AFANASYEVA Steers TENETMEDIA Marketing and Messaging for RT

34. On or about November 1, 2023, one of the six commentators listed on TENETMEDIA ‘s website (“MATT CHRISTIANSEN“) posted a video on YouTube announcing the launch of TENETMEDIA . In the video, MATT CHRISTIANSEN explained that TENETMEDIA was a “project” of Chen and Donovan, who were “trying to build a new platform for independent media” with an initial lineup of six content creators, namely, Dave Rubin through MATT CHRISTIANSEN.
35. After the public launch of TENETMEDIA , AFANASYEVA, using her covert personas “Helena Shudra” and *Victoria Pesti,” aggressively advanced RT‘s investment in TENETMEDIA in at least two ways.
36. First, AFANASYEVA demanded that Chen press TENETMEDIA ‘s hired commentators to share TENETMEDIA content with the commentators’ pre-existing audiences-thus magnifying the impact of RT‘s messaging through TENETMEDIA . For example:a. On or about February 16, 2024, AFANASYEVA (as “Helena Shudra“) messaged Chen on Discord: “I do worry that neither [BENNY JOHNSON] nor [Dave Rubin] share any raw videos posted on X. [Tim Pool] shared only one video this week. [LAUREN SOUTHERN] didn’t share any raw videos, she only shared her mini doc and its promo. [TAYLER HANSEN] is good at sharing our content so far.” AFANASYEVA then asked: “[D]o you think it would be possible if [Producer-1] could start posting videos a bit earlier?” Chen responded that Chen would “talk to [Producer-1] about posting earlier,” and in fact did so. A few days later, AFANASYEVA (as “Helena Shudra‘”) again messaged Chen: “ls [Producer-1] going to post things earlier today?… I think we need to post things earlier and ask [the commentators] media managers to share raw videos (with subtitles) posted on [TENETMEDIA ] X. At least one share per day. Not one share per week.” Chen replied that Chen “asked (Producer-1] to share at least once per day with the creators,” but noted that the commentators were not contractually obligated to share TENETMEDIA content. AFANASYEVA (as “Helena Shudra‘”) responded: “I know this is not an obligation, but we are falling behind with numbers and we need to make our best so the creators can share one raw video per day at least for now.”b. With Chen‘s assistance, AFANASYEVA amplified her request that TENETMEDIA ‘s commentators promote TENETMEDIA content by repeating that request through a second fake persona, “Victoria Pesti.” On or about February 21, 2024, AFANASYEVA (as “Helena Shudra“) messaged Chen on Discord: “Please make invite for Victoria” referring to an invitation for the new Victoria Pesti'” account to join the TENETMEDIA Discord Server. After Chen responded that Chen had already sent the invitation “yesterday,” AFANASYEVA (as “Helena Shudra“) replied, “Sorry I thought you would send it to me here”- thus implying that AFANASYEVA was operating both the “Helena Shudra” and Victoria Pesti” accounts. Chen then assured AFANASYEVA that Chen would “intro Victoria to the chat and restate the importance of social sharing.” The next day, as promised, Chen posted a message to the TENETMEDIA Discord Server, introducing “Victoria Pesti” from “or investor’s team.” AFANASYEVA (as Victoria Pesti'”) announced that “[f]rom now on our top priority should be establishing [TENETMEDIA ] social media presence and we do ask you to start sharing [TENETMEDIA ] posts through your own accounts daily.”
37. Second, with Chen and Donovan‘s backing, AFANASYEVA directed TENETMEDIA staff to publish specific content that AFANASYEVA identified. On or about January 15, 2024, Chen wrote in a channel on the TENETMEDIA Discord Server (the Producer Discord Channel”) comprised of AFANASYVEA, KALASHNIKOV, Chen, Donovan, Producer-1, Producer-2, and Producer-3: “[Helena] is going to start creating customized videos for us to post on our socials of viral content that’s floating around.” Between in about January 2024 and in or about June 2024, AFANASYVEA posted links to approximately 841l video clips, which were routinely posted by TENETMEDIA staff onto TENETMEDIA ‘s social media channels. On occasion, TENETMEDIA staff privately contacted Chen or Donovan to push back on AFANASYEVA’s content and were rebuffed. For example:a. On or about February 15, 2024, AFANASYEVA (as “Helena Shudra“) shared with TENETMEDIA a video of a well-known U.S. political commentator visiting a grocery store in Russia. AFANASYEVA posted the video in the Producer Discord Channel. Later that day, Producer-1 privately messaged Donovan on Discord: They want me to post this” referencing the video that AFANASYEVA had posted but it just feels like overt shilling.” Donovan replied that Chen “thinks we should put it out there.” Producer-1 acquiesced, responding, “”alright I’l put it out tomorrow.”b. As another example, on or about March 22, 2024, AFANASYEVA (as “Helena Shudra“) shared in the Producer Discord Channel a video of the March 22, 2024 terrorist attack on a music venue in Moscow, which killed approximately 145 people and injured hundreds more. Producer-1 privately messaged Chen, writing: “I don’t know if you saw it, but they want me to post some footage from an attack in Moscow today. There’s a watermark in the middle of the page that’s blurred, which looks bad, and it’s also pretty graphic. You can see people getting shot, albeit from far away.” Chen did not push back on the content of the clip, but replied in the Producer Discord Channel: “I’m not sure it’s a good idea to blur out someone’s watermark.” AFANASYEVA (as “Helena Shudra“) then assured the group that “[i]t’s fine no worries. It falls under fair use.” Producer-1 and Producer-2 found a video clip of the attack without a watermark and posted the clip to X, satisfying AFANASYEVA’s request.c. The next day, on or about March 23, 2024, AFANASYEVA (as “Helena Shudra“) privately messaged Chen on Discord asking that “one of our creators . .. record something about [the] Moscow terror attack.” Despite public reporting that the foreign terrorist organization ISIS had claimed responsibility for the attack, AFANASYEVA requested that TENETMEDIA blame Ukraine and the United States, writing: “I think we can focus on the Ukraine/U.S. angle. … [T]he mainstream media spread fake news that ISIS claimed responsibility for the attack yet ISIS itself never made such statements. All terrorists are now detained while they were heading to the border with Ukraine which makes it even more suspicious why they would want to go to Ukraine to hide.” Chen responded that Chen would ask Benny Johnson, and, the next day, confirmed that Benny Johnson said “he’s happy to cover it.”
38. By in or about June 2024, Chen authorized AFANASYEVA and KALASHNIKOV to post content directly on TENETMEDIA ‘s platform, bypassing TENETMEDIA employees altogether. Specifically, on or about June 12, 2024, in a Discord message, Chen informed Producer-l that going forward,” “Helena’s team,” i.e., AFANASYEVA and KALASHNIKOV, would “be posting their own vids directly” to TENETMEDIA ‘s social media accounts. Chen thus gave AFANASYEVA and KALASHNIKOV unfettered access to serve RT messaging to TENETMEDIA ‘s audiences.