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UN ITED STA TE S O F A M ER IC A
Defendant.
/
C R IM IN A L C O V ER SH EET
Did this m atter originate from a m atterpending in theN orthern R egion ofthe United
StatesAttom ey's Oftice priorto O ctober 14,2003? Y es X No
W IFRED O A .FERRER
UN ITED STATES ATTORN EY
BY :
F N CISCO .M A D E
A SSISTA N T UN ITED STA TE A TTO RN EY
Fla.Bar.N o.41481
99 N .E.4th Street
M iam i,Flolida 33132-2111
TEL (305)961-9159
FAX (305)530-7976
francisco.maderal@ usdoj.gov
Case 1:16-cr-20769-DMM Document 3 Entered on FLSD Docket 08/15/2016 Page 2 of 17
AO 91(Rev.08/09) CriminalComplaint
United StatesofAmerica )
M.
) CaseNo.1% <-3 UQ Q QQc
ROBERT K.DECKER,a/k/a,'DIGITALPOSSIZOIM,'' )
)
)
W Continuedontheattachedsheet.
Complainant'
ssignature
Date: /-P'(
Jud e'
ssignature
A FFIDA V IT
INTRODUCTION
offenses enum erated in Title 18,United States Code,Section 2516(1),and in Title 21,United
2. This affidavit is m ade in support of a crim inal com plaint charging Robert
K enneth DECKER , a/k/a, EEDIG ITA LPO SSIZOIZI,'' w ith conspiracy to distribute controlled
substances,in violation ofTitle 21,U nited States Code,Section 846,and conspiracy to launder
about the m atters set forth herein, but only those facts and circum stances that 1 believe are
sufficientto establish probable cause forthe Courtto sign a crim inalcom plaint.
4. The statem ents contained in this affidavit are based upon m y investigation,
inform ation provided by other sw orn 1aw enforcem ent ofscers and on m y expedence and
PROBABLE CAUSE
This application stem s from an ongoing crim inalinvestigation into drug dealers
M arket.
Case 1:16-cr-20769-DMM Document 3 Entered on FLSD Docket 08/15/2016 Page 4 of 17
In the course of this investigation, 1 have learned that the Alphabay M arket
narcotics,in exchange for Bitcoin and other,peer-to-peer crypto-currencies (also known as,
virtualcurrencies).
As set forth in m ore detail below , probable cause exists that DECKER is
distributing controlled substances and laundering in the proceeds of his activities using the
Bitcoin and the dark web,in conspiracy with the unknown administratorts)ofthe Alphabay
M arketand others.
The Internetis a globalnetw ork of com puters and other devices. D evicesdirectly
connected to the Internetare identified by their unique IP address.This num ber is used to route
infonnation between devices.G enerally, when one device contacts a second device, the first
device m ustbe directed to the IP address ofthe second device. M oreover,when the firstdevice
contacts the second device,the firstdevice provides its own IP address to the second device,so
that the second device know s w here to direct its response. A ccordingly, the tw o connected
user will type the dom ain nam e of the w ebsite- which com m only corresponds to a plain-
language nam e for the w ebsite, c.g., w ww .google.com - into the Uniform Resource Locator
Name System (DNS'') server,which then translates the domain name into the appropriate
num ericalIP address,and thereby allow sthe userto connectw ith the requested w ebsite.
generallylthe user can type that IP address directly into the U RL bar and access the w ebsite in
addressfor any know n U RL and the registered ow ner and location ofany IP address.Thus,w ith
This isproblem atic for anyone conducting crim inalactivity on the intem etand w ishing to rem ain
anonyrRous.
com m unication sent through Tor is directed through num erous relays w ithin the netw ork- and
1The selwer or virtual server w ith a particular IP address can hostm ultiple w ebsites, in which
case entering thatparticular IP addresswould notdirecta userto a single website.However,if
an IP address is associated w ith a single w ebsite,entedng the IP address as described above
would directthe userto thatparticularw ebsite.
2 Private individuals operating hom e com puters usually do not ow n and register their own IP
address;instead,they subscribe to broadband accounts w ith ISPS,such as Com cast or A T& T,
whichinturnassign orleasean IP addresstothem (thesubscriber).Nevertheless,theIP address
can usually be traced to its assi> ed user ata given pointin tim e using the ISPSrecords ofw hich
subscriberw as assigned w hich IP address and w hen.
3
Case 1:16-cr-20769-DMM Document 3 Entered on FLSD Docket 08/15/2016 Page 6 of 17
w rapped in a layer ofencryption ateach relay- such thatthe end recipientofthe com m unication
13. ln orderto accessthe Tornetw ork,anyone can sim ply dow nload the Torbrow ser
softw are and use it to access the internet.The user sim ply inputs a w ebsite IP address or U RL
into the Tor brow ser and the Tor brow ser autom atically encrypts and routes the com m unication
through severalrelays and then outto the destination so thatthe destination w ebsite can only see
I-lomeComputtr M,
,$$.
14,
.
.google,rom
1R:l23.456.789
ln this illustration of a standard internet connection,the w ebsite w ww .google.com can see the
15. Sim ilarly,any person m onitoring the internet traffic at a point betw een the two
w ould see the connection betw een IP 123.456.786 and w w w .google.com and know that those
4
Case 1:16-cr-20769-DMM Document 3 Entered on FLSD Docket 08/15/2016 Page 7 of 17
On the other hand,in the case of a Tor netw ork com m unication,w hen a person
connects to a w ebsite, the traffic is encrypted and routed through m ultiple relays, and that
websitecannotseethatpersonsIP address:
0r
IP:()0 l.00l-001
I'lomtomputtr
1P:123,
456,78t
) www .google-com
TbrRelay 2
1P:* 2-002.
002
TorRelay 3
IP:(
* 3-f)01,
003
In this illustration of a Tor netw ork connection, the website w ww .google.com cannot see the
ln addition,any person m onitoring the internettraffic ata pointbetw een the hom e
com puter and ww w .google.com and would not know that those tw o devices w ere
com m unicating. Instead, depending on the m onitoring point, that person w ould only see the
directconnectionsbetweenthehomecomputerand first(orentry'')Torrelay,betweenthetirst
and second,or second and third Tor l-elays,or between the third (or 'Yxif') Tor relay and
ww w .google.com .
address of the w ebsite in order to have directed a corm ection to it through the Tor netw ork.
Case 1:16-cr-20769-DMM Document 3 Entered on FLSD Docket 08/15/2016 Page 8 of 17
A ccordingly,although the IP address ofthe useris hidden from the w ebsite, the IP address ofthe
The Tor netw ork addresses this problem through a feature know n as t'hidden
Services.''
B .H idden Services:W ebsite A nonym ity Provided by the Tor N etw ork
20. To achieve tnze,tw o-w ay anonm ity,the Tor netw ork also enables w ebsites to
hosting the w ebsite. Such hidden selwices'' operating on Tor have com plex w eb addresses,
21. This alleviatesthe need fora Tornetwork user to know the true IP address ofa
w ebsite.Ratherthe user can directhis Tor brow ser to the onion address,reach the w ebsite,and
neitherthe usernor the w ebsite know s the other's IP address- two-w ay anonym ity is achieved.
Crim inals have taken advantage of the D ark w eb to create w ebsites w ith online
m arketplaces dedicated to the traftk king of controlled substances and other illicit goods.
on the Dark W eb, and how -to guides such as: :l-low to Buy D nlgs Online from D arknet
M arVCtS.''5
transactions online,in a m anner sim ilar to w ell-know n online m arketplaces such as eBay. Like
eBay:
create accounts on A lphabay to advertise their products,such as narcotics or hacked com puter
passw ords,and buyers create accounts to brow se sellers'products and purchase them ; in this
A lphabay vendors.A lphabay also provides a m eans by w hich its users can com m unicate w ith its
advertised and sold and are im m ediately and prom inently visible on the Alphabay w ebsite.Som e
of the item categories listed on the A lphabay w ebsite are: ttFraud,'' tDrtlgs & Chem icals,''
com m erce by w orking to ensure the anonym ity ofits adm inistrators,as w ellasofthe buyers and
Case 1:16-cr-20769-DMM Document 3 Entered on FLSD Docket 08/15/2016 Page 10 of 17
sellers who participate in com m erce on the website.The website is designed to achieve this
anonym ity prim arily by operating asa hidden selwice on the Tornetw ork.
c. To further prom ote anonym ity,purchases are m ade prim arily in bitcoin
A lphabay subsequently transfers the funds to the seller's accountor w allet upon satisfaction of
the term s of sale.ln doing so,A lphabay also provides a ttum bling''or Gtm ixing''service w hich
essentially scram bles m ultiple buyer-seller Bitcoin transactions together in order to concealthe
bitcoin paym ents from buyer to seller orcom m ission paym ents to the adm inistrator.Thus,there
isno directbitcoin transaction betw een the buyer and the seller.
25. The true identity of the individual or individuals w ho control and operate the
Alphabaywebsite,i.e.,theadministratorts),isunknown.
26. O ther D ark W eb m arketplaces,such as N ucleus,D ream M arket,Abraxas,A gora
andEvolution,someofwhichnolongerexist,operate(oroperated)in essentiallythesameway.
D .GD IG ITALPO SSIZOI4''V endor on Alphabay and O ther D ark W eb M arkets
27. Since at least O ctober of 2015,agents w ith the D EA have been investigating a
narcotics vendor, known as 'CD IG ITA LPO SSIZOI4,'' appearing on several D ark W eb
m arketplaces.4 On several occasions, DEA agents have m ade undercover, online purchases of
4 On O ctober 19, 2015,D EA agents review ed blog posts on reddit.com - a social m edia and
new s aggregation,web contentrating and discussion w ebsite- and identified a reddit.com user
w ith the usernam e tCD IGITA LPOSSIZOI4''. D IG ITA LPO SSIZOI4 posted various com m ents on
reddit.com fonlm s,indicating hissale ofcontrolled substanceson variousdark w eb m arkets.
8
Case 1:16-cr-20769-DMM Document 3 Entered on FLSD Docket 08/15/2016 Page 11 of 17
purchased narcotics via U .S.M ail,shipped to undercover m ailboxes in the Southern D istrictof
Florida.Forinstance:
vendor iQDIGITA LPO SSIZOI4'' on the N ucleus M arketplace for .36 bitcoins. In the
vendor'4D IG ITA LPO SSIZOI4''on the D ream M arketM arketplace for .099 bitcoins;and,
vendorCD IG ITA LPO SSIZOI4''on the D ream M arketM arketplace for .22 bitcoins.
28. In all three instances, the controlled substances w ere shipped via U nited States
Southel'n D istlict of Florida. A fter accepting the U C order, D IG lTA LPO SSl2014 wrote the
30. E:DIG ITA LPO SSIZOI4'' has conducted thousands of transaction on num erous
10,738 transactions; N ucleus, w ith 2,373 transactions; Dream M arket, w ith 96l transactions'
,
Abraxas, w ith 200 transactions; and, A gora and Evolution, w ith an unknown num ber of
9
Case 1:16-cr-20769-DMM Document 3 Entered on FLSD Docket 08/15/2016 Page 12 of 17
(Percocet),oxycontin,morphine,andhydromorphone(Dilaudid).
E.DE CK ER & D ecker R esidence A ssociated w ith CCD IG ITA LPO SSIZOI4M
31. A tor near the tim e ofthe first controlled purchase from CCD IG ITA LPO SSIZOIZS''
32. Prior to the tirst controlled purchase, agents perform ed an internet search for
E6-fhis issom e fire shizit!!!!The buds are tight and dank as hell!!! 1'11bring it to
you as long as you have yourhard card. l've gota lotofstrains. Textm e and 1'11
letyou know whatl gotat the presenttim e and 1etm e know how m uch you are
5 D EA was able to confirm thatCED IG ITA LPO SSIZOI4''is the sam e vendor across allofthese
D ark W eb m arketplaces by confirm ing that in each instance 6ED IG ITA LPO SSIZOIZS'' w as
advertising the sam e public encryption key.Persons w ho are involved w ith D ark W eb narcotics
trafficking utilize public key encryption to com m unicate w ith otherpurchasers and sellers on the
m arketplace in order, for instance, to provide inform ation such as a shipping address. If the
m essage w as not encrypted, it would be visible by the adm inistrators of the D ark W eb
m arketplace,and by law enforcem ent,if the m arketplace server w as ever located and seized.
Public key encryption allows the sender of a message to encrypt thatm essage using a long
passcode know n as a public key,w hich the recipientofthe m essage publicly provides to anyone
w ishing to com m unicate w ith them .Thatm essage,in turn,can only be derypted by the recipient
using a corresponding private key know n only to them .The m ost com m only used encryption is
thatknown asPrettyGoodPrivacy(PGP)encryption.Almostal1Dark W ebmarketplacevendor
profiles advertise a public PGP key forthis purpose;the PG P key,therefore,doublesas a unique
fingerprintvisible acrossdark w eb platfonns.
Case 1:16-cr-20769-DMM Document 3 Entered on FLSD Docket 08/15/2016 Page 13 of 17
revealed thatthe num beris a V elizon W ireless cellphone num ber registered to D EC KER atthe
PO SSIBLE''on Facebook.com . Both Facebook accountsare active and postphotos ofD ECK ER
and DECKER'Sw ife atvarious places in D etroit,M ichigan. O n D ecem ber25,2014,D ECK ER'S
36. Postal analysis revealed thatthe aforem entioned package originated in D earborn
online com pany w hich allow sitscustom ersto printtheir ow n stam ps and shipping labels.
37. ln addition, according to the United States Postal Selwice, the P.O . Box was
opened on N ovem ber 14,2014 and listed DECK ER as the only individualauthorized to receive
m ail.
38. On Febnzary 26, 2016, D EA agents observed a 2013 M aroon Honda, bearing
Florida license plate EM GF78 parked in the drivew ay of the D ecker Residence.A query of
Case 1:16-cr-20769-DMM Document 3 Entered on FLSD Docket 08/15/2016 Page 14 of 17
Florida Highw ay Safety and M otor Vehicles revealed that Florida license plate EM GF78 is
enforcem entbegan m onitoring the intenzettraffic to and from the IP addressassociated with the
DeckerResidence.
40. A s discussed above,because ofthe anonym ity provided by the Tor netw ork such
m onitoring w ould not revealthe ultim ate IP address of devices com m unicated w ith through the
Tor netw ork. H owever, such m onitoring could reveal connections to com puters generally
A lphabay through Tor,w illnot reveal any specific IP address associated w ith Alphabay.Rather
such m onitoring couldf reveal connections to com puters generally associated w ith the Tor
network as tt-f'
or N odes,''w hich are the com puters and servers designated by the adm inistrators
ofthe Tornetw ork to route com m unicationsthrough the encrypted Tornetw ork.
6 This w ould not necessarily be the case if the person w as adding an additional layer of
anonymity,such as a virtualprivate network (VPN) colmection,between them and the Tor
netw ork.
12
Case 1:16-cr-20769-DMM Document 3 Entered on FLSD Docket 08/15/2016 Page 15 of 17
A com puterattem pting to connectto the Tornetw ork m ustknow how to contact
a TorN ode in order to initiate a Tor network session,and Tor N ode IP addresses are publicly
from the Com cast IP address associated w ith the D ecker Residence.The pen/trap order results
obtained through July 23, 2016 reveal frequent internet connections from the D ECK ER 'S
residence IP address to know n Tor N odes and,therefore,the Tor netw ork,w hich is consistent
w ith som eone logging on to the crim inal,D ark W eb m arketplaces, such as A lphabay,through
A lthough D EA has ceased m onitoring the IP routing inform ation from the Decker
G .Bitcoin A nalysis
46. Analysis of D ECK ER 'S financial records revealed that DECK ER has a bitcoin
account w ith Coinbase- a bitcoin wallet host and exchanger. Coinbase records revealed that
D ECK ER 'S Coinbase usernam e is D IG ITA LPO SSIZOI4. The em ail listed on D ECK ER 'S
Coinbaseaccountisdigitalpossizol4@yahoo.com.Thetelephonenumberlisted on DECKER'S
Coinbase account m atched the contact num ber that D lG lTA LPO SSI2014 listed in the
aforementionedwww.michigan.budtrader.com marijuanaadvertisement.
47. A preliminary analysisofthe bitcoin block chain revealed thatthe majority of
D ECK ER 'S incom ing bitcoin transactions in his Coinbase account originated from dark net
Case 1:16-cr-20769-DMM Document 3 Entered on FLSD Docket 08/15/2016 Page 16 of 17
m arkets such as A gora M arketplace,N ucleus M arket and Evolution M arketplace. In addition,
outgoing bitcoin transactions w ent to Local Bitcoins- a peer-to-peer bitcoin exchange often
utilized by dark w eb vendorsto anonym ously exchange bitcoin drug proceeds fortiatcurrency.
48. Analysis of D ECK ER 'S bank accounts revealed that D ECK ER spent over
51. A form aldetennination ofdeath has notyetbeen m ade by the coroner.H ow ever,
according to the victim 's fam ily, N .l. strtzggled w ith opioid drug abuse, and there w as no
The day after N .l.'s death,his fam ily discovered a torn-open and em pty U .S.
priority m ailpackage in N .l.'s room .D ECKER was listed as the return addressee and the D ecker
shipped from Dearborn heights M ichigan on July 22,2016 and picked up at a Post O ffice in
Scott,A rkansas on July 25,2016- three days before N .I.'s death.N o pills or other narcotics
Later that sam e day after N .1.'s death,a new package w as delivered to N .I.'s
hom e w ith DECKER 'S P.O .Box listed as the return address.Inside the package,N .l.'s fam ily
discoverednine(9)hydromorphone(Dilaudid)pills.Accordingtothetracking data,thepackage
w as shipped from Dearborn heightsM ichigan on July 27,2016- the day before N .1.'s death.
14
Case 1:16-cr-20769-DMM Document 3 Entered on FLSD Docket 08/15/2016 Page 17 of 17
C ONCLUSION
trafficking activities, know ing that the transaction was designed to conceal and disguise the
nature of the proceeds, in violation of Title 18,United States Code,Section 1956(h) and
1956(a)(1).