- 2 on Discord: "also I say we bill the russians for the last month once we're done the extra opeds," referring to Founder-1's paid opinion articles for RT. And on or about January 5, 2022, Founder-2 messaged an acquaintance on Discord about paid leave that "[t]he Russians" had offered to Founder-1.
- From in or about October 2021 to in or about May 2022, separate and apart from Founder-1's contract with RT's parent organization, ANO-TV Novosti, Founder-2 also worked directly for RT and with Ruptly GmbH, RT's German subsidiary. Founder-2's paid work for RT included, among other things, preparing English-language text messages describing news events. During this time, Founder-2 and KALASHNIKOV appear to have had overlapping business contacts: On or about May 18, 2022, a Ruptly GmbH employee sent a Russian-language email to six recipients, including Founder-2 and KALASHNIKOV, requesting that they send their work email addresses to gain account access to Ruptly's website.
11. U.S. Company-1 is a United States corporation established under the laws of Tennessee. Founder-1 has described U.S. Company-1 as the U.S. subsidiary of Founder-1's Canadian company, Canadian Company-1; as set forth above, from in or about March 2021 to in or about February 2022, Founder-1 used Canadian Company-1 to produce content for RT pursuant to a written contract. Founder-1 incorporated U.S. Company-1 on or about January 19, 2022, and applied with the Tennessee Department of State to transact business under its current operating name, which Company-1 uses on its website and social media channels, on or about May 22, 2023. On its website, U.S. Company-1 describes itself as a "network of heterodox commentators that focus on Western political and cultural issues" and identifies six commentators—including Commentator-1 and Commentator-2—as its "talent." U.S. Company-1 regularly posts videos featuring these commentators, as well as other videos that do not feature the commentators, across
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