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- dropped the network. But as RT itself has boasted, despite its post-March 2022 bans on broadcasting and lack of formal distribution channels in the United States, Canada, the United Kingdom, and the European Union, the Government of Russia continues to use RT to direct disinformation and propaganda at Western audiences. For example, on or about February 25, 2024, RT's editor-in-chief declared, during a Russian television appearance, that "public opinion in the West is changing, very rapidly and very cheerfully," due in part to RT. RT's editor-in-chief further explained that, despite being "banished everywhere on February 25"—referring to the start of Russia's invasion of Ukraine in February 2022—RT had built "an enormous network, an entire empire of covert projects that is working with the public opinion, bringing truth to Western audiences."
- As set forth below, U.S. Company-1 is one of RT's "covert projects" in the United States.
BACKGROUND ON CERTAIN INDIVIDUALS AND ENTITIES
- KOSTIANTYN KALASHNIKOV, a/k/a "Kostya," the defendant, is a citizen of Russia and an employee of RT. KALASHNIKOV has identified himself as the "Deputy Chief of the Digital Media Projects Department" for RT, is a member of an internal RT email distribution list reserved for "leaders" at RT, and manages multiple RT covert distribution channels in the United States, including U.S. Company-1. As set forth below, Founder-1 introduced KALASHNIKOV to U.S. Company-1 employees and affiliates as a purported outside editor, and KALASHNIKOV edited U.S. Company-1 content without disclosing that he was working for RT. KALASHNIKOV also participated in an internal U.S. Company-1 messaging group comprised solely of KALASHNIKOV, Founder-1, Founder-2, and an individual purporting to act as a representative of U.S. Company-1's investor, "Eduard Grigoriann," but who was, in fact, a fake persona ("Persona-1"), as described below. In that messaging group, KALASHNIKOV monitored
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