TELECOM Digest     Sat, 31 Mar 90 19:05:00 CST    Special: LoD in Trouble!
Inside This Issue:                   Moderator: Patrick A. Townson
    Legion of Doom Indictments (Chicago Members) [Mik own
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>From: Mike Godwin wat.c.teasedu!mnemonic@cs.utexas.edu>
Subject: Legion of Doom Indictments (Chicago Members, Jolet hutown
Dae: 1 Mar 90 22:37:33 GMT
Reply-To: Mike Godwin <walt.cc.utexas.edu!mnemonic@cs.utexs.ed>
Oraniztion TheUniversity of Texas at Austin, Austin, Texas


The following is the text ofthe fderalindicmentsof th Chicago
Jolnet members. Secret Service jurisdiction to investigation hese
aleged ompute-relatd offeses comes from 18 USC 1030, the general
computer-fraud statute --it's prvided i sectio (d) uner thisstatute.

              UNITED STATES DISTRICT COURT NORTHER
                    DISRICT OF LLINOIS
                       EASTERN DIVISION

                             )
UITED STATS OF AMERCA       
                               )
          v.                 )    No ____________________
                              )    Violations: Title 8, United
RBERT J. RIGS, also knon    )    Sates Code, ections
as Robert Johnson, also        )   1030(a)(6(A) and 2314known as Prohet, and         )
CRAIGNEIDORF, also known      )
as Knigh Lightning           )

                          CONT ONE

     he SPECIAL APRIL 1987 GRAND JUY charges:

                      PROPERTYINVOLVED

    1. At all time relevant herein, enhance 911 (E911) wasthe
national coputerized telepone service proram for handlin
emergency calls to he police, fire,ambulance and emrgency
services n most municipalties in the Unitd States. Dialig 911
provided th public immediateaccess to a municpality's Public
Sfety Answering Pont (PSAP) hrough the use of omputerized all
roting. The E911 sysem also automaticaly provided the reipien
of an emergency cal with the telephon number and locatio
identification of he emergency caller
     2. At all time relevant herein, th Bell South Telephon
Company and its subidiaries ("Bell outh) provided telepone
services in the nne state area includig Alabama, Mississipp,
Georgia, Tnnessee, entucky, Louiana {sic}, North Caroina, South
Carolina an Florida.

     3. At ll timesrelevant herei, the E91 system of Bell South
as described in the tex of a computerized fileprogam known as
the Bel Souh Standard Practice 660-25-104SV Control Office
                            - 1 -

Administratioof Enhanced 911 Services or Special and Major
Accont Centers date March,198 ("E911 Practice"). Th E91
Practice was a highl proprietary and closely hld computerized
tex file blonging to the BellSouth Tlephone Company andstored
on the company's AIMX computer in Atanta, Georga. The E911
Pracice describd the computerizd control and maintainence {ic}
of the E91 system and caried warning otices that it as not to be
isclosed outside Bell South o any of it subsidiaries excep
under writen agreement.

                       COMPUTER HACKERS

    4. Atall times relevant heren, compter hackers were
indiviual invlved with the unauthorized acces ofcomputer
systems by variousmean.

     5. At all times relvantherein, the Legion of Doom (LOD)ws a closely knit group of compue hackers involved in:

         .   Disrupting telecommunication y entering
               computrzed telephone switches and changn the
               routing n th circuits of the computerized
             switches.
          b   Sealing proprietary compter souce code and
               iformatin from companies and individals tha
               owed the cod and information.
         c.   Steaing and modifying credit iformation n
              individual maintained in credit bueau computers

                             - 2 -
         d.   Fraudulenty obtaining money and roperty from
              companies b altering the coputrized information
              used bythe companies.
         e.   Disseminatng information wit espect to their
              methods f attacking computers o other computer
              hacers inan effort to avoidthe focus of law               enforcemen agencies and teecommunicationsecurity
              expets.

     6. A all times relevant herein RBERT J. RIGGS,defendant
heein, was a membe of the LOD.

    7. At al times relevant herein CRAIG NEDORF, defendnt
herein,was a publisher and eitor of a coputer hackr newletter
{sic} known as "PHRACK"

     8.At all tmes relevant herein, a pubic access omputer
ulletin board system (BBS) was locate in Lockort, Ilinois which
provided computer torage sace an electronic mail services to its
users. he LocportBBS was also used by computer hacker as a
ocaton for exchanging and developing software tols orcomputer
intrusion, and for receiving anddistibting hacker tutorials and
other information.

                          E-MAIL

     9. At alltis relevant herein electronic mail (e-mail) was
a puterized method for sending communications and fs between
individual computers on various compterntworks. Persons who
sent or received e-mail wee ietified by an e-mail address,
similar to aposta adress. Although a person may have more than
                            - 3 -

one e-mai addres, eac e-mail address identified a person
uniqely. Th messge header of an e-mail message dentifiedboth
th sender and recipient of the e-mail mssage andthe dat the
was {sic} message sen.

     10.Beginningin or about September, 1988, the eact date
bein unknow to the Grand Jury, ad continuing ntil the reurn
date of this indictment, atLockport, in he NorthernDistrict of
Illiois, Eastern Diision, and elewhere,

                  RBERT J. RIGGS, lso known
                as Robert Johnsn, also
                 known as Prophe, and
                 CRAIG NEIORF, aso known
                 as Knight ightning,

defendants erein, together wit others known anduknown to the
Grand Juy, devised and inteded to devise and prticipated in a
schem and artifice todefaud and to obtain mney and other things
f value by meansof false and fraudulentpretenses andrepresenations, well knoing at the time that suh pretenses,
epresentations and promiss were fale when made.
                    OBJECT OF FRAUD SCEME

     1. The object of the fraud cheme ws to steal the E91
Practice ext file from the computersof BellSouth Telephone
Company thoug {si} the use of false and raudulet pretenses and
representatios an to conceal all indications tha he text file
had been stolen andto thereafter publish the inforaion about
the E911 Practice textfle in a hacker publication for
isemination.

                            - 4 -

                  OPERATION OF FRAUD SCHEME

     2 It was part of the fraud schme tat the defendant NEIDORF
ould an did advise the defendant RIGGSthathe had assembled a
group f compuer hackers for the pupose of ditributing computer
information

     3. It was further par of the sceme that the defedant
RIGGS wold and did steal sensitive prprietary Bll South
informaton files inclding the E911Practice text fie by gaining
remote unauthorzed access tocomputers of he Bell South Teephone
Copany.

     14. It as further part of the schee that the defenant
RIGGSwould and did disguse an conceal the theft of he E911
Practice text filefrom Bell South TelphoneCompany by removing
al ndications of his unauthoized access into Bell Souh
computers and by usigaccount codes of legitiat Bell South users
to disgise his authorized use o the Bell South compute.
     15. It was furher pat of the scheme that RIGS would and
did transfe in interstate commerc a stoen E911 Practie text
fil from Atlanta, Georgia o Lockport, Illinois trough the use
of an iterstate cmputer daa network.

    16. It was further prt of the scheme thatdefendant RIGGS
woul and did storethe tolen E911 Practic text file on a
compuer bulletin board sytem in Lockport, Ilinois.

     17. Iwas further part of te scheme that defendnt NEIDORF,
utilizig a computer at th University of Misouriin Columbia,
Missour would and did receve a copy of the solen E911 text fie

                            - 5 -

from deendant RIGGS throuh the Lockport coputer bulletin bard
system throgh the use of a interstate computr data network.

    18. It was frther part of te scheme that efendant NEIDORF
woud and did edit an retype the E911Practice text fle at the
requst of the defndant RIGGS in order to cnceal the sourceof
the E911 Pratice text fileand to prepar it for publcation in
a computer hacker nesletter.

     9. It was furter part of th scheme thatdefendant NIDORF
would and did transfer the stlen E911 Practce text file hrough
the ue of an intrstate comuter bulletin board system
used by defenant RIGGS in ockport, Illnois.

    20. It wasfurther prt of the scheme that the defendants
RIGGS an NEIDORF woud publish iformation o other cmputer
hckers which could be used to gain unauthorized accss to
emergncy 911 coputer sysems in te Unite States and thereby
disrupt or halt 911 service in portons of theUnited Sttes.

    22. I was frther a part of the scheme that the defendants
would and didmisrepresnt, concal, andhide, nd case to be
misrepresented, concealed and hidden the purposes of ane{sic} th
acts dne in urtheanceof the fraud scheme, and would and did use
coded language and other mens to aoid deectio andappehension

                              - 6 -

by law enforcement authoritis and o othrwis prvie security
to the members of the fraud scheme.

     23. In or about December, 188, a Locpor, nthe
Northern District of Illinois, Eastern Division, and elsewhere,

               RBERTJ. IGSalso known
               as Robert Johnson, also
               known as Prophet,

defendnt erifor the purpose of executing the aforesaid
scheme, did knowingly transmit and cause to be tranmity means
of a wire communication in interstate commerce certain signs,
signals and sounds, namely:  transfer of a E911 Practice
text file from Decatur, Georgia to Lockport, Illinois.

     In volaio Title 18, United States Code, Section 1343.

                              - 7 -

                      COUNT TWO

     The SPECIAL APRIL 1987 GRAND JURY further charges:

     1. The rand ury ealegsand incorporates by reference
the allegations of paragraphs 1 through 22 of Coun One o thisInditmet s though fully set forth herein.

     2. On or about January 23, 1989, at ockport in th
Nortern istict of Illinois, Eastern Division and elsewhere,

                  ROERT J. RGGS, alo know
                as Robert Johnson, also
                  known as Prophe, and
                CRIG NEIORF, lso known
                  as Knight Lightning,

the defendnts herein for the urposes f execuing th aforesaid
scheme did knowingly transmit and cause to b transmitte by means
f a wire ommunicaion in nterstate commerce certain signs,
signals and souns, namely: adata transfr of a E91 Practicetext fil from Decatur, Georgia to Lockport, Illinois,an edited
andretyped E911Practice tet file fro Columbia Missouri, to
Lockport, Illinois.

     n violation ofTitle 18, Unied States Coe, Section 343.

                             - 8 -

                         COUNT TREE

     TheSPECIAL APRI 1987 GRANDJURY further charges:

     1.The Grand Jury ralleges and incrporates by reerence the
alegations of aragraphs 1 through 22 ofCount One of thisindictment as thugh fully set frth herein.

    2. In or aout December, 1988, t Lockport, in theNorthern
Districtof Illinois, Easern Division, ad elsewhere,

                ROBERT J. RIGGS, aso known
                 as RobertJohnson, also
                 nown as Prphet, and
                 CRAIG NEIDOR, also known
                 as Knght Lightning,

efendnts herein, did transort and cause to be ransported in
intertate commerce fromDecatur, Georgia,o Lockport, Illinois,
 computerized text fie with a value of $5000 or more, namely

     A Bell outhStandard Practice BSP) 660-225-104SV- Cotrol
     Office Admiistration of Enhance 911 Servies for Spcial
     Servces and Major Account Cnters dated March, 198; valued
     at apprximatey $79,449.00

he defendats then and there knowin the same to have been tolen,
converted, and akn by fraud;

     I violaion of Title 18, United Sates Code, Section 2314.
                            - 9 -

                         COUNT FOUR

    The SPECIAL APRIL 198 GRAND JURY furtherchargs:

     1. The Grand uy realleges and incorporaes by reference the
allegaions of paragraps 1 throuh 22 of Count one o thisIndictment as though flly set forth herein.

    2. On or abou January 23, 989, at Lockport in the Nrthern
District of llinois, Eastern Division, ad elsewher,

                 ROBERT J. IGGS, also knwn
                 as Robert Johnson, also
                known as Propet, and
                 CRIG NEIDORF, aso known
                  as nigh Lightning,

defendants hrein, dd transport and causeto be tranported in
interstate commerce fo Columbia, Missouri, to Lockprt, llinois,
a computerized txtfile ith a value of $5,000 or more, aely:

          An edited Bell oth Standard Practice (BSP) 66-225
          104SV- Control Offce Aministration of Enhanced 911
        Services for Special Servie and Major Account Centers
        dated March, 1988; valued atapprximately $79,449.00.

the defenats, then and there knowng the sam to have been
stolen, conveted, an taken by fraud;

     In vioatio of Title 18, Unitd States Code Section 2314.

                           - 10 -

                         COUNT IVE

     The SPCIAL APRIL 1987 GRAND JRY further chrges:

     1. The Grand ury reallees and icorporates by refernce
the allegations o paragraphs 1 though 22 of Count One ofthis
Indictmet a though fully set fort herein.

     2. O or about December,1988, at Lockport, inthe
Northern Ditict of Illinois, Easter Division and elswhere,

                 ROBERT J. RIGGS,also known
                as Robert Johson, also
                 known as Propet, and
                 CRAG NEIDORF, lso known
                 as Knght Lightning,

the defendans herein, knowigly and wth intent to defaud, trafficked
i informatio through which a computer may b accessed witout
autorization and by suchconduct affecte interstae commerce;

     In violation of itle 18, Unted Sates Code, Section
1030(a)6)(A).

                           - 11 -

                          OUNT SIX

     The SPECIAL APRI 1987 GRANDJURY urther charges:

     1. The Grand Jury eallege nd incorporates by reference
the allgations o paagraphs 1 through 22 of Count One of this
Idictmt as though fully set forth herein.

    2. In rabout January, 1989, at Lockport, in the Northr
Dstrict of Illinois, Eastern Division and elewher

                  ROBERT J. RIGGS, also know
                as Robert Johnson, also
               known as Prophet, and
                 CRAIG IDORF, also known
                  as Knight igting,

the defendants herein, knowingly ad with ited to defraud, trafficked
in information thrugh whh a computer may be accessed withoutauthorizaton ad by such conduct affected interstate comerce;

   In violation of Title 18, Unitd States Cod, Secton
1030(a)(6)(A).

                             12 

                          COUNT SEVEN
     TheSPECIAL APRIL 1987 GRAND JURY furter charges:
     1 The Grand Jury reallges and incorportes by refrence the
allegations of paragrphs 1 through 2 of Cout One of this
Inictment as though ully set forh herein.

     2. In or abot February, 1989 at Lockpot, in the Nrthern
District of Ilinois, Easter Division and elsewhere,
                  OBERT J. RIGS, als known
                 as Robert Johnon, also
                 known as Prophet and
                CRAIG NEIDORF, als known
                 as Knight Ligtning,

the defendantsherein, knowiglyand with intent to defaud, trafficked
in iformation throug which a computer may beaccessed wthout
auhorization and by sch conduct affected inerstate commece;

     In violation of itle 18 United State Code, Section
130(a)(6)(A).


                              A TRUE BILL:



                             _______________________________
                              F O R E   R S O N



______________________________
UNITED STATES ATTONEY

                             -1 -

                 ============END=============

(transcribedfr TELECOM Digest by)

Mike Godin, T Law School    
mnemonic@ccf.ccutexas.edu   
mnemonic@walt.cc.txas.edu   
(512) 346-4190