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- events and issues in the United States, such as immigration, inflation, and other topics related to domestic and foreign policy. While the views expressed in the videos are not uniform, the subject matter and content of the videos are often consistent with the Government of Russia's interest in amplifying U.S. domestic divisions in order to weaken U.S. opposition to core Government of Russia interests, such as its ongoing war in Ukraine.
- Since publicly launching in or about November 2023, U.S. Company-1 has posted nearly 2,000 videos that have garnered more than 16 million views on YouTube alone. U.S. Company-1 never disclosed to its viewers that it was funded and directed by RT. Nor did U.S. Company-1 or its two founders and principal executives ("Founder-1" and "Founder-2") register with the Attorney General as an agent of a foreign principal, as required by law.
- KALASHNIKOV, AFANASYEVA, Founder-1, and Founder-2 also worked together to deceive two U.S. online commentators ("Commentator-1" and "Commentator-2"), who respectively have over 2.4 million and 1.3 million YouTube subscribers. Founder-1 and Founder-2 contracted with Commentator-1 and Commentator-2 to produce videos, using Commentator-1's and Commentator-2's own names and leveraging their existing audiences, for license and publication by U.S. Company-1. KALASHNIKOV, AFANASYEVA, Founder-1, and Founder-2 worked together to mask U.S. Company-1's true source of funding—i.e., RT—by falsely portraying to Commentator-1 and Commentator-2 that U.S. Company-1 was sponsored by a private investor named "Eduard Grigoriann." In truth and in fact, Grigoriann was a fictional persona. For example, during contract negotiations, Commentator-1 requested that Founder-1 provide a profile or article on "Eduard Grigoriann." In response, Founder-1 sent Commentator-1 a one-page profile, provided to Founder-1 by another fictional persona purporting to represent "Eduard Grigoriann," falsely describing "Eduard Grigoriann" as an "accomplished finance
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