Alexander Indictment
MrVidmar
COUNTS ONE-THIRTY-FOUR: 18 U.S.C. � 1030(a)(2)(C) - Computer Intrusion
COUNT THIRTY-FIVE: 18 U.S.C. � 1028(A)(a)(1) and 1030(c)(2)(B)(ii)-
Aggravated Identity Theft
A true bill.
INDICTMENT
The Grand Jury charges:
INTRODUCTORY ALLEGATIONS
At all times relevant to this Indictment:
The United States Chess Federation (USCF), headquartered in Crossville,
Tennessee, was a not-for-profit membership organization founded in 1939
for chess players and chess supporters consisting of over 80,000 members
and 2,000 affiliated chess clubs and organizations.
2. Yahoo! (Yahoo) was an Electronic Communications Service Provider
providing electronic mail ("e-mail") and other services to the public in
the United States and abroad, and its e-mail computers and servers for
the yahoo.com domain were located in Sunnyvale, California. Yahoo's
e-mail accounts required the entry of the account holder's usernarne and
password before access to the account was granted.
3. Randall Hough (Hough) was a resident of Alhambra, California and a
member of the USCF's Board of Directors. Hough was the subscriber of the
e-mail account: randal...@yahoo.com provided by Yahoo. Hough did not
authorize anyone to access his Yahoo e-mail account.
4. Gregory Alexander (ALEXANDER) was a resident of Everett, Washington,
and worked in the Internet Technology offices of the University of
Washington. ALEXANDER also served as a volunteer web developer who
maintained and moderated the Chess Discussion Forum on the website known
as chessdiscussion.com
COUNT ONE THROUGH THIRTY-FOUR: (18 U.S.C. 1030(a)(2)(C) and
(c)(2)(B)(ii) - Intentionally Accessing A Computer Without Authorization)
6. The factual allegations in paragraphs 1 through 4 are re-alleged and
incorporated herein as if set forth in full.
7. On or about the dates set forth below, in the Northern District of
California, GREGORY ALEXANDER intentionally and without authorization
accessed a protected computer, to wit: the e-mail server operated by
Yahoo administering the e-mail account randal...@vahoo.com, by means
of interstate communications, and thereby obtained information from said
protected computer, on the dates and times as set forth below:
I Tue 23:49:44 (PST) 24-Jun-2008
2 Mon 00:17:27 (PST) 23-Jun-2008
3 Sat 00:54:31 (PST) 21-Jun-2008
4 Mon 07:52:46 (GMT) 02-Jun-2008
5 Thu 06:53:44 (GMT) 29-May-2008
6 Sat 06:52:13 (GMT) 19-Apr-2008
7 Thu 06:56:55 (GMT) 18-Apr-2008
8 Wed 06:34:24 (GMT) 16-Apr-2008
9 Tue 00:43:49 (PST) 15-Apr-2008
10 Mon 07:22:59 (GMT) 14-Apr-2008
11 Sun 08:14:05 (GMT) 13-Apr-2008
12 Sat 08:22:24 (GMT) 12-Apr-2008
13 Fri 00:35:02 (PST) 11-Apr-2008
14 Thu 01:28:50 (PST) 10-Apr-2008
15 Fri 22:33:14 (PST) 10-Apr-2008
16 Wed 08:49:09 (GMT) 12-Mar-2008
17 Sun 11:02:28 (GMT) 09-Mar-2008
18 Sat 09:06:32 (GMT) 08-Mar-2008
19 Wed 08:02:06 (GMT) 05-Mar-2008
20 Tue 08:33:27 (GMT) 04-Mar-2008
21 Sun 08:53:12 (GMT) 02-Mar-2008
22 Sat 08:50:33 (GMT) 01-Mar-2008
23 Tue 09:24:49 (GMT) 26-Feb-2008
24 Sun 09:38:17 (GMT) 17-Feb-2008
25 Sun 09:30:06 (GMT) 17-Feb-2008
26 Sun 08:54:02 (GMT) 20-Jan-2008
27 Fri 07:59:00 (GMT) 18-Jan-2008
28 Thu 06:49:03 (GMT) 17-Jan-2008
29 Wed 09:34:00 (GMT) 02-Jan-2008
30 Sat 00:42:07 (PST) 01-Dec-2007
31 Fri 23:57:25 (PST) 29-Nov-2007
32 Wed 08:04:02 (GMT) 28-Nov-2007
33 Tue 08:03:31 (GMT) 27-Nov-2007
34 Mon 09:00:49 (GMT) 26-Nov-2007
All in violation of 18 U.S.C. �� 1030(a)(2)(C) and (c)(2)(B)(ii).
COUNT THIRTY-FIVE: (18 U.S.C. � 1028A(a)(1)--Aggravated Identity Theft)
8. The factual allegations in paragraphs 1 through 4 are re-alleged and
incorporated herein as if set forth in full.
9. On or about November 2007 and continuing through on or about August
2008, in the Northern District of California,
GREGORY ALEXANDER
did knowingly possess and use, without lawful authority, a means of
identification of another person, that is, the username and password
used to access information on a computer, during and in relation to an
offense under 18 U.S.C. �� 1030(a)(2)(C) and (c)(2)(B)(ii), namely,
felony fraud in connection with computers, said offense being a felony
enumerated in 18 U.S.C. � 1028A(a)(1).
JOSEPH P. RUSSONIELLO United States Attorney
MATTHEW A. PARRELLA
Chief, Computer Hacking and Intellectual Property Unit