UNITED STATES OF AMERICA          

The United States Attorney for the District of New Jersey charges:

The Defendant

     1.      At all times relevant to this Information, defendant ALEXEY V. IVANOV was a 20-year-old computer hacker living in Chelyabinsk,

Russia, who frequently collaborated with other Russian computer hackers to gain unauthorized access to, and steal passwords, credit card numbers,

and other financial information from, the computer systems of U.S. companies.

Financial Services, Inc.

     2.      At all times relevant to this Information, Financial Services, Inc. ("FSI") was an Internet web hosting and electronic banking processing

company located in Glen Rock, New Jersey that owned, maintained and operated a computer network for the use of its customers and employees. A

computer on this network, a machine in Glen Rock identified by the company as Ralph, was one of several computers on which were stored

employee passwords for the FSI computer network.

Another computer on this network, a machine in Glen Rock identified by the company as Trixie, was the primary computer used by employees of

FSI for storing customer credit card numbers and related customer data. The Ralph machine and the Trixie machine were used by employees of FSI

in interstate and foreign commerce and communication and, thus, were "protected computers" within the meaning of Title 18, United States Code,

Section 1030(e)(2)(B).

The Intended Fraud

     3.      From on or about March 22, 2000, through at least as late as on or about May 2, 2000, at Glen Rock, in the District of New Jersey, and

elsewhere, the defendant

ALEXEY V. IVANOV

knowingly and with intent to defraud did access without authorization protected computers, that is the Ralph machine and the Trixie machine at FSI,

and by means of such access furthered the intended fraud and obtained things of value, namely passwords for the FSI computer network,

approximately 3,500 credit card numbers of FSI customers, and related card holder information.

Stealing Passwords and Credit Card Numbers from FSI

     4.      It was a part of the intended fraud that on or about March 22, 2000, defendant ALEXEY V. IVANOV, via an Internet connection from

Russia, accessed the Ralph machine and the Trixie machine at FSI without authorization and downloaded: (a) eleven passwords used by FSI

employees to access the FSI computer network; and (b) a text file containing approximately 3,500 credit card numbers and associated card holder

information for FSI customers.

     5.      It was a further part of the intended fraud that in or about April 2000, defendant ALEXEY V. IVANOV transferred the stolen FSI

passwords to a file named "PASS_FSI" on his laptop computer to facilitate future unauthorized access into the FSI computer network.

Extorting Money from FSI

     6.      It was a further part of the intended fraud that on or about March 29, 2000, a confederate of defendant ALEXEY V. IVANOV, using the

aliases "Alexander" and "Grisha," sent an electronic mail ("e-mail") message from Russia to an employee of FSI in Glen Rock, New Jersey, in which

he stated that he was part of a group of computer hackers who had accessed the FSI computer system without authorization and had stolen customer

credit card numbers and associated card holder information for FSI customers. In the e-mail message, this confederate of defendant ALEXEY V.

IVANOV threatened to publicly release this stolen credit card information unless FSI paid him $3,000.

     7.      It was a further part of the intended fraud that on or about March 30, 2000, in light of FSI's failure to immediately agree to pay him $3,000,

this confederate of defendant ALEXEY V. IVANOV sent this same FSI employee an electronic message via the Internet from Russia using the alias

"Jimbo" in which he doubled his extortion demand to $6,000. After further communications with the FSI employee, this confederate of defendant

ALEXEY V. IVANOV agreed to settle for an extortion payment of $5,000 from FSI.

     8. It was a further part of the intended fraud that on or about March 30, 2000, this confederate of defendant ALEXEY V. IVANOV sent an

e-mail message to this same FSI employee in which he threatened that he would again access the FSI computer network and cause damage to this

network if FSI failed to immediately agree to his demand for an extortion payment of $5,000.

     9.      It was a further part of the intended fraud that on or about the following dates, this confederate of defendant ALEXEY V. IVANOV caused

FSI to wire a total of $5,000 to a bank account at Alfabank in Moscow, Russia, as follows:

In violation of Title 18, United States Code, Sections 1030(a)(4) and 2.

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