IN THE UNITED STATES DISTRICT COURT FOR THE FILED ———WOFFACOURT EASTERN DISTRICT OF VIRGINIA MAR - 6 2018 Alexandria Division CleryTT TR tg ) MNDER SEAL) UNITED STATES OF AMERICA ) NADER oe ) Criminal No. 1:18er // v. Count 1: Conspiracy to Commit ) Computer Intrusion (18 U.S.C. $§ 371, ) 1030(a)(1), 1030(a)(2), JULIAN PAUL ASSANGE, Defendant. ) 1030(c)(2)(B)Gi)) March 2018 Term — at Alexandria, Virginia INDICTMENT THE GRAND JURY CHARGES THAT: GENERAL ALLEGATIONS At times material to this Indictment: 1. Chelsea Manning, formerly known as Bradley Manning, was an intelligence analyst Base Hammerin Iraq. in the United States Army, who was deployedto Forward Operating 2. classified Manning held a “Top Secret” security clearance, and signed a disclosure or retention information nondisclosure agreement, acknowledgingthat the unauthorized injury to the United States or negligent handling ofclassified information could cause irreparable or be used to the advantage of a foreign nation. 3. the classification Executive Order No. 13526 and its predecessor orders define levels assigned to classified information. Under the Executive Order, information may be could be expected to classified as “Secret” if its unauthorized disclosure reasonably cause serious information can damageto the national security. Further, under the Executive Order, classified level of United generally only be disclosed to those persons who have been granted an appropriate tion in States government security clearance and possess a need to know the classified informa connection to their official duties. 4, Julian Paul Assange was the founder and leader of the WikiLeaks website. The restricted WikiLeaks website publicly solicited submissions of classified, censored, and other information. 5. Assange, who did not possess 4 security clearance or need to know, was not authorized to receive classified information of the United States. 6. Between in or around January 2010 and May 2010, Manning downloaded four, nearly complete databases from departments and agencies of the United States. These databases contained approximately 90,000 Afghanistan war-related significant activity reports, 400,000 Iraq war-related significant activities reports, 800 Guantanamo Bay detainee assessment briefs, and 250,000 U.S. Department of State cables. Many of these records were classified pursuant to of Executive Order No. 13526 orits predecessor orders. Manning provided the records to agents y WikiLeaks so that WikiLeaks could publicly disclose them on its website. WikiLeaks publicl released the vast majority of the classified records on its website in 2010 and 2011. 7. On or about March 8, 2010, Assange agreed to assist Manning in cracking a Secret password stored on United States Department of Defense computers connected to the nts and Internet Protocol Network, a United States government network used for classified docume essor orders. communications, as designated according to Executive Order No. 13526orits predec 8. Manning, who had access to the computers in comnection with her duties as an to transmit to intelligence analyst, was also using the computers to download classified records to bypass or circumvent WikiLeaks. Army regulations prohibited Manning from attempting sharing personal security mechanisms on Government-provided information systems and from accounts and authenticators, such as passwords. 9. a The portion of the password Manning gave to Assange to crack was stored as trative-level “hash value” in a computer file that was accessible only by users with adminis e, privileges. Manning did not have administrative-level privileges, and used special softwar of the namely a Linux operating system, to access the computer file and obtain the portion password provided to Assange. 10, Cracking the password would have allowed Manningto log onto the computers it more difficult under a usernamethat did not belong to her. Such a measure would have made tion. for investigators to identify Manning as the source ofdisclosures of classified informa 11. Prior to the formation of the password-cracking agreement, Manning had already from provided WikiLeaks with hundreds of thousands of classified records that she downloaded cant departments and agencies of the United States, including the Afghanistan war-related signifi activity reports and Iraq war-related significant activities reports. 12. ng was At the time he entered into this agreement, Assange knew that Manni ofthe providing WikiLeaks with classified records containing national defense information United the purpose States. Assange was knowingly receiving such classified records from Manning for ofpublicly disclosing them on the WikiLeaks website. 13. the For example, on March 7, 2010, Manning and Assange discussed the value of fore entering the password Guantanamo Baydetainee assessment briefs, and on March 8, 2010,be hing [she had] on JTF cracking-agreement, Manning told Assange that she was “throwing everyt all I really have gotleft.” GTMOat [Assange] now.” Manning also said “after this upload, that’s Nm To which Assange replied, “curious eyes never run dry in my experience.” Followingthis, between March 28, 2010, and April 9, 2010, Manning used a United States Department of Defense computer to download the U.S. DepartmentofState cables that WikiLeaks later released publicly. COUNT 14. The general allegations set forth in paragraphs 1 through 13 are re-alleged and incorporated into this Count as though fully set forth herein. 15. Beginning on or about March 2, 2010, and continuing thereafter until on or about March 10, 2010, the exact date being unknown to the Grand Jury, both dates being approximate and inclusive, in an offense begun and committed outside of the jurisdiction of any particular State or district of the United States, the defendant, JULIAN PAUL ASSANGE, who will be first brought to the Eastern District of Virginia, did knowingly and intentionally combine, conspire, confederate and agree with other co-conspirators known and unknown to the GrandJury to commit an offense against the United States, to wit: (A) to knowingly access a computer, without authorization and exceeding authorized access, to obtain information that has been determined by the United States Government pursuant to an Executive order andstatute to require protection against unauthorized disclosure for reasons of national defense and foreign relations, namely, documents relating to the national defense classified up to the “Secret” level, with reason to believe that such information so obtained could be used to the injury of the United States and the advantage of any foreign nation, and to willfully communicate, deliver, transmit, and cause to be communicated, delivered, or transmitted the same, to any person notentitled to receiveit, and willfully retain the same andfailto deliverit to the officer or employee entitled to receive it; and (B) to intentionally access a computer, without authorization and exceeding authorized access, to obtain information from a department and agency of the United States in furtherance ofa criminal actin violation of the laws of the United States,that is, a violation of Title 18, United States Code, Sections 641, 793(c), and 793(e). (In violation of Title 18, United States Code, Sections 37 1, 1030(a)(1), 1030(a)(2), 1030(c)(2)(B)Gi).) PURPOSE AND OBJECT OF THE CONSPIRACY 16. The primary purposeofthe conspiracy wasto facilitate Manning’s acquisition and transmission of classified information related to the national defense of the United States so that WikiLeaks could publicly disseminate the information on its website. MANNERS AND MEANS OF THE CONSPIRACY 17. Assange and his co-conspirators used the following ways, manners and means, among others, to carry out this purpose: 18. It was part of the conspiracy that Assange and Manning used the “Jabber” online chat service to collaborate on the acquisition and dissemination of the classified records, and to - enter into the agreementto crack the password stored on United States Department of Defense computers connected to the Secret Internet Protocol Network. 19. It was part of the conspiracy that Assange and Manning took measures to conceal Manningas the sourceofthe disclosure ofclassified records to WikiLeaks, including by removing usernamesfrom the disclosed information anddeleting chat logs between Assange and Manning. 20. It was part of the conspiracy that Assange encouraged Manning to provide information and records from departments and agencies of the United States. 21. It was part of the conspiracy that Assange and Manning used a special folder on a cloud drop box of WikiLeaks to transmit classified records containing information related to the national defense of the United States. ACTS IN FURTHERANCE OF THE CONSPIRACY 22. In orderto further the goals and purposesof the conspiracy, Assange andhis co- conspirators committed overt acts, including, but not limited to, the following: 23. Onorabout March 2, 2010, Manning copied a Linux operating system to a CD,to allow Manning to access a United States Department of Defense computerfile that was accessible only to users with administrative-level privileges. 24. Onorabout March 8, 2010, Manning provided Assange with part of a password stored on United States Department of Defense computers connected to the Secret Internet Protocol Network. 25. Onorabout March 10, 2010, Assange requested more information from Manning related to the password. Assange indicated that he had beentryingto crack the password by stating that he had “no luck so far.” A TRUE BILL ——- DATE Tracy Doherty-McCormick Acting United States Attorney By:. Mle Diy af ellen S. Dwyer Thomas W. Lek Assistant United States Attorneys No. _1:18cR{ \ UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA Alexandria Division THE UNITED STATES OF AMERICA VS. JULIAN PAUL ASSANGE Se Sr SSEESa eTree enetaraeananawenateed ~ INDICTMENT In violation of Title 18 U.S.C. §§ 371, 1030(a)(1), 1030(a)(2), 1030(¢)(2)(B)(i) Conspiracy to Commit Computer Intrusion A true bill. Foreman Filed in open court this 6th day, of _March_ A.D. 2018