I, the undersigned Complainant, being duly sworn, state the following is true and correct to the best of my knowledge and belief.

COUNT ONE

(Wire Fraud)

On or about July 15, 2015, in the State and District of Minnesota and elsewhere, the defendant, SEYED SAJJAD SHAHIDIAN, having devised a scheme to defraud, and for the purpose of executing a scheme to defraud and to obtain property by means of false or fraudulent pretenses, knowingly transmitted and caused to be transmitted by means of wire communications in interstate and foreign commerce an interstate wire communication; specifically, a payment of for the purchase of computer software from a PayPal account controlled by the defendant to Digital River, a payment processing company located in Minnetonka, Minnesota, in violation of Title 18, United States Code, Section 1343.

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