UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

-x

UNITED

STATES OF AMERICA - v. -

SEALED INDICTMENT 12 Cr.

RYAN ACKROYDr a/k/ a "kaylar rr a/k/a "lolrll a/k/a "lolspoonrll JAKE DAVISr a/k/a "topiaryrll a/k/a "atopiaryll DARREN MARTYNr a/k/ a "pwnsauce r tr a/k/a "raepsaucerll a/k/a "networkkittenrll and DONNCHA orCEARRBHAILr a/k/a "palladiumr tr Defendants.
-x

COUNT ONE (CONSPIRACY TO COMMIT COMPUTER HACKING - INTERNET FEDS)

The Grand Jury charges: BACKGROUND 1. including ON ANONYMOUS AND INTERNET
2008r

FEDS up through and
fl

Since at least in or about

on or about the date of this Indictmentr of computer common hackers

"Anonymous

has been a loose confederation sharingr among other thingsr identifying

and others slogansr

interestsr

common

and common certain online which

symbols.

During

that time periodr a deliberate campaign of

members

of Anonymous

have waged

destructionr

intimidationr

and criminalitYr against

as part of businesses and

they have carried

out cyber attacks

government world.

entities

in the United

States and throughout

the

2.

Between

in or about December

2010 and in or about with Anonymous who

May 2011, one group of individuals engaged hackers Feds." Internet websites entities in such criminal who collectively At various

affiliated

conduct was composed referred

of elite computer as "Internet members of

to themselves

times relevant

to this Indictment,

Feds carried and computer in the United

out a series of cyber attacks systems of certain business

against

the

and government including,

States and around the world, businesses

among others,

the following a.

and organizations: party in Ireland,

Fine Gqel, a political the website HBGary,

which maintained b. Federal, computer provided things, LLC

"www.finegae12011.comi" Inc. and its affiliate, HBGary

(collectively

referred

to herein

as "HBGary"),

security computer

firms based security

in the United

States which among other

software

and services,

to their clients,

and which maintained and Company

the website

"www.HBGaryFederal.comi" c. commercial broadcast

Fox Broadcasting television

("Fox"), a States,

network

in the United

which maintained 3. (1) breaking

the website

"www.fox.com." involved, deleting among other things: data, and stealing

These

cyber attacks systems,
2

into computer

confidential

information,

including

encrypted

and unencrypted of individual stolen from (3) on the

.sensitive personal victims; victims' publicly Internet victims' Internet

information

for thousands

(2) de-encrypting computer disclosing by dumping systems,

confidential including

information

encrypted

passwords;

that stolen confidential it on certain websites; accounts;

information (4) hijacking

email and Twitter websites; online and/or

(5) defacing

victims'

(6) "doxing," personal

that is, publicly information, number, of, among the victim

disclosing

a victim's

identifying

such as the victim's email account, other things, to harassment. 4.

name, address, number,

Social

Security

and telephone intimidating

with the object and subjecting

the victim

At various

times relevant of Internet

to this Indictment, Feds sought to

and

as part of Anonymous, publicize their

members

Internet things:

assaults

and intimidate messages

their victims in which attacks; they

by, among other they discussed

(1) posting

online

their attacks

and threatened

additional

(2) using particular posted messages

logos and slogans when, and defaced websites;

for example, and

online

(3) discussing

their attacks 5.

with members At various

of the press. times relevant to this Indictment, of Internet conduct, and

much like other members despite their efforts

of Anonymous,

members

Feds,

to publicize
3

their illegal

typically example,

attempted

to hide their true identities when they communicated

by, for or

using aliases

with the public

with each other. 6. members At various times relevant to this Indictment, of Anonymous,

of Internet using,

Feds, much

like other members Internet

communicated

among other means, that is, real-time,

Relay Chat online

("IRC") channels forums. Others, members

text-based

Some of these channels particularly of Internet including channels

were open to the public. of Anonymous criminal Instead, those by and

in which members and organized were not.

Feds planned

activity, channels

cyber attacks,

were generally only, usually

password-restricted to trusted

and available

invitation themselves of Internet coordinated

individuals

who had proven members

through past criminal

hacking.

Specifically, planned and

Feds and their co-conspirators their cyber attacks IRC channels

using password-restricted,

invitation-only "#Hackers," 7. members a/k/a

such as "#InternetFeds,"

and \\#hq," among others. At various times relevant to this Indictment, the

of Internet a/k/a

Feds included, "101," a/k/a

among others, "lolspoon,"

RYAN ACKROYD, a/k/a

"kayla,"

JAKE DAVIS,

"topiary," a/k/a

a/k/a

"atopiary," a/k/a

DARREN MARTYN,

a/k/a

"pwnsauce,"

"raepsauce," a/k/a

"networkkitten,"

and DONNCHA as well as

O'CEARRBHAIL,

"palladium,"
4

the defendants,

other

individuals,

including,

but not limited

to, individuals

who used the online aliases

"SABU,"

"TFLOW," and "AVDNIT."

THE DEFENDANTS 8. ACKROYD, DAVIS, a/k/a At all times relevant "kayla," a/k/a a/k/a to this Indictment, "lolspoon," RYAN

"101," a/k/a "atopiary," in the United

and JAKE were

a/k/a

"topiary,"

the defendants, Kingdom. "kayla,"

computer

hackers 9.

who resided

The role of RYAN ACKROYD, "lolspoon," charged the defendant,

a/k/a

a/k/a

"101," a/k/a conspiracies things, computer

in each of the included, among other in victims' access

in this Indictment and exploiting

identifying systems

vulnerabilities

for the purpose

of gaining

unauthorized

to those systems.
10.

The role of JAKE DAVIS,

a/k/a

"topiary,"

a/k/a charged as a

"atopiary,"

the defendant,

in each of the conspiracies among other things, acting

in this Indictment spokesman

included,

for the groups for example

charged

in Counts One and Two of this in interviews activities; with the media and organizing with

Indictment,

by engaging

and publicizing and storing the computer Indictment.
11.

those groups'

hacking

confidential hacking

information

stolen in connection

described

in Counts One and Two of this

At all times relevant "pwnsauce," a/k/a

to this Indictment, a/k/a

DARREN

MARTYN,

a/k/a

"raepsauce,"
5

"networkkitten," the defendants,

and DONNCHA were computer

O'CEARRBHAIL, hackers

a/k/a

"palladium," in Ireland.

who resided FEDS

CYBER ATTACKS 12. including including

BY INTERNET

From in or about December

2010, up to and of Internet Feds,

in or about May 2011, members RYAN ACKROYD, JAKE DAVIS, a/k/a a/k/a a/k/a

"kayla," a/k/a "topiary," a/k/a

"101," a/k/a "atopiary," a/k/a

"lolspoon," DARREN

a/k/a

MARTYN,

"pwnsauce,"

"raepsauce," a/k/a

"networkkitten," the defendants, others,

and DONNCHA

O'CEARRBHAIL,

"palladium," among on, and

and their co-conspirators, launched

including, cyber attacks

SABU, TFLOW and AVUNIT, access

gained unauthorized systems

to, the websites

and computers

of the following

victims,

among others:

Hack of Fine Gael a. O'CEARRBHAIL website, In or about January 2011, MARTYN and

participated

in a cyber attack

on Fine Gael's and in

www.finegae12011.com. accessed without

Among other things, MARTYN authorization computer

O'CEARRBHAIL Arizona

servers

used by Fine Gael to maintain the website.

its website,

and uploaded

code that defaced

Hack of HBGary b. MARTYN, In or about February 2011, ACKROYD, DAVIS,

and their co-conspirators,

including

SABU, TFLOW and

6

AVUNIT, computer

participated systems c.

in a cyber attack on the website

and

of HBGary. Among other things, ACKROYD, accessed without DAVIS, MARTYN,

and their co-conspirators computer

authorization and Colorado and

servers used by HBGary information

in California

stole confidential approximately employees

from those servers,

including

60,000 emails

from email accounts of HBGary

used by HBGary LLC (the

and a senior executive Executive"),

Federal,

"HBGary Federal

which ACKROYD, disclosed

DAVIS, and MARTYN, via the website

and their co-conspirators www.thepiratebay.org that permits users d. conspirators

publicly

website

(an anonymous

file sharing

to post stolen content), ACKROYD, DAVIS, MARTYN, gained

among other means. and their coemails of an Inc. to the to

used information authorization,

from those stolen

access, without email account (the "HBGary, servers computer

and steal the contents

belonging

to a senior executive

of HBGary, access

Inc. Executive");

gain unauthorized an online

for the website hacking

www.rootkit.com.

forum on and

maintained data,

by the HBGary,

Inc. Executive, and encrypted access

steal confidential passwords

including

usernames

for approximately and deface

80,000 user accounts; account Federal

without

authorization Federal

the Twitter

of the HBGary Executive number by, and home

Executive;

and dox the HBGary posting his Social
7

among other things,

Security

address

on his Twitter

account without

his authorization

or

approval. e. conspirators ACKROYD, DAVIS, MARTYN, and their coof the encrypted and

de-encrypted

tens of thousands

www.rootkit.com publicly usernames belonging certain

users' passwords

that they had stolen, passwords,

disclosed

those de-encrypted

the rootkit.com

they had stolen, and the contents to the HBGary, Inc. Executive,

of the email account them on

by dumping

Internet

websites. Hack of Fox

f. MARTYN, O'CEARRBHAIL,

In or about April

2011, ACKROYD,

DAVIS, SABU,

and their co-conspirators, in a cyber attack

including

TFLOW and AVUNIT, and computer

participated of Fox. Among other

on the website

systems g.

things, ACKROYD, accessed

DAVIS, without

MARTYN,

O'CEARRBHAIL, authorization

and their co-conspirators computer servers

in California

used by Fox and including

stole and publicly a database

disclosed

confidential

information, telephone

of the names,

dates of birth,

numbers, for

email addresses,

and residences,

among other

information,

more than 70,000 potential television show.

contestants

on "X-Factor,"

a Fox

8

STATUTORY 13. and including

ALLEGATIONS 2010, up to District of

From at least in or about December

in or about May 2011, in the Southern RYAN ACKROYD, JAKE DAVIS, a/k/a a/k/a a/k/a

New York and elsewhere, "101," a/k/a "atopiary," a/k/a "lolspoon,"

"kayla," a/k/a "topiary," a/k/a

DARREN MARTYN,

"pwnsauce,"

a/k/a "raepsauce," a/k/a

"networkkitten,"

and DONNCHA

O'CEARRBHAIL,

"palladium," willfully agreed

the defendants,

and others

known and unknown, confederated, in computer and

and knowingly,

combined,

conspired,

together

and with each other to engage of Title 18, United

hacking,

in violation

States Code, Section

1030 (a) (5) (A). 14. It was a part and an object a/k/a "kayla," a/k/a a/k/a of the conspiracy "lolspoon,"

that RYAN ACKROYD, JAKE DAVIS, a/k/a a/k/a

"101," a/k/a

"topiary," a/k/a

"atopiary," a/k/a

DARREN MARTYN, and

"pwnsauce,"

"raepsauce,"

"networkkitten," and

DONNCHA

O'CEARRBHAIL,

a/k/a

"palladium,"

the defendants, would

others known and unknown, cause the transmission command,

willfully

and knowingly information,

and did

of a program,

code and

and, as a result of such conduct, cause ·damage without

would and did to a protected loss one and

intentionally computer, resulting

authorization,

which would and did cause a loss from a related course of conduct aggregating
9

(including affecting

more other protected

computers)

to at least $5,000

to one and more persons of Title 18, United 1030 (c) (4) (B) (i) and

during

anyone

year period,

in violation

States

Code, Sections

1030 (a) (5) (A),

(c) (4) (A) (i) (I) . OVERT ACTS

15. the illegal others,

In furtherance thereof,

of the conspiracy

and to effect

object

the following

overt acts, among of New York and

were committed

in the Southern

District

elsewhere: a. O'CEARRBHAIL, electronic a/k/a a/k/a On or about January "palladium," 9,2011, DONNCHA sent an "pwnsauce,"

the defendant, a/k/a

communication a/k/a

to DARREN MARTYN, "networkkitten,"

"raepsauce," computer

the defendant, the

containing

code to be used to deface website. In or about February

www.finegae12011.com b. computer located

2011, SABU used a

in New York, New York to access without servers used by HBGary to employees and steal tens of and the

authorization thousands HBGary

computer

of emails belonging Executive. c.

of HBGary

Federal

In or about "atopiary,"

February

2011, JAKE DAVIS, accessed

a/k/a

"topiary,"

a/k/a

the defendant,

without

authorization Executive

the Twitter

account

of the HBGary fraudulent

Federal

and posted

one or more

tweets.

10

d. a/k/a "kayla,"

In or about February

2011,

RYAN ACKROYD, the defendant, belonging to the

a/k/a "101," a/k/a authorization

"lolspoon,"

accessed HBGary,

without

an email account

Inc. Executive

and sent one or more

fraudulent

emails

from that account website requesting e.

to an administrator administrative

for the www.rootkit.com to that website. 7, 2011, TFLOW uploaded to as well as

access

On or about February of stolen

links to tens of thousands employees of HBGary

emails belonging Executive

and the HBGary

Federal

a copy of certain

text that had been used to deface the website, to an account "HBGary on the website

www.HBGaryFederal.com www.thepiratebay.org f. the IRC channel Twitter account

in the name

leaked emails." 8, 2011, DAVIS, had locked the and stated, using

On or about February

#hq, discussed of the HBGary

how Twitter Federal

Executive

"That works tweets.

in our favour. his SSN."

His Twitter

still has all our

Including g.

On or about February

9, 2011, ACKROYD, he had received

using

the IRC channel of emails

#hq, asked TFLOW whether to the HBGary,

a copy

belonging

Inc. Executive,

to which

TFLOW responded

affirmatively

and stated

that he would add them

to an "online viewer."

11

h. the IRC channel used by HBGary. i. the IRC channel IRC/Skype,

On or about February

12, 2011, SABU, using data on a server

#hq, stated that he had deleted

On or about February

13, 2011, DAVIS,

using

#hq, told AVUNIT

"I'm happy to talk to press on and told TFLOW that he

have done

[so] for months," 150 journalists."

had "talked to maybe j.

In or about May 2011, SABU used a computer authorization containing a computer personal

in New York, New York to access without server used by Fox and download information television relating show. (Title 18, United States

a database

to potential

contestants

on the X-Factor

Code, Section

1030(b).)

COUNT TWO (CONSPIRACY TO COMMIT COMPUTER HACKING - LULZSEC)

The Grand Jury further 16. this Indictment forth herein. BACKGROUND 17. The allegations are repeated

charges: 1 through 12 and 15

in paragraphs and realleged

as though

fully set

ON LULZSEC the publicity of Fine Feds,

In or about May 2011, following as a result

that they had generated Gael and HBGary, including among

of their hacking members a/k/a

other victims, a/k/a "kayla," 12

of Internet "101," a/k/a

RYAN ACKROYD,

"lolspoonlll JAKE DAVIS I a/k/a "topiarylll DARREN MARTYN
I

a/k/a

"atopiarylll and
I II

a/k/ a "pwnsauce

I

II

a/k/ a "raepsauce as well as SABU members
I

a/k/ a
I

"networkkittenlll the defendants AVUNIT group
I

I

TFLOW

and

formed and became

the principal
1I

of a new hacking

I

"Lulz Securityll or "LulzSec. 18. Like Internet cyber assaults

Fedsl LulzSec on the websites entities

undertook

a campaign systems States and

of malicious of various

and computer in the United

business

and government Although

and throughout

the world.

the members

of LulzSec

their co-conspirators for humorous interpreted criminal purposes as "laughs

claimed to have engaged ("lulzll is Internet
I II

in these attacks

slang which can be
I

"humor

I II

or "amusementll)
I

LulzSec

IS

acts includedl informationl

among other things including

the theft of personal

confidential information computer

sensitive
I

for thousands

of individuals

from their victimsl

systems;

the public disclosure

of that confidential of Internet with bogus

information websites; requests

on the Internet;

the defacement

and overwhelming for information

victimsl

computers

(known as "denial of serv i.ce" or "DoSII

attacks) . 19. notoriety broadcast Also like Internet Fedsl LulzSec and repeated sought to gain efforts to As

for their hacks by varied

their acts of online destruction their cyber assaults
13

and criminality.
I

a means of publicizing

members

of LulzSec

and their co-conspirators .. www.LulzSecurity.com; www.thepiratebay.org;

maintained

a website, "LulzSec" at all of and

..an account and a Twitter

in the name account,

"@LulzSec;"

which they used to, among other things, announce issue written "press releases" and publicly

their hacks

about the~; mock their victims; disclose confidential

solicit donations; information

they had stolen Similar

through

their cyber attacks. Feds, as a means of as well as intimidating used "press their

20. publicizing victims,

to Internet assaults,

their online

members

of LulzSec

and their co-conspirators in, for example, their

particular releases,"

logos and slogans their website

defacements,

and on the Twitter account.

www.LulzSecurity.com 21.

website

and the @LulzSec

Despite

going to great lengths the members

to seek attention and their co-

for their illegal conspirators identities. aliases, means,

conduct,

of LulzSec

- like Internet Among other

Feds - attempted they referred

to hide their true to themselves by

things,

attempted

to promote

false personas, in an effort

and used technical to conceal

including

proxy

servers,

themselves

online. 22. At various times relevant to this Indictment, a/k/a "kayla," a/k/a a/k/a

members

of LulzSec,

including

RYAN ACKROYD, a/k/a

"101," a/k/a "atopiary,"

"lolspoon," and DARREN

JAKE DAVIS, a/k/a 14

"topiary," a/k/a

MARTYN,

"pwnsauce,"

"raepsauce,"

a/k/a

"networkkitten,"

the defendants,

as well as launched of the

SABU, TFLOW, and AVUNIT, cyber attacks following

and their co-conspirators, and computer systems

on the websites

victims, a.

among others: Sony Pictures Entertainment ("Sony and media shows and

Pictures"), company, movies

a division

of Sony, a global .and distributed

electronics television

which produced

and maintained b.

the website

"www.sonypictures.comj" Service service ("PBS"), a

The Public Broadcasting television broadcasting

non-profit States,

public

in the United

which maintained c.

the website

"www.pbs.orgj" chapter of the an information

The Atlanta, Alliance between industry

Georgia

Infragard

Members

("Infragard-Atlanta"), the Federal concerned Bureau

sharing partnership ("FBI") and private infrastructure website

of Investigation critical the

with protecting

in the United

States, which maintained and

"www.infraguardatlanta.orgj" d. Bethesda which

Softworks,

a video game company "Brink" and ... and

based

in Maryland,

owned the videogame

maintained

the website 23.

"www.brinkthegame.com times relevant and exploiting

At various

to this Indictment, vulnerabilities in of

in addition

to identifying computer

their victims' LulzSec

systems on their own, the members hackers

also received

from other computer 15

information

regarding

vulnerabilities and government

in the computer entities.

systems of a variety used this or stored

of business information

LulzSec members on those entities

to launch cyber attacks

it in anticipation 24. members

of future attacks. times relevant to this Indictment, communicated with using

At various

of LulzSec

and their co-conspirators and coordinated

each other and planned password-restricted, among others,

their cyber attacks

invitation-only and "#hq".

IRC channels,

including,

"#upperdeck"

CYBER ATTACKS 25.

BY LULZSEC at

From in or about May 2011, up to and including of LulzSec, including JAKE

least in or about June 2011, members ACKROYD, DAVIS, a/k/a a/k/a "kayla," a/k/a a/k/a

RYAN

"101," a/k/a "atopiary," a/k/a

"lolspoon," and DARREN

a/k/a

"topiary," a/k/a

MARTYN, the

"pwnsauce,"

"raepsauce,"

"networkkitten,"

defendants, SABU, TFLOW, unauthorized

and their co-conspirators, and AVUNIT, access launched

including,

among others,

cyber attacks

on, and gained systems of

to, the websites among others:

and computers

the following

victims,

Hack of PBS a. MARTYN, AVUNIT, In or about May 2011, ACKROYD, including DAVIS,

and their co-conspirators, in retaliation

SABU, TFLOW and to be unfavorable Frontline,

for what they perceived

news coverage

in an episode

of the PBS news program 16

undertook PBS.

a cyber attack on the website

and computer

systems

of

b. conspirators, Virginia servers, names,

ACKROYD,

DAVIS, MARTYN, authorization

and their cocomputer servers in

accessed

without

used by PBS, stole confidential including, among other things, usernames

information databases

from those

containing

email addresses,

and passwords and other

of more than and

approximately entities

2,000 PBS employees

individuals that

associated

with PBSi publicly websites,

disclosed the

information

on certain

including

www.LulzSecurity.com including

websitei

and defaced

the PBS website,

by inserting

a bogus news article. Hack of Sony Pictures

c.

In or about May 2011, ACKROYD, including

DAVIS,

and

their co-conspirators, participated Pictures.

SABU, TFLOW and AVUNIT, systems without used by Sony authorization and

in a cyber attack on computer This attack computer included servers accessing

Sony Pictures' publicly

in California, websites,

and stealing the

disclosing

on certain website,

including

www.LulzSecurity.com least approximately website, including

confidential

information

for at

100,000 users of the www.sonypictures.com the users' passwords, of birth. email addresses, home

addresses,

and dates

17

Hack of Infragard-Atlanta d. MARTYN, AVUNIT, In or about June 2011, ACKROYD, including DAVIS,

and their co-conspirators, launched cyber attacks

SABU, TFLOW and and computer included and other stealing

on the website These attacks passwords,

systems of Infragard-Atlanta. the login credentials, confidential

encrypted

information

for approximately

180 users of the defacing publicly including the

Infragard-Atlanta that website; disclosing

website,

www.atlantainfraguard.org; the stolen passwords; and

de-encrypting

the stolen confidential passwords,

user information,

the de-encrypted

on certain websites,

including

www.LulzSecurity.com

website. Hack of Bethesda Softworks DAVIS,

e. MARTYN,

In or about June 2011, ACKROYD, including TFLOW,

and their co-conspirators, in a cyber attack stealing

participated Bethesda

on the computer

systems

used by including

Softworks,

confidential

information, passwords,

authorization accounts website,

keys, as well as usernames, 200,000

and email Softworks' and

for approximately

users of Bethesda ACKROYD, DAVIS,

..ww.brinkthegame.com... w publicly

MARTIN,

their co-conspirators, data on certain website.

disclosed

some of that stolen

websites,

including

the www.LulzSecurity.com

18

STATUTORY 26. including District a/k/a a/k/a

ALLEGATIONS

From at least in or about May 2011, up to and

at least in or about June 2011, in the Southern of New York and elsewhere, "lolspoon," RYAN ACKROYD, a/k/a a/k/a "kayla,"

"101," a/k/a "atopiary," ajk/a

JAKE DAVIS, a/k/a

"topiary," a/k/a

and DARREN MARTYN, "networkkitten," willfully

"pwnsauce,"

"raepsauce,"

the defendants,

and others conspired,

known and unknown, confederated, in computer

and knowingly,

combined,

and agreed hacking,

together

and with each other to engage of Title 18, United States

in violation

Code, Section 27.

1030 (a) (5) (A) . It was a part and an object a/k/a "kayla," a/k/a a/k/a of the conspiracy "lolspoon,"

that RYAN ACKROYD, JAKE DAVIS, MARTYN, a/k/a

"101," a/k/a

"topiary,"

"atopiary,"

and DARREN

a/k/a

"pwnsauce,"

a/k/a

"raepsauce,"

a/k/a

"networkkitten," willfully a program,

the defendants,

and others known and unknown, of

and knowingly information, would

would and did cause the transmission code and command, and, as a result of

such conduct, authorization, cause a loss conduct

and did intentionally computer,

cause damage without which would and did

to a protected (including

loss resulting

from a related

course of

affecting

one and more other protected

computers) during

aggregating anyone

to at least

$5,000 to one and more persons

year period,

and which would and did cause damage
19

affecting

a computer

used by and for an entity of the United of the

States Government, administration security,

to wit the FBI, in furtherance national defense

of justice,

and national States Code, Sections (V).

in violation

of Title 18, United

1030 (a) (5) (A), 1030 (c) (4) (B) (i) and

(c) (4) (A) (i) (I) and

OVERT ACTS 28. In furtherance thereof, of the conspiracy and to effect

the illegal object others,

the following

overt acts, among of New York and

were committed

in the Southern

District

elsewhere: a. "topiary," Twitter a/k/a On or about May 6, 2011, JAKE DAVIS, "atopiary," in the name b. located computer the defendant, "@LulzSec." established a a/k/a

account

In or about May 2011, SABU used a computer access to

in New York, New York, to gain unauthorized systems used by PBS and install one or more means ("backdoors")

surreptitious secretly

by which SABU and others authorization.

could

re-access c.

those systems without

In or about May 2011, DAVIS wrote aebogus the www.pbs.org website. a/k/a and SABU

news article,

which was used to deface d.

In or about May 2011, RYAN ACKROYD, "lolspoon," computer the defendant,

"kayla," accessed

a/k/a

"101," a/k/a

without

authorization

servers used by PBS and

downloaded

confidential

information.
20

e. located

In or about May 2011, SABD used a computer access to

in New York, New York, to gain unauthorized

servers used by Sony Pictures. f. located In or about June 2011, SABD used a computer access to,

in New York, New York to gain unauthorized one or more backdoors in, computer

and install

systems used by

Infragard-Atlanta. g. without authorization confidential h. named as a defendant vulnerability ACKROYD In or about June 2011, ACKROYD accessed and

servers used by Infraguard-Atlanta information.

downloaded

In or about June 2011, a co-conspirator herein provided information concerning Softworks

not a to

in computer

systems used by Bethesda of LulzSec.

and other members i.

On or about June 12, 2011, ACKROYD to gain unauthorized Softworks, install access

used the

fo~egoing

vulnerability

to computer

systems used by Bethesda backdoors, download

one or more of LulzSec, and

which he provided

to other members

confidential j.

information. In or about June 2011, DAVIS used a backdoor to access without Softworks authorization computer

provided

by ACKROYD

systems used by Bethesda information, which DAVIS

and download

confidential

then organized.

21

k. following message

On or about June 12, 2011, MARTYN posted in the IRC channel #upperdeck:

the

"Ok, who are we

raping, brink?"

to which ACKROYD 1.

responded

affirmatively. the

On or about June 12, 2011, DAVIS posted in the IRC channel #upperdeck:

following

message

"so everyone

knows, Brink

leakage

is 100% organized

on my end; just waiting

on the 200K DB." m. On or about June 21, 2011, a co-conspirator herein provided network SABU with confidential ave hq in

not named as a defendant files relating

to a computer

at the "madison of Sony.

nyc" of Sony Music Entertainment, (Title 18, United FORFEITURE 29. offenses ACKROYD, DAVIS, States

a division

Code, Section

1030(b).)

ALLEGATION

AS TO COUNTS ONE AND TWO one or both of the RYAN

As a result

of committing

alleged a/k/a

in Counts One and Two of this Indictment, a/k/a a/k/a "101," a/k/a "atopiary," a/k/a "lolspoon," JAKE

"kayla,"

a/k/a

"topiary," a/k/a

DARREN MARTYN, and

a/k/a

"pwnsauce," DONNCHA forfeit
§

"raepsauce," a/k/a

"networkkitten,"

O'CEARRBHAIL, to the United

"palladium,"

the defendants,

shall

States, pursuant

to 18 U.S.C. or derived from,

982(a) (2) (B), any property obtained directly

constituting,

proceeds

or indirectly including

as a result of one or to a sum of

both of the said offenses,

but not limited

22

money

representing

the amount of proceeds

obtained

as a result

of one or both of the said offenses. SUBSTITUTE 30. property, ASSETS PROVISION forfeitable of the defendants: of due

If any of the above-described of any act or omission

as a result a.

cannot be located upon the exercise

diligence; b. deposited has been transferred or sold to, or

with, a third person; c. has been placed beyond the jurisdiction of

the Court; d. or e. which has been commingled without with other property has been substantially diminished in value;

cannot be subdivided

difficulty; to 18 U.S.C.

it is the intent of the United

States, pursuant

23

§

982(b) (1) and 21 U.S.C.

§

853(p) { to seek forfeiture

of any

other property forfeitable

of said defendants

up to the value of the above

property.

(Title 18{ United States Code{ Sections 982(a) (2) (B) and (b) (1){ Title 21{ United States Code { Section 853(p).)

PREET BHARARA

united

States Attorney

24

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