Case 1:18-cr-00032-DLF Document 1 Filed 02/16/18 Page 32 of 37
| Approximate Date | Account Name | Means of Identification |
| June 16, 2016 | T.B. | Social Security Number Date of Birth |
| June 16, 2016 | A.R. | Social Security Number Date of Birth |
| June 16, 2016 | T.C. | Social Security Number Date of Birth |
| June 16, 2016 | T.W. | Social Security Number Date of Birth |
90. Defendants and their co-conspirators also used, without lawful authority, the social security numbers, home addresses, and birth dates of real U.S. persons to open accounts at PayPal, a digital payments company, including the following accounts:
| Approximate Date | Initials of Identity Theft Victim |
Means of Identification |
| June 16, 2016 | T.B. | Social Security Number Date of Birth |
| July 21, 2016 | A.R. | Social Security Number Date of Birth |
| August 2, 2016 | T.W. | Social Security Number Date of Birth |
| November 11, 2016 | J.W. | Home Address |
| January 18, 2017 | V.S. | Social Security Number |
Defendants and their co-conspirators also established other accounts at PayPal in the names of false and fictitious U.S. personas. Some personas used to register PayPal accounts were the same as the false U.S. personas used in connection with the ORGANIZATION's social media accounts.
91. Defendants and their co-conspirators purchased credit card and bank account numbers from online sellers for the unlawful purpose of evading security measures at PayPal, which used account numbers to verify a user's identity. Many of the bank account numbers purchased by Defendants
32
