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 and groups on social media Defendants and their co-conspirators purchased advertisements on Facebook to further promote the allegations.

a. On or about August 4, 2016, Defendants and their co-conspirators began purchasing advertisements that promoted a post on the ORGANIZATION-controlled Faeebook account “Stop A.I.” The post alleged that “Hillary Clinton has already committed voter fraud during the Democrat Iowa Caucus.”

b. On or about August 11, 2016, Defendants and their co-conspirators posted that allegations of voter fraud were being investigated in North Carolina on the ORGANIZATION-controlled Twitter account @TEN_GOP.

c. On or about November 2, 2016, Defendants and their co-conspirators used the same account to post allegations of “#VoterFraud by counting tens of thousands of ineligible mail in Hillary votes being reported in Broward County, Florida.”

48. From at least April 2016 through November 2016, Defendants and their co-conspirators, while concealing their Russian identities and ORGANIZATION affiliation through false personas, began to produce, purchase, and post advertisements on US. social media and other online sites expressly advocating for the election of then-candidate Trump or expressly opposing Clinton. Defendants and their co-conspirators did not report their expenditures to the Federal Election Commission, or register as foreign agents with the US. Department of Justice.

49. To pay for the political advertisements, Defendants and their co-conspirators established various Russian bank accounts and credit cards, oﬁen registered in the names of ﬁctitious U.S. personas created and used by the ORGANIZATION on social media Defendants and their co-

conspirators also paid for other political advertisements using PayPal accounts.

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