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Form
No.
USA-33S-274
(Ed.
9-25-5S
UNITEDSTATES
DISTRICT
COURTSOUTHERNDISTRICTOFNEW
YORK
UNITEDSTATESOF
AMERICA
HECTORXAVIER
MONSEGUR,
a/k/a
"Sabu,"
a/k/a"XavierDeLecn,"
a/k/a
"Leon,"
Defendant.INFORMATION
SI
11
Cr.
666
(LAP)
(18U.S.C.§§1030(b),1030(a)(5)(A),
1030(a)(4),1029(b)(2),
1349,
1028A
and
2)
PREET
BHARARA
United
StatesAttorney.
 
UNITED
STATES
DISTRICT
COURTSOUTHERN
DISTRICTOFNEWYORK
UNITED
STATESOFAMERICA
v.
HECTOR
XAVIER
MONSEGUR,
a/k/a
"Sabu,"
a/k/a"Xavier
DeLeon,"a/k/a
"Leon,"
Defendant
SEALED
INFORMATION
SI11
Cr.
666
(LAP)
COUNTONE
(Conspiracy
to
Engage
inComputerHacking
--
Anonymous)
The
United
States
Attorney
charges:
THE
DEFENDANT
1.
At
all
times
relevant
tothis
Information,HECTOR
XAVIER
MONSEGUR,
a/k/a
"Sabu,"
a/k/a
"XavierDeLeon,"
a/k/a
"Leon,"
thedefendant,was
anexperiencedcomputerhackerwho
residedin
New
York,
New
York.
AtvarioustimesrelevanttothisInformation,
MONSEGURwasaninfluentialmember
of
three
hacker
organizations
--
Anonymous,Internet
Feds,
and
Lulz
Security(also
known
as"LulzSec")--thatwereresponsibleformultiplecyberattacksonthecomputersystemsofvarious
businesses
and
governments
inthe
United
States
and
throughout
theworld.
2.
Atall
times
relevant
tothis
Information,
MONSEGUR's
primary
area
of
expertise
and
rolein
hacker
 
organizationswastoactasa
"rooter,"that
is,
acomputer
hacker
whoidentifiedvulnerabilities
in
the
computer
systems
of
potential
victims
to
be
exploited
for
the
purpose
of
gaining
unauthorizedaccesstothesystems.Upondiscoveringthesevulnerabilities,MONSEGUReitherpassedinformationregarding
them
to
other
hackers,
who
sought
to
exploit
them,
orMONSEGUR
exploitedthevulnerabilitieshimself.MONSEGURalsoprovided
infrastructure
supportto
members
of
hacker
organizations,that
is,
unauthorized
accessto
computer
servers
and
routersthat
others
coulduse
to
launchcyber'attacks
on
victims.
BACKGROUND
ON
ANONYMOUS
3.
At
alltimes
relevant
tothis
Information,
"Anonymous"
was
a
collective
of
computerhackersandother
individualslocatedin
the
UnitedStates
and
elsewhere
that
undertook
"operations"
--
that
is,
coordinated
effortsthat
included
cyber
attacks
--
againstindividuals
and
entitiesthat
were
perceived
tobe
hostile
to
Anonymous
and
itsmembers'
interests.Theseattacksincluded,amongotherthings,the
theft
andlaterdissemination
of
confidential
information
from
computersystemsand
the
defacement
of
Internet
websites.
These
attacks
alsoincludedattacksagainst
websites,
known
as
"denial
of
service"
or
"DoS"attacks,
whichinvolved
theuseof
computers
to
bombard
a
victim's
websitewithbogusrequests
for
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