UNITED STATES OF AMERICA, HUNTER MOORE and CHARLES EVENS, aka "Gary," 0 FILE ZUIHDEC 20 PH h= 07 mt mam>>: s.n1s1n1c1Cc_0LlIF . PST OF UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA October 2013 Grand Jury U.S.C. 1030(a)(2)(C), Unauthorized Access to a Protected Computer to Obtain Information; 18 U.S.C. 1028A(a)(1): Aggravated Plaintiff, "In-gpi v. 371: Conspiracy; Identity Theft; 18 U.S.C. 2: Aiding and Abetting and Causing an Act To Be Done] Defendants. The Grand Jury charges: COUNT ONE [18 U.S.C. 371] A. INTRODUCTION l0 At all times relevant to this Indictment: a0 Defendant HUNTER MOORE resided in Woodland, California. b. Defendant MOORE operated the website on which he posted, among other things, nude or sexually explicit photos of victims submitted by other ,7 . /6/y individuals without the victim's permission for purposes of revenge. c. Defendant CHARLES EVENS, also known as "Gary" resided in the Central District of California. d. Defendant MOORE used the following e-mail accounts: isanyoneup@gmail.com and e. Defendant EVENS used the following e-mail accounts: and f. The online form used to submit images on defendant MOORE's website is hosted through JotForm.com. g. Defendant MOORE used online Paypal accounts with the following user IDs: "Hunter Moore," "Catalyst Web Services," and "quebella." h. Victims L.B., V.E., K.L., P.K., T.G., S.M., and T.K. maintained e-mail accounts that contained, among other things, nude pictures of themselves and others. i. Google, Inc. ("Google") provided e-mail services to users all over the world. j. Yahoo! Inc. ("Yahoo!") provided e-mail services to users all over the world. B. THE OBJECT OF THE CONSPIRACY 2. Beginning on an unknown date and continuing through on or about May 2, 2012, in Los Angeles County, within the Central District of California, and elsewhere, defendants MOORE and EVENS, together with others known and unknown to the Grand Jury, knowingly combined, conspired, and agreed to commit the 2 following offense against the United States: To access a protected computer without authorization to obtain information for private financial gain, in violation of Title 18, United States Code, Sections 1030(a)(2)(C), C. THE MANNER AND MEANS OF THE CONSPIRACY 3. The object of the conspiracy was carried out, and to be carried out, in substance, as follows: a. Defendant EVENS would gain unauthorized access to the e-mail accounts of hundreds of victims (the "victims' accounts") by various means, including "hacking" into the victims' accounts, and obtain information, including nude pictures, belonging to the victims and stored on the victims' accounts. b. Defendant EVENS would send nude pictures obtained from the victims' accounts to defendant MOORE in exchange for payment. c. Defendant MOORE, aware that defendant EVENS had obtained the nude pictures by gaining unauthorized access into the victims' accounts, would send payments to defendant EVENS using Paypal or directly from his bank account in exchange for the nude pictures, would offer defendant EVENS additional money to obtain unlawfully additional nude pictures, and would post the victims' nude pictures on his website, without the victims' authorization. D. OVERT ACTS 4. In furtherance of the conspiracy and to accomplish its object, defendants MOORE and EVENS, together with others known and unknown to the Grand Jury, committed, and willfully caused 3 others to commit, the following overt acts, among others, in the Central District of California and elsewhere: 2011, defendant Overt Act No. 1: On or about October 10, EVENS sent to defendant MOORE an e-mail discussing "how to hack e-mails." Overt Act No. 2: On or about October 15, 2011, defendant MOORE sent to defendant EVENS an e-mail asking defendant EVENS to work for him. Overt Act No. 3: On or about October 17, 2011, defendant MOORE sent to defendant EVENS an e-mail offering to pay defendant EVENS $200 per week using Paypal. Overt Act No. 4: On or about October 17, 2011, defendant EVENS sent to defendant MOORE an e-mail stating that the hacking that defendant EVENS is doing is illegal. Overt Act No. 5: On or about October 17, 2011, defendant MOORE sent to defendant EVENS an e-mail stating that he is employing defendant EVENS and instructing defendant EVENS to use an anonymous Paypal account to avoid detection of their scheme and connection to each other. 2011, defendant Overt Act No. 6: On or about October 17, MOORE sent to defendant EVENS an e-mail stating that defendant EVENS would receive payments "from catalyst or something paypal." Overt Act No. 7: 2011, defendant On or about October 18, MOORE sent to defendant EVENS an e-mail asking defendant EVENS to send him naked pictures and stating that he would send payments to defendant EVENS using Paypal. Overt Act No. 8: On or about October 29, 2011, defendant MOORE sent to defendant EVENS an e-mail stating that they needed to create new e-mail accounts and delete evidence of the hacking scheme. Overt Act No. 9: On or about December 8, 2011, defendant EVENS sent to defendant MOORE an e-mail asking for $250 for nude pictures of "6 guys and 6 girls." On or about December 8, 2011, defendant Overt Act No. 10: MOORE sent to defendant EVENS an e-mail stating he would like "as many as possible" (referring to the nude pictures that defendant EVENS had obtained by hacking into the victims' accounts). Overt Act No. 11: On or about December 8, 2011, defendant EVENS accessed victim L.B's e-mail account without authorization. Overt Act No. 12: On or about December 8, 2011, defendant EVENS obtained pictures, including a nude picture, of victim L.B. from victim L.B.'s e-mail account. Overt Act No. 13: On or about December 11, 2011, defendant EVENS submitted pictures, including a nude picture, of victim L.B. to defendant MOORE's website, 14: Overt Act No. On or about December 14, 2011, defendant MOORE paid $145.70 to defendant EVENS using Paypal. Overt Act No. 15: On or about December 29, 2011, defendant MOORE posted a nude picture of victim L.B. on his website, Overt Act No. 16: On or about December 30, 2011, defendant EVENS accessed victim V.E.'s e-mail account without authorization. Overt Act No. 17: On or about December 30, 2011, defendant EVENS obtained pictures, including a nude picture, of victim V.E. from victim V.E.'s e-mail account. On or about December 31, 2011, Overt Act No. 18: defendant MOORE sent to defendant EVENS an e-mail stating he needed all the nude pictures defendant EVENS had obtained by hacking into the victims' accounts. Overt Act No. 19: On or about January 1, 2012, defendant EVENS accessed victim K.L.'s e-mail account without authorization. 2012, defendant Overt Act No. 20: On or about January 1, EVENS obtained nude pictures of victim K.L. from victim K.L.'s e-mail account. 2012, defendant Overt Act No. 21: On or about January 2, MOORE sent to defendant EVENS an e-mail asking defendant EVENS to "hack more." 2012, defendant Overt Act No. 22: On or about January 4, EVENS accessed victim P.K.'s e-mail account without authorization. Overt Act No. 23: On or about January 4, 2012, defendant EVENS obtained pictures, including a nude picture, of victim D.W. from victim P.K.'s e-mail account. 2012, defendant Overt Act No. 24: On or about January 7, EVENS accessed victim T.G.'s e-mail account without authorization. Overt Act No. 25: On or about January 7, 2012, defendant EVENS obtained pictures, including nude pictures, of victim T.G. and others from victim T.G.'s e-mail account. Overt Act No. 26: On or about January 8, 2012, defendant MOORE sent to defendant EVENS an e-mail asking defendant EVENS to "hack all week for me" and stating that he could pay defendant EVENS. Overt Act No. 27: On or about January 8, 2012, defendant EVENS submitted pictures, including a nude picture, of victim K.L. to defendant MOORE's website, defendant Overt Act No. 28: 2012, On or about January 8, EVENS submitted pictures, including a nude picture, of victim D.W. to defendant MOORE's website, Overt Act No. 29: On or about January 8, 2012, defendant MOORE paid $294 to defendant EVENS using Paypal. Overt Act No. 30: On or about January 8, 2012, defendant MOORE posted a nude picture of victim D.W. on his website website, Overt Act No. 31: On or about January 9, 2012, defendant EVENS submitted pictures, including a nude picture, of victim V.E. to defendant MOORE's website, Overt Act No. 32: On or about January 9, 2012, defendant MOORE posted a nude picture of victim K.L. on his website website, Overt Act No. 33: On or about January 9, 2012, defendant EVENS submitted pictures, including a nude picture, of victim T.G. to defendant MOORE's website, Overt Act No. 34: On or about January 9, 2012, defendant MOORE paid $264 to defendant EVENS using Paypal. Overt Act No. 35: 2012, defendant On or about January 12, MOORE posted a nude picture of victim V.E. on his website website, Overt Act No. 36: On or about January 16, 2012, defendant MOORE sent to defendant EVENS an e-mail asking defendant EVENS to "back more." Overt Act No. 37: 2012, defendant On or about January 22, EVENS accessed victim S.M.'s e-mail account without authorization. Overt Act No. 38: On or about January 22, 2012, defendant EVENS obtained nude pictures of victim S.M. from victim S.M.'s e-mail account. Overt Act No. 39: On or about January 24, 2012, defendant EVENS submitted pictures, including a nude picture, of victim S.M. to defendant MOORE's website, Overt Act No. 40: On or about January 25, 2012, defendant MOORE paid $200 to defendant EVENS using Paypal. Overt Act No. 41: On or about January 27, 2012, defendant MOORE posted a nude picture of victim S.M. on his website Jwebsite, 42: Overt Act No. On or about January 29, 2012, defendant MOORE sent to defendant EVENS an e-mail stating he needed nude pictures. Overt Act No. 43: On or about January 29, 2012, defendant EVENS accessed victim T.K.'s e-mail account without authorization. Overt Act No. 44: On or about January 29, 2012, defendant EVENS obtained pictures, including a nude picture, of victim T.K. from victim T.K.'s e-mail account. Overt Act No. 45: On or about January 29, 2012, defendant EVENS submitted pictures, including a nude picture, of victim T.K. to defendant MOORE's website, Overt Act No. 46: 2012, defendant On or about January 29, MOORE paid $350 to defendant EVENS using Paypal. Overt Act No. 47: On or about January 29, 2012, defendant MOORE posted a nude picture of victim T.K. on his website website, Overt Act No. 48: On or about February 21, 2012, defendant MOORE sent to defendant EVENS an e-mail requesting nude pictures of "7 girls and 3 dudes." Overt Act No. 49: On or about February 21, 2012, defendant MOORE sent to defendant EVENS an e-mail confirming defendant MOORE's mother's e-mail address as quebella2011@gmail.com. Overt Act No. 50: On or about February 21, 2012, defendant EVENS sent to defendant MOORE an e-mail requesting a wire transfer. 2012, Overt Act No. 51: On or about February 21, defendant EVENS sent to defendant MOORE an e-mail containing defendant bank account information. Overt Act No. 52: On or about February 21, 2012, defendant MOORE electronically transferred $500 from his bank account to defendant EVENS. Overt Act No. 53: On or about February 23, 2012, defendant MOORE electronically transferred $135 from his bank account to defendant EVENS. Overt Act No. 54: On or about February 23, 2012, defendant MOORE sent to defendant EVENS an e--mail stating that he "only sent 135." defendant On or about March 2, 2012, Overt Act No. 55: MOORE sent to defendant EVENS an e--mail asking defendant EVENS to submit nude pictures so defendant MOORE could "send the other lk." Overt Act No. 56: On or about March 2, 2012, defendant MOORE electronically transferred $900 from his bank account to defendant EVENS. Overt Act No. 57: On or about March 2, 2012, defendant EVENS sent to defendant MOORE an e--mail confirming that he had received $900. 10 COUNTS TWO THROUGH EIGHT [18 U.S.C. 1030(a)(2)(C), 2] S. The Grand Jury hereby repeats and realleges paragraphs 1, 3, and 4 of this Indictment, including all subparagraphs, as if fully set forth herein. 6. On or about the dates set forth below, in Los Angeles County, within the Central District of California, and elsewhere, defendants HUNTER MOORE and CHARLES EVENS, also known as "Gary," aiding and abetting one another, knowingly and intentionally accessed and caused to be accessed without authorization, and thereby obtained information, namely, the contents of the following victim's e-mail account, from a computer used in and affecting interstate and foreign commerce, a server of the service provider described below, for namely, purposes of private financial gain: COUNT DATE ACCOUNT HOLDER SERVICE PROVIDER VICTIM TWO 12/8/2011 L.B. Google THREE 12/30/2011 V.E. Google FOUR 1/1/2012 K.L. Google FIVE 1/4/2012 P.L. Google SIX 1/7/2012 T.G. Yahoo! SEVEN 1/22/2012 S.M. Google EIGHT 1/29/2012 T.K. Google 11 COUNTS NINE THROUGH FIFTEEN [18 U.S.C. 1028A(a)(l), 2] 7. The Grand Jury hereby repeats and realleges paragraphs 1, 3, and 4 of this Indictment, including all subparagraphs, as if fully set forth herein. 8. On or about the dates set forth below, in Los Angeles County, within the Central District of California, and elsewhere, defendants HUNTER MOORE and CHARLES EVENS, also known as "Gary," aiding and abetting one another, knowingly and without lawful authority possessed and used, and willfully caused others to possess and use, means of identification of the usernames of the below-described other persons, that is, individuals, during and in relation to the below-described felony violations of unauthorized access to a protected computer to obtain information for private financial gain, in violation Sections 1030(a)(2)(C), of Title 18, United States Code, DATE VICTIM RELATED NINE 12/8/2011 L.B. TWO TEN 12/30/2011 V.E. THREE ELEVEN 1/1/2012 K.L. FOUR TWELVE 1/4/2012 P.L. FIVE THIRTEEN 1/7/2012 T.G. SIX 12 COUNT DATE VICTIM RELATED COUNT FOURTEEN 1/22/2012 S.M. SEVEN FIFTEEN 1/29/2012 T.K. EIGHT A TRUE BILL I Foreperson 4' ANDRE BIROTTE JR. United States Attorney fl/2'. OW ROBERT E. DUGDALE Assistant United States Attorney Chief, Criminal Division WESLEY L. HSU Assistant United States Attorney Chief, Cyber and Intellectual Property Crimes Section ERIC D. VANDEVELDE Assistant United States Attorney Deputy Chief, Cyber and Intellectual Property Crimes Section WENDY T. WU Assistant United States Attorney Cyber and Intellectual Property Crimes Section 13