a term used by liberals, but we're trying to create a conservative network." Founder-1 suggested that "[Commentator-1] and Eduard could simply speak together" to clarify the profile.
19. On or about June 2, 2023, "Eduard Grigoriann" circulated an email to Founder-1 and to Commentator-1's assistant, scheduling a Zoom meeting for "05:00 PM Paris" that day. (In prior email correspondence, Founder-1 represented to another potential commentator that "Eduard Grigoriann" was based in "Paris.") At approximately 8:58 a.m. Central Time that day, "Eduard Grigoriann" replied to his earlier email: "I am there guys." The time, in fact, was 3:58 p.m. in Paris—but it was 4:58 p.m. in Moscow. Approximately two minutes later, "Eduard Grigoriann" performed a Google search for "time in Paris." "Eduard Grigoriann" then replied again to his email, in part: "Sorry, wrong hour. Didn't sync the calendar."
20. After further negotiations, in which Founder-2 also participated, Founder-1 and the purported representatives of "Eduard Grigoriann" secured contracts with Commentator-1 and Commentator-2. Specifically:
- Commentator-1's contract, which was between Commentator-1's production company and U.S. Company-1, provided for "four weekly videos" to be hosted by Commentator-1 and livestreamed by U.S. Company-1. In exchange for a monthly fee of $400,000, plus a $100,000 signing bonus and an additional performance bonus, Commentator-1's production company agreed that "any and all content created . . . under this Agreement shall be the property of" U.S. Company-1.
- Commentator-2's contract, which was between Commentator-2's production company and U.S. Company-1, provided for weekly videos to be hosted by Commentator-2 and livestreamed by U.S. Company-1. In exchange for a fee of $100,000 per video, Commentator-2's production company granted U.S. Company-1 "a non-exclusive, non-
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