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Case 1:18-cr-00032-DLF   Document 1     Filed 02/16/18     Page 21 of 37 Defendants and their co-conspirators did not register as foreign agents with the U.S. Department of Justice.

52. In order to build attendance for the rallies, Defendants and their co-conspirators promoted the events through public posts on their false U.S. persona social media accounts. In addition, Defendants and their co-conspirators contacted administrators of large social media groups focused on U.S. politics and requested that they advertise the rallies.

53. In or around late June 2016, Defendants and their co-conspirators used the Facebook group “United Muslims of America” to promote a rally called “Support Hillary. Save American Muslims” held on July 9, 2016 in the District of Columbia. Defendants and their co-conspirators recruited a real U.S. person to hold a sign depicting Clinton and a quote attributed to her stating “I think Sharia Law will be a powerful new direction of freedom.” Within three weeks, on or about July 26, 2016, Defendants and their co-conspirators posted on the same Facebook page that Muslim voters were “between Hillary Clinton and a hard place.”

54. In or around June and July 2016, Defendants and their co-conspirators used the Facebook group “Being Patriotic,” the Twitter account @March_for_Trump, and other ORGANIZATION accounts to organize two political rallies in New York. The first rally was called “March for Trump” and held on June 25, 2016. The second rally was called “Down with Hillary” and held on July 23, 2016.


 * a. In or around June through July 2016, Defendants and their co-conspirators purchased advertisements on Facebook to promote the “March for Trump” and “Down with Hillary” rallies.


 * b. Defendants and their co-conspirators used false U.S. personas to send individualized messages to real U.S. persons to request that they participate in and

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