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1. From at least in or about August 2020 to at least in or about November 2020, SEYYED MOHAMMAD HOSEIN MUSA KAZEMI a/k/a "Mohammad Hosein Musa Kazem," a/k/a "Hosein Zamani," and SAJJAD KASHIAN a/k/a "Kiarash Nabavi," the defendants, both of whom are nationals of the Islamic Republic of Iran ("Iran"), participated in a coordinated and multi-faceted, cyber-enabled campaign to intimidate and influence American voters, and otherwise undermine voter confidence and sow discord, in connection with the 2020 U.S. Presidential election (the "Voter Intimidation and Influence Campaign").
2. At all times relevant to this Indictment, Eeleyanet Gostar (now known as Emennet Pasargad) was an Iran-based company that purported to provide cybersecurity services within Iran. Eeleyanet Gostar has provided services to the Iranian Government, including to an influential governmental body, the Guardian Council. SEYYED MOHAMMAD HOSEIN MUSA KAZEMI, a/k/a "Mohammad Hosein Musa Kazem," a/k/a "Hosein Zamani," and SAJJAD KASHIAN, a/k/a "Kiarash Nabavi," the defendants, were experienced hackers who worked as contractors for Eeleyanet Gostar.
3. The first phase of the Voter Intimidation and Influence Campaign occurred in or about September and October 2020, when the members of the conspiracy conducted reconnaissance on, and attempted to compromise, approximately eleven state voter websites, including state voter registration websites and state voter information websites. These efforts resulted in the successful exploitation of misconfigured computers of a particular U.S. state ("State-1"), and the resulting unauthorized downloading of voter information for more than 100,000 State-1 voters.