3 Daddona, agreeing that Daddona could then sell the packs to the public using packaging and advertisements that falsely represented the goods to be Ultracade.
The game packs were sold at significantly lower prices than the retail prices charged by Global VR. CR 1 at 4. From September to October 2006, defendant also conspired to defraud Countrywide Home Loans by falsely claiming in his application for a nearly $3,000,000 loan and line of credit that he was currently employed by Global VR. In fact, defendant had been terminated by the company after an internal investigation revealed that he was selling Ultracade game packs for his own benefit after agreeing to and being compensated for the transfer of his intellectual property rights to Global VR. Exhibit A at 4.
II. The Indictments
On July 1, 2009, defendant and Michael Daddona were indicted on 35 counts of conspiracy to commit mail and wire fraud, trafficking in counterfeit goods, theft of trade secrets, mail and wire fraud, conspiracy to commit money laundering, money laundering, and bank fraud. CR 1. On August 18, 2011, a federal grand jury returned a superseding indictment against defendant and Daddona, charging them with 53 counts of conspiracy to commit mail and wire fraud, mail and wire fraud, trafficking in counterfeit goods, transportation of stolen goods, theft of trade secrets, and money laundering. CR
Case: 14-10055 04/21/2014 ID: 9065953 DktEntry: 14-1 Page: 3 of 16