- team." AFANASYEVA (as "Victoria Pesti") announced that "[f]rom now on our top priority should be establishing [U.S. Company-1] social media presence and we do ask you to start sharing [U.S. Company-1] posts through your own accounts daily."
37. Second, with Founder-1 and Founder-2's backing, AFANASYEVA directed U.S. Company-1 staff to publish specific content that AFANASYEVA identified. On or about January 15, 2024, Founder-1 wrote in a channel on the U.S. Company-1 Discord Server (the "Producer Discord Channel") comprised of AFANASYVEA, KALASHNIKOV, Founder-1, Founder-2, Producer-1, Producer-2, and Producer-3: "[Helena] is going to start creating customized videos for us to post on our socials of viral content that's floating around." Between in about January 2024 and in or about June 2024, AFANASYVEA posted links to approximately 841 video clips, which were routinely posted by U.S. Company-1 staff onto U.S. Company-1's social media channels. On occasion, U.S. Company-1 staff privately contacted Founder-1 or Founder-2 to push back on AFANASYEVA's content and were rebuffed. For example:
- On or about February 15, 2024, AFANASYEVA (as "Helena Shudra") shared with U.S. Company-1 a video of a well-known U.S. political commentator visiting a grocery store in Russia. AFANASYEVA posted the video in the Producer Discord Channel. Later that day, Producer-1 privately messaged Founder-2 on Discord: "They want me to post this" referencing the video that AFANASYEVA had posted but "it just feels like overt shilling." Founder-2 replied that Founder-1 "thinks we should put it out there." Producer-1 acquiesced, responding, "alright I'll put it out tomorrow."
- As another example, on or about March 22, 2024, AFANASYEVA (as "Helena Shudra") shared in the Producer Discord Channel a video of the March 22, 2024 terrorist attack on a music venue in Moscow, which killed approximately 145 people and injured hundreds
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