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 department to maintain the digital infrastructure used in the ORGANIZATION’S operations; and a ﬁnance department to budget and allocate funding.

The ORGANIZATION sought, in part. to conduct what it called “information warfare against the United States of America” through ﬁctitious U.S. personas on social media platforms and other lntemet-based media.

By in or around April 2014, the ORGANIZATION formed a department that went by various names but was at times referred to as the “translator project." This project focused on the US. population and conducted operations on social media platforms such as YouTube, Faceboolt, Instagram, and Twitter. By approximately July 2016, more than eighty ORGANIZATION employees were assigned to the translator project.

By in or around May 2014, the ORGANIZATION’s strategy included interfering with the 2016 US. presidential election, with the stated goal of “spread[ing] distrust

towards the candidates and the political system in general.”

Defendants CONCORD MANAGEMENT AND CONSULTING LLC (Kouxopn

Meﬂemmenr n Koncamnnr) and CONCORD CATERING are related Russian entities with

various Russian government contracts. CONCORD was the ORGANIZATIONS primary source

of funding for its interference operations. CONCORD controlled funding, recommended

personnel, and oversaw ORGANIZATION activities through reporting and interaction with

ORGANIZATION management.

CONCORD funded the ORGANIZATION as part of a larger CONCORD-funded interference operation that it referred to as “Project .Lakhta.” Project Lakhta had

multiple components, some involving domestic audiences within the Russian