AUSA Jordan M. Matthews (312) 697-4090 AO 91 (Rev. 11/11) Criminal Complaint UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UNITED STATES OF AMERICA CASE NUMBER: v. FARHAN SHEIKH CRIMINAL COMPLAINT I, the complainant in this case, state that the following is true to the best of my knowledge and belief. On or about August 13, 2019, at Chicago, in the Northern District of Illinois, Eastern Division, and elsewhere, the defendant violated: Code Section Offense Description Title 18, United States Code, Section 875(c) transmitting a threat in interstate commerce This criminal complaint is based upon these facts: X Continued on the attached sheet. BARRETT JAMES RIFE Special Agent, Federal Bureau of Investigation (FBI) Sworn to before me and signed in my presence. Date: August 17, 2019 Judge’s signature City and state: Chicago, Illinois SUSAN E. COX, U.S. Magistrate Judge Printed name and Title UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS AFFIDAVIT I, BARRETT JAMES RIFE, being duly sworn, state as follows: 1. I am a Special Agent with the Federal Bureau of Investigation, and have been so employed since 2018. I am currently assigned to the Chicago Field Office, West Resident Agency Squad CT-2. As part of my duties as a FBI Special Agent, I investigate criminal violations relating to domestic terrorism and criminal violations including but not limited to Title 18, United States Code, Sections 249, 875, 922, and 924, and Title 26, United States Code, Section 5861. I have been involved with various electronic surveillance methods, the debriefing of subjects, informants, and witnesses, as well as others who have knowledge of interstate threatening communications. 2. This affidavit is submitted in support of a criminal complaint alleging that FARHAN SHEIKH has violated Title 18, United States Code, Section 875(c). Because this affidavit is being submitted for the limited purpose of establishing probable cause in support of a criminal complaint charging SHEIKH with transmitting a threat in interstate commerce, I have not included each and every fact known to me concerning this investigation. I have set forth only the facts that I believe are necessary to establish probable cause to believe that the defendant committed the offense alleged in the complaint. 3. The facts set forth in this affidavit are based on the following: my personal knowledge; knowledge obtained from other individuals during my participation in this investigation, including other law enforcement officers; interviews of witnesses; my review of records related to this investigation; communications with others who have knowledge of the events and circumstances described herein; and information gained through my training and experience. I. IFUNNY POSTS 4. Law enforcement learned of a series of threatening communications posted to iFunny (ifunny.co) by an individual utilizing the username “awarded.” iFunny is a type of social media platform that has both a website and a mobile application, on which users can post internet memes. A meme is typically a humorous image, video, or piece of text that is copied and spread by internet users. An iFunny user typically has a page on which that user can post memes. 5. Based on information received from a lawyer for iFunny, the servers for iFunny are not located in the state of Illinois and iFunny is a Delaware corporation. 6. On or about August 13, 2019, the FBI learned that an iFunny user utilizing the username “awarded” had posted a threat. Agents and analysts viewed the publically available page of “awarded” located at https://iFunny.co/user/awarded and found the posts referenced below. 2 7. On or about August 13, 2019, the following threatening statements were posted by username “awarded” on iFunny:1 Victim A Street A I most recently reviewed these posts on or about August 16, 2019. The posts are in chronological order, but exact times of the postings are not available. 1 3 0 iFunny at: featured 9 weekly digests Animals I Nature Anime Hang: Art Creative Cars Celebrities Gaming Girls Internet Memes Movies Victim A Street A 8. Based on open source information, Victim A is located on Street A in Chicago, Illinois, approximately 4 miles from FARHAN SHEIKH’s residence. 5 9. Based on information from other law enforcement officers, open source media, and law enforcement’s interview of SHEIKH, which is discussed below, the reference to “armyofchrist” in one of the above posts is a reference to Justin Olsen, an iFunny user from Ohio, who was recently arrested by the FBI for posting threatening communications towards federal agents on the iFunny platform. Olsen was in possession of both firearms and ammunition at the time of his arrest. Olsen was charged by criminal complaint in the Northern District of Ohio in case number 19MJ-06156. II. IDENTIFICATION OF FARHAN SHEIKH 10. Multiple postings on the iFunny account of “awarded” indicated the user has multiple Twitter accounts. 11. On or about February 3, 2019, “awarded” posted the following: 12. On or about January 23, 2018, “awarded” posted the following: 6 13. On or about July 27, 2018, “awarded” posted the following, which indicates that the individual who uses the “awarded” account has a birthday on or about July 27, 2000: 14. Agents searched the username “awarded” on other social media platforms and identified the following additional accounts likely utilized by the same user as the iFunny account: a. An Instagram account with the user name “@awarded_iFunny”, which is the same name as the Twitter account referenced above. 7 b. A Facebook account utilizing the username of “awardeds.vids”, which also has a link to iFunny on the profile page. 15. The cover photographs used on the profile landing pages of the iFunny, Twitter, and Instagram accounts all feature either German soccer team Borussia Dortmund or soccer player Marco Reus who plays for the Borussia Dortmund team: Facebook profile page for “awarded.vids”: iFunny profile page: 8 Instagram profile page: 16. Twitter records for @ijustwantaehoe and @awardediFunny reflect that the account subscriber utilized the following identifying information: a. telephone numbers: (773) XXX-17502 (@awarded_iFunny), (773) XXX-73403 (@ijustwantaehoe); b. e-mail addresses: farhanmazsheikh@gmail.com (@ijustwantaehoe) , crazygameaholic@gmail.com (@awarded_iFunny). 17. Subpoena returns from iFunny reflect that the “awarded” account subscriber utilized the following identifying information: 18. a. telephone number: the 1750 Number; b. e-mail address: crazygameaholic@gmail.com. Information received from iFunny also reflect that user “awarded” accessed iFunny from “Device: Samsung sm-975u” and that the location of the user is Chicago, Illinois. This phone number has been anonymized because this affidavit will be publicly filed. This phone number will be referred to as the 1750 Number. 2 This phone number has been anonymized because this affidavit will be publicly filed. This phone number will be referred to as the 7340 Number. 3 9 19. According to Accurint records, the 1750 Number is registered to FARHAN SHEIKH at an address on W. Thome Avenue in Chicago (the “Thome Residence”), which as explained below is SHEIKH’s home address without the apartment number, and the 7340 Number is registered to another person with the last name Sheikh, at the same street address on W. Thome Avenue but only included a portion of the apartment number.4 20. Illinois Secretary of State Records state that FARHAN SHEIKH has a date of birth in July 2000, and resides at the Thome Residence. SHEIKH’s date of birth is almost identical to the birthday indicated in the post above. III. INTERVIEW OF FARHAN SHEIKH 21. On or about August 16, 2019, agents executed a search warrant on the Thome Residence. SHEIKH was present in the residence during the search and spoke with agents.5 During the course of the interview, SHEIKH stated that the “awarded” iFunny account belonged to him. SHIEKH told law enforcement that he had accessed the “awarded” iFunny account as recently as the day agents came to speak to him, August 16, 2019. When SHIEKH was asked why he thought that the FBI was at his residence, he responded that he believed it was due to a “joke” that he posted on iFunny. SHIEKH stated that he posted something to iFunny about shooting an abortion clinic. When asked whether SHIEKH specified a shooting in his posting, SHIEKH responded, “I said those things.” This is consistent with the post above that 4 This name and address have been anonymized because the affidavit will be publicly filed. The following is a summary of some of the statements made by SHEIKH during the interview and is not verbatim. 5 10 stated, “I am done with my state and thier [sic] bullshit abortion laws and allowing innocrnt [sic] kids to be slaughtered for the so called ‘womans right’ bullshit. Ive seen nothing but whores go out of the way to get an abortion, but no more. I will not tolerate this anymore. Im DONE. On August 23rd 2019, I will go to the [Victim A] in Chicago on [Street A]. I will proceed to slaughter and murder any doctor, patient, or visitor i see in the area and I will not back down. consider this a warning for anyone visiting…” When SHIEKH was asked whether he picked a specific date, he responded that he posted a specific date and that it was just a random date. When SHIEKH was asked whether he targeted a specific clinic, he said yes. When SHIEKH was asked why he picked that specific clinic, SHIEKH said, “I just searched a random clinic.” SHIEKH also stated that he posted something about FBI agents and in the post said for the FBI to come after him. This is consistent with the post above that reads, “To all the fbi agents in this app, I am NOT a satirical account. I post what I mean, and i WILL carry out what I post”. SHEIKH also stated that he made additional posts related to the same topic. SHEIKH told agents that he accessed his social media accounts from his Samsung Galaxy cell phone. SHEIKH said that his phone number was the same as 1750 Number. SHEIKH also admitted that he was familiar with the user “armyofchrist” on iFunny and that he subscribed to the account on iFunny. 11 IV. CONCLUSION 22. Based on the information above, Affiant submits that there is probable cause that FARHAN SHEIKH transmitted a threat in interstate commerce, in violation of Title 18, United States Code, Section 875(c). FURTHER AFFIANT SAYETH NOT. BARRETT JAMES RIFE Special Agent, Federal Investigation SUBSCRIBED AND SWORN to before me on August 17, 2019. SUSAN E. COX United States Magistrate Judge 12 Bureau of