Investor Discord Channel, writing: "Hey @[Persona-1] , just wanted to follow up and see if your finance department has any update on the transfers."
KALASHNIKOV and AFANASYEVA Begin Operations
at U.S. Company-1
31. As U.S. Company-1 prepared to launch in the fall of 2023 , consistent with Persona-1's instruction to Founder-1 to work with the "Russian firm we agreed to hire," Founder-1 introduced KALASHNIKOV to U.S. Company-1 employees and affiliates as an outside editor hired by U.S. Company-1 's investor. In this role, KALASHNIKOV monitored U.S. Company1's internal communications and edited content published by U.S. Company-I , without disclosing that he was an RT employee. KALASHNIKOV also introduced his fellow RT employee AFANASYEVA to provide additional day-to-day direction to U.S. Company-1 employees and commentators, as set forth below.
32. On or about August 2, 2023 , Founder-1 created a Discord server for use by U.S. Company-1 employees, associates, and contributors (the "U.S. Company-1 Discord Server"). In the weeks that followed, Founder-1 subdivided the U.S. Company-1 Discord Server into various Discord channels, including channels for individual contributors and their teams to discuss production-related matters, a channel to discuss pitches and story concepts, and channels for the production team to post videos for publication by U.S. Company-1. Founder-1 added KALASHNIKOV to most of these Discord channels, typically introducing KALASHNIKOV as an editor. For example:
- On or about August 7, 2023, Founder-1 created a Discord channel for the production of videos by one of the six commentators listed on U.S. Company-1's website ("Commentator-4") and told Commentator-4 that KALASHNIKOV "is heading up the editing team, so you and him can start to discuss how to get started working together." Through this
20
