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Case: 1:19-cr-00275 Document #: 23 Filed: 07/25/19 Page 1 of 18 PageID #:170

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EASTERN DIVISION

JUL 2 5 20t9

UNITED STATES OF AMERICA
Case No. 19 CR275

v.
WETYLIN HUANG,
also known as "Kelly Huang,"
FINDREAM, LLC, and
SINOCONTECH, LLC

1.

ruLY

ONE

JUDGE DURKIN

2018 GRAND JURY charges:

At times material to this indictment:

a.

,HffIro.;i,ili,..:

Violations: Title 18, United States
Code, Sections 371,1546(a), and 2

COUNT
The SPECIAL

RECE tVED

MACiSTRATE JUDGE

WETYUN HUANG, also known as "Kelly Huang," was a citizen of

the People's Republic of China.

b.

FINDREAM, LLC was incorporated in the State of California by

HUANG. FINDREAM maintained a bank account at JP Morgan Chase Bank, for

which HUANG was the sole signatory. FINDREAM maintained an account with
PayPal, for which HUANG was the registered user.

c.

SINOCONTECH, LLC was incorporated in the State of Delaware

d.

The "Chinese Looking For Job" website was the China-based

by HUANG.

website for HUANG and FINDREAM.

e.

The "Job Hunters of North America" WeChat platform was the

China-based WeChat platform for HUANG and FINDREAM.

f.

University A was a university located in Chicago, Illinois.

@E

 Case: 1:19-cr-00275 Document #: 23 Filed: 07/25/19 Page 2 of 18 PageID #:170

g.

An F-1 visa permitted a foreign national to study in the United

States at a university, college, or other academic institutions. Before applying for an

F-1 visa, students had to first be accepted by a Student and Exchange Visitor
Program ("SEV;'"; approved school. Afber the SEVP-approved school accepted a
foreign national as a student, the student had to be registered in the Student and
Exchange Visitor Information System ('SEVIS"). The SEVP-approved school issued

the student a Form I-20 "Certif.cate of Etigibility for Nonimmigrant Student Status

-

For Academic and Language Students." After the student received the Form I-20

and registered

in SEVIS, the student had to appiy at a U.S. Embassy or Consulate

for a student F-1 visa. The student was required to present the Form I-20 to the
consular of6"cer during the visa interview.

h.

An F-l visa-holder could extend. the visa by participating in the

Optional Practical Training ('OPT") program, which required the F-l visa-holder to
obtain temporary employment directly related to their major area of study. The OPT
employment could be completed before and/or after completion of the F-1visa-holder's

studies for up to one year. An

F-l visa-holder who received a science, technolory,

engineering, and mathematics ("STEM') degree could extend participation

in

the

OPT program for up to an additional2years. A student was required to list their OPT

employment on their Form I-20.

A student was required to submit a Form

Training Plan for STEM OPT Students
extension.

I-983

in order to apply for the STEM OPT

 Case: 1:19-cr-00275 Document #: 23 Filed: 07/25/19 Page 3 of 18 PageID #:170

i.

An H-18 visa permitted United

States-based employers to

temporarily employ foreign national workers in specialty occupations. A specialty
occupation required the application of specialized knowledge and a bachelor's degree

or the equivalent of work experience. An H-18 visa permitted a foreign national to
stay in the United States for three years, and was extendable to six years.

2.

Beginning no later than on or about September 6,2013, and continuing

until on or about April 7 2019, at Chicago, in the Northern District of Illinois, and
elsewhere,

WEIYUN HUANG,
also known as "KeIIy Huang,"
FINDREAM, LLC, and

SINOCONTECH, LLC,
defendants herein, conspired with Individuals XQ, LT, YG, JC, JL, and SZ, and others

known and unknown to the Grand Jury to knowingly subscribe as true under penalty
of perjury under 28 U.S.C. S 1746 a false statement

with respect to a material fact in

d.ocuments required. by the immigration laws and regulations prescribed thereunder,

namely, nonimmigrant H-1B visas and Optional Practical Training extensions on
nonimmigrant F-1 student visas, that is, Forms I-20,I-129, and I-983, stating that
the students were employed by FINDREAM, LLC and SINOCONTECH, LLC, which
statements the defendants then knew were fa1se,

in that the students were not

employed by FINDREAM, LLC or SINOCONTECH, LLC,

in violation of Title

18,

United States Code, Section 1546(a).

3.

It was part of the conspiracy that beginning

September 6, 2013, and continuing

no later than on or about

until on or about April
3

t,

2019, HUANG and

 Case: 1:19-cr-00275 Document #: 23 Filed: 07/25/19 Page 4 of 18 PageID #:170

FINDREAM falsely and fraudulently represented, in exchange for a fee, that at least
approximately 2,025 F-1 visa holders

in the United States while employed by

FINDREAM, when they knew that the visa holders were

.not

employed at

FINDREAM.

4.

It was further part

of the conspiracy that beginning no later than on or

about December 12, 2016, and continuing until on or about April L, 2019, HUANG
and SINOCONTECHprovided false and fraudulent employment at SINOCONTECH

to at least approximately 660 F-1 visa holders in the United States in exchange for a
fee, when they knew that the F-1 visa holders were not employed at SINOCONTECH.

5.

It was further part

of the conspiracy that beginning no later than on or

about April 1,2017, and continuing until on or about

April L,2019, HUANG

and

FINDREAM applied for nonimmigrant H-lB-visas in the United States for at least
approximately 8 customers by falsely and fraudulently claiming those customers
were employed at FINDREAM in exchange for a fee, when they knew that the H-18

visa applicants were not employed at FINDREAM.

6.

It

was further part of the conspiracy that HUANG and FINDREAM

advertised FINDREAM as a "startup company in technology services and consulting"

with clients in China and the United States on its website "www.findream.us," when
they knew FINDREAM, LLC did not deliver any technology services or consulting.
7

It

-

Novembe

r

was further part of the conspiracy that beginning no later than

2014, at the direction of HUANG and FINDREAM, Ind,ividual XQ agreed

to write computer code in order to develop portions of the "www.fi.ndream.us" website.

4

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8.

It

was further part of the conspiracy that HUANG used FINDREAM

and SINOCONTECH to provide proof of OPT employment to their customers, who
were F-1 visa-holders in the United States, in exchange for a fee, when they knew

that FINDREAM and SINOCONTECH did not employ the customers.

9.

It

was further part of the conspiracy that HUANG used the "Chinese

Looking for Job" website and "Job Hunters of North America," WeChat platform to
advertise FINDREAM and SINOCONTECH to F-1visa-hold.ers in the United States
seeking OPT employment and H-1B visas.

10. It was further party of the conspiracy that beginning no later than in or
around 2015, at the direction of HUANG and FINDREAM, Individual XQ agreed to

monitor and manage the content of the "Job Hunters of North America" WeChat
platform.

11. It was further part of the conspiracy that HUANG, FINDREAM, and
SINOCONTECH provided customers offer letters and verifi.cation of employment
Ietters as evidence of the customers'employment at FINDREAM or SINOCONTECH

in exchange for a fee, when they knew that that these materials were false and that
the customers did not work for FINDREAM or SINOCONTECH.

12. It was further part of the conspiracy

that HUANG, FINDREAM, and

SINOCONTECH's services permitted customers

to list FINDREAM or

SINOCONTECH as their OPT employer on their Forms I-20 in exchange for a fee,

when they knew that the customers did not work for FINDREAM
SINOCONTECH.

or

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13. It was further part of the conspiracy

that HUANG, FINDREAM, and

SINOCONTECH executed Forms I-983 OPT Training Plans

for their

STEM

customers in exchange for a fee, when they knew that these materials were false and

that the customers did not work for FINDREAM or SINOCONTECH.

t4. It was further part of the conspiracy that HUANG

and FINDREAM

issued payroll payments to customers for a fee as further evidence of the customer's

purported employment at FINDREAM, when they knew that the customers supplied
the payroli fuodr, had not performed any work for FINDREAM, and were not entitled

to any payroll payment.

15. It was further part of the conspiracy that HUANG

and FINDREAM

issued Form 1099-MISC tax forms to customers for a fee as further evidence of the
customer's purported employment at FINDREAM, when they knew the customers

did not do any work for FINDREAM and did not receive taxable income from
FINDREAM.

Indiuidual LT

16. It was further part of the conspiracy that HUANG

and FINDREAM

agreed to provide Individual LT an offer letter, a Form I-983 OPT Training Plan,

payroll, and a Form 1099-MISC tax form, all showing that Individual LT worked for
FINDREAM, so that Individual LT could report FINDREAM as his employer in a
document required by the immigration laws or regulations prescribed thereunder,

when they knew Individuat LT did not work for FINDREAM.

In exchange,

Individual LT paid HUANG and FINDREAM a total of $4,970 in 2016 through 2018.

 Case: 1:19-cr-00275 Document #: 23 Filed: 07/25/19 Page 7 of 18 PageID #:170

17. It was further part of the conspiracy that HUANG and FINDREAM
received an additional $29,750 from Individual LT

in 2016 through

2018, and paid

Individual LT a total of $29,750 in 2016 through 2018, for his purported employment

with FINDREAM, when they knew that Individual LT did not work for FINDREAM
and the source of the purported FINDREAM income was Individual LT.

18. It was further part of the conspiracy that HUANG and FINDREAM
issued Individual

LT Form

1099-MISC

tax forms claiming FINDREAM

paid

Individual LT $19,250 for the 2016 tax year and $21,000 for t}ne 2017 tax year, when
they knew that Individuai LT did not work for FINDREAM and FINDREAM did not
pay Individual LT any income in 2016 or 2017.

Indiuidual

YG

19. It was further part of the conspiracy that HUANG and FINDREAM
agreed to provide Individual YG an offer letter, a Form I-983 OPT Training Plan,

payroll, and a Form 1099-MISC tax form, all showing Individual YG worked for
FINDREAM, so that Individual YG could report FINDREAM as her employer in a
document required by the immigration laws or regulations prescribed thereunder,

when they knew Individual YG did not work for FINDREAM.

In

exchange,

Individ,ual YG paid HUANG and FINDREAM a total of $1,175 in 2016.

20. It was further part of the conspiracy that HUANG and FINDREAM
received an additional $4,500 from Individual YG in 2016, and paid Individual YG a

total of $4,500 in 2016 for her purported employment with FINDREAM, when they

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knew that Individual YG did not work for FINDREAM and the source of the
purported FINDREAM income was Individual YG.

21. It was further part of the conspiracy that HUANG and FINDREAM
issued Individual YG

a Form 1099-MISC tax form claiming FINDREAM paid

Individual YG a total of $4,500 for the 2016 tax year, when they knew that
Individual YG did not work for FINDREAM and FINDREAM did not pay Individual
YG any income in 2016.

Indiuidual JC

22. It was further part of the conspiracy that HUANG and FINDREAM
agreed to provide Individual JC an offer letter, an employment verification letter, a

Form I-983 OPT Training PIan, and a Form 1099-MISC tax form, all showing

Individual JC worked for FINDREAM, so that Individuat JC could report
FINDREAM as his employer in a document required by the immigration laws or
regulations prescribed thereunder, when they knew Individual JC did not work for

FINDREAM. In exchange, Individual JC paid HUANG and FINDREAM a total of
$1,100 in 2016.

23. It was further part of the conspiracy that HUANG and FINDREAM
issued Individual JC

a Form

1099-MISC

tax form claiming FINDREAM paid

Individual JC a total of $24,000 for tlne 2017 tax year, when they knew that
Individual

JC did not work for FINDREAM and FINDREAM did not

Individua1 JC any income tn2017.

pay

 Case: 1:19-cr-00275 Document #: 23 Filed: 07/25/19 Page 9 of 18 PageID #:170

Indiuidual JL

24. It was further part of the conspiracy that HUANG and FINDREAM
agreed to submit a false Form I-129 Petition seeking an H-18 visa for Individual JL,

when they knew Individual

JL did not work for

FINDREAM.

In

exchange,

Individual JL paid HUANG and FINDREAM a total of $9,500 in 2018.

Indiuidual SZ

25.
agreed"

to

It was further part

of the conspiracy that HUANG and SINOCONTECH

provid.e Individual SZ an offer letter

for Individual SZ to work for

SINOCONTECH, when they knew Individual SZ did not work for SINOCONTECH,

which offer letter Individual SZ submitted to University A as proof to University A

that Individual SZ had

secured employment

with

SINOCONTECH, so that

University A would subscribe as true under penalty of perjury Individual SZ's Form
I-20.

26. It was further part of the conspiracy that HUANG, FINDREAM, and
SINOCONTECH received at least approximately $2 million from customers for whom
they agreed to falsely certifii employment in documents required by the immigration
laws and regulations.

27. It was further part of the conspiracy that HUANG, FINDREAM, and
SINOCONTECH, concealed, misrepresented and hid, and caused to be concealed,

I

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misrepresented and hidden, the existence and purpose of the conspiracy, and acts
done in furtherance of the conspiracy.

Overt Acts

28.

In furtherance of the conspiracy and to effect its objects and purposes,

HUANG, FINDREAM, and SINOCONTECH, committed and caused to be committed
the following overt acts, among others, within the Northern District of Illinois and
elsewhere:

Indiuidual LT

a.

On or about February 1,2016, HUANG and FINDREAM sent an

email to Individual LT attaching a letter offering Individual LT employment at
FINDREAM.

b.

On or about February 23,2016,Individual LT sent HUANG and

FINDREAM $400 via Chase QuickPay.

c.

On or about June 3, 2016, Individual LT subscribed as true under

penalty of perjury on a Form I-983 Training PIan for STEM OPT Students that he
was employed by FINDREAM in Mountain View, California.

Ind,iuid.ual YG

d.

On or about September 14,20L6,IndividualYG sent HUANG and

FINDREAM $500 via PayPal.

e.

On or about September 20,2016, HUANG and FINDREAM sent

an email to Individual YG attaching a letter offering Individual YG employment at

FINDREAM.

10

 Case: 1:19-cr-00275 Document #: 23 Filed: 07/25/19 Page 11 of 18 PageID #:170

f.

On or about September 21, 2016,Individua1 YG subscribed as

true under penalty of perjury on a Form I-983 Training Plan for STEM OPT Students

that she was employed by FINDREAM in Chicago, Illinois.

Indiuid.ual JC

g.

On or about November

LT,z}ll,Individua1 JC sent HUANG and

FINDREAM $900 via Chase QuickPay.

h.

On or about November 23, 2016, HUANG and FINDREAM sent

an email to Individual JC attaching a letter offering Individual JC employment at
FINDREAM.

i.

On or about November 28,2016,Individual JC subscribed as true

under penalty of perjury on a Form I-983 Training Plan for STEM OPT Students that
he was employed by FINDREAM in Chicago, Illinois.

Indiuidual JL

j.

On or about January 2, 20L8, Individual JL sent HUANG and

FINDREAM $2,000 via Chase QuickPay.

k.

On or about January 3, 2018, HUANG and FINDREAM sent an

email to Individual JL attaching a contract of employment between Individual JL
and FINDREAM.

t.

On or about March 30, 2018, HUANG subscribed as true under

penalty of perjury on a Form I-729 that Individual JL was employed by FINDREAM

in Mountain View, California.

11

 Case: 1:19-cr-00275 Document #: 23 Filed: 07/25/19 Page 12 of 18 PageID #:170

Indiuidual SZ

m.

On or about February 20,2018,Individual SZ sent HUANG and

FINDREAM $200 via PayPal.

n.

On or about February 21, 20L8, HUANG and FINDREAM sent

an email to Individual SZ attaching a letter offering Individual SZ employment at
SINOCONTECH.

o.

On or about November 5, 2018, Individual SZ, HUANG, and

SINOCONTECH caused University A to subscribe as true und.er penalty of perjury
on a Form I-20 that Individual SZ was employed bV SINOCONTECH in New York,
New York from February 5, 2018 through April 1, 2018.
A1l in violation of Tit1e 18, United States Code, Section 371.

t2

 Case: 1:19-cr-00275 Document #: 23 Filed: 07/25/19 Page 13 of 18 PageID #:170

COUNT TWO
The SPECIAL JULY 2018 GRAND JURY turther charges:

1.

Paragraphs 1(a), (b), (d), (e), (g), and (h) of Count One are incorporated

2.

On or about June 3,2016, at Chicago, in the Northern District of Illinois,

here.

and elsewhere,

WETTJN HUANG,
also known as "KeIIy Huang," and

FINDREAM,LLC,
defendants herein, did knowingly subscribe as true under penalty of perjury under

28 U.S.C. S 1746 a false statement with respect to a material fact

in a document

required by the immigration laws and regulations prescribed thereunder, namely, an

Optional Practical Training extension on a nonimmigrant F-l student visa, that is,
an individual acting on behalf of FINDREAM, LLC, falsely certified on a Form I-983

Training PIan that FINDREAM, LLC in Mountain View, California, employed
Individual LT, which statement Individual LT and the defendants then knew was
false, in that Individual LT was not employed by FINDREAM, LLC;

In violation of Title 18, United States Code, Sections 1546(a) and 2.

13

 Case: 1:19-cr-00275 Document #: 23 Filed: 07/25/19 Page 14 of 18 PageID #:170

COUNT THREE
The SPECIAL JULY 20LB GRAND JURY turther charges:

1.

Paragraphs 1(a), @), (d), (e), (g), and (h) of Count One are incorporated

2.

On or about September 21,20L6, at Chicago, in the Northern District of

here.

Illinois, and elsewhere,

WEMJN HUANG,
also known as "Kelly Huang," and

FINDREAM, LLC,
defendants herein, did knowingly subscribe as true under penalty of perjury under

28 U.S.C. S 1746 a false statement with respect to a material fact

in a document

required by the immigration laws and regulations prescribed thereunder, namely, an

Optional Practical Training extension on a nonimmigrant F-1 student visa, that is,
an individual acting on behalf of FINDREAM, LLC, falsely certifi.ed. on a Form I-983

Training Plan that FINDREAM, LLC in Chicago, Illinois, employed Individual YG,
which statement Individual YG and the defendants then knew was false, in that
Individual YG was not employed by FINDREAM, LLC;

In violation of Title 18, United States Code, Sections 15a6(a) and

l4

2.

 Case: 1:19-cr-00275 Document #: 23 Filed: 07/25/19 Page 15 of 18 PageID #:170

COUNT FOUR
The SPECIAL JULY 2018 GRAND JURY turther charges:

1.

Paragraphs 1(a), O), (d), (e), (g), and (h) of Count One are incorporated

2.

On or about November 28, 2016, at Chicago, in the Northern District of

here.

Illinois, and elsewhere,
WETTUN HUANG,
also known as "Kelly Huang," and
FINDREAM, LLC,
defendants herein, did knowingly subscribe as true under penalty of perjury under

28 U.S.C. S 1746 a false statement with respect to a material fact

in a document

required by the immigration laws and regulations prescribed thereunder, that is, an

individual acting on behalf of FINDREAM, LLC, falsely certifi,ed on a Form I-983
Training Plan that FINDREAM, LLC in Chicago, Illinois, employed Individual JC,
which statement Individual JC and the defendants then knew was false, in that
Individual JC was not employed by FINDREAM, LLC;
In violation of Title 18, United States Code, Sections 15a6(a) and 2.

15

 Case: 1:19-cr-00275 Document #: 23 Filed: 07/25/19 Page 16 of 18 PageID #:170

COUNT FIVE
The SPECIAL

ruLY

2018 GRAND JURY turther charges:

1.

Paragraphs 1(a), (b), (d), (e), and (i) of Count One are incorporated here.

2.

On or about March 30, 2018, at Chicago, in the Northern District of

Illinois, and elsewhere,
WETYUN HUANG,
also known as "KeIIy Huang," and

FINDREAM,LLC,
defendants herein, did knowingly subscribe as true under penalty of perjury under
28 U.S.C. S 1746 a false statement

with respect to a material fact in a document

required by the immigration laws and regulations prescribed thereunder, namely, a

nonimmigrant H-1B visa, that is, HUANG caused to be submitted a Form I-L29
stating that FINDREAM, LLC in Mountain View, California, employed Individual
JL, which statement defendants then knew was false, in that Individual JL was not
employed by FINDREAM, LLC;

In violation of Title 18, United. States

16

Cod.e,

Section 1546(a).

 Case: 1:19-cr-00275 Document #: 23 Filed: 07/25/19 Page 17 of 18 PageID #:170

COUNT SD(
The SPECIAL JULY 2018 GRAND JURY further charges:

1.

Paragraphs 1(a) through (h) of Count One are incorporated here.

2.

On or about November 5, 2018, at Chicago, in the Northern District of

Illinois, and elsewhere,
WETTUN HUANG,
also known as "Kelly Huang," and

SINOCONTECH, LLC,
defendants herein, did knowingly cause University
penalty of perjury under 28 U.S.C.

S 1746 a

A to subscribe as true under

false statement with respect to a material

fact in a document required by the immigration laws and regulations prescribed
thereunder, namely, an Optional Practical Training extension on a nonimmigrant F1 student visa, that is, Individual SZ submitted a Form I-20 stating that she was
employed

by SINOCONTECH, LLC in New York, New York, which statement

Individual SZ and the defendants then knew was false, in that Individual SZ was not
employed by SINOCONTECH, LLC;

In violation of Tit1e 18, United States Code, Sections 15a6(a) and

L7

2.

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FORFEITURE ALLEGATION
The SPECIAL JULY 2018 GRAND JURY alleges:

1.

The allegations of this Indictment are incorporated here for the purpose

of alleging forfeiture, pursuant to Tit1e 18, United States Code, Section 982(a)(6).

2.

As a result of their violations of Title 18, United States Code, Sections

371 and 1546(a), as alleged in this Indictment,
WETYLIN HUANG,
also known as "Kelly Huang,"
FINDREAM, LLC, and
SINOCONTECH, LLC,

defendants herein, shall forfeit to the United States, pursuant to Title 18, United
States Code, Section 982(a)(6), any and all right, title, and interest defendants may
have

in any property, real or personal that constitutes and is derived from or is

traceable to the proceed.s obtained. directly and indirectly from the commission of the
offense and that is used, and intended to be used, to facilitate the commission of the
offense.

3.

The interests of defendants subject to forfeiture pursuant to Title

18,

United States Code, Section 982(a)(6), include, but are not limited to, a money
judgment.
A TRUE BILL:

FOREPERSON

UNITED STATES ATTORNEY
18