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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:

The "Guerrilla Media Campaign in the United States

The “Guerrilla Media Campaign in the United States

  1. SDA documents include a proposal for another campaign focused on influencing the United States, titled “The Guerrilla Media Campaign in the United States.” See Exhibit 9.[i] The Guerilla Media Campaign focused on exploiting the perceived polarization of U.S. society by focusing on eight “Campaign Topics.” As reflected in the proposal, SDA anticipated using social media profiles on Facebook, X (formerly known as Twitter), YouTube, and Truth Social but noted that with “Facebook, Tiviter and YouTube, we need to create multiple perishable’ accounts, primarily for the work with comments.” The Guerilla Media Campaign would disseminate its propaganda through posts, “comments on social networks and local group chats”, memes, and “video content, including news stories in the Fox News style.” SDA’s plan stated “In order for this work to be effective, you need to use a minimum of fake news and a maximum of realistic information. At the same time, you should continuously repeat that this is what is really happening, but the official media will never tell you about it or show it to you.” I believe the reference to the “work in the comments” is a reference to Doppelganger’s creation of inauthentic social media profiles to post comments on social media that included links to the cybersquatted domains, including the SUBJECT DOMAINS. Further, it appears that SDA required a large number of “perishable” accounts to disseminate this content because of enforcement eforts by U.S. social media companies to identify and deactivate accounts associated with Doppelganger. Finally, as noted above, GAMBASHIDZE’s notes from meetings with the Presidential Administration reveal a suggestion to use “real facts to complement fake facts.”

[i] This document follows the same template frequently used by SDA, like in The Good Old U.S.A. Project.