IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA UNITED STATES OF AMERICA V. KRISTOPHER LEE DALLMANN (Counts 1?5, and 12?15) DARRYL JULIUS POLO a/k/ a djppimp? (Counts 1, 6411, and 16?19) DOUGLAS M. COURSON (Count 1) FELIPE GARCIA (Count 1) JARED EDWARD a/k/a Jared Edwards (Count 1) PETER H. HUBER (Count 1) YOANY VAILLAN a/k/a Yoany Vaillant Faj ardc (Count 1) LUIS ANGEL VILLARINO (Count 1), Defendant?s. Alexandria Division Count 1: CoUnts 4-5: Counts 8&9: . Counts 2-3: Counts 6-7: Criminal No. 1 18 U. C. 371 Conspiracy to Commit Criminal Copyright Infringement 17 506(a)(1)(A) and 106(1) and 18 U.S.C. 2319(b)(3) and 2 Criminal Copyright Infringement by Reproduction or Distribution and Aiding and Abetting 17 U.S.C. 506(a)(1)(A) and 106(4); 18 U.S.C. 2319(b)(3) and 2 Criminal Copyright Infringement By Public Performance and Aiding and Abetting - 17 U.S.C. 18 S. C. ?2319(d)(2) and 2 Criminal Copyright Infringement by Distributing a Copyrighted Work Being Prepared for CoInmercial Distribution and Aiding and Abetting 17 U.S.C. 506(a)(1)(A) and 106(1) and 18.U.S.C. 2319(b)(3) and 2 Criminal Copyright Infringement by Reproduction or Distribution and Aiding and Abetting THE GRAND JURY CHARGES THAT: Counts 10-11: Counts 12?14: Count 15: Counts 16?18: 17 U.S.C. 506(a)(1)(A) and 106(4); 18 U.S.C. 2319(b)(3) and 2 Criminal Copyright Infringement By Public Perfonrnance and Aiding and Abetting 18 US .C. 1956(a)(1)(A)(i) and 13(1) and 2 - Money Laundering and Aiding and Abetting 18 U.S.C. 1956(a)(3)(A) and (B) and 2 Money Laundering and Aiding and Abetting 18 U.S.C. 1956(a)(1)(A)(i) and and 2 Money Laundering and Aiding and Abetting Count 19: 18 U.S.C. 1956(a)(3)(A) and (B) and 2 Money Laundering and?Aiding and Abetting Perfeiture Notice INDICTMENT INTRODUCTION At all times relevant to this Indictment: 2 August 2019 Term m- at Alexandria, Virginia A From in or about 2007 to on or about November 16, 2017, defendant KRISTOPHER LEE DALLMANN, with the assistance of others known and unknown to the Grand Jury, including defendants DARRYL JULIUS POLO a/k/a djppimp, DOUGLAS M. COURSON, FELIPE GARCIA, JARED EDWARD JAUREQUI a/k/a Jared Edwards, PETER H. HUBER, YOANY VAILLANT a/k/a Yoany I Vaillant Faj ardo, and LUIS ANGEL VILLARINO, Operated Jet?icks, an online, subscription-based service that permitted users to stream and, at times, download copyrighted television programs without the permission of the relevant copyright owners. The defendants willfully reproduced tens of thousands of copyrighted television episodes, without the permission of copyright owners, and distributed the infringing programs to individuals located throughout the United States, including many individuals located within the Eastern District of Virginia. The estimated harm to television program copyright owners as well as licensed streaming services caused by et?icks was millions of dollars. . I 2. et?icks functioned as a subscription?based service akin to well~known, legitimate online video streaming and downlOad services, such as Net?ix, Hulu, Vudu, and Amazon Prime Video. That is, for a subscription fee as little as $9.99 per month, Jet?icks enabled its subscribers to watch an unlimited number of commercial-free television programs, often within days of the episodes? ?rst airings, on their internet- connected devices. Jet?icks sought to make its television pro grams available on numerous devices, platforms, and software including the Apple iPhone, Apple iPad, Android phone, Android tablet, Apple Safari, Goo gle Chromecast, Microsoft Edge, Apple TV, Amazon Fire TV, Microsoft XBOX One, Sony PlayStation 4, Nintendo Wii U, Sarnsung TV, and Roku. Jet?icks, at one point in its history, claimed to offer more than 183,200 television episodes and have more than 37,000 subscribers. 3. Jet?icks obtained television programs from sites hosting in?'inging content including torrent sites and Usenet sites, using automated programs and databases such as SickRage, Sick Beard, SABnizbd, and a. A torrent site refers to a website that uses the BitTorrent communication ?protocol?, (a set of rules that different computer systems agree to use) for peer?to?peer file sharing, which commonly includes the distribution and'reproduction of digital video ?les including television programs and motion pictures. Instead of downloading a file such as a television program or motion picture from a single source, BitTorrent enables users to connect through the internet to the devices of other BitTorrent users in order to download and upload simultaneously pieces of the work from and to . other users. To send or receive a televisionlpro gram or motion picture through BitTorrent, a person uses a computer program called a BitTorrent client on his or her internet?connected device. A user who wants to share a television program or motion picture creates a ?torrent file? that he or she makes available to others, often through a torrent site. That torrent ?le contains instructions for identifying the Internet Protocol addresses of other torrent site users who have the television program and for downloading that work from those users. Once a user downloads all the pieces of the television program or motion picture from the other torrent site users, the television program or motion picture is automatically reassembled into its original form and is ready to be watched. As a result, a torrent site with a lot of users willing to share their libraries of television programs or motion pictures can facilitate fast downloading of works from multiple computers that possess those works and are willing to share them. b. Usenet was originally designed as an electronic bulletin?board service. Once it started including binary newsgroups, it became a popular place to ?nd ?les (a binary ?le is a computer ?le that is not a text One particular Usenet site started indexing the binaries available on Usenet and created the NZB ?le format. An NZB ?le is basically the Usenet equivalent of a BitTorrent torrent ?le, in that it points to a ?le available elsewhere on Usenet. Many binaries available on Usenet are infringing television programs and motion pictures. Unlike torrent sites, Usenet is not peer-to-peer and providers typically impose restrictions on their users such as requiring payment, limiting the number of days of ?le retention, or capping the amount of data that can be downloaded. Many copyrighted works are made available on Usenet without permission of the copyright owners, and some Usenet providers and indexers are designed to facilitate searching and dewnloading of infringing material. c. SickRage (which is also known now as SickChill) is an automated program that downloads, processes, and then stores television programs on a computer or other device. When a user adds a television episode to SickRage, the program pulls information about the show (such as air date and episode name or number) from an internet database such as thetvdb.com or tvrage.com. Because SickRage knows when a new episode of a selected show will air, it will start searching at the appropriate time for that file on any torrent and N213 sites selected by the user. SickRage offers over 40 torrent sites including some of the biggest pirate sites in the world, such as The Pirate Bay, RARBG, and Torrentz, and allows users to enable NZB search as well. Users can establish quality settings, instructing SickRage to only download files with a certain quality level. Moreover, when the ?le is downloaded, SickRage does post?processing on the ?le, moves it to a folder on your device, and even renames it. (1. Sick Beard works similarly to SickRage, focusing more on Usenet sites rather than torrent sites. Like SickRage, Sick Beard is an automated program that downloads, processes, and stores television programs on a computer or other device. Sick Beard supports a number of NZB indexers that are well?known for offering infringing video content. c. SAanbd is an automated program that downloads, veri?es, and stores NZB ?les from Usenet. Users can use programs such as SickRage or Sick Beard to browse Usenet through NZB indexers and locate NZB ?les they want, such as speci?c television programs; once they ?nd the ?les they-desire, they can download them through SAanbd, where those ?les can then be further processed through SickRage, Sick Beard, or similar programs. f. or TVDB is an online database of television programs located at that includes televisionseries, season, and episode information and images that can be used by software and websites to give information about speci?c television programs offered for streaming or downloading in video libraries. 4. At various times, Jet?icks used thedomains jet?icks.mobi, jet?icksnet, and jet?ickscom, as well as servers and computers in the United States and Canada to search for, download, process, store, stream, and make available for download infringing television programs. . 4 5. From in or about 2014 to the present, defendant POLO operated iStreamItAll an online, subscription?based service that permitted users to stream and download copyrighted television programs and motion pictures without the permission of the relevant copyright owners. POLO willfully reproduced tens of thousands of copyrighted television episodes and motion pictures, without the permission of copyright owners, and distributed the infringing programs to individuals-located throughout the United States, including many individuals located within the Eastern District of Virginia. The estimated harm to television program and metion picture copyrightowners as well as licensed streaming services caused by ISIA was millions of dollars. 6. Like et?icks, ISIA functioned as a subscription-based service akin to well?known, legitimate online video streaming and download?services. In fact, - website. reveals that the Service has an interface and operation similar to et?icks, except . that ISIA includes both motion pictures and commercial?free television programs. website, at one point in its history, stated that ISIA orks\on all your favorite devices, including: Kodi Addon, Amazon Firestick, Android TV (Nvidia Shield, Xiaomi Mi Box, Sony Bravia Sharp Aquous Smart TV, etci. .) Chromecast, Android Phones, iPhones, iPads, AppleTV (Airplay), PC Mac, SmartTV?s, XBOX One, Almost anything with a web browser.? Subscription plans included a option at l9.99, a quarterly option at $54.99, a semi-annualoption at $99.99, and a yearly option at $179.99. website also stated that it offered ?Unlimited Commercial Free TV Shows Movies? with ?Over" 389.8 TV Series, Episodes, 10511 Movies, Current Season Daily Updates From All Your Favonte TV Series!? Moreover, in 2017, lSlA?s website claimed HAVE MORE CONTENT THEN ALL OF OUR JETFLICKS, NETF LIX, HULU, VUDU, AMAZON PRIME However, according to copyright owners, ISIA?m?like Jet?icks?provided content Without their 7 permission and Without any compensation. 7. ISIA obtained television programs from sites hosting in?inging content (including torrent sites and Usenet sites), using automated programs such as SickRage, SickBeard, and SABand. 8. At various times, ISIA used the domains istreamitallcom and jisueamitall.mobi, as well as servers and computers in the United States and Canada to search for, download, process, store, stream, and make available for download in?dnging television programs. 9. Since in .or about at least 2012, POLO also operated other sites used to obtain infringing content, including SmackDownOnYou, a pay?only NZB indexer site that he used for income and to obtain television programs and motion pictures for ISIA. COUNT ONE (18 USO. 371 Conspiracy to Commit Criminal Copyright Infringement) THE GRAND JURY CHARGES THAT: 10. The factual allegations contained in Paragraphs 1 through 4 are re?alleged and incorporated as if set forth herein in their entirety. I 11. Beginning at least in or about 2007 and continuing until at least on or about November 16, 20 7, in the Eastern District of Virginia and elsewhere, the. defendants KRISTOPHER LEE DALLMANN, DARRYL JULIUS POLO a/k/a djppimp, DOUGLAS M. COURSON, FELIPE GARCIA, JARED EDWARD JAUREQUI a/k/a Jared Edwards, . PETER H. HUBER, YOANY VAILLAN a/k/a Yoany Vaillant Faj ardo, and LUIS ANGEL VILLARINO each knowingly and intentionally combined, conspired, and agreed together and with each other, and with other persons known and unknown to the Grand Jury, to willfully, and for purposes of commercial advantage and private ?nancial gain, infringe copyrights by reproduction and distribution of at least ten copies of one or more copyrighted works during a 180~day period with a total retail value of'more than $2,500, in violation of Title 17, U.S. Code, Section and Title 18, US. Code, Section 2319(b)(1). Purpose of the Conspiracy . 12. It was the general purpose of the conspiracy for the defendants and others to enrich themselves by searching the inteinet for copies of copyrighted television programs, and then, without permission from the copyright owners, reproduce tens of thousands of those works and subsequently distribute and stream the works to tens of thousands of paying subscribers located throughout the United States, including hundreds of individuals located within the Eastern District of Virginia. Manner and Means of the Conspiracy 13. In ?i?herance of the conspiracy, defendants and others known and unknown to the Grand Jury employed, among others, the following manner and means: a. It was part of the conspiracy that members of the conspiracy did computer coding, database programming, and related technical work to create, maintain, and run Jet?icks. - I b. It was further part of the conspiracy that members of the conspiracy worked on graphic design for the Jet?icks website and sought to promote its popularity through search engine optimization, social media posts, and other means. 0. It was further part of the conspiracy that members of the conspiracy used automated and manual software applications to search torrent and Usenet sites on the internet for copyrighted television programs, especially programs that had been aired recently, and to download tens of thousands of those shows without permission from the copyright owners. d. It was further part of the conspiracy that infringing Copies of copyrighted works were reproduced and stored on computer servers owned and leased in the United States and Canada, in order to further the distribution, streaming, and additional reproduction of those copyrighted works. e. It was further part of the conspiracy that members of the conspiracy used automated and manual software applications to process and repair the copyrighted television programs to make them easier for Jet?icks subscribers to search, 10 use, View, and download. f. It was further part of the conspiracy that members of the conspiracysold subscriptions to tens of thousands of customers around the United States, . including many in the Eastern District of Virginia, making et?icks? inventory of tens of thousands of copyrighted television programs available for streaming and, at times, downloading. g. It was further part of the conspiracy that members of the conspiracy searched the internet for users who were allowing others to obtain Jet?icks content for free by sharing et?icks logins and passwords, and sought to secure the Jet?icks site and servers to prevent individuals from ?stealing? et?icks content. h. It was further part of the conspiracy that members of the conspiracy would seek out new and popular television programs that they could distribute and stream without permission of the copyright owners, and would search manually for television programs on other websites hosting infringing content. i. It was further part of the conspiracy that members of the conspiracy made infringing copies of copyrighted works available through Jet?icks for streaming and, at times, for downloading. j. It was further part of the conspiracy that members of the conspiracy were notified that Jet?icks was engaged in copyright infringement and that Jet?icks was blocked from using certain applications and services, but they continued to operate and expand Jet?icks. . I k. It was further part of the conspiracy that members of the conspiracy searched for information on industry and law enforcement actions against 11 intemet piracy, undercover operations in this area, and the provisions of the Digital Millennium Copyright Act codified at Title 17, US. Code, Section 512, which provides, among other things, that when an online Service provider receives notice from a copyright owner or agent of the copyright owner regarding infringing material at the provider, it must act expeditiously to remove that material. 1. i It was further part of the conspiracy that members of the conspiracy ?nancially pro?ted from the reproduction, distribution, and streaming of infringing copies of copyrighted works made available to users through Jet?icks. m. It was further part of the conspiracy that members of the conspiracy performed various roles that served to promote the success of the conspiracy. Many members held multiple roles, not just one. Some of the roles included, but were not limited, to the following: 1) Management: DALLMANN ran the et?icks operation but COURSON and later JAUREQUI assisted with some of the management? responsibilities. Tasks included making strategic decisions about the direction and future of Jet?icks; helping with hiring decisions; and dealing with vendors and payment processors I 2) Computer programing and coding: DALLMANN, POLO, HUBER, VAILLANT, and VILLARINO handled Jet?icks? most technical tasks?those involving computer programing and coding. Duties included writing and revising computer scripts for the Jet?icks website and/ or mobile applications which would download, process, store, stream, and distribute infringing television programs on multiple devices using SickRage, Sick Beard, SAanbd, NZB indexer sites, 12 and similar software or internet locations; resolving ?broken? television programs-or television series that needed to be ?updated?; answering questions about how to use et?icks on multiple video streaming platforms and testing the service on different devices; providing advice on marketing strategies including improving Jet?icks? search engine and mobile app store rankings, increasing internet and mobile traf?c to Jet?icks, boosting the number of custOmers, advertising and distributing .Jet?icks mobile apps, and developing email and social media campaigns; and working on security tools including and ?digital rights management? to prevent-others from ?stealing? et?icks infringing television programs. 3) Design of website, apps, and customer interface and technical assistance: DALLMANN, COURSON, GARCIA, JAUREQUI, HUBER, POLO, and VILLARINO had duties helping design and improve the Jet?icks website, mobile apps, and customer interface, and also handled'related technical tasks. Responsibilities included working with Sick Beard, SickRage, SAanbd, NZB indexer sites, and similar software or internet locations to download, process, store, stream, and distribute infringing television pro grams requested by customers as well as new and upcoming shows; monitoring the load of Jet?icks? servers and ensuring the functioning of the servers; helping choose hardware to run et?icks assisting in the design of the Jet?icks website and mobile apps as well as accompanying marketing and social media communications; identifying issues with the Jet?icks subscriber interface, the et?icks television program inventory, and the quality of television pro grams and accompanying season/episode information, and seeking to improve these; creating lists of et?icks television programs; and testing Jet?icks on different devices. 13 4) Subscriptions and revenue: DALLMANN, COURSON, JAUREQUI, HUBER, POLO, VAILLANT, and VILLARINO had duties of ?xing issues with customer subscriptions and billing; tracking Jetflicks? actual or expected revenue; working on ideas to increase pro?tability and encourage additional subscribers and subscriber renewals; and helping determine popular television programs based on clicks and feedback from customers and then using that information to download these or similar shows. 5) Customer support: DALLMANN, COURSON, GARCIA, and JAUREQUI received and responded to complaints, requests, and questions from subscribers regarding missing or ?broken? shows, billing issues, and adding new shows to the et?icks database; shared information about ?broken? and requested shows with other members of the conspiracy; and drafted lists of subscribers and emails to be sent to customers. Overt Acts 14. It further was part of the conspiracy that at least the following acts in furtherance of and to effect the objects of the above-described conspiracy were committed in the Eastern District of Virginia and elsewhere: a. From at least January 5, 2009, until at least November 16, 2017, members of the conspiracy owned, rented, and used computer servers located in the United States and Canada to help run Jet?icks, including locating, reproducing, processing, storing, distributing, and streaming infringing copies of copyrighted materials. 14 b. From at least December 29, 2008, to at least November 16, 2017, .mernbers of the conspiracy accessed and controlled numerous internet domains related to Jet?icks, including jet?icksmobi, jet?icksnet, and jet?ickscom. I c. On or about May 20, 2012, members of the conspiracy caused a $29.99 charge to Mastercard number X9622, which belonged to M.G., a resident of Arlington, Virginia, in the Eastern District of Virginia, for a six?month Jet?icks subscription. I d. On or about July 24, 2012, members of the conspiracy caused a $29.99 charge to Visa card number X2153,'which belonged to M.T., a resident of Ashburn, Virginia, in the Eastern District of Virginia, for a six?month et?icks . subscription. e. On or about,Novernber 16, 2012, DALLMANN received from the Motion Picture Association of America on behalf of its members, cease?and? desist letters that?were sent by hand delivery, Federal Express, and email and that demanded that Jet?icks discontinue its unauthorized distribution of copyrighted material. f. On or about November 19, 2012, POLO searched the internet for ?mpaa website moles,? ?fake mpaa user account,? ?correct letter to dmca response,? and ?drnca reply,? and visited various related sites, including an article entitled Want to Help Quash The Pirate Bay.? g. On or about January 7, 2014, COURSON emailed DALLMANN to inform him, ?we do have the shameless episode but it doesn?t air until 1-12-14 so we are unable to run it as the basic info in sick beard from TVDB is not yet available. ?Simple Pleasures,? episode one of season four of the television program ?Shameless,? 15 aired on Showtime on January 12, 2014. h. On or about January 17, 2015, GARCIA emailed COURSON to complain, lot of the latest shows (example: little women LA, Snooki and wow, Penny Dreadful) are not airing the following day.? COURSON then responded, ?(those shows generally take several days .before the ?les are available, nothing we can do to make it faster, they are uploaded as soon as I see the ?les become available) - you can see some of the shows I am waiting for by going to Sickbeard Backlog I pull all these shows at least once a day until they come in.? i. On or about March 9, 20.15, and again on or about March 9, 2016, members of the conspiracy caused a charge of $133.75 to Visa card number X7270, which belonged to L.S., a resident of Arlington, Virginia, in the Eastern District of Virginia, for an annual Jet?icks subscription with additional services. j. On or about September 4, 2015, COURSON emailed HUBER and stated, ?Peter,Not sure what you changed but I am trying to upload shows and nothing is happening. It shows Last copy order still active! And none of the ?les (America?s Got Talent 0E22) are leaving the Sort ?le Please take a look at this and let me I need to get shov?vs uploaded.? Episode 22 of Season 10 of ?America?s Got Talen did not air until September 15, 2015. . k. On or about July 5, 2015, COURSON emailed DALLMANN, am trying to work the backlog and this is the response I am getting upon placing the ?le into ?Torrents? in the ?Downloads?'folder The item [kator]australiasnexttopmodel. can?t be copied because there isn?t enough free space.? Katcr referred to one of the domains for the torrent site Kickass Torrents. 16 l. I On or about October 9, 2015, members of the conspiracy received a comment on the Jet?icks acebook page from user J.W. that read, "?You do realize jet?icks is some bootleg shit right? You might be paying, but this is totally illegal I conten i . m. On or about February 24, 2016, May 24, 2016, and November 20, 2016, members of the conspiracy'caused a $19.99 charge to Visa card number X3 600, which belonged to a resident of Alexandria, Virginia, in the Eastern District of Virginia, for a three?month et?icks subscription. 11. On or about April 15, 2016, members of the conspiracy caused a charge of $19.99 to Visa card number X1030, which belonged to S.M., a resident of Alexandria, Virginia, in-the Eastern District of Virginia, for a three?month et?icks subscription. 0. On or about July 28, 2016, a member of the conspiracy using the email?address support@j' et'?ickscom sent an email to POLO, stating, ?You are a vital team member. . . but thats the Whole we are a team . Remember, I have to communicate to our clients when they have legitimate issues. I also have to communicate to Kris when I brag and say you earned every penny of your pay. I want to be able to show that we are functioning as a team and that issues are resolved as fast as they are noticed.? The email went on to discuss plans for a ?massive? project to increase the number of television pro grams at Jet?icks, improve the quality of the new uploaded shows and avoid customer complaints, and improve the ways the television programs displayed in Jet?icks. 1'7 p. On or about August 5, 2016, DALLMANN emailed VAILLANT a ?le called ?archiveizip? with subject ?server Scripts.? This zip ?le contained multiple PHP computer scripts for uploading TV shows, processing the shows, checking the shows, changing the shows? ?lenames, ?ripping? subtitles, putting the shows in a database for approval, and getting server status; many of the scripts containedthe text ?This is programmed by Darryl Polo as well as the server name jet?icksmobi and password. Some of the scripts state, IS TO BUILD A TABLE OF ALL THE TV SHOWS FOR THE AUTOMATIC - q. On or about August 9, 2016, members of the conspiracy caused a six-month subscription to begin for an undercover El agent in the Eastern District of Virginia, with a seven-day free trial. r. On or about August 9, 2016, members of the conspiracy, without permission from the copyright owner, caused the streaming of the episode ?Norman Saves the world? of the television program ?Ray Donovan,? which was originally aired on Showtime on August 7, 2016, when an undercover agent streamed this work in the Eastern District of Virginia from Jet?icks; 3. On or about August 15, 2016, members of the conspiracy caused a $29.99 charge to American Express X4255, which belonged to an undercover FBI agent located in the Eastern District of Virginia, for a six-month et?icks subscription. t. On or about October 3, 2016, using his Bank of America account X4488 in the name of Kris Dallmann dba Rentua?Geek, DALLMANN paid $680.04 to a company headquartered in Monroe, Louisiana, to lease IP address 67.77.105.136 that he used with Jet?icks. 18 u. On or about November 20, 2016, members of the conspiracy caused a $19.99 charge to Visa card number X3600, which belonged to B.P., a resident of Alexandria, Virginia, in the Eastern District of Virginia, for a three?month et?icks subscription. V. On or about December 29, 2016, members of the conspiracy, without permission from the copyright owner, caused the streaming of a copy of the episode ?Paradise? of the television program ?The which was originally aired on Net?iX on December 16, 2016, when an undercover agent streamed this work in the Eastern District of Virginia from et?icks. . W. On or about. January 4, 2017, members of the conspiracy, without permission from the copyright owner, caused the distribution of a copy of the episode f?Blood Washed Away? of the television program ?12 Monkeys,? which was originally aired on Syfy on July 11, 2016, when an undercover agent downloaded this work in the Eastern District of Virginia from et?icks. . X. On or about January 4, 2017, members-of the conspiracy, Without permission from the copyright owner, caused the distribution of a copy of the episode ?Memory of Tomorrow? of the television program ?12 Monkeys,? which was originally aired on Syfy on July 18, 2016, when an undercover agent downloaded this work in the Eastern District of Virginia from et?icks. y. On or about January 10, 201.7, members of the conspiracy caused a $29.99 charge to Capital One Bank card number X1449, whichbeIonged to R.L., a i resident of Woodbridge, Virginia, in the Eastern District of Virginia, for a six?month et?icks subscription. 19 z. On or about January 11, 2017, using his Wells Fargo bank account number $6241 in the name of Jet?icks, LLC, paid $59.95 to a company headquartered in Reston, Virginia, to provide Domain Name Servers services for Jet?icks. aa. On or about January 23, 2017, members of the conspiracy caused a charge of $133.75 to Visa card number X4242, which belonged to M.B., a resident of Ashburn, Virginia, in the Eastern District of Virginia, for an annual et?icks subscription with additional services. I ?bb. On orlabout January 27, 2017, using his Wells Fargo bank account number X6241 in the name of et?ieks, LLC, DALLMANN paid $400 to VILLARINO for services for et?icks. cc. On or about February 10, 2017,.using his Wells Fargo bank account number X6241 in the name of Jet?icks, LLC, DALLMANN paid $158 to a hosting provider in Canada to rent one or more servers to host 'Jet?icks. . dd. On or about April 3, 2017, DALLMANN and VILLARINO had the following exchange: When et?icks starts making crazy in a few DALLMANN How much do you need to make to be full? time for Jet?icks only? VILLARINO 120k a year DALLMANN . That Jet?icks made 750k 3 years 500k in And BALL . a sad 350k last year ALLM ANN If we didn't have the people that took advantage, we ?d be awesome ee. On or about April 18, 2017, members of the conspiracy caused a $16.97 charge to Visa card X0104, which belonged to an undercover FBI agent located in 20 ff. On or about May 18, 20l 7, DALLMANN and VILLARINO had I the Eastern District of Virginia, for a one~month Jet?icks subscription. the following exchange: let me explain the background of how we got there DALLMANN . the showswere out of with what was on the DALLMANN and the script that launches shows DALLMANN automatically (the scripts on. [servers] leOl?leO4) weren?t launching the shows properly I so We decided the best solution was to delete the entire shows database, and re?add the shows and have yonay DALLMANN create an admin interface Where we could use this new scripting to add shows if there ever was an issue VILLARINO 0k ALLMANN so he created it for us.. w.hich is the method you see when you go in the admin DALLMANN file manager TV Shows ALLMANN he did a pretty good job creating his script that adds shows to the VILLARINO 0k . then he tried to fix the scripting on 31 001-sl 004 so that DALLMANN new shows and episodes would launch in the same methods he created in his scripting ALLM ANN obvipusly that wasn?t since special characters . aren handled the same way which i don?t blame him he was just trying to fix" DALLMANN darryl scripting. . VILLARINO Show? was develop by DALLMANN YOnay that was the scripting that he developed to get all shows DALLMANN via server?side and repopulate the database based on . that information DALLMANN using the TVDB and Sickrage . . so basically he took the folder name, and used that in DALLMANN conjunction with the TVDB ID, and the ?les listed on the server to repopulate the database DALLMANN i will take credit for the 21 gg. On or about May 3, 2017, DALLMANN and VILLARJNO had thelfollowing exchange: DALLMANN and what should we start working on, lol VILLARINO When you will have the new design ready? well, security obviously, but we'll have to adapt our DALLMANN - show launching system I NH and we will be using a different version of SickRage DALL API [Application Programming VILLARINO Ok so maybe that part of once we know content can go into the correct folders, be secure, and write all info to DALLMANN the database properly from the SickRage then we can ?nish the site DALLMANN sound cool? DALLMANN so Security with 1. DALLMANN Setup 2 Servers in the office DALLMANN create launch modi?cations DALLMANN write to 3 (part 2) DALLMANN lol DALLMANN finish 4 VILLARINO 0k . ALLMANN awesome, I 11 start creating'more content and see you what time? hh. Between on or'about May 4 and 5, 2017, DALLMANN and VILLARINO communicated about the television pro grams being offered'on .IJet?icks. DALLMANN expressed an interest in ?.mp4 ?les . . . so there aren?t open files sitting on the server,? which led to the following exchange on or about May 5, 2017: I suppose I can do the it gives me DALLMANN more then just save the ?les instead of the ones as DALLMANN i dunno, you decide, lol VILL ARIN 0 read module/issues/596 ALLM ANN so 1t 11 be DRM [digital management] Instead of the regular 22 DALLMANN VILL ARIN 0 already ash the developer we can secure the video With out a license server DALLMANN haha, that wasn?t there when i opened the page DALLMANN if we need a license server, that link will probably be DALLMANN what we and it?s no big as long as we have redundant servers in different locations but I?d rather not have a license server if but DALLMANN be as secure as if we had a license server con?guration DALLMANN PlayReady isn?t an VILLARINO ols: DALLMANN just saying. . .lol let?s just the requirements are not aligned with our busrness DALLMAN (D PlayReady is a digital rights management technology developed by Microsoft that is intended to prevent the unauthorized copying of media ?les; to use PlayReady, a . company must enter into a license agreement with Microsoft. ii. On or about May 20, 2017, members of the conspiracy caused a charge of $133.75 to a Chase Bank card Visa number X0563, which belonged to .P., a resident of Alexandria, Virginia, in the Eastern District of Virginia, for an annual et?icks subscription with additional services. jj. . On or about May 22, 2017, DALLMANN corresponded with VILLARINO that the episodes were launching without the names being changed from SickRage, stating, ?Hey Luis, I?m sure you?re at work, but there?s an issue we?re having with the shows launching.? VILLARINO responded, ?What is the problem?? DALLMANN then noted, ?The episodes are launching without changing the name, and then launching them as' seasons.? He then sent VILLARINO a screenshot of ?ve episodes with ?le names showing that they came from pirate sites including, for example, 23 This was the episode ?Long Live Love? of the television program ?Switched at Birth,? which. originally aired April 11', 2017, on Freeform and was then available on Amazon Prime Video; according to the ?le name, the episode was ?ripped? from Amazon by the a ?release group? that distributed infringing content. DALLMANN then responded, ?Jared took it upon himself to put shows in the folders without renaming them properly.? Shortly after that, DALLMANN told VILLARINO, ?We launched over 600 episodes the past 4 days.? 0 kk. On' or about November 16, 2017, DALLMANN possessed two computers (one of "which was connected to an additional four hard drives) that contained, among other things, tens of thousands of downloaded video ?les and thousands of torrent files, with a creation date of the video ?les ranging from in or about August 2002 to November 16, 2018. For example, DALLMANN possessed multiple copiesof all seven episodes of season 7 of ?Game of Thrones,? which aired on HBO from July 16, 2017, to August 27, 2017. .These tens of thousands of downloaded video files included at least 10 copies of one or more copyrighted works withxa total retail value of more than $2,5 00. 11. On or about November 16, 2017, DALLMANN possessed a download folder on a computer that showed numerous downloaded infringing television programs. For example, on June 27, 2017, he downloaded all 12 episodes of ?Dark Shadows,? a 1991 television series, . I m. On or about November 16, 2017, DALLMANN caused the download of the episode ?Borderlines? of the television program Team,? which 24 was originally aired on CBS Televisio? on November 15, 2017, from the torrent site RARBG. . (All in Violation of Title 18, US. Code, Seotion 371, Title .18, US. Code, Section 506(a)(1)(A) (C), and Title 18, Code, Sections 23 25 COUNT TWO (17 U.S.C. 506(a)(1)(A) and 106(1) and 18 U.S.C. ?2319(b)(3) and 2 Criminal Copyright Infringement by Reproduction or Distribution and Aiding and Abetting) THE GRAND IURY CHARGES THAT: 15. The factual allegations contained in Paragraphs 1 through 4 are re-allegied and incorporated as if set forth herein in their entirety. i 16. On or about January 4, 2017, in the Eastern District of Virginia and. elsewhere, the defendant, KRISTOPHER LEE DALLMANN, did willfully, and for purposes of commercial advantage and private financial gain, infringe a copyright in the episode ?Blood Washed Away? of the television program ?12 Monkeys? by distributing a copy over the internet. (Allin Violation of Title 17, US. Code, Sections 506(a)(1)(A) and 106(1) and (3), and Title 18, US. Code, Sections 23l9(b)(3) and 2.) . 26 COUNT THREE (17 U.S.C. 506(a)(1)(A) and 106(1) and l8 U.S.C. ?2319(b)(3) and 2 Criminal Copyright Infringement by Reproduction or Distribution and Aiding and Abetting) THE GRAND JURY CHARGES THAT: 17. The factual allegations contained in Paragraphs 1 through 4 are re?alleged and incorporated as if set forth herein in their entirety. 18. On or about January 4, 2017, in the Eastern District of Virginia and elsewhere, the defendant, KRISTOPHER LEE DALLMANN, did willfully, and for purposes of commercial advantage and private financial gain, infringe a copyright in the episode ?Memory of Tomorrow? of the television program ?12 Monkeys? by distributing a copy over the internet. (All in violation of Title 17, U.S.Code, Sections 506(a)(1)(A) and 106(1) and (3), and Title 18, U.S.Code, Sections 23 l9(b)(3) and 2.) 27 COUNT FOUR (17 U.S.C. 506(a)(1)(A) and 106(4); 18 U.S.C. 2319(b)(3) and 2 4 Criminal Copyright Infringement By Public Performance and Aiding and Abetting) THE GRAND JURY CHARGES THAT: 19. The factual allegations contained in Paragraphs 1 through 4 are alleged and incorporated as if set forth herein in their entirety. 20. On or about December 29, 2016, in the Eastern District of Virginia and elsewhere, the defendant, KRISTOPHER LEE DALLMANN, did willfully, and for purposes of commercial advantage and private ?nancial gain, infringe a copyright in the episode ?Paradise? of the?television program ?The by streaming, that is, publicly performing the work over the internet. (Allin Violation of Title 17, U.S. Code, Sections 506(a)(1)(A) and 106(4), and Title 18, U.S. Code, Sections 2319(b)(3) and 2.) - 28 W. (17 U.S.C. 506(a)(1)(A) and 106(4); 18 U.S.C. 2319(b)(3) and 2 Criminal Copyright Infringement By Public Performance and Aiding and Abetting) THE GRAND JURY CHARGES THAT: 21. The factual allegations contained in Paragraphs 1 through 4 are re? alleged and incorporated as if set forth herein in their entirety. 22. On or about August 9, 2016, in the Eastern District of Virginia and elsewhere, the defendant, KRISTOPHER LEE DALLMANN, did willfully, and for purposes of commercial advantage and private ?nancial gain, infringe a copyright in the episode ?Norman Saves the World? of the television program ?Ray Donovan,? by streaming, that is, publicly performing the Work over the internet. (Allin Violation of Title 17, US. Code, Sections 506(a)(1)(A) and 106(4), and Title 18, U.S. Code, Sections 2319(b)(3) and 2.) 29 COUNT SIX (17 U.S.C. and 18 U.S.C. ?2319(d)(2) and 2 Criminal Copyright Infringement by Distributing a Copyrighted Work Being Prepared for Commercial Distribution and Aiding and Abetting) THE GRAND IURY CHARGES THAT: I 23. The factual allegations contained in Paragraphs 5 through 9 are re-alleged and incorporated as if set forth herein in their entirety. 24. On or about May 27, 2019, in the Eastern District of Virginia and elsewhere, the defendant, I DARRYL JULIUS POLO a/k/a djppimp, willfully, and for purposes of commercial advantage and private ?nancial gain, infringed a copyright by distributing a work being prepared for commercial distributionin the United States, namely, the copyrighted motion picture ?Us? by making it available on a computer network accessible to members of the public, when the defendant knew and should have known that the work was intended for commercial distribution. (Allin Violation of Title 17, US. Code, Sections 506(a)(1)(C) and Title 18, US. Code, Sections 23l9(d)(2) and 2.) .30 COUNT SEVEN (17 U.S.C. 18 USE. 23l9(d)(2) and 2 a Criminal Copyright Infringement by Distributing a Copyrighted Work Being Prepared for Commercial Distribution and Aiding and Abetting) - .THE GRAND JURY CHARGES THAT: 25. The factual allegations contained in Paragraphs 5 through 9 are re?alle'ged' and incorporated as if set forth herein in their entirety. On or about June 19, 2019, in the Eastern District of Virginia and elsewhere, the defendant, . DARRYL JULIUS PoLo a/k/a djppimp, willfully, and for purposes of commercial advantage and private ?nancial gain, infringed a copyright-by distributing a work being prepared for commercial distribution in the. United States, namely,the copyrighted motion picture ?Dumbo,? by making it available on a computer network accessible to members of the public, when the defendant knew and should have known that the work was intended for commercial distribution. (All in violation of Title 17, US. Code, Sections and Title 18, US. Code, Sections 2319(d)(2) and 2.). 31 COUNT EIGHT (17 U.S.C. 506(a)(1)(A) and 106(1) and 18 [1.8.0 ?2319(b)(3) and 2 Criminal Copyright Infringement by Reproduction or Distribution and Aiding and Abetting) THE GRAND JURY CHARGES THAT: 27. The factual allegations contained in Paragraphs 5 through 9 are re-alleged and incorporated as if set forth herein in their entirety. 28. On or about January 4, 2017, in the Eastern District of Virginia and elsewhere, the defendant, DARRYL JULIUS POLO a/k/a djppimp, did willfully, and for purposes cf commercial advantage and private financial gain, infringe a copyright in the episode ?Red on Red? of the television program ?Shooter? by distributing a copy over the internet. (Allin Violation of Title 17, US. Code, Sections 506(a)(1)(A) and 106(1) and (3), and Title 18, U.S. Code, Sections 23 l9(b)(3) and 2.) 32 COUNT NINE (17 U.S.C. 506(a)(l)(A) and 106(1) and 18 U.S.C. ?2319(b)(3) and 2 Criminal Copyright Infringement by Reproduction or Distribution and Aiding and Abetting). THE GRAND JURY CHARGES THAT: 29. The factual allegations contained in Paragraphs 5 through 9 are renalleged and incorporated as if set forth herein in their entirety. A 30. On or about January 4, 2017, in the Eastern District of Virginia and elsewhere, the defendant, DARRYL JULIUS POLO a/k/a djppimp, did willfully, and for purposes of commercial advantage and private ?nancial gain, infringe a copyright in the of the motion picture ?Finding Dory? by distributing a copy over the internet. (All in yiolation of Title 17, U.S. Code, Sections 506(a)(l)(A) and 106(1) and (3), and Title 18, U.S. Code, Sections 2319(b)(3) and 2.) 33 COUNT TEN (17 U.S.C. 506(a)(1)(A) and 106(4); 18 U.S.C. 2319(b)(3) and2 Criminal Copyright Infringement By Public? Performance and Aiding and Abetting) THE GRAND IURY CHARGES THAT: 31. The factual allegations contained in Paragraphs 5 through 9 are re?alleged and incorporated. as if set forth herein in their entirety. 32. On or about September 1, 2016, in the Eastern District of Virginia and elsewhere, the defendant, 2 DARRYL JULIUS POLO a/k/a djppimp, did willfully, and for purposes of commercial advantage and private ?nancial gain, infringe a Copyright in the episode ?How to Live? of the television program ?Tyrant,? by streaming, that is, publicly performing the work over the internet. (All 1n Violation of Title 17, U. S. Code, Sections 506(a)(1)(A) and 106(4), and Title 18, U. S. Code, Sections 2319(b)(3) and 2.) 34 COUNT ELEVEN (l7 U.S.C. 506(a)(1)(A) and 106(4); 18 U.S.C. 2319(b)(3) and 2 Criminal Copyright Infringement By Public Performance and Aiding and Abetting) THE GRAND JURY CHARGES THAT: 33. The factual allegations contained in Paragraphs 5 through 9 are re?alleged and incorporated as if set forth herein in their entirety. 34. On or about December 29, 2016, in the Eastern District of Virginia and elsewhere, the defendant, DARRYL JULIUS POLO a/k/a djppimp,? did willfully, and for purposes of commercial advantage and private financial gain, infringe a copyright in the motion picture ?Inferno,? by streaming, that is, publicly performing the work over the internet. (Allin Violation of Title 17, US. Code, Sections 506(a)(1)(A) and 106(4), and Title 18,- U.S. Code, Sections 2319(b)(3) and 2.) 35 COUNT TWELVE (18 U.S.C. 195 and and Z?Money Laundering and Aiding and Abetting) THE GRAND JURY CHARGES THAT: . 35. The factual allegations contained in Paragraphs 1 through 4 are re-alleged and incorporated as if set forth herein in their entirety. 36. On or about January 10, 2017, in the Eastern District of Virginia and elsewhere, the defendant, KRISTOPHER LEE DALLMANN, did knowingly conduct and attempt to conduct a ?nancial transaction affecting interstate and foreign commerce, namely, by making a payment through Wells Fargo bank account number X6241 in the name Jet?icks, LLC to a company headquartered in Reston, Virginia, to provide Domain Name Server services for Jet?icks, which involved the proceeds of a speci?ed unlawful activity, that is, criminal copyright infringement and conspiracy to commit criminal copyright infringement, in the Eastern District of Virginia and elsewhere, with the intent to promote the carrying on of that speci?ed unlawful activity, and knowing-that the transaction was designed in whole and in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of that ?specified unlawful activity, and that while conducting and attempting to conduct such financial transaction knew that the property involved in the financial transaction represented the proceeds of that speci?ed unlawful activity. - (Allin violation of Title 18, US. Code, Sections 1956(a)(1)(A)(i) and and 2.) ?36 COUNT THIRTEEN (18 U.S.C. 1956(a)(1)(A)(i) and and 2?Money Laundering and Aiding and Abetting) THE GRAND JURY CHARGES THAT: 37. The factual allegations contained in Paragraphs 1 through 4 are re?alleged . and incorporated as if set forth herein in their entirety. I. i 38. ?On or about January 27, 2017, in the Eastern District of Virginia and. elsewhere, the defendant, . . LEE DALLMANN, did knowingly conduct and attempt to conduct a ?nancial transaction affecting interstate and foreign commerce, namely, by making a payment through Wells Fargo bank account number n6241 in the name Jet?icks, LLC to LUIS ANGEL for computer programming and coding services to Jet?icks, which involved the proceeds. of a specified unlawful activity, that. is, criminal copyright infringement and conspiracy to commit criminal copyright infringement, in the Eastern District of Virginia and elsewhere, with the'intent to promote the carrying on of that specified unlanul activity, and knowing that the transaction was designed in Whole and in part to conCeal and disguise the nature, location, scurce, ownership, and control of the-'proceedsof that speci?ed unlawful activity, and that while Conducting and attempting to conduct such ?nancial transaction knew that the property involved in the financial transaction represented the proceeds of that speci?ed unlawful activity. (All. in violation of Title '18, US. Code, Sections and and 2.) 37 COUNT FOURTEEN (18 U.S.C. 1956(a)(l)(A)(i) and and 2~?Money Laundering and Aiding and Abetting) THE GRAND JURY CHARGES THAT: 39. The factual allegations contained in Paragraphs 1 through 4 are re-alleged and incorporated as if set forth herein in their entirety. 40. On or about February 9, 2017, in the Eastern District of Virginia and elsewhere, the defendant, KRISTOPHER LEE DALLMANN, did knowingly conduct and attempt to conduct a ?nancial transaction?affecting interstate and foreign commerce, namely, by making a payment through Wells lFargo bank account number x6241 in the name et?icks, LLC to a hosting provider in Canada to rent one or more servers to host Jet?icks, which involved the proceeds of a speci?ed unlawful activity, that is, ?Crirninal copyright infringement and conspiracy to commit criminal copyright infringement, in the Eastern District of Virginia and elsewhere, with the intent to promote the carrying on of that speci?ed unlawful activity, and knowing that the transaction was designed in whole and in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of that speci?ed unlaw?il activity, and that while conducting and attempting to conduct such ?nancial transaction knew that the property involved in the ?nancial transaction represented the proceeds of that speci?ed unlawful activity. (Allin violation of Title 18, US. Code, Sections l956(a)(l)(A)(i) and and 38 COUNT IFTEEN (l 8 U.S.C. l956(a)(3)(A) and (B) and 2?Money Laundering and Aiding and Abetting) THE GRAND JURY CHARGES THAT: 41. The factual allegations contained in Paragraphs 1 through 4 are re?alleged and incorporated as if set forth hereinlin their entirety: 42. On or about October 3, 2016, in the Eastern District of Virginiaand elsewhere, the defendant, KRISTOPHER LEE DALLMANN, with the intent to promote the carrying on of a speci?ed unlawful activity, namely, criminal copyright infringement and conspiracy to commit criminal copyright infringement, and the intent to conceal and the nature, location, source, ownership, and control ofpropertyi believed to he proceeds of that speci?ed unlawful activity, did linowingly conduct and attempt to conduct a ?nancial transaction affecting interstate and foreign commerce, namely, by making a payment through Bank of America bank account number X4488 in the name of Kris Dallmann dba Rent?a?Geek to a company headquartered in Monroe, Louisiana, to lease Internet Protocol address 67.77.105.136 for use with Jet?icks, Which involved property represented by a law enforcement of?cer and agent to he proceeds of that speci?ed unlawful activity in the Eastern lDistrict of Virginia and elsewhere, and property used to conduct and facilitate that speci?ed unlawful activity. I (All in violation of Title 18, US. Code, Sections 1956(a)(3)(A) and (B) and 2.) 39 COUNT SIXTEEN . (18 U.S.C. l956(a)(1)(A)(i) and. and Z?Money Laundering and Aiding and Abetting) THE GRAND JURY CHARGES THAT: 43. The factual allegations contained in Paragraphs 5 through 9 are reualleged and incorporated as if set forth herein in their entirety. 44. On or about June2, 2017, in the Eastern District of Virginia and elsewhere, the defendant, DARRYL JULIUS POLO a/k/a djppimp, did knowingly conduct and attempt to conduct a financial transaction affecting interstate and foreign commerce, namely, by making a payment through Wells Fargo bank account number X8077 in the name of LP. to a company headquartered in Foster City, California, to provide payment gateway services for ISIA, which involved the proceeds of a specified unlawful activity, that is, criminal copyright infringement and conspiracy to commit criminal copyright infringement, in the Eastern District of Virginia and elsewhere, ?with the intent to promote the carrying on of that specified unlawful activity, and knowing that the transaCtion was designed in whole and in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of that speci?ed unlawful activity, and that while conducting andattempting to conduct such financial transaction knew that the property involved in the financial transaction 1 represented the proceeds of that speci?ed unlawful activity. (Allin Violation of Title 18, US. Code, Sections 1956(a)(1)(A)(i) and and 2.) 40 COUNT SEVEN TEEN (18 U.S.C. 195 and and Z?Money Laundering and Aiding and Abetting) THE GRAND JURY CHARGES THAT: 45. The factual'allegations contained in Paragraphs 5 through 9 are re?alleged and incorporated as if set forth herein in their entirety. 46. On or about June 14, 2017, in the Eastern District of Virginia and elsewhere, the defendant, DARRYL JULIUS POLO a/k/a djppimp, did knowingly conduct and attempt to conduct a ?nancial transaction, affecting interstate and foreign commerce, namely, by making a payment through Wells Fargo bank account number X8 077 in the name of LP. to a company?headquartered in Atlanta, Georgia, for high-speed internet service used to help run ISIA, which involved the proceeds of a Specified unlawful activity, that is, criminal copyright infringement and conspiracy to commit criminal copyright infringement, in the Eastern District of Virginia and elsewhere, with the intent to promote the carrying on of that specified unlawful activity, and knowing that the transaction was designed in whole and in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of that Specified unlaw?il activity, and that while conducting and attempting to conduct such financial transaction knew that the property involved in the ?nancial transaction represented the proceeds. of that speci?ed unlawful activity. 1 (Allin violation of Title-1 8, US. Code, Sections l956(a)(1)(A)(i) and and 2.) 41 COUNT EIGHTEEN (18 U.S.C. 195 and and 2-?Money Laundering and Aidng and Abetting) THE GRAND JURY CHARGES THAT: 47. The factual allegations contained in Paragraphs 5 through 9 are re-alleged and incorporated as if set forth herein in their entirety. 48. From on or about July 29, 2017, to on or about August 30, 2017, in'the Eastern District of Virginia and elsewhere, the defendant, I DARRYL JULIUS POLO a/k/a djppimp, did kndwingly conduct and attempt to conduct a ?nancial transaction affecting interstate and foreign commerce, namely, by making a payment through Wells Fargo bank account number X8077 in the name of L.P. to a hosting provider in Canada to rent one or more- servers to host ISIA and websites used to obtain television programs and motion pictures for ISIA, which involved the proceeds of a speci?ed unlawful activity, that is, criminal copyright infringement and conspiracy to commit criminal copyright infringement, in the Eastern District of Virginia and elsewhere, with the intent'to promote the carrying on of that speci?ed unlawful activity, and knowing that the transaction was designed in whole and in part to conceal and disguise the nature, location, source,ownership, and control of the proceeds .of that speci?ed unlawful activity, and that while conducting and attempting to conduct such ?nancial transaction knew that the property involved in the ?nancial transaction represented the proceeds of that speci?ed unlawful activity. (Allin violation of Title 18, U.S. Code, Sections 1956(a)(l)(A)(i) and and 2.) 42 COUNT NINETEEN - (18 U.S.C. 1956(a)(3)(A) and (B) and2?-Money Laundering and Aiding and . Abetting) THE GRAND CHARGES THAT: 49. The factual allegations contained in Paragraphs 5 through 9 are re-alleged and incorporated as if set forth herein in their entirety. 50. On or about September 16, 2016, in the Eastern District of Virginia and elsewhere, the defendant, I DARRYL JULIUS POLO a/k/a djppimp, I with the intent to promote the carrying on of aspeci?ed unlawful activity, namely, criminal copyright infringement and conspiracy to commit criminal copyright infringement, and the intent to conceal and disguise the nature, location, source, ownership, and control of property believed to be proceeds of that speci?ed unlawful activity, did knowingly conduct and attempt to conduct a ?nancial transaction affecting interstate and foreign commerce, namely, by making a payment through Wells Fargo bank account number X8077 in the name of LP. to a company headquartered in Phoenix, Arizona, to purchase Secure Sockets Layer certi?cates for the servers he used for'lSIA, which involved property represented by a law enforcement of?cer and agent to be proceeds of that speci?ed unlawful activity in the Eastern District of Virginia and elsewhere, and property used to conduct and facilitate that speci?ed unlawful activity. (All inviolation of Title 18, US. Code, Sections l956(a)(3)(A) and (B) and2.) 43 NOTICE OF FORFEITURE (18 U.S.C. 18 U.S.C. 982(a)(l); 18 U.S.C. ?2323; 21 U.S.C. 853; 28 U.S.C. 51. The allegations contained in Paragraphs 1 through 9 and Counts One through Nineteen of this Indictment are hereby realleged and incorporated by reference for the purpose of alleging forfeiture. THE GRAND IURY HEREBY FINDS THAT: 52. There is probable cause that the property described in this NOTICE OF FORFEITURE is subject to forfeiture pursuant to the statutes described herein. Notice as to Counts One through Nineteen as to All Defendants 5 3. Pursuant to Federal Rule of Criminal Procedure the United States of America gives notice to all defendants that, in the event of a conviction of any of the offenses charged in Counts One through Nineteen of this Indictment, the United States intends to forfeit the property of that defendant as is further described in this FORFEITURE NOTICE. 54. Pursuant to 18 U.S.C. as incorporated by 28 U.S.C. 2461(0), each defendant who is convicted of conspiracy to commit criminal copyright infringement, in violation of 18 U.S.C. 371, shall forfeit to the United States any property, real or personal, which constitutes or is derived from proceeds traceable to the conspiracy. 55. Pursuant to 18 U.S.C. 2323, each defendant who is convicted of criminal I copyright infringement, in violation of 17 U.S.C. 506 and 18 U.S.C. 2319, shall forfeit to the United States: 44 a. any article, the making or traf?cking of which is, prohibited under 17 U.S.C. 506 or 18 U.S.C. 2319; b. any property used, or intended to be used, in any manner or part to commit or facilitate the commission of a violation of or 17 U.S.C. 506 or 18 U.S.C. 2319; and 0., any property constituting or derived from any proceeds obtained directly or indirectly as the result of the commission of a violation of 17 U.S.C. 506 or 18 U.S.C. 2319. 56. Pursuant to 18 U.S.C. 982(a)(1), each defendant who is convicted ?of money laundering, in violation of 18 1956, shall forfeit to the United States any property, real or personal, involved in such offense, and any property traceable to such . property. Property Subject to Forfeiture 57. The United States of America gives notice to all defendants that the property to be forfeited includes, but is not limited to, the following: 1. Drobo 5D direct attached storage array, model serial number DRB141901700606, containing a Plextor M6M 64GB solid state drive, model PX-64M6M, provided by KRISTOPHER LEE DALLMANN to agents on or about November 20, 2017; 2. The following items seized on or about November 16, 2017, from a house in Las Vegas, Nevada, used by DALLMANN for Jet?icks: a. Apple watch, red, serial number b. Supersonic Magnum 128GB thumb drive, black and blue; 0. HTC Nexus tablet, serial number 45 Small computer, make unknown, serial number W03 103 000249; Toshiba 5126B solid state drive, serial number Seagate 2TB hard drive, serial number Seagate 2TB hard drive, serial number Seagate 2TB hard drive, serial number Apple MacBook Pro computer, serial number Computer in Thermaltake case, serial number . W037 7N 1103000426; Apple Mac mini computer inside blue Jet?icks case; Apple Mac mini computer, serial number YM9522Q09G5 Apple Mac mini computer, serial number Apple Mac mini computer, serial number YM003 Apple Mac mini computer, serial number Apple Mac mini computer, serial number Apple Mac mini computer, serial number Apple Mac mini computer, serial number Apple Mac mini computer, serial number Apple Mac mini computer, serial number 46 8.8.. bb. 00. dd. 66. ff. gg. ii. ji- Apple Mac mini computer, serial number Apple Mac mini computer, serial number . Apple Mac mini computer, serial number C07CU87FDD6K, Apple Mac mini computer, serial number Apple Mac mini computer, serial number C07F 3 Apple Mac mini computer, serial number- Apple Mac mini computer, serial number C07G3 Y7 Apple Mac mini computer, serial number. Apple Mac mini computer, serial number Apple Mac mini computer, serial number Apple Mac mini computer, serial number Apple Mac mini computer, serial number YMO 0223 Seagate 7200.12 hard drive, serial number Hitachi 640GB hard drive, serial number HP Invent hard drive, serial number Seagate 1TB hard drive, serial number 47 ll. 00. PP-, qu SS. uu. XX. ZZ. 38.8.. 000. Nokia phone, White; Hitachi hard drive, serial number YAGHXS WD hard drive, serial number HP Invent 146GB hard drive, serial number Western Digital 1.5TB hard drive, serial number WMAZA923 623 1 Hitachi hard drive, serial number 7 Seagate hard drive, serial number Hitachi hard drive, serial number Western Digital 500GB hard drive, serial number Apple hard drive, serial number C8 Seagate 500GB hard drive, serial number WD 1.5TB 64MB cache hard driVe, Serial number WD 1.5TB 64MB cache hard drive, serial number Seagate 1TB hard drive, serial number WD hard drive, serial number Seagate hard drive, serial number WD 64MB cache hard drive 1.5TB, serial number WMAZA92725 82; DN computer thumb drive; Apple Mac mini computer, serial number 48 ?66. - 111. 000. quI- 1.11.111. Apple Mac mini computer, serial number Apple Mac mini computer, serial number Seagate AZTB hard drive, black, serial number Samsung Tablet, black, in OtterB OX, with Windows Vista; Apple Mac mini computer, serial number owe hard drive, serial number - (Er?Technology 4TB dual hard drive, serial number . G?Technology 4TB dual hard drive, serial number . Sprint serial number . SanDisk 16GB thumb drive, G?Force 320GB hard drive, serial number BMW 8GB micro SD card; MacBook Pro computer, serial number Apple TV, serial number iPad tablet 16GB, serial number Apple Mac mini computer, serial number Elgato Game Capture HD60, serial nurriber - Drive MWI 320GB hard drive in case, 'serial number 49 6686. Apple Mac mini computer, model A1345, serial number Samsung tablet, model serial number Apple laptop, serial number ASUS tablet, model TF3 DOT serial number 15 100? 03 Sarnsung 16 GB tablet, model SM-TBZO, serial number . ASUS Nexus tablet, black; Apple Mac Pro computer, model A1289, serial number Sony PlayStation Vita with memory card, serial number .1 Google cell phone, model blue and white; Sandisk Cruzer Micro 2.0GB thumb drive, Five USB Devices including; 64 GB Sony serial number USM64CA1 Nintendo Switch Mariokart8 serial number AABPA13A000, Apple MacBook Air stick containing drivers serial number A1384, Smith Wesson Connect thumb drive, and a device labled Elite by Centron; Polaroid Cube camera; LaCie hard drive, model LRDOTU6, serial number NL3 5 1 SZS Microsoft Xbox 3 60, serial number 562319214105 Kingston DataTraveler 4GB thumb drive, model DT108, on keychain; 2' 50 LG smart watch, serial number 1111. Apple iPad with red case, serial number Apple computer tower, model A1289, serial number H093 Duracell 64GB thumb drive; PNY 32GB thumb drive; LaCie hard drive, model serial number Home-built computer in Therrnaltake case; and Super Micro server, serial number L82600052KF 1358. The following items seized On or abOut November 16,2017, from a second house in Las Vegas, Nevada, used by DALLMANN for Jet?icks: a. Apple MacBook Pro computer, model A1398, serial number b. I NeXStar Sata 6GB hard drive, model serial number 0657108425; c. SIIG SuperSpeed USB 3.0 to Sata 2.5? enclosure; d. Apple iPhone, White, model A13 87, serial number e. Seagate 1TB had drive, serial number f. Apple iPad 64GB tablet, model A1397, serial number g. Toshiba laptop, part number serial number 760274801; and h. Dell computer, 42940? serial number J3ZF451 51 The following items seized on or about November 16, 2017, from a house in Las Vegas, Nevada, used by DARRYL JULIUS POLO a/k/a djppimp for ISIA: a. ASUS tablet, silver, serial number b. Toshiba hard drive, red, serial number c. WD ?My Passport Ultra" hard drive, serial number d. Seagate Expansion portable hard drive, serial number e. Sandisk 4GB thumb drive, black and White, model serial number f. Apple MacBook Pro, silver, serial number g. Seagate Expansion desktop hard drive, black, model SRDONFZ, serial number h. LG Computer Tower in Cooler Master case, serial number RC310BKR2009450033 8; . i. Seagate Expansion desktop hard drive labeled ?Wii?U?, black, serial number j. . .1 Seagate Expansion desktop hard drive labeled "Xbox-3 60,? black, serial number k. Seagate Expansion desktop hard drive labeled black, serial number 1. Apple MacBook Air, silver, serial number Cl 7MXDB3 G085 m. DREVO X1 60 GB solid state drive, serial number n. Computer tower in Corsair case, serial number 054615029704; 1 52 bb. CC. dd. Computer tower in Thermaltake case, serial number Toshiba 500 GB hard drive, serial number Z3 70CL5 HGST hard drive, part?number 0Fl4696, serial number - Computer tower serial number 148 023 7 Computer tower in Thermaltake case, white, serial number SoftLayer server, serial number Hitachi hard drive, serial number Seagate Backup Plus portable hard drive, serial number Unirex 8GB thumb drive; Kingston 8GB Micro SD card serial number 5150885508; Apple iPhone, model Al 6 8 8, gold and white; Grey Apple iPhone . Samsung Galaxy S6 Edge cell phone, model IMEI number 359715061543880; Seagate Constellation hard drive, model ST31000524NS, serial number Samsung 1TB hard drive, model HD103 SJ serial number and Toshiba laptop computer, blue, part number 01 5 00 8. 4. 7 The following domain names used by DALLMANN for Jet?icks: jet?icks.mobi, jet?icksnet, and jet?icks.com; and ?53 5 . The following domain names used by POLO for ISIA: istreamitalleom and istreamitallmobi. Substitute Assets 58. If any of the property described above, as a result of an act or omission of the defendants, a. cannot be located upon the exercise of due diligence; b. has been transferred to, sold to, or deposited with a third party; 0. has been placed beyond the jurisdiction of the Court; d. has been substantially diminished in yalue; or e. a has been cominingled with other property which cannot be divided ?Without dif?culty, the United States shall be entitled to and intends to seek forfeiture of substitute property 54 pnrsuant to 21 U.S.C. 853(p), as incorporated by 18 U.S.C. 982(b)(1) and 2323(b)(2), and 28 U. S. 2461(0). (In accordance with Title 18, United States Code, Sections 982(a)(1) and 2323; Title 21, U. S. Code, Section 853(p); Title 28 U. S. Code Section 2461(c); and Rule Federal Rules of Criminal Procedure.) . G. ZACHARY TERWILLIGER A TRUE BILL: UNITED STATES ATTORNEY WV . ALEXANDER P. EEREANG . Fereperson of the Grand Jury ASSISTANT UNITED STATES A TORNEY MATTHEW A. LAMBERT SENIOR COUNSEL COMPUTER CRIME AND INTELLECTUAL PROPERTY SECTION U. S. DEPARTMENT OF JUSTICE 55