Page:U.s. v. kalashnikov and afanasyeva indictment 0.pdf/16

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  1. transferable . . . license, during the applicable License Term, to display, transmit, and distribute the Licensed Content."

Founder-1 and Founder-2 Negotiate The
U.S. Company-1 Contract with the "Russians"

21. In or about mid-2023, as Founder-1 worked to recruit Commentator-1 and Commentator-2 to perform work on behalf of "Eduard Grigoriann," Founder-1 began negotiating an expanded role for Founder-1 and Founder-2 and U.S. Company-1 in their developing enterprise, as set forth below.

22. On or about March 31, 2023, Persona-1 emailed Founder-1 "a draſt of the new contract that we would like to offer." Persona-1 described the new contract as consisting of two stages: "[t]he pre-talent-signing, where your scope of work is similar to now," and "the post-talent-signing, which is after we sign [Commentator-2] and [Commentator-1], with your help." Persona-1 advised that "the scope of your work will grow substantially to include managing the channel" in the "post-talent-signing" phase, with "new areas of responsibility and our new offered compensation." In a subsequent email, on or about April 14, 2023, Persona-1 informed Founder-1 that the "management and marketing" for the new platform's social media accounts would "be done by the Russian firm we agreed to hire," but "[y]ou will of course be the CEO and set the working standard and path for them to follow, and possibly you could hire a few more people from your side to further handle the operational side of things." On or about April 17, 2023, Founder-1 replied, in part, that Founder-1 was "happy to work with the Russian firm." As set forth below, this "Russian firm" consisted of KALASHNIKOV and AFANASYEVA, who later monitored and directed U.S. Company-1's activities under the guise of an outside editing firm.

23. Founder-2 worked closely with Founder-1 to negotiate their expanded business arrangement with "Eduard Grigoriann." For example, in private messages on Discord on or about

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