IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA

Holding a Criminal Term 
Grand Jury Sworn in on January 8, 2016

INDICTMENT 

The Grand Jury charges that:

GENERAL ALLEGATIONS

At all times material to this Indictment:

1. Defendant JOAO MANUEL PEREIRA DA FONSECA (..FONSECA',) is a citizen of Po(ugal. Def'endant FONSECA is an electrical-mechanical engineer who owns a company called Tratoscope Research and Development Technologies in portugal.

2. Defendant FONSECA also worked with another Portuguese company, identified herein as the "Portuguese Company." The owner of the Portuguese Company is identified herein as "Coconspirator A."

3. The Portuguese Company also worked with an Iranian company, identified herein as the "lranian Company." One of the employees olthe Iranian Company is identified herein as ''Coconspirator 8."

4. The Iranian Company and the Portuguese Company also worked with a Turkish company, identified herein as the "Turkish Company." The owner ofthe Turkish Company is identified herein as "Coconspirator C."

5. A company located in New Hampshire, identified herein as the "New Hampshire Company," manufactures equipment, that is, an ultra-precision diamond turning lathe that helps produce precision lenses that could have both military and non-military uses ("precision lens equipment").

6. A company located in North Dakota, identified herein as the "North Dakota Company," manufactures a two axis positioning and rate table system that is used to test high precision inertial guidance systems that could have both military and non-military uses ("inertial guidance system test table").

[...]

Read the full indictment below.