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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 SUBJECT DOMAINS

THE SUBJECT DOMAINS

    1. As described above, the SUBJECT DOMAINS were used by individuals abroad who are working under the direction and control of the Russian government, and in particular KIRIYENKO, GAMBASHIDZE, SDA, TUPIKIN, and STRUCTURA, all of whom have been sanctioned by the U.S. Government, along with ANO Dialog, TABAK, and others, to advance their interests and the interests of the Russian government and to facilitate the violation of, or in violation of, the SUBJECT OFFENSES.
    2. As set forth above and in Attachments A-1 through A-9, a search of publicly available Who.is domain name registration records revealed the dates that the SUBJECT DOMAINS were registered, with which registrar, the headquarters of that registrar, the registrant of each of the SUBJECT DOMAINS, and the top-level domain for each of the SUBJECT DOMAINS.