◆ SpookStack

COUNT TWO . 2. From in or about February 2002 through in or about April 2002, in the Southern District of New York and elsewhere, ADRIAN LAMO, the defendant, knowingly and with intent to defraud trafficked in and used one and more unauthorized access devices during a one-year period, and by such conduct obtained anything of value aggregating $1,000 and more during that period, to wit, LAMO created, and subsequently used, approximately five user identification namés and passwords under the New York Times’ account with the electronic information service LexisNexis, and by such conduct obtained LexisNexis search services valued in excess of $300,000 during a one-year period. (Title 18, United States Code, Section 1029(a) (2) .) The bases for-the deponent’s knowledge and the foregoing charges are, in part, as follows: 1. I am a Special Agent with the Federal Bureau of Investigation ("FBI") assigned to the Cybercrime Task Force of the FBI's New York Field Division. I have been so employed for approximately two years, and have been an agent of the FBI for ‘approximately six and one-half years. In addition, I have an undergraduate degree in computer science. In the course of my career with the FBI, I have participated in the investigation and prosecution of numerous crimes involving unauthorized access of protected computers. 2. I have participated in the investigation of this matter, and I am familiar with the information contained in this affidavit based on my own personal participation in the investigation, my review of documents and computer records, and conversations I have had with other law enforcement agents and other individuals. Because this affidavit is submitted for the limited purpose of establishing probable cause to arrest ADRIAN LAMO, the defendant, I have not included herein the.details of every aspect of the investigation. Where the actions, conversations, and statements of others are related herein, they are related in substance and in part, except where otherwise indicated. 3. Through my training and experience as an FBI agent, I am familiar with “hackers” and “hacking.” In general, hackers discover and explore vulnerabilities and security weaknesses in computer networks and software. Hackers carry out their activities using hacker tools that can either be custom written software code or, as is more common, software readily FBI(19-cv-1495)-228