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Case 2:24-mj-01395 Document 4 Filed 09/04/24 Filed Under Seal

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
UNITED STATES OF AMERICA
V
CERTAIN DOMAINS
AFFIDAVIT IN SUPPORT OF SEIZURE WARRANT

I, (REDACTED) being duly sworn, hereby declare as follows:

Targeting the U.S. by Influencing Other Countries.

Targeting the U.S. by Influencing Other Countries.

    1. SDA records also revealed its planning of campaigns targeting foreign countries, including Mexico and Israel, with the intent that those efforts would influence associated ethnic or religious groups residing in the United States. The goal of these campaigns was twofold: (1) to influence each countries’ populace; and (2) to influence the U.S. 2024 Presidential Election. A Presidential Administration meeting note from January 13, 2023, revealed that one of the objectives of the campaign, which had been assigned to GAMBASHIDZE, was to draft a media plan for work through expat community media outlets (Armenia–France; Turkey–Germany. Israel–USA)” and to “compile a list of scenarios for stirring inter-ethnic, religious, racial, and political conflicts in focus countries’.”
    2. For example, one SDA document with the sub-heading “PROJECT OF EFFECTIVE PROXY PARTICIPATION IN THE NOVEMBER 2024 CAMPAIGN” presented a theme of “México no perdona” which translates in English to “Mexico does not forgive.” See Exhibit 11. The campaign intended to encourage anti-American sentiment” as well as to exacerbate confrontation between the United States and Mexico. Although the campaign would target Mexico, the campaign’s goal also intended to influence the U.S. Presidential Election. The proposal concluded with: “Today, the time has come to show to the United States that it is under a threat. And we can do it.”
    3. As another example, an SDA document described a project titled The Comprehensive Information Outreach Project in Israel (and also Jewish Community Outreach in the US)”. See Exhibit 12. Similar to the document relating to Mexico, one of the stated goals of this campaign was to influence the 2024 U.S. Presidential Election. Notably, the proposal suggested creating a full-fledged three language” information project that would “target Jewish communities across the globe, first and foremost in Israel and the US.” I believe that this reference to a full-fledged online information project is likely a reference to the unique Doppelganger media brands discussed below.
    4. Consistent with other Doppelganger campaigns explicitly targeting the United States, this Israel-related campaign would involve the creation of a media brand, targeted advertising to spread content, the publication of articles in legitimate media, and an operation involving the widespread posting of social media comments impersonating Israelis. A separate SDA document provided an example of how to pose as an Israeli and disseminate fake articles an comments presenting an unattributed Russian narrative through comments on social media. See Exhibit 13.