◆ SpookStack

employees and personal information regarding 3,000 contributors to the New York Times Op-Ed page; that LAMO had accessed information regarding New York Times home delivery subscribers; and that LAMO had gained this access to the NYT Intranet through an open proxy server. The author of the Article provided the Internet Protocol addresses? (“IP addresses”) for seven proxy servers allegedly accessed by LAMO. The author of the Article stated that his source, i.e. LAMO, had provided screen captures’ showing internal images of the NYT Intranet, along with other information confirming the intrusion. The author of the Article also provided LAMO’s cellular telephone number -- (415) 505-HACK® -- to NYT Representative One. {b) Following the initial conversation with the author of the Article, the New York Times conducted an internal investigation into the alleged intrusion and confirmed that an unauthorized intruder had accessed the NYT Intranet using a proxy server® that was among the seven identified by the author of the Article.’ The investigation revealed that the intruder had 3 An Internet Protocal or IP address is a unique numeric address use by computers on the Internet to communicate. ‘ A “screen capture” is an electronic image, something like a digital snapshot, of an individual’s computer screen at a particular moment in time. 5 I have obtained and reviewed subscriber and billing records from the cellular telephone company that provides service to telephone number (415) 505-HACK. Those records reflect that the telephone is subscribed to by an individual with the ljast name Lamo, with a mailing address in northern Ca, I have determj indivi b7E ing address is believe to be the defendant. In addition, LAMO maintains a website at http: //adrian. adrian.ord. On that website, LAMO lists his telephone number as (415) 505-HACK, 6 A representative of the New York Times has advised ‘me that this proxy server is located in Manhattan. ? Based on my training and experience, I have learned that a software tool called “Proxy Hunter” is widely used by hackers to identify unsecured proxy servers on the internet. In connection with a different computer intrusion of MCI WorldCom, -4- FBI(19-cv-1495)-230