I! [HS 5 .1“ I. PIE 32. Defendants and their co-conspirators, through fraud and deceit, created hundreds of social media accounts and used them to develop certain fictitious U.S. personas into “Ieader[s] of public opinion” in the United States.
33. ORGANIZATION employees, referred to as “specialists,” were tasked to create social media accounts that appeared to be operated by U.S. persons. The specialists were divided into day-shifl and night-shift hours and instructed to make posts in accordance with the appropriate us. time zone. The ORGANIZATION also circulated lists of U.S. holidays so that specialists could develop and post appropriate account activity. Specialists were instructed to write about topics germane to the United States such as US. foreign policy and US. economic issues. Specialists were directed to create “political intensity through supporting radical groups, users dissatisfied with [the] social and economic situation and oppositional social movements.”
34. Defendants and their co-conspirators also created thematic group pages on social media sites, particularly on the social media platforms Facebook and Instagram. ORGANIZATION- eontrolled pages addressed a range of issues, including: immigration (with group names including “Secured Borders”); the Black Lives Matter movement (with group names including “Blacktivist”); religion (with group names including “United Muslims of America” and “Army of Jesus"); and certain geographic regions within the United States (with group names including “South United" and “Heart of Texas”). By 2016, the size of many ORGANIZATION-controlled groups had grown to hundreds of thousands of online followers.
35. Starting at least in or around 2015, Defendants and their co-conspirators began to purchase advertisements on online social media sites to promote ORGANIZATION-controlled social media groups, spending thousands of US. dollars every month. These expenditures were included in the
budgets the ORGANIZATION submitted to CONCORD.
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