name ("k"). On approximately 38 occasions between in or about December 2023 and in or about January 2024, KALASHNIKOV's Discord account was accessed from a Moscow-based IP address that was also used to access KALASHNIKOV's personal Gmail account on approximately 10 occasions.
29. On or about June 21, 2023, Founder-2 joined the Investor Discord Channel, describing Founder-2's role as "mostly helping with the company's back end of things while [Founder-1] focuses on the more forward-facing aspects." In the Investor Discord Channel, Founder-1, Founder-2, and Persona-1 (purporting to act on behalf of "Eduard Grigoriann") discussed major decisions for U.S. Company-1, such as the hiring of staff, contract negotiations with contributors (including Commentator-1 and Commentator-2), and payments to U.S. Company-1 and commentators. KALASHNIKOV monitored and occasionally participated in those discussions.
30. Founder-2 also used the Investor Discord Channel to, among other things, submit U.S. Company-1's invoices to Persona-1, and to press for payment of those invoices. For example, on or about September 11, 2023, at approximately 8:07 p.m. Central Time, Founder-2 wrote in the Investor Discord Channel: "Today marks two weeks since I submitted the invoice for August. Any idea for the delay? We are signing the large contracts and need to be certain we will get the funding to pay these people." Persona-1 did not immediately respond. While awaiting a reply from Persona-1, Founder-1 searched for the then-current time in Moscow. Specifically, at approximately 8:50 p.m. Central Time on or about September 11, 2023, Founder-1 searched on Google: "time in Moscow." The time was, in fact, approximately 4:50 a.m. in Moscow. Approximately three days later, on or about September 14, 2023, Founder-1 followed up in the
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