FILEO TOIGMAR 1S AMT 31 2 > MOE RRS ER ‘ : : « > : sete sriaes onerener count : fon nit cent oreTRICP oF caLtromNTA 10 | ozzeo stares oF amerrcn, exo. 16- OR16-01 57 a iainsiee, rutonwatzon 2 : U8 v8.0, 5 10006) (2) 60), (c) (2) (B) (ii), (ii): Unauthorized Access to a Protected Computer to Obtain Information] 23 | rvaw counmns, Defendant ae ‘The United States Attorney charges wv (28 U.8.c. $8 1030(a) (2) (c), (e) (2) (B) (44), (4449) a6 2. Apple, Inc. (“apple”), located in Cupertino, california, 19 operates computers used by subseribers all over the world in 20 [interstate and foreign commerce and communications. one of the 22 [services that Apple provides to its custoners is "icloud,” a *cloud” 22 | computing back-up system for subscriber data. Photographs and videos 23 [taken on Apple iphones and o:her digital devices can be automatically 24 | backed up to the iCloud, making them accessible to users on the 25 | mternet. 26 2. Googie, 1c. ("Geesle"), located in Mountain view, 27 |catifornia, operates conpute:s used by subscribers all over the world 28 |[in interstate and foreign commerce and communications. one of the ®3 [services that Google provides to its customers is Gnail, an e-mail 2 | service a 3. Between on or about November 2, 2012, and September 2, 4 ] 2014, sn tos angeles county, within the central District of 5 |catitornia, and almewhere, defendant RYAN COLLINS, knowingly, 6 intentionally, and in furtherance of criminal and tortious acts, 7 namely, Grand Teft, in violation of California Penal Code Section @ |407, and the california state tores of Invasion of Privacy and 9 J2nerusion upon seclusion, accessed without authorization and ir 10 excess of authorization Apple icloud and Grail accounts, which were 1a | maintained on protected computers as that term is defined in Title 12 |28, united states code, s fon 1030(@) (2) (5), belonging to more than 100 victims, including female celebrities residing within the Central District of California, and thereby obtained complete iCloud backups, as fav as fas ae as 20 a 2 23 24 25 26 27 28 2aa 16 ae as 20 aa 22 23 24 2s 26 27 28 exceeded $5,000 photographs, and other private information, the value of which BILEEN M. DECKER United States Attorney Petuee OD ona hax PATRICIA A. DONAHUE Assistant United States Attorney Chief, National security Division TRACY LL. WILKISON Assistant United states Attorney Chiet, cyber and Intellectual Property crimes section STEPHANIE CHRISTENSEN Assistant United states Attorney Deputy Chief, cyber and Intellectual Property crimes Section, RYAN WHITE Assistant United States Attorney Cyber and Intellectual Property’ (Crimes Section vice: cHoU Assistant United States Attorney Cyber and Intellectual Property’ (Crimes Section