May-14-99 03:20 PM FBI WFO MEDIA OFFICE Sent by: FBI 7037823446 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division UNITED STATES OF AMERICA ) ) v. ) Criminal No. ) ) Counts 1-3: Computer Intrusion ERIC BURNS ) (18 U.S.C. $ 1030(a)(5) also known as "Zyklon" ) ) Defendant. ) INDICTMENT May 1999 Term - At Alexandria, Virginia COUNT 1 THE GRAND JURY CHARGES THAT: From on or about August 25, 1998, through on or about January 22, 1998, in the Eastern District of Virginia and elsewhere, ERIC BRUNS, also known as "Zyklon," defendant herein, knowingly and intentionally cuased transmissions from a computer in Shoreline, Washington, of progress, information, codes, and commands, and as a result of such conduct, intentionally caused damage without authorization to a computer of Electric Press, Kerndon, Virginia, which was a protected computer used by and for the United States Information Agency, and agency of the United States Government, and the conduct affected the use of the computer by and for the government and caused loss aggregating at least $5,000 to at least one individual between August 25, 1998 and March 1, 1999. (In violation of Title 18, United States Code, Section 1030(a)(5)(A).) COUNT 2 THE GRAND JURY CHARGES THAT: From on or about December 28, 1998, through on or about December 31, 1998, in the Eastern District of Virginia and elsewhere, ERIC BURNS, also know as "Zyklon," the defendant herein, knowingly and intentionally caused transmissions from a computer in Shoreline, Washington, of programs, information, codes, and commands, and as a result of such conduct, intentionally caused damage without authorization to a computer of Computer Tech Services, doing business as LaserNet, in Fairfax, Virginia, which was a protected computer used in interstate commerce and communication, and caused loss aggragating at least $5,000 to at least one individual between December 28, 1998, and March 1, 1999. (In violation of Title 18, United States Code, Section 1030(a)(5)(A).) COUNT 3 THE GRAND JURY CHARGES THAT: From on or about December 28, 1998, through on or about January 11, 1999, in the Eastern District of Virginia and elsewhere, ERIC BURNS, also known as "Zyklon," defendant herein, knowingly and intentionally caused the transmission from a computer in Shoreline, Washington, of programs, information, codes, and commands, and as a result of such conduct, intentionally caused damage without authorization to computers operated by Issue Dynamics, Inc. in Alexandria, Virginia, and Washington, D.C., which were protected computers used in interstate commerce and communications, and caused loss aggragating at least $5,000 to at least one individual between December 28, 1998, and March 1, 1999. (In violation of Title 18, United States Code, Section 1030(a)(5)(A).) A TRUE BILL: __________________________ FOREPERSON UNITED STATES GRAND JURY (signed) ______________________ Helen F. Fahey United States Attorney (signed) ______________________ Justin W. Williams Assistant United States Attorney Chief, Criminal Division (signed) ______________________ Jack Henly Assistant United States Attorney