UNITED STATES DISTRICT COURT NORTHERN

DISTRICT OF ILLINOIS

EASTERN DIVISION

)

UNITED STATES OF AMERICA )

)

v. ) No. ______________________

) Violations: Title 18, United

ROBERT J. RIGGS, also known ) States Code, Sections

as Robert Johnson, also ) 1030(a)(6)(A) and 2314

known as Prophet, and )

CRAIG NEIDORF, also known )

as Knight Lightning )

COUNT ONE

The SPECIAL APRIL 1987 GRAND JURY charges:

PROPERTY INVOLVED

1. At all times relevant herein, enhanced 911 (E911) was the national computerized telephone service program for handling emergency calls to the police, fire, ambulance and emergency services in most municipalities in the United States. Dialing 911 provided the public immediate access to a municipality's Public Safety Answering Point (PSAP) through the use of computerized all routing. The E911 system also automatically provided the recipient of an emergency call with the telephone number and location identification of the emergency caller.

2. At all times relevant herein, the Bell South Telephone Company and its subsidiaries ("Bell South") provided telephone services in the nine state area including Alabama, Mississippi, Georgia, Tennessee, Kentucky, Lousiana {sic}, North Carolina, South Carolina and Florida.

3. At all times relevant herein, the E911 system of Bell South was described in the text of a computerized file program known as the Bell South Standard Practice 660-225-104SV Control Office

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Administration of Enhanced 911 Services for Special and Major Account Centers date March, 1988 ("E911 Practice"). The E911 Practice was a highly proprietary and closely held computerized text file belonging to the Bell South Telephone Company and stored on the company's AIMSX computer in Atlanta, Georgia. The E911 Practice described the computerized control and maintainence {sic} of the E911 system and carried warning notices that it was not to be disclosed outside Bell South or any of its subsidiaries except under written agreement.

COMPUTER HACKERS

4. At all times relevant herein, computer hackers were individual involved with the unauthorized access of computer systems by various means.

5. At all times relevant herein, the Legion of Doom (LOD) was a closely knit group of computer hackers involved in:

a. Disrupting telecommunications by entering computerized telephone switches and changing the routing on the circuits of the computerized switches.

b. Stealing proprietary computer source code and information from companies and individuals that owned the code and information.

c. Stealing and modifying credit information on individuals maintained in credit bureau computers.

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d. Fraudulently obtaining money and property from companies by altering the computerized information used by the companies.

e. Disseminating information with respect to their methods of attacking computers to other computer hackers in an effort to avoid the focus of law enforcement agencies and telecommunication security experts.

6. At all times relevant herein ROBERT J. RIGGS, defendant herein, was a member of the LOD.

7. At all times relevant herein CRAIG NEIDORF, defendant herein, was a publisher and editor of a computer hacker newletter {sic} known as "PHRACK."

8. At all times relevant herein, a public access computer bulletin board system (BBS) was located in Lockport, Illinois which provided computer storage space and electronic mail services to its users. The Lockport BBS was also used by computer hackers as a location for exchanging and developing software tools for computer intrusion, and for receiving and distributing hacker tutorials and other information.

E-MAIL

9. At all times relevant herein electronic mail (e-mail) was a computerized method for sending communications and files between individual computers on various computer networks. Persons who sent or received e-mail were identified by an e-mail address, similar to a postal address. Although a person may have more than

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one e-mail address, each e-mail address identified a person uniquely. The message header of an e-mail message identified both the sender and recipient of the e-mail message and the date the was {sic} message sent.

10. Beginning in or about September, 1988, the exact date begin unknown to the Grand Jury, and continuing until the return date of this indictment, at Lockport, in the Northern District of Illinois, Eastern Division, and elsewhere,

ROBERT J. RIGGS, also known
as Robert Johnson, also
known as Prophet, and
CRAIG NEIDORF, also known
as Knight Lightning,

defendants herein, together with others known and unknown to the Grand Jury, devised and intended to devise and participated in a scheme and artifice to defraud and to obtain money and other things of value by means of false and fraudulent pretenses and representations, well knowing at the time that such pretenses, representations and promises were false when made.

OBJECT OF FRAUD SCHEME

11. The object of the fraud scheme was to steal the E911 Practice text file from the computers of Bell South Telephone Company though {sic} the use of false and fraudulent pretenses and representations and to conceal all indications that the text file had been stolen; and to thereafter publish the information about the E911 Practice text file in a hacker publication for dissemination.

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OPERATION OF FRAUD SCHEME

12. It was part of the fraud scheme that the defendant NEIDORF would and did advise the defendant RIGGS that he had assembled a group of computer hackers for the purpose of distributing computer information.

13. It was further part of the scheme that the defendant RIGGS would and did steal sensitive proprietary Bell South information files including the E911 Practice text file by gaining remote unauthorized access to computers of the Bell South Telephone Company.

14. It was further part of the scheme that the defendant RIGGS would and did disguise and conceal the theft of the E911 Practice text file from Bell South Telephone Company by removing all indications of his unauthorized access into Bell South computers and by using account codes of legitimate Bell South users to disguise his authorized use of the Bell South computer.

15. It was further part of the scheme that RIGGS would and did transfer in interstate commerce a stolen E911 Practice text file from Atlanta, Georgia to Lockport, Illinois through the use of an interstate computer data network.

16. It was further part of the scheme that defendant RIGGS would and did store the stolen E911 Practice text file on a computer bulletin board system in Lockport, Illinois.

17. It was further part of the scheme that defendant NEIDORF, utilizing a computer at the University of Missouri in Columbia, Missouri would and did receive a copy of the stolen E911 text file

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>from defendant RIGGS through the Lockport computer bulletin board system through the use of an interstate computer data network.

18. It was further part of the scheme that defendant NEIDORF would and did edit and retype the E911 Practice text file at the request of the defendant RIGGS in order to conceal the source of the E911 Practice text file and to prepare it for publication in a computer hacker newsletter.

19. It was further part of the scheme that defendant NEIDORF would and did transfer the stolen E911 Practice text file through the use of an interstate computer bulletin board system used by defendant RIGGS in Lockport, Illinois.

20. It was further part of the scheme that the defendants RIGGS and NEIDORF would publish information to other computer hackers which could be used to gain unauthorized access to emergency 911 computer systems in the United States and thereby disrupt or halt 911 service in portions of the United States.

22. It was further a part of the scheme that the defendants would and did misrepresent, conceal, and hide, and cause to be misrepresented, concealed and hidden the purposes of ane {sic} the acts done in furtherance of the fraud scheme, and would and did use coded language and other means to avoid detection and apprehension

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by law enforcement authorities and to otherwise provide security to the members of the fraud scheme.

23. In or about December, 1988, at Lockport, in the Northern District of Illinois, Eastern Division, and elsewhere,

ROBERT J. RIGGS, also known
as Robert Johnson, also
known as Prophet, and
CRAIG NEIDORF, also known
as Knight Lightning,

defendant herein, for the purpose of executing the aforesaid scheme, did knowingly transmit and cause to be transmitted by means of a wire communication in interstate commerce certain signs, signals and sounds, namely: a data transfer of a E911 Practice text file from Decatur, Georgia to Lockport, Illinois.

In violation of Title 18, United States Code, Section 1343.

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COUNT TWO

The SPECIAL APRIL 1987 GRAND JURY further charges:

 

1. The Grand Jury realleges and incorporates by reference the allegations of paragraphs 1 through 22 of Count One of this Indictment as though fully set forth herein.

2. On or about January 23, 1989, at Lockport, in the Northern District of Illinois, Eastern Division and elsewhere,

ROBERT J. RIGGS, also known
as Robert Johnson, also
known as Prophet, and
CRAIG NEIDORF, also known
as Knight Lightning,

the defendants herein, for the purposes of executing the aforesaid scheme did knowingly transmit and cause to be transmitted by means of a wire communication in interstate commerce certain signs, signals and sounds, namely: a data transfer of a E911 Practice text file from Decatur, Georgia to Lockport, Illinois, an edited and retyped E911 Practice text file from Columbia, Missouri, to Lockport, Illinois.

In violation of Title 18, United States Code, Section 1343.

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COUNT THREE

The SPECIAL APRIL 1987 GRAND JURY further charges:

1. The Grand Jury realleges and incorporates by reference the allegations of paragraphs 1 through 22 of Count One of this indictment as though fully set forth herein.

2. In or about December, 1988, at Lockport, in the Northern District of Illinois, Eastern Division, and elsewhere,

ROBERT J. RIGGS, also known
as Robert Johnson, also
known as Prophet, and
CRAIG NEIDORF, also known
as Knight Lightning,

defendants herein, did transport and cause to be transported in interstate commerce from Decatur, Georgia, to Lockport, Illinois, a computerized text file with a value of $5,000 or more, namely:

A Bell South Standard Practice (BSP) 660-225-104SV- Control Office Administration of Enhanced 911 Services for Special Services and Major Account Centers dated March, 1988; valued at approximately $79,449.00

the defendants then and there knowing the same to have been stolen, converted, and taken by fraud;

In violation of Title 18, United States Code, Section 2314.

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COUNT FOUR

The SPECIAL APRIL 1987 GRAND JURY further charges:

1. The Grand Jury realleges and incorporates by reference the allegations of paragraphs 1 through 22 of Count one of this Indictment as though fully set forth herein.

2. On or about January 23, 1989, at Lockport, in the Northern District of Illinois, Eastern Division, and elsewhere,

ROBERT J. RIGGS, also known
as Robert Johnson, also
known as Prophet, and
CRAIG NEIDORF, also known
as Knight Lightning,

defendants herein, did transport and cause to be transported in interstate commerce from Columbia, Missouri, to Lockport, Illinois, a computerized textfile with a value of $5,000 or more, namely:

An edited Bell South Standard Practice (BSP) 660-225- 104SV- Control Office Administration of Enhanced 911 Services for Special Services and Major Account Centers dated March, 1988; valued at approximately $79,449.00.

the defendants, then and there knowing the same to have been stolen, converted, and taken by fraud;

In violation of Title 18, United States Code, Section 2314.

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COUNT FIVE

The SPECIAL APRIL 1987 GRAND JURY further charges:

1. The Grand Jury realleges and incorporates by reference the allegations of paragraphs 1 through 22 of Count One of this Indictment as though fully set forth herein.

2. On or about December, 1988, at Lockport, in the Northern District of Illinois, Eastern Division and elsewhere,

ROBERT J. RIGGS, also known
as Robert Johnson, also
known as Prophet, and
CRAIG NEIDORF, also known
as Knight Lightning,

the defendants herein, knowingly and with intent to defraud, trafficked in information through which a computer may be accessed without authorization and by such conduct affected interstate commerce;

In violation of Title 18, United States Code, Section 1030(a)(6)(A).

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COUNT SIX

The SPECIAL APRIL 1987 GRAND JURY further charges:

1. The Grand Jury realleges and incorporates by reference the allegations of paragraphs 1 through 22 of Count One of this Indictment as though fully set forth herein.

2. In or about January, 1989, at Lockport, in the Northern District of Illinois, Eastern Division and elsewhere,

ROBERT J. RIGGS, also known
as Robert Johnson, also
known as Prophet, and
CRAIG NEIDORF, also known
as Knight Lightning,

the defendants herein, knowingly and with intend to defraud, trafficked in information through which a computer may be accessed without authorization and by such conduct affected interstate commerce;

In violation of Title 18, United States Code, Section 1030(a)(6)(A).

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COUNT SEVEN

The SPECIAL APRIL 1987 GRAND JURY further charges:

1. The Grand Jury realleges and incorporates by reference the allegations of paragraphs 1 through 22 of Count One of this Indictment as though fully set forth herein.

2. In or about February, 1989, at Lockport, in the Northern District of Illinois, Eastern Division and elsewhere,

ROBERT J. RIGGS, also known
as Robert Johnson, also
known as Prophet, and
CRAIG NEIDORF, also known
as Knight Lightning,

the defendants herein, knowingly and with intent to defraud, trafficked in information through which a computer may be accessed without authorization and by such conduct affected interstate commerce;

In violation of Title 18, United States Code, Section 1030(a)(6)(A).

A TRUE BILL:

________________________________

F O R E P E R S O N

________________________________

UNITED STATES ATTORNEY

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