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**************************************************************************** >C O M P U T E R U N D E R G R O U N D< >D I G E S T< *** Volume 1, Issue #1.15 (June 16, 1990) ** **************************************************************************** MODERATORS: Jim Thomas / Gordon Meyer REPLY TO: TK0JUT2@NIU.bitnet COMPUTER UNDERGROUND DIGEST is an open forum dedicated to sharing information among computerists and to the presentation and debate of diverse views. -------------------------------------------------------------------- DISCLAIMER: The views represented herein do not necessarily represent the views of the moderators. Contributors assume all responsibility for assuring that articles submitted do not violate copyright protections. -------------------------------------------------------------------- *** SPECIAL ISSUE: June Indictment of Craig Neidorf *** -------------------------------------------------------------------- The new indictment drops some charges and introduces others. The logic required to connect the acts to the charges requires considerable prosecutorial intellectual aerobics. We invite comments from all perspectives. We again encourage law enforcement agents or sympathizers to join the dialogue, because we believe that productive discussion is in the interests of all in the computer world. Moderators Note: This is a verbatim copy of the indictment, transcribed from a third generation Fax/Photcopy of the original. As of this writing we have been unable to obtain a copy from the US Government. While in the past we were able to have materials mailed to us, upon inquiry this time we were told by the that a copy would have to be picked up in person at the Federal Building in downtown Chicago. Special thanks go out to the CuD reader who supplied us with this copy, saving us the trip downtown. ===================================================================== UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UNITED STATES OF AMERICA ) ) v. ) No. 90 CR 70 ) Violations : Title 18, United ROBERT J. RIGGS, also known ) States Code, Sections as Robert Johnson, also ) 1343 and 2314 known as Prophet, and ) CRAIG NEIDORF, also known ) as Knight Lightning ) _Count One_ The SPECIAL APRIL 1990 GRAND JURY charges: _Introduction_ 1. At all times relevant herein, Enhanced 911 (E911) was the national computerized telephone service program for handling emergency calls to the police, fire, ambulance and emergency services in most municipalities in the United States. Dialing 911 provided the public immediate access to a municipality's Public Safety Answering Point (PSAP) through the use of computerized call routine. The E911 system also automatically provided the recipient of an emergency call at the PSAP with the telephone number and location identification of the emergency caller. 2. At all times relevant herein, the Bell South Telephone Company and its subsidiaries (Bell South) provided telephone services in the nine state area including Alabama, Mississippi, Georgia, Tennessee, Kentucky, Louisiana, North Carolina, South Carolina and Florida. [end of page one] _DEFINITION OF TERMS_ 3. _The E911 Test File_ - At all times relevant herein, the E911 system of Bell South was described in the computerized text file known as the Bell South Standard Practice 660-225-104SV Control Office Administration of Enhanced 911 Services for Special and Major Account Centers, dated March 1988 (E911 text file). The E911 text file was a highly proprietary and closely held computerized text file belonging to the Bell South Telephone Company and stored on the company's AIMS-X computer in Atlanta, Georgia. The E911 text file described the computerized control, maintenance and service of the E911 system and carried warning notices that it was not to be disclosed outside Bell South or any of its subsidiaries except under written agreement. 4. _Text File_ - As used here, a "file" is a collection of related data records treated as a unit by a computer and stored in a computer's memory on a disk or other permanent storage device. A "text file" is a collection of stored data, which, when recovered from a disk or other storage device, presents typed English characters displayed on a computer monitor, a printer or in any other display medium compatible with the computer storing the data. 5. _Computer Hackers_ - As used here, computer hackers are individuals involved with the unauthorized access of computer systems by various means. Computer hackers commonly identify themselves by aliases or "hacker handles" when communicating with other hackers. [page] 2 6. _Legion of Doom_ - As used here the Legion of Doom (LOD) was a closely knit group of computer hackers involved in: a. Disrupting telecommunications by entering computerized telephone switches and changing the routing on the circuits of the computerized switches. b. Stealing proprietary computerized information from companies and individuals. c. Stealing and modifying credit information on individuals maintained in credit bureau computers. d. Fraudulently obtaining money and property from companies by altering the computerized information used by the companies. e. Sharing information with respect to their methods of attacking computers with other computer hackers in an effort to avoid law enforcement agencies and telecommunication experts from focusing on them, alone. 7. _Bulletin Board System_ - At all times relevant herein, a bulletin board system (BBS) was a computer, or portion thereof, operated as a medium of communication between computer users at different locations. Users accessed or got on the BBS through telephone line link ups from the user's computer to the BBS computer, which could be in the same building or around the world. BBS's could be used to exchange messages (electronic mail) or store [page] 3 information. BBS's were public commercial services or privately operated. 8. _JOLNET BBS_ - At all times relevant herein, a public access computer bulletin board system was located in Lockport, Illinois, which provided computer storage space and electronic mail service to its users. The Lockport BBS was called "Jolnet". The Jolnet BBS was also used by computer hackers as a location for exchanging and developing software tools for computer intrusion, and for receiving and distributing hacker tutorials and other computer access information. 9. _E-Mail_ - At all time relevant herein, electronic mail (e-mail) was a computerized method for sending communications and computer files between computers on various computer networks. Persons who sent or received e-mail were identified by an e-mail address, similar to a postal address. Although a person may have more than one e-mail address, each e-mail address identified a person uniquely. The message header of an e-mail message identified both the sender and recipient of the e-mail message and the date the message was sent. _DEFENDANTS_ 10. At all times relevant herein ROBERT J. RIGGS, defendant herein, was a member of the LOD. 11. At all time relevant herein, CRAIG NEIDORF, defendant herein, was a publisher and editor of a computer hacker newsletter known as "PHRACK". He disseminated this newsletter by sending it so those individuals on the mailing list. [page] 4 12. Beginning in or about February, 1988 and continuing until the return date of this indictment, at Lockport, In the Northern District of Illinois, Eastern Division, and elsewhere, ROBERT J. RIGGS, also known as Robert Johnson, also known as Prophet, and CRAIG NEIDORF, also known as Knight Lightning, defendants herein, together with others known and unknown to the Grand Jury, devised and intended to devise and participated in a scheme and artifice to obtain property by means of false and fraudulent pretenses and representations, well knowing at the time that such pretenses and representations were false and fraudulent when made. _OBJECT OF FRAUD SCHEME_ 13. The object of the defendants' scheme was to fraudulently obtain and steal private property in the form of computerized files by gaining unauthorized access to other individuals' and corporations' computers, copying the sensitive computerized files in those computers, and then publishing the information from the computerized files in a hacker publication for dissemination to other computer hackers. _OPERATION OF THE FRAUD SCHEME_ 14. It was part of the fraud scheme that the defendant NEIDORF would and did solicit information about how to illegally access computers and telecommunications systems from computer hackers, including the defendant RIGGS. [page] 5 15. It was further part of the scheme that between about February, 1988 and Novemeber, 1988 the defendant RIGGS would and did fraudulently obtain sensitive proprietary Bell South information files including the E911 text file by gaining remote unauthorized access to computers of the Bell South. 16. It was further part of the scheme that the defendant RIGGS would and did disguise and conceal and did attempt to disguise and conceal the theft of the E911 text file from Bell South by removing all indications of his unauthorized access into Bell South computers and by using account codes of legitimate Bell South users to disguise his unauthorized use of the Bell South computer. 17. It was further part of the scheme that between about February, 1988 and November 23, 1988 [transcribers note: copy illegible at this point, year could be 1989], RIGGS would and did transfer in interstate commerce the fraudulently obtained E911 text file from Decatur, Georgia to Lockport, Illinois through the use of an interstate computer data network. 18. It was further part of the scheme that defendant RIGGS would and did store the stolen E911 text file on a computer bulletin board system in Lockport, Illinois under the name Robert Johnson, as alias he used to conceal his true identity. 19. It was further part of the scheme that between about October, 1988 and January 23, 1989 defendant NEIDORF, utilizing a computer at the University of Missouri in Columbia, Missouri would and did receive a copy of the stolen E911 text file from defendant RIGGS through the lockport computer bulletin board system through the use of an interstate computer network. [page] 6 20. It was further part of the scheme that defendant NEIDORF would and did edit and retype the E911 text file at the request of the defendant RIGGS in an attempt to conceal the fact that Bell South's computer system had been entered by RIGGS without authority and that RIGGS had fraudulently obtained the E911 text file in order to convert Bell South's private and proprietary text file and the information it contained therein to the defendants' own use and the use of others and to prepare it for dissemination and disclosure in the computer newsletter, "Phrack". 21. It was further part of the scheme that on or about January 23, 1989, defendant NEIDORF would and did transfer an edited version of the stolen E911 test file through the use of an interstate computer data network from his computer at the University of Missouri to the computer bulletin board system used by defendant RIGGS in Lockport, Illinois. 22. It was further part of the scheme that on or about February 24, 1989 defendant NEIDORF disseminated the disguised E911 text file in issue 24 of "PHRACK" newsletter. 23. It was further part of the scheme that the defendant NEIDORF would disseminate and disclose this information to others for their own use, including to other computer hackers who could use it to illegally manipulate the emergency 911 computer systems in the United States and thereby disrupt or halt 911 service in portions of the United States. 24. It was further part of the scheme that the defendants used aliases, coded language and other means to avoid detection and [page] 7 apprehension by law enforcement authorities and to otherwise provide security to the members of the fraud scheme. 25. It was further a part of the scheme that the defendants would and did misrepresent, conceal, and hide, and cause to be misrepresented, concealed and hidden the purposes of the acts done in furtherance of the fraud scheme. 26. Between in or about February, 1988 and Novemeber, 1988, at Lockport, in the Northern District of Illinois, Eastern Division, and elsewhere, ROBERT J. RIGGS, also known as Robert Johnson, also known as Prophet, defendant herein, for the purpose of executing the aforesaid scheme, did knowingly transmit and cause to be transmitted by means of a wire and radio communication in interstate commerce from Decatur, Georgia to Lockport, Illinois, certain signs, signals and sounds, namely: a data transfer of Bell South E911 Standard Practice test file dated March, 1988 (as further defined in paragraph 3 of this Count of this Indictment). In violation of Title 18, United States Code, Section 1343. [page] 8 _COUNT TWO_ The SPECIAL APRIL 1990 GRAND JURY further charges: 1. The Grand Jury realleges and incorporates by reference the allegations of paragraphs 1 through 25 of Count One of this Indictment as fully set forth herein. 2. On or about July 23, [transcribers note: date illegible in copy] 1988, at Lockport, in the Northern District of Illinois, Eastern Division and elsewhere, CRAIG NEIDORF, also known as Knight Lightning, defendant herein, for the purposes of executing the aforesaid scheme did knowingly transmit and cause to be transmitted by means of a wire and radio communication in interstate commerce from Columbia, Missouri to Lockport, Illinois certain signs, signals and sounds, namely: a data transfer of Phrack World News announcing the beginning of the "Phoenix Project"; In violation of Title 18, United States code [sic] , Section 1343 [page] 9 _COUNT THREE_ The SPECIAL APRIL 1990 GRAND JURY further charges: 1. The Grand Jury realleges and incorporates by reference the allegations of paragraphs 1 through 25 of Count One of this Indictment as fully set forth herein. 2. On or about September 19, 1988, at Lockport, in the Northern District of Illinois, Eastern Division and elsewhere, CRAIG NEIDORF, also known as Knight Lightning, defendant herein, for the purposes of executing the aforesaid scheme did knowingly transmit and cause to be transmitted by means of a wire and radio communication in interstate commerce from Columbia, Missouri to Lockport, Illinois certain signs, signals and sounds, namely: a data transfer of E-mail from defendant NEIDORF to defendant RIGGS and "Scott C." In violation of Title 18, United States code [sic] , Section 1343 [page] 10 _COUNT FOUR_ The SPECIAL APRIL 1990 GRAND JURY further charges: 1. The Grand Jury realleges and incorporates by reference the allegations of paragraphs 1 through 25 of Count One of this Indictment as fully set forth herein. 2. On or about September 29, 1988, at Lockport, in the Northern District of Illinois, Eastern Division and elsewhere, ROBERT J. RIGGS, also known as Robert Johnson, also known as Prophet, and CRAIG NEIDORF, also known as Knight Lightning, defendants herein, for the purposes of executing the aforesaid scheme did knowingly transmit and cause to be transmitted by means of a wire and radio communication in interstate commerce from Lockport, Illinois to Columbia, Missouri certain signs, signals and sounds, namely: a data transfer of E-mail from the defendant RIGGS to the defendant NEIDORF; In violation of Title 18, United States Code , Section 1343 [page] 11 _COUNT FIVE_ The SPECIAL APRIL 1990 GRAND JURY further charges: 1. The Grand Jury realleges and incorporates by reference the allegations of paragraphs 1 through 25 of Count One of this Indictment as fully set forth herein. 2. Between in or about October, 1988 and January 23, 1989 at Lockport, in the Northern District of Illinois, Eastern Division and elsewhere, ROBERT J. RIGGS, also known as Robert Johnson, also known as Prophet, and CRAIG NEIDORF, also known as Knight Lightning, defendants herein, for the purposes of executing the aforesaid scheme did knowingly transmit and cause to be transmitted by means of a wire and radio communication in interstate commerce [sic] Lockport, Illinois to Columbia, Missouri certain signs, signals and sounds, namely: a data transfer of Bell South's E911 Practice text file dated March, 1988 (as further defined in paragraph 3 of Count One of this Indictment) from defendant RIGGS to defendant NEIDORF; In violation of Title 18, United States Code , Section 1343 [page] 12 _COUNT SIX_ The SPECIAL APRIL 1990 GRAND JURY further charges: 1. The Grand Jury realleges and incorporates by reference the allegations of paragraphs 1 through 25 of Count One of this Indictment as fully set forth herein. 2. Between in or about October, 1988 and January 23, 1989 at Lockport, in the Northern District of Illinois, Eastern Division and elsewhere, ROBERT J. RIGGS, also known as Robert Johnson, also known as Prophet, and CRAIG NEIDORF, also known as Knight Lightning, defendants herein, for the purposes of executing the aforesaid scheme did knowingly transmit and cause to be transmitted by means of a wire and radio communication in interstate commerce from Lockport, Illinois to Columbia, Missouri a computerized text file with a value of $5,000 or more, namely: A Bell South Standard Practice (BSP) 660-225-104SV- Control Office Administration of Enhanced 911 Services for Special Services and Major Account Centers dated March, 1988, valued at approximately $23,900.00; the defendants then and there knowing the same to have been stolen, converted, and taken by fraud; In violation of Title 18, United States code [sic] , Section 2314 [page] 13 _COUNT SEVEN_ The SPECIAL APRIL 1990 GRAND JURY further charges: 1. The Grand Jury realleges and incorporates by reference the allegations of paragraphs 1 through 25 of Count One of this Indictment as fully set forth herein. 2. Between in or about December 23 1988, at Lockport, in the Northern District of Illinois, Eastern Division and elsewhere, CRAIG NEIDORF, also known as Knight Lightning, defendant herein, for the purposes of executing the aforesaid scheme did knowingly transmit and cause to be transmitted by means of a wire and radio communication in interstate commerce from Columbia, Missouri to Lockport, Illinois certain signs, signals and sounds, namely: a data transfer of Phrack Newsletter, Issue 22, Files 1, 4, 5 and 6; In violation of Title 18, United States Code , Section 1343 [page] 14 _COUNT EIGHT_ The SPECIAL APRIL 1990 GRAND JURY further charges: 1. The Grand Jury realleges and incorporates by reference the allegations of paragraphs 1 through 25 of Count One of this Indictment as fully set forth herein. 2. Between in or about January 23, 1988 at Lockport, in the Northern District of Illinois, Eastern Division and elsewhere, ROBERT J. RIGGS, also known as Robert Johnson, also known as Prophet, and CRAIG NEIDORF, also known as Knight Lightning, defendants herein, for the purposes of executing the aforesaid scheme did knowingly transmit and cause to be transmitted by means of a wire and radio communication in interstate commerce from Columbia, Missouri to Lockport, Illinois certain signs, signals and sounds, namely: a data transfer of an edited Bell South E911 Standard Practice text file dated March, 1988 (as further defined in paragraph 3 of Count One of this Indictment); In violation of Title 18, United States Code , Section 1343 [page] 15 _COUNT NINE_ The SPECIAL APRIL 1990 GRAND JURY further charges: 1. The Grand Jury realleges and incorporates by reference the allegations of paragraphs 1 through 25 of Count One of this Indictment as fully set forth herein. 2. On or about July 23, 1988, at Lockport, in the Northern District of Illinois, Eastern Division and elsewhere, ROBERT J. RIGGS, also known as Robert Johnson, also known as Prophet, and CRAIG NEIDORF, also known as Knight Lightning, defendants herein, did transmit and cause to be transmitted by means of a wire and radio communication in interstate commerce from Columbia, Missouri to Lockport, Illinois, a computerized text file with a value of $5,000 or more, namely: An edited Bell South Standard Practice (BSP) 660-225-104SV- Control Office Administration of Enhanced 911 Services for Special Services and Major Account Centers dated March, 1988, valued at approximately $23,900.00; the defendants, then and there knowing the same to have been stolen, converted, and taken by fraud; In violation of Title 18, United States Code , Section 2314. [page] 16 _COUNT TEN_ The SPECIAL APRIL 1990 GRAND JURY further charges: 1. The Grand Jury realleges and incorporates by reference the allegations of paragraphs 1 through 25 of Count One of this Indictment as fully set forth herein. 2. On or about February 23, 1988, at Lockport, in the Northern District of Illinois, Eastern Division and elsewhere, CRAIG NEIDORF, also known as Knight Lightning, defendant herein, for the purposes of executing the aforesaid scheme did knowingly transmit and cause to be transmitted by means of a wire and radio communication in interstate commerce from Columbia, Missouri to Lockport, Illinois certain signs, signals and sounds, namely: a data transfer of Phrack Newsletter, Issue 24, including an edited Bell South Standard Practice (BSP) 660-225-104SV- Control Office Administration of Enhanced 911 Services for Special Services and Major Account Centers dated March, 1988; In violation of Title 18, United States Code , Section 1343 [page] 17 _COUNT ELEVEN_ The SPECIAL APRIL 1990 GRAND JURY further charges: 1. The Grand Jury realleges and incorporates by reference the allegations of paragraphs 1 through 25 of Count One of this Indictment as though fully set forth herein. 2. On or about February 24, 1989, at Lockport, in the Northern District of Illinois, Eastern Division and elsewhere, ROBERT J. RIGGS, also known as Robert Johnson, also known as Prophet, and CRAIG NEIDORF, also known as Knight Lightning, defendants herein, did transport and cause to be transported in interstate commerce from Columbia, Missouri to Lockport, Illinois, a computerized text file with a value of $5,000 or more namely: A Bell South Standard Practice (BSP) 660-225-104SV- Control Office Administration of Enhanced 911 Services for Special Services and Major Account Centers dated March, 1988, valued at approximately $23,900.00; the defendants, then and there knowing the same to have been stolen, converted, and taken by fraud; In violation of Title 18, United States code [sic] , Section 2314 A TRUE BILL: _________________________________ F O R E P E R S O N ___________________________________ UNITED STATES ATTORNEY [page] 18 [transcribed from FAXed copy 6/14/90. GRM] =+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+ + END CuD, #1.15 + +=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+===+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+= !