri ption Conspiracy to Distribute Controlled Substances Sections846& 841(b)(1)(a) Thiscrim inalcomplaintisbased on these facts: SEE ATTACHED AFFIDAVIT. W Continuedontheattachedsheet. Comp ainant' ssignature Austin D.l-ove S/A DEA Printednameand title Swornto beforeme and signed in my presence. Date: City and state: 1 Qî Miam i,Florida Judge'ssignature Jonat n Goodman,U.S.Magistrate Judge Printednameand title Case 1:17-cr-20648-RNS Document 1 Entered on FLSD Docket 09/01/2017 Page 3 of 17 A FFID A V IT 1,AUSTIN D.LOVE,SpecialAgentwiththeDnlgEnforcementAdministration(DEA), being tirstduly sworn,hereby depose and state as follow s: INTRODUCTION Thisapplication in furtheranceofan investigation workedjointly with theFederal Bureau of lnvestigations (FB1), the Internal Revenue Service (lRS), Homeland Security Investigations(HS1),andtheUnitedStatesPostallnspection Service(USPIS). 2. I am an investigative or law enforcem entofticer of the U nited States w ithin the meaningofSection 251047)ofTitle18oftheUnitedStatesCode.Thatis,lam an officerofthe United States w ho is em pow ered by 1aw to conduct investigations of,and to m ake arrests for, offensesenumerated in Title 18,United StatesCode,Section 2516(1),and in Title 21,United StatesCode,Sections 846 and 878. This affidavit is m ade in support of a crim inal com plaint charging G al V A LLERIU S, a/k/a,tr xyM onsterr''w ith conspiracy to distribute in narcotics in violation of Title 21,United StatesCode,Section 846. 1 have notnecessarily included in the affidavit each and every factknow n to m e about the m atters set forth herein, but only those facts and circum stances that I believe are sufficientto establish probable cause forthe Courtto sign a crim inalcom plaint. The statem ents contained in this affidavit are based upon m y investigation, . inform ation provided by other sw orn 1aw enforcem ent offcers and on m y expedence and training as a federalagentand the experience and training ofotherfederalagents. Case 1:17-cr-20648-RNS Document 1 Entered on FLSD Docket 09/01/2017 Page 4 of 17 PROBABLE C AUSE This application stem s from an ongoing crim inal investigation into drug dealers operating on crim inalonline m arketplace w ebsites,including a w ebsite know n as Dream M arket. In the course ofthis investigation,Ihave learned thatthe Dream M arketw ebsite is one ofm any The Onion Router (ççTor'')network or ççdark web''criminalmarketplaces.Dream M arketis designed to prom ote the anonym ous sale of illegal item s, such as narcotics, in exchange for Bitcoinandother,peer-to-peercrypto-currencies(alsoknown as,virtualcurrencies). A s set forth in m ore detailbelow ,probable cause exists thatV A LLERIU S,acted as an A dm inistrator,Senior M oderator and Vendor on D ream M arket,playing a criticalrole in supporting daily illicit transactions betw een buyers and vendors on D ream M arket, such as the trafficking in narcoticsand laundering in the proceeds oftheir activitiesusing the Bitcoin and the dark web,in conspiracy with additionalknown and unknown administratorts),moderators,and vendors ofthe D ream M arket. A .TH E TO R N ETW O R K A N D TH E RD A RK W EB '' The Intenzetis a globalnetw ork ofcom puters and other devices. D evices directly connected to the Intem et are identified by their unique IP address.This num ber is used to route inform ation betw een devices. G enerally,w hen one device contacts a second device, the first device m ustbe directed to the IP address of the second device. M oreover,when the firstdevice contacts the second device,the first device provides its ow n IP address to the second device,so that the second device know s where to direct its response. A ccordingly, the tw o connected devices (forinstance,a home computerand the www.google.com website server)know each other'sIP address. Case 1:17-cr-20648-RNS Document 1 Entered on FLSD Docket 09/01/2017 Page 5 of 17 9. The typicalusef m ay notknow the IP address ofa websites he visits. Typically,a user w ill type the dom ain nam e of the w ebsite- which com m only corresponds to a plainlanguage nam e for the w ebsite,e.g., ww w .google.com - into the Uniform Resource Locator (:EURL'')baratthetop oftheirwebbrowsers.ThisdomainnamewillbetransmittedtoaDomain Name System (ççDNS'') server,which then translates the domain name into the appropriate num ericalIP address,and thereby allow sthe userto connectw ith the requested w ebsite. 10. How ever, if a user know s of a unique IP address for a particular w ebsite, generally'the user can type that IP address directly into the U RL bar and access the w ebsite in thatm anner. In addition,publicly available databases can be easily searched to obtain the IP addressfor any know n UR L and the registered ow ner and location ofany IP address.Thus,w ith additionalinquiry, m ostany U RL or IP address can be traced to itsow nerand physicallocation.z This isproblem atic foranyone conducting clim inalactivity on the intem etand w ishing to rem ain anonyrRous. 1The server or virtual selwer w ith a particular IP address can hostm ultiple w ebsites,in w hich case entering thatparticular IP address w ould notdirecta user to a single w ebsite.H ow ever,if an IP address is associated with a single website,entering the IP address as desclibed above w ould directthe userto thatparticularw ebsite. 2 Private individuals operating hom e com puters usually do not ow n and register their own IP address' ,instead,they subscribe to broadband accounts w ith ISPS,such as Com cast or A T& T, whichin tul'nassign orleasean IP addresstothem (thesubscriber).Nevertheless,theIP address can usually be traced to its assigned user ata given pointin tim e using the ISPSrecordsofw hich subscriberw asassigned which IP address and when. Case 1:17-cr-20648-RNS Document 1 Entered on FLSD Docket 09/01/2017 Page 6 of 17 B.U ser A nonym ity Provided by the Tor N etw ork 12. The Onion Router(Tor)network isa specialnetwork ofcomputers distlibuted around the w orld designed to conceal the true IP addresses of the users of the netw ork.Every com m unication sentthrough Tor is directed through num erous relays w ithin the netw ork- and w rapped in a layerofencryption ateach relay- such thatthe end recipientofthe com m unication hasno w ay oftracing the com m unication back to itstrue oliginating IP address. 13. ln orderto access the Tor netw ork,anyone can sim ply dow nload the Tor brow ser softw are and use it to access the internet.The user sim ply inputs a w ebsite IP address or U RL into the Torbrow ser and the Tor brow ser autom atically encrypts and routes the com m unication through severalrelays and then outto the destination so thatthe destination w ebsite can only see theIP addressofthelast(orççexif')relayandnottheIP addressofthedeviceactuallyconnecting to the destination website. 14. By way of illustration, in a standard internet com m unication, when a person connectsto a w ebsite,thatw ebsite can see thatpersons IP address: l' lometrom ptlttr 1P':123. 456-789 wstw,-google. tom In this illustration of a standard internet connection,the w ebsite ww w .google.com can see the homecomputerIP address(123.456.789)and,ofcourse,theuserofthehome computerknew the URL,and therefore the IP address,of ww w .google.com ,which the userhad to type into his brow ser to colm ectto the w ebsite in the firstplace.Thus,each users'IP addressis know n to the other,and the ow ner and location ofboth can laterbe traced. Case 1:17-cr-20648-RNS Document 1 Entered on FLSD Docket 09/01/2017 Page 7 of 17 15. Sim ilarly, any person m onitoling the internet traffic at a point betw een the tw o would see the connection betw een IP 123.456.786 and ww w .google.com and know that those tw o devicesw ere com m unicating. On the other hand, in the case of a Tor netw ork com m unication,w hen a person connects to a w ebsite, the traffic is encrypted and routed through m ultiple relays, and that w ebsite cannotsee thatpersonsIP address: ' 1-0rRelal-l lP:00I.00 I-001 HomeCœmputtr IP:123,456.78t ) ww,w ,google-com TnrRelay 2 1P:* 2.002, 002 TorRelay 3 IP:003.003. 003 ln this illustration of a Tor netw ork com w ction, the website w w w .google.com cannot see the home computerIP address(123.456.789), .instead itonly seestheIP addressofthedeviceitis directly connected to,the third (or Etexit'') Torrelay,with IP address003.003.003,which IP address cannotbe traced back to the hom e com puteruser. In addition,any person m onitoring the internettraffic ata pointbetw een the hom e com puter and w w w .google.com and would not know that those tw o devices w ere com m unicating. Instead,depending on the m onitoring point, that person w ould only see the directconnectionsbetween thehomecomputerand first(ortçentry'')Torrelay,between thefirst Case 1:17-cr-20648-RNS Document 1 Entered on FLSD Docket 09/01/2017 Page 8 of 17 and second, or second and third Tor relays,or between the third (or ç6 exif') Torrelay and ww w .google.com . 18. A s w ith a standard internetconnection,the userm usthave know n the U RL or IP address of the w ebsite in order to have directed a connection to it through the Tor network. Accordingly,although the IP address ofthe userishidden from the w ebsite,the IP addressofthe w ebsite m ustbe known to the user- the anonym ity is only one-w ay. 19. The Tor netw ork addresses this problem through a feature know n as Eçhidden services.'' C .H idden Services:W ebsite Anonym ity Provided by the Tor N etw ork To achieve tnle, tw o-w ay anonym ity, the Tor netw ork also enables w ebsites to operate inside the netw ork in a m anner thatconceals the true IP address ofthe com puter server hosting the website. Such ûçhidden selwices'' operating on Tor have com plex w eb addresses, generated in a com puter algorithm ,ending in i6.onion.''U nlike a standard U RL,there is no way to retrieve a w ebsite server'strue IP addressfrom its .onion Toraddress alone. This alleviates the need for a Tor netw ork user to know the tnle IP address of a w ebsite.Rather the user can directhis Tor brow serto the .onion address,reach the website,and neither the user northe w ebsite know s the other's IP address- tw o-w ay anonym ity is achieved. This netw ork ofanonym oususersand websitesisthe tçDark W eb.'' 22. Crim inals have taken advantage of the D ark w eb to create w ebsites w ith online m arketplaces dedicated to the trafficking of controlled substances and other illicit goods. W ebsitessuch aswww.deepdotweb.com m aintain an overview ofillegalm arkem lacesoperating Case 1:17-cr-20648-RNS Document 1 Entered on FLSD Docket 09/01/2017 Page 9 of 17 on the Dark W eb, and how -to guides such as: Eçl-low to Buy D rugs Online from Darknet M arkets.''3 D .Description ofthe Dream M arketN arcotics D istribution Conspiracy Dream M arketprovides an infrastnlcture thatallows buyers and sellers to conduct transactions online,in a m anner sim ilar to w ell-known online m arketplaces such as eB ay.Like eBay: a. D ream M arket functions as an interm ediary betw een buyers and sellers. Sellers create accountson Dream M arketto advertise theirproducts,such asnarcoticsor hacked com puter passw ords,and buyers create accounts to brow se sellers'products and purchase them ; in thisregard,D ream M arket's website interface issim ilarto w ell-know n online m arketplaces; b. D ream M arket perform s m oderator and m aintenance services, such as receiving com plaints,providing technicalassistance,and allow ing custom ers to postreview s of D ream M arket vendors. D ream M arket also provides a m eans by w hich its users can com m unicate with itsadm inistratorsand operators;and Dream M arket charges a com m ission from every transaction as a percentage ofthe sale price. 24. How ever,unlike legitim ate online m arketplaces, Dream M arket is dedicated and designed to facilitate the sale ofillegalnarcotics and drug paraphenzalia.Forexam ple: Illegaldrugs,such as m etham phetam ines,heroin,and cocaine,are openly advertised and sold and are im m ediately and prom inently visible on the Dream M arketw ebsite. 3htTs://www.deepbotweb.coe zols/lz/3o3uy-dOgs-online-from-daru etmarkets/ Case 1:17-cr-20648-RNS Document 1 Entered on FLSD Docket 09/01/2017 Page 10 of 17 The D ream M arket website is specifically designed to facilitate illegal com m erce by w orking to ensure the anonym ity ofits adm inistrators,as wellas ofthe buyers and sellers who participate in com m erce on the w ebsite.The w ebsite is designed to achieve this anonym ity prim arily by operating as a hidden service on the Tornetw ork. To further prom ote anonym ity,purchases are m ade prim arily in bitcoin (orothervirtualcun-ency)using Dream M arket'sescrow services,i.e.,abuyertransfersfunds from his or her ow n accountor virtual-currency w alletinto an Dream M arketaccountor w allet, and D ream M arket subsequently transfers the funds to the seller's account or w allet upon satisfaction of the term s of sale. ln doing so, D ream M arket also provides a t'tum bling''or ttm ixing'' services w hich essentially scram bles m ultiple buyer-seller Bitcoin transactions together in order to concealthe bitcoin paym ents from buyerto seller or com m ission paym ents to the adm inistrator.Thus,there is no directbitcoin transaction betw een the buyerand the seller. 25. A s of A ugust 29,20l7,there are a total of 94,236 listings on D ream M arket,to include the following categolies: çr nlgs''(47405listings).The''Dnlgs''categoryisbroken down intothe follow ing sub-categories:Stim ulats,Opioids,Ecstasy,Cannabis,Barbituates,Belzzos,Cannabis, Dissociatives, Prescription, Psychedelics, RCs, Steroids and W eight Loss. Each sub-category contains differenttypesofcontrolled substances,such as heroin,fentanyl,m etham phetam ine and cocaine. For exam ple, the E6stim ulats'' category contains 934 listings for crystal m etham phetam ine ranging from .5 gram s to 11 pounds per listing,totaling over 200 pounds of crystalm etham phetam ine atany given tim e. Case 1:17-cr-20648-RNS Document 1 Entered on FLSD Docket 09/01/2017 Page 11 of 17 b. ttllligitalGoods''(41394listings).ThettDigitalGoods''categoryisbroken dow n into the follow ing sub-categories: D ata,D rugs,E-Books,Fraud,Fraud Related,Hacking, lnform ation,Other,Security,SoAw are. çtDl'ugParaphernalia''(456listings). d. Services(3056listings).Theççservices''category isbroken down intothe follow ing sub-categories: Hacking,lDs & Passports,M oney,Other,Cash out. tçother''(2382 listings).The ttotherCategory''isbroken down into the following sub-categories:Counterfeits, Electronics,Jew elry, Lab Supplies, M iscellaneous and D efense. These activities and the m arketplace w ebsite itself is overseen, m anaged and controlled by Dream M arketadministratorts)and moderatorsin conspiracy with each otherand allofthe vendors on the m arketplace. Dark W eb m arketplace adm inistrators typically create,m odify,m aintain, and controlthe actual w ebsite and the sever on which its located,as w ell as ultim ately controlthe activity am ong the m arketplace's participants,including the appointm ent of m oderators and otherto help in thatroll. b. M oderators typically m oderate disputes betw een the m arketplace's vendors and buyers and seek to assure the continued operation ofits activities. The tnze identity of the gtloftheindividualswho currently controland operate on .. the Dream M arketw ebsite asadm inistrators,m oderators orvendorsis unknown. E .D ream M arket:D rug D istribution & V enue in Southern D istrictofFlorida 28. Since at least February of 20l6,agents identified narcotics vendors operating on Dream M arket under the follow ing m onikers: Digitalpossizol4, Rexim usM axim us and Case 1:17-cr-20648-RNS Document 1 Entered on FLSD Docket 09/01/2017 Page 12 of 17 M ethForDum m ies.On severaloccasions,D EA agents have m ade undercover online purchases of crystal m eth, LSD and hydrocodone from the aforem entioned vendors on Dream M arket and received the drugs via U .S. M ail, shipped to undercover m ailboxes in M iam i, Florida. For instance: On February 25, 2016,D EA agents purchased 100 sheets of LSD from Rexim usM axim us on D ream M arket for 1.084 bitcoins.ln the descliption, Rexim usM axim us stated' .'<100X G D F 150ug LSD !!''. O n M ay 25, 2016, DEA agents purchased one hydrocodone pill from D igitalpossizol4 on D ream M arket for 0.0993 bitcoins. In the description, Digitalpossizol4 stated:ç(ONE)10.325Hydrocodone 14.50apiece.'' On M ay 25, 2016, DEA agents purchased 10 hydrocodone pills from D igitalpossizol4 on Dream M arket for 0.2207 bitcoins. In the description, D igitalpossizol4 stated,KKITEN)7.5Hydrocodone$100.00 free2/3daypriori.'' On M ay 25, 2016, DEA agents purchased gram s of crystal m etham phetam ine from M ethForDum m ies on Dream M arket for 1.516 bitcoins. ln the description,M ethForDummiesstated,CCM FD'SHQ crystalmethamphetamine28grams.'' 29. ln a11 four instances, the controlled substances w ere shipped via United States Priority M ail to M iam i, Florida. Laboratory results confinned that the above-listed item s contained controlled substances,including LSD ,hydrocodone,and crystalm etham phetam ine. F.Ro xyM onster''A dm inistrator,Senior M oderator & V endor on D ream M arket 30. On January 27,2017,D EA agents logged into Dream M arketand observed a link to ççFonlm ''on the Dream M arkethom e page.A gents clicked on the link,w hich took them to a Torw ebsite called D ream M arketForum .Based on m y training and experience,dark w eb m arket 10 Case 1:17-cr-20648-RNS Document 1 Entered on FLSD Docket 09/01/2017 Page 13 of 17 adm inistrators create forum w ebpages on the dark w eb to allow vendors, buyers and adm inistrators to discuss anything related to the dark w eb m arket.In order to post on the forum , onemustcreate aprofilewith ausemameand password,anyone canjoin the forum,butonly a Dream M arket,adm inistrator,m oderator or vendor,verified by the D ream M arketadm inistrators w ill appear m arked as an ççadm inistrator,''ççm oderator'' or fçvendor'' on the fonlm .4 U nverified forum users are m arked as 'tm em bers'' 31. W hile brow sing the D ream M arket Forum , agents navigated to a topic called CCIELOFFICIAL STAFFjjI''undertheçWnnouncements''tab.Thefirstpostingwaswrittenon July 23,2016 by user6r xyM onster.'' The posting stated: Anyone that' s claim ing to M od orAdm in who ' s noton this list- should be reported im m ediatelv. A dm in:Speedstepper SeniorM oderator:OxyM onster M oderators..Quasimodo,Friedlhechicken Ticketconductors..X ray,Spanishconnect'' SeniorModerator@ Dream marketIchud# eqm4ihj'.onl 'on//al=ss78l 32. The user 'to xyM onster's''title w as m arked as SeniorM oderator. A gents clicked on the user 'toxyM onster'' and w ere taken to 'to xyM onster's''protile on D ream M arket. The profile stated that'r xyM onster's''was a Senior M oderatoron Dream M arket,whose profile was registered on the Dream M arketFort zm on M ay 10,2015. 33. Severalm onths later,on June 30,2017,agentsalso identified tto xyM onster''as a vendor on Dream M arket. ççoxyM onster's vendor profile featured listings for Schedule 11 4 On the Dream M arketForum , w henever a userposts a com m ent,his/herusernam e isdisplayed nextto the com m ent.A lso,nextto the usernam e,a user is identified as a Dream M arketvendor, m oderator, adm inistrator, or m em ber. A ll vendors, m oderators and adm inistrators have to be veritied as such by the Dream M arketadministratorts).Unvelitied Dream M arketusers are m arked asm em bers. Case 1:17-cr-20648-RNS Document 1 Entered on FLSD Docket 09/01/2017 Page 14 of 17 controlled substances O xycontin and Ritalin.H isprofile listed 60 priorsales and five starreview s from buyers.In addition, his profile stated that he ships from France to anywhere in Europe. U nderthe tt-rerm s and Conditions''section,hisprofile stated, Iz lzrchighl y recommend using TradeRouteforpurchasingfrom us: Trade routeilbgzton ion//shop =oxyM onster...'' THE OFFICIAL TIP JAR FOR '' DM WATTEAM ''(STAFF)IS. . lDREAMv7kl6T8bMyE7ghe4nLQVSdBbPJAe. A gents navigated to the aforem entioned TradeRoute link, w hich 1ed them to OxyM onster's dnlg vendor page TradeRoute- an em erging dark w eb m arketplace sim ilar to Dream M arket. O xyM onster's TradeRoute profile stated thathe w asan active drug vendor,w ho ships from France to Europe and the United Statesand hasbeen a m em ber since February,2017. In addition,hisprotile stated: YES,wc wcrc m ods on E vo YES,wc wcrc adm ins on D ream 35. In other posts on the Dream M arket forum ,'toxyM onster''characterized him self as a D ream M arket adm inistrator.For instance,on Decem ber 10,2015,tûo xyM onster''posted the follow ing' . Beingprom oted is always nice,especially once hitting the 'A dm in ''role. Thatbeingsaid,wcwillbefocusingmoreonthemarket' saspectsobviously. O n A ugust28,2017,agents once again logged into the D ream M arketforum and view ed çço xyM onster's'' profile. At that tim e, his title was changed to E'V endor'' on D ream M arket. H is profile also stated thathe has 1,052 posts and his last post w as on February l3, 2017.In addition,he had a signature,which stated: 12 Case 1:17-cr-20648-RNS Document 1 Entered on FLSD Docket 09/01/2017 Page 15 of 17 SeniorM oderator@ Dream marketIchudk eqm4idjj.onion//ai=ss78l''*REAL DSAWAT STAFF T1P JAR:1DM ' AMv7kl6T8bMyE7ghe4nLQVydBbPJAe.5 37. A gents review ed all of ççoxyM onster's'' posts on the D ream M arket Forum , w hich began on h4ay l0, 2015 and ended on Decem ber 22, 2016. f'O xyM onster's'' posts responded to custom er com plaints,provided tips on staying anonym ous on the dark w eb and posted the nam es ofthe officialstaffofDream M arket. On A ugust 29, 2017, agents view ed tçoxyM onster's'' D ream M arket vendor profile. This tim e, the vendor profile stated that he w ill also ship to the U nited States. The vendorprofilenow had 70 verified salesand stilllisted the same Dream M arketstafftip jar bitcoin w alletand he w as lastonline on August29,2017. 39. In sum ,6r xyM onster''know ingly participated the Dream M arket conspiracy not only as a vendor,but also,in a leadership and organizational roll as a senior m oderator and adm inistrator. F.G aIV ALLE RIU S ldentified as Go xyM onster'' 40. After observing the bitcoin ''tip jar'' advertised by çtoxyMonsyter,'' agents conducted analysis of the incom ing and outgoing transactions from that bitcoin address and learned that15outof17 outgoingtransactionsfrom thettoxyM onster''tipjarwentto multiple wallets controlled by French nationalGalV A LLERIU S on Localbitcoins.com . Open source data revealed that VA LLERIU S has lnstagram and Tw itter accounts. A gents com pared the w riting style of '6oxyM onster''on D ream M arket fonlm while in Senior 5Based on m y training and expelience, abitcoin kç tipjar,''isutilizedby darkwebmarketvendors and adm inistrators to receive tips in bitcoin for their service from the users of the dark w eb m arket. 13 Case 1:17-cr-20648-RNS Document 1 Entered on FLSD Docket 09/01/2017 Page 16 of 17 M oderatorrole to the writing style ofV A LLER IU S on his public Instagram and Tw itteraccounts. A gents discovered m any sim ilarities in the use of w ords and punctuation to including:the w ord tûcheersi''double exclam ation m arks; frequent use of quotation m arks' , and interm ittent French posts. 42. On A ugust 31,2017,VA LLER IU S travelled to the United States forthe firsttim e to attend an internationalbeard com petition in Austin,Texas.A border search ofhislaptop upon his anivalatA tlanta InternationalA irportconfinned his identity as tto xyM onster.''On his laptop wastheTOR browser,apparentlog-in credentialsforDream M arket,$500,000 worth ofbitcoin, and a PGP encryption ke/ entitled ''OxyMonster'' which matched that advertised as E6oxyM onster's''on D ream M arket. 6Persons who are involved w ith Dark W eb narcotics trafficking utilize public key encryption to com m unicate w ith other purchasers and sellers on the m arketplace in order, for instance, to provide inform ation such as a shipping address.lf the m essage w as not encrypted,it w ould be visible by the adm inistrators of the D ark W eb m arketplace, and by law enforcem ent, if the m arketplace server w as ever located and seized.Public key encryption allow s the sender of a m essage to encryptthatm essage using a long and unique passcode know n as a public key,w hich the recipient of the m essage publicly provides to anyone w ishing to com m unicate w ith them . Thatm essage,in tum ,can only be decrypted by the recipientusing a corresponding private key know n only to them .The m ostcom m only used encryption is thatknow n as Pretty Good Privacy (PGP)encryption.Almosta1lDark W eb marketplacevendorprotilesadvertiseapublicPGPkey for thispup ose;the PG P key,therefore,doubles as a unique fingerprintvisible across dark w eb platform s. 14 Case 1:17-cr-20648-RNS Document 1 Entered on FLSD Docket 09/01/2017 Page 17 of 17 C ONCLIJSION 43. Based on the foregoing,probable cause exists thatG alV A LLERIU S,did,atleast from M ay 20l5 to August 2017 conspire to distribute controlled substances,including cocaine, fentanyl,m etham phetam ine,LSD ,and oxycodone in violation of Title 21, United States Code, Section 846. Respectfully subm itted, A . A U STIN D .LO VE,SPECIA L A G EN T DRU G EN FOR CEM EN T A DM INISTR ATIO N The cont nts of this written affidavit w ere subscribed and swornbeforem onAugustx ,2017. JON A H GO O DM A N HO N OR AB LE UN IT STA TES M A G ISTRATE JU D GE