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