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Case 1 18 cr 00633 ERK Document 8 Filed 11 27 18 Page 2 of 34 PageID 49. as soon as an internet user accessed a website and concluded within milliseconds before the. webpage displayed to the user Businesses seeking to promote their goods and services. online brands commonly used entities called demand side platforms DSPs to bid in. these auctions and thereby had their advertisements placed on webpages that real human. internet users were browsing Brands commonly paid for advertising on a lump sum basis. and publishers commonly received payment based on how many times users clicked on or. viewed advertisements sometimes referred to as impressions The entities in between. the brands and the publishers the DSPs SSPs and ad networks that connected SSPs with. publishers charged fees along the way, 3 The defendants in this case used sophisticated computer programming. and infrastructure spread around the world to exploit the digital advertising industry through. fraud They represented to others that they ran legitimate ad networks that delivered. advertisements to real human internet users accessing real internet webpages In fact the. defendants faked both the users and the webpages in each of the charged schemes they. programmed computers they controlled to load advertisements on fabricated webpages via. an automated program in order to fraudulently obtain digital advertising revenue. 4 In one iteration a datacenter based scheme referred to in the ad. industry as Methbot the defendants used computers they controlled that they had rented. from commercial datacenters in Dallas Texas and elsewhere. 5 In another iteration a botnet based scheme referred to in the ad. industry as 3ve 2 Template A the defendants used computers to which they had gained. unauthorized access i e that had been hacked including computers belonging to. Case 1 18 cr 00633 ERK Document 8 Filed 11 27 18 Page 3 of 34 PageID 50. individuals and businesses in the United States and elsewhere including in the Eastern. District of New York,1 The Defendants, 6 The defendant ALEKSANDR ZHUKOV was a citizen of the Russian. Federation He led the development ofthe datacenter based scheme ZHUKOV served as. the chief executive officer of Ad Network 1 the identity of which is known to the Grand. Jury Ad Network 1 was a private corporation owned by ZHUKOV with offices in the. Russian Federation and the Republic of Bulgaria It purported to assist customers with. delivering advertisements to real human internet users via its ad network. 7 The defendant BORIS TIMOKHIN was a citizen ofthe Russian. Federation and worked for Ad Network 1 TIMOKHIN handled programming aspects of. the datacenter based scheme, 8 The defendant MIKHAIL ANDREEV was a resident of the Russian. Federation and the Ukraine and worked for Ad Network 1 ANDREEV handled. programming aspects ofthe datacenter based scheme, 9 The defendant DENIS AVDEEV was a citizen of the Russian. Federation and worked for Ad Network 1 AVDEEV handled technical and business. aspects ofthe datacenter based scheme, 10 The defendant DMITRY NOVIKOV was a resident ofthe Russian.
Federation and worked for Ad Network 1 NOVIKOV handled administrative and. coordination aspects ofthe datacenter based scheme. 11 The defendant SERGEY OVSYANNIKOV was a citizen of the. Republic of Kazakhstan He led the development ofthe botnet based scheme and provided. Case 1 18 cr 00633 ERK Document 8 Filed 11 27 18 Page 4 of 34 PageID 51. technical assistance to the operators ofthe datacenter based scheme OVSYANNIKOV. served as a principal and owner of Ad Network 2 the identity of which is known to the. Grand Jury Ad Network 2 was a private corporation owned by OVSYANNIKOV and. ALEKSANDRISAEV with a registration address in Edinburgh Scotland It purported to. assist customers with delivering advertisements to real human internet users via its ad. 12 The defendant ALEKSANDR ISAEV was a citizen of the Russian. Federation and served as a principal owner and chief executive officer of Ad Network 2. ISAEV handled business and contracting aspects ofthe botnet based scheme. 13 The defendant YEVGENIY TIMCHENKO was a resident ofthe. Republic of Kazakhstan and worked at Ad Network 2 TIMCHENKO handled logistical. and administrative aspects ofthe botnet based scheme. II The Schemes to Defraud,A The Datacenter Based Scheme. 14 In or about September 2014 ZHUKOV TIMOKHIN ANDREEV. AVDEEV and NOVIKOV collectively the Methbot defendants launched a digital. advertising fraud scheme under the guise of operating Ad Network 1 Ad Network 1 had. business arrangements with other advertising networks that enabled it to receive payment in. return for placing advertising placeholders ad tags with publishers on behalf ofthose. advertising networks Rather than place these ad tags on real publishers webpages. however ZHUKOV and others rented more than 1 900 computer servers located at. commercial datacenters in Dallas Texas and elsewhere and used those datacenter computer. servers to simulate humans viewing ads on fabricated webpages By these means the. Case 1 18 cr 00633 ERK Document 8 Filed 11 27 18 Page 5 of 34 PageID 52. Methbot defendants caused thousands of datacenter computer servers to load fabricated. webpages offer up the advertising space on the fabricated webpages for bidding and load. advertisements on the fabricated webpages through an automated computer program This. activity the fraudulent ad traffic was not viewed by any real human internet users. 15 ZHUKOV and others programmed the datacenter computer servers to. load fabricated webpages that is mostly blank webpages containing a blank space for an. ad that purported to be located at the domains of well known publishers ZHUKOV. researched lucrative domains to fabricate and ran online searches for the top 10000. domains and top 100k domains ZHUKOV then sent TIMOKHIN new domains to try. deliberately targeting the top USA desktop domains for businesses in the United States. In this way the Methbot defendants fabricated or spoofed more than 250 000 webpages. distributed across more than 5 000 domains associated with online publishers including the. domains ofthousands of businesses in the United States and multiple businesses in the. Eastern District of New York, 16 TIMOKHIN ANDREEV and others also programmed the datacenter. computer servers to simulate the internet activity of real human internet users when loading. the fabricated webpages in order to deceive SSPs and others in the digital advertising. industry and to evade fraud detection software widely used in the industry They developed. programming code that caused the datacenter computer servers to operate an automated. browser click on online advertisements a randomly determined number oftimes simulate a. mouse moving around and scrolling down a webpage control and monitor video playback. and falsely appear to be signed into popular social media services The programming code. Case 1 18 cr 00633 ERK Document 8 Filed 11 27 18 Page 6 of 34 PageID 53. contained explicit references to Meth and Fake including MethBrowser. MethFlashObjects FakeClient and FakedPixel, 17 In furtherance of their fraudulent scheme the Methbot defendants. communicated with one another about the development ofthis programming code using an. online project management platform For example,a On or about October 25 2014 ANDREEV circulated. programming code and stated that it was designed to ensure that signals coming from the. datacenter computer servers had the correct browser parameters. b On or about October 28 2014 NOVIKOV instructed, TIMOKHIN to carry out research about how to make mouse moves and scroll more.
realistic meaningful on the datacenter computer servers ZHUKOV similarly instructed. TIMOKHIN to address the lack of mouse move an undertaking that continued over the. following year TIMOKHIN researched methods for simulating mouse movements by for. example running an online search for actionscript simulate mouse click. c On or about October 28 2014 NOVIKOV discussed, ejmulating video watch on the datacenter computer servers and cautioned that t he. videos need to be clicked on and watched for 60 90 seconds This was because advertisers. often would not pay for a video impression unless they knew that the user had watched the. video for a substantial amount oftime,d On or about November 21 2014 ANDREEV circulated. programming code and stated that it was designed to set the datacenter computer servers IP. Case 1 18 cr 00633 ERK Document 8 Filed 11 27 18 Page 7 of 34 PageID 54. address time zone to EST Eastern Standard Time by default Earlier that day. ANDREEV had run an online search for new york timezone. e On or about December 1 2014 ANDREEV circulated, programming code designed to cause the datacenter computer servers to automatically start. and stop an online video player and stated Basically this is how it is possible to generate. the events, f In a to do list dated June 25 2015 ZHUKOV instructed. TIMOKHIN to cause the datacenter computer servers to appear to be signed into Facebook. add authorization for Facebook users There is Google twitter too but no FB There. should be approximately 40 ofthem, g On or about August 4 2015 ZHUKOV stated that he intended.
to research the fraud detection software deployed by certain U S cybersecurity firms and. check out their filter for the possibility offucking them over. 18 On or about October 16 2016 after discovering that the signals coming. from the datacenter computer servers did not register as fraudulent with a certain U S. cybersecurity firm ZHUKOV boasted to TIMOKHIN that their scheme was magnificent. On or about December 10 2016 ZHUKOV sent an email to a potential business partner in. which he offered 100 USA traffic that could pass through filters from various U S. cybersecurity firms and amounted to 20 50 millions sic impressions daily. 19 To further deceive SSPs and others in the digital advertising industry. into believing that the datacenter computer servers were genuine human users ZHUKOV. and others leased more than 650 000 Internet Protocol IP addresses from various IP. Case 1 18 cr 00633 ERK Document 8 Filed 11 27 18 Page 8 of 34 PageID 55. address leasing companies and assigned multiple IP addresses to each ofthe datacenter. computer servers ZHUKOV AVDEEV and others then created false entries for the. datacenter computer servers in a global register ofIP addresses These false entries made it. appear that the datacenter computer servers controlled by the Methbot defendants were. residential computers belonging to individual human internet users who were subscribed to. various residential internet service providers For example. a Several ofthe false IP address registry entries misappropriated. or mimicked the corporate identities of at least six major U S internet service providers. including at least one provider with offices in the Eastern District of New York ZHUKOV. maintained a list ofthese and other false corporate names in his cloud storage account. None ofthe IP addresses registered in the respective U S internet service providers real or. mimicked names was actually in their possession custody or control In this way the. Methbot defendants sought to make it appear to SSPs and others that the computers in. question belonged to customers ofthese internet service providers rather than being located. in datacenters, b For the same reason the Methbot defendants also incorporated. false usage and location information into the IP address registries For example on or about. May 13 2016 AVDEEV directed an IP leasing company to change the Usage type for. approximately 261 000 leased IP addresses from commercial or datacenter to ISP. internet service provider ascribe a more diverse set of cities and states to the leased IP. addresses and reduce the number of leased IP addresses associated with certain small cities. to more realistic levels commensurate with their populations In this way the Methbot. Case 1 18 cr 00633 ERK Document 8 Filed 11 27 18 Page 9 of 34 PageID 56. defendants sought to make it appear to SSPs and others that the computers in question. belonged to real human internet users located in homes and businesses around the country. 20 The Methbot defendants thus created the illusion that real human. internet users were visiting real internet webpages ZHUKOV and others solicited bids on. the opportunity to show advertisements to those purported users In response DSPs bid on. those opportunities The winning DSPs made payments to SSPs using money provided by. brands in return for the purported impressions and the SSPs transferred those payments to. advertising networks to be passed along the chain ofintermediaries described above. 21 OVSYANNIKOV collaborated with the Methbot defendants to. knowingly obtain fraudulent ad traffic for his own companies OVSYANNIKOV did. business with the Methbot defendants purchased fraudulent ad traffic from the Methbot. defendants and provided the Methbot defendants with technical advice and assistance to. ensure that the fraudulent ad traffic passed as real For example on or about October 22. 2014 OVSYANNIKOV instructed NOVIKOV that the datacenter computer servers. automated browsers needed to include accept language in their headers vindicating the. purported user s preferred language to evade fraud detection software Similarly in or. these auctions and thereby had their advertisements placed on webpages that real human internet users were browsing Brands commonly paid for advertising on a lump sum basis and publishers commonly received payment based on how many times users clicked on or viewed advertisements sometimes referred to as impressions The entities in between

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