[From: TELECOM Digest, Sat, 31 Mar 90]


    Legion of Doom Indictments (Chicago Members) [Mike Godwin]
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From: Mike Godwin 
Subject: Legion of Doom Indictments (Chicago Members, Jolnet Shutdown)
Date: 31 Mar 90 22:37:33 GMT
Reply-To: Mike Godwin 
Organization: The University of Texas at Austin, Austin, Texas


The following is the text of the federal indictments of the Chicago
Jolnet members. Secret Service jurisdiction to investigation these
alleged computer-related offenses comes from 18 USC 1030, the general
computer-fraud statute -- it's provided in section (d) under this
statute.

              UNITED STATES DISTRICT COURT NORTHERN
                      DISTRICT OF ILLINOIS
                        EASTERN DIVISION

                               )
UNITED STATES OF AMERICA       )
                               )
          v.                   )    No. ______________________
                               )    Violations: Title 18, United
ROBERT J. RIGGS, also known    )    States Code, Sections
as Robert Johnson, also        )    1030(a)(6)(A) and 2314
known as Prophet, and          )
CRAIG NEIDORF, also known      )
as Knight Lightning            )

                            COUNT ONE

     The SPECIAL APRIL 1987 GRAND JURY charges:

                        PROPERTY INVOLVED

     1. At all times relevant herein, enhanced 911 (E911) was the
national computerized telephone service program for handling
emergency calls to the police, fire, ambulance and emergency
services in most municipalities in the United States. Dialing 911
provided the public immediate access to a municipality's Public
Safety Answering Point (PSAP) through the use of computerized all
routing. The E911 system also automatically provided the recipient
of an emergency call with the telephone number and location
identification of the emergency caller.

     2. At all times relevant herein, the Bell South Telephone
Company and its subsidiaries ("Bell South") provided telephone
services in the nine state area including Alabama, Mississippi,
Georgia, Tennessee, Kentucky, Lousiana {sic}, North Carolina, South
Carolina and Florida.

     3. At all times relevant herein, the E911 system of Bell South
was described in the text of a computerized file program known as
the Bell South Standard Practice 660-225-104SV Control Office

                              - 1 -

Administration of Enhanced 911 Services for Special and Major
Account Centers date March, 1988 ("E911 Practice"). The E911
Practice was a highly proprietary and closely held computerized
text file belonging to the Bell South Telephone Company and stored
on the company's AIMSX computer in Atlanta, Georgia. The E911
Practice described the computerized control and maintainence {sic}
of the E911 system and carried warning notices that it was not to be
disclosed outside Bell South or any of its subsidiaries except
under written agreement.

                         COMPUTER HACKERS

     4. At all times relevant herein, computer hackers were
individual involved with the unauthorized access of computer
systems by various means.

     5. At all times relevant herein, the Legion of Doom (LOD)
was a closely knit group of computer hackers involved in:

          a.   Disrupting telecommunications by entering
               computerized telephone switches and changing the
               routing on the circuits of the computerized
               switches.
          b.   Stealing proprietary computer source code and
               information from companies and individuals that
               owned the code and information.
          c.   Stealing and modifying credit information on
               individuals maintained in credit bureau computers.

                              - 2 -

          d.   Fraudulently obtaining money and property from
               companies by altering the computerized information
               used by the companies.
          e.   Disseminating information with respect to their
               methods of attacking computers to other computer
               hackers in an effort to avoid the focus of law
               enforcement agencies and telecommunication security
               experts.

     6. At all times relevant herein ROBERT J. RIGGS, defendant
herein, was a member of the LOD.

     7. At all times relevant herein CRAIG NEIDORF, defendant
herein, was a publisher and editor of a computer hacker newletter
{sic} known as "PHRACK."

     8. At all times relevant herein, a public access computer
bulletin board system (BBS) was located in Lockport, Illinois which
provided computer storage space and electronic mail services to its
users. The Lockport BBS was also used by computer hackers as a
location for exchanging and developing software tools for computer
intrusion, and for receiving and distributing hacker tutorials and
other information.

                             E-MAIL

     9. At all times relevant herein electronic mail (e-mail) was
a computerized method for sending communications and files between
individual computers on various computer networks. Persons who
sent or received e-mail were identified by an e-mail address,
similar to a postal address. Although a person may have more than

                              - 3 -

one e-mail address, each e-mail address identified a person
uniquely. The message header of an e-mail message identified both
the sender and recipient of the e-mail message and the date the
was {sic} message sent.

     10. Beginning in or about September, 1988, the exact date
begin unknown to the Grand Jury, and continuing until the return
date of this indictment, at Lockport, in the Northern District of
Illinois, Eastern Division, and elsewhere,

                  ROBERT J. RIGGS, also known
                  as Robert Johnson, also
                  known as Prophet, and
                  CRAIG NEIDORF, also known
                  as Knight Lightning,

defendants herein, together with others known and unknown to the
Grand Jury, devised and intended to devise and participated in a
scheme and artifice to defraud and to obtain money and other things
of value by means of false and fraudulent pretenses and
representations, well knowing at the time that such pretenses,
representations and promises were false when made.

                     OBJECT OF FRAUD SCHEME

     11. The object of the fraud scheme was to steal the E911
Practice text file from the computers of Bell South Telephone
Company though {sic} the use of false and fraudulent pretenses and
representations and to conceal all indications that the text file
had been stolen; and to thereafter publish the information about
the E911 Practice text file in a hacker publication for
dissemination.

                              - 4 -

                    OPERATION OF FRAUD SCHEME

     12. It was part of the fraud scheme that the defendant NEIDORF
would and did advise the defendant RIGGS that he had assembled a
group of computer hackers for the purpose of distributing computer
information.

     13. It was further part of the scheme that the defendant
RIGGS would and did steal sensitive proprietary Bell South
information files including the E911 Practice text file by gaining
remote unauthorized access to computers of the Bell South Telephone
Company.

     14. It was further part of the scheme that the defendant
RIGGS would and did disguise and conceal the theft of the E911
Practice text file from Bell South Telephone Company by removing
all indications of his unauthorized access into Bell South
computers and by using account codes of legitimate Bell South users
to disguise his authorized use of the Bell South computer.

     15. It was further part of the scheme that RIGGS would and
did transfer in interstate commerce a stolen E911 Practice text
file from Atlanta, Georgia to Lockport, Illinois through the use
of an interstate computer data network.

     16. It was further part of the scheme that defendant RIGGS
would and did store the stolen E911 Practice text file on a
computer bulletin board system in Lockport, Illinois.

     17. It was further part of the scheme that defendant NEIDORF,
utilizing a computer at the University of Missouri in Columbia,
Missouri would and did receive a copy of the stolen E911 text file

                              - 5 -

>from defendant RIGGS through the Lockport computer bulletin board
system through the use of an interstate computer data network.

     18. It was further part of the scheme that defendant NEIDORF
would and did edit and retype the E911 Practice text file at the
request of the defendant RIGGS in order to conceal the source of
the E911 Practice text file and to prepare it for publication in
a computer hacker newsletter.

     19. It was further part of the scheme that defendant NEIDORF
would and did transfer the stolen E911 Practice text file through
the use of an interstate computer bulletin board system
used by defendant RIGGS in Lockport, Illinois.

     20. It was further part of the scheme that the defendants
RIGGS and NEIDORF would publish information to other computer
hackers which could be used to gain unauthorized access to
emergency 911 computer systems in the United States and thereby
disrupt or halt 911 service in portions of the United States.

     22. It was further a part of the scheme that the defendants
would and did misrepresent, conceal, and hide, and cause to be
misrepresented, concealed and hidden the purposes of ane {sic} the
acts done in furtherance of the fraud scheme, and would and did use
coded language and other means to avoid detection and apprehension

                              - 6 -

by law enforcement authorities and to otherwise provide security
to the members of the fraud scheme.

     23. In or about December, 1988, at Lockport, in the
Northern District of Illinois, Eastern Division, and elsewhere,

               ROBERT J. RIGGS, also known
               as Robert Johnson, also
               known as Prophet,

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

     In violation of Title 18, United States Code, Section 1343.

                              - 7 -

                            COUNT TWO

     The SPECIAL APRIL 1987 GRAND JURY further charges:

     1. The Grand Jury realleges and incorporates by reference
the allegations of paragraphs 1 through 22 of Count One of this
Indictment as though fully set forth herein.

     2. On or about January 23, 1989, at Lockport, in the
Northern District of Illinois, Eastern Division and elsewhere,

                  ROBERT J. RIGGS, also known
                  as Robert Johnson, also
                  known as Prophet, and
                  CRAIG NEIDORF, also known
                  as Knight Lightning,

the defendants herein, for the purposes of executing the aforesaid
scheme did knowingly transmit and cause to be transmitted by means
of a wire communication in interstate commerce certain signs,
signals and sounds, namely: a data transfer of a E911 Practice
text file from Decatur, Georgia to Lockport, Illinois, an edited
and retyped E911 Practice text file from Columbia, Missouri, to
Lockport, Illinois.

     In violation of Title 18, United States Code, Section 1343.

                              - 8 -

                           COUNT THREE

     The SPECIAL APRIL 1987 GRAND JURY further charges:

     1. The Grand Jury realleges and incorporates by reference the
allegations of paragraphs 1 through 22 of Count One of this
indictment as though fully set forth herein.

     2. In or about December, 1988, at Lockport, in the Northern
District of Illinois, Eastern Division, and elsewhere,

                  ROBERT J. RIGGS, also known
                  as Robert Johnson, also
                  known as Prophet, and
                  CRAIG NEIDORF, also known
                  as Knight Lightning,

defendants herein, did transport and cause to be transported in
interstate commerce from Decatur, Georgia, to Lockport, Illinois,
a computerized text file with a value of $5,000 or more, namely:

     A Bell South Standard Practice (BSP) 660-225-104SV- Control
     Office Administration of Enhanced 911 Services for Special
     Services and Major Account Centers dated March, 1988; valued
     at approximately $79,449.00

the defendants then and there knowing the same to have been stolen,
converted, and taken by fraud;

     In violation of Title 18, United States Code, Section 2314.

                              - 9 -

                           COUNT FOUR

     The SPECIAL APRIL 1987 GRAND JURY further charges:

     1. The Grand Jury realleges and incorporates by reference the
allegations of paragraphs 1 through 22 of Count one of this
Indictment as though fully set forth herein.

     2. On or about January 23, 1989, at Lockport, in the Northern
District of Illinois, Eastern Division, and elsewhere,

                  ROBERT J. RIGGS, also known
                  as Robert Johnson, also
                  known as Prophet, and
                  CRAIG NEIDORF, also known
                  as Knight Lightning,

defendants herein, did transport and cause to be transported in
interstate commerce from Columbia, Missouri, to Lockport, Illinois,
a computerized textfile with a value of $5,000 or more, namely:

          An edited Bell South Standard Practice (BSP) 660-225-
          104SV- Control Office Administration of Enhanced 911
          Services for Special Services and Major Account Centers
          dated March, 1988; valued at approximately $79,449.00.

the defendants, then and there knowing the same to have been
stolen, converted, and taken by fraud;

     In violation of Title 18, United States Code, Section 2314.

                             - 10 -

                           COUNT FIVE

     The SPECIAL APRIL 1987 GRAND JURY further charges:

     1. The Grand Jury realleges and incorporates by reference
the allegations of paragraphs 1 through 22 of Count One of this
Indictment as though fully set forth herein.

     2. On or about December, 1988, at Lockport, in the
Northern District of Illinois, Eastern Division and elsewhere,

                  ROBERT J. RIGGS, also known
                  as Robert Johnson, also
                  known as Prophet, and
                  CRAIG NEIDORF, also known
                  as Knight Lightning,

the defendants herein, knowingly and with intent to defraud, trafficked
in information through which a computer may be accessed without
authorization and by such conduct affected interstate commerce;

     In violation of Title 18, United States Code, Section
1030(a)(6)(A).

                             - 11 -

                            COUNT SIX

     The SPECIAL APRIL 1987 GRAND JURY further charges:

     1. The Grand Jury realleges and incorporates by reference
the allegations of paragraphs 1 through 22 of Count One of this
Indictment as though fully set forth herein.

     2. In or about January, 1989, at Lockport, in the Northern
District of Illinois, Eastern Division and elsewhere,

                  ROBERT J. RIGGS, also known
                  as Robert Johnson, also
                  known as Prophet, and
                  CRAIG NEIDORF, also known
                  as Knight Lightning,

the defendants herein, knowingly and with intend to defraud, trafficked
in information through which a computer may be accessed without
authorization and by such conduct affected interstate commerce;

     In violation of Title 18, United States Code, Section
1030(a)(6)(A).

                             - 12 -

                           COUNT SEVEN

     The SPECIAL APRIL 1987 GRAND JURY further charges:

     1. The Grand Jury realleges and incorporates by reference the
allegations of paragraphs 1 through 22 of Count One of this
Indictment as though fully set forth herein.

     2. In or about February, 1989, at Lockport, in the Northern
District of Illinois, Eastern Division and elsewhere,

                  ROBERT J. RIGGS, also known
                  as Robert Johnson, also
                  known as Prophet, and
                  CRAIG NEIDORF, also known
                  as Knight Lightning,

the defendants herein, knowingly and with intent to defraud, trafficked
in information through which a computer may be accessed without
authorization and by such conduct affected interstate commerce;

     In violation of Title 18, United States Code, Section
1030(a)(6)(A).


                                A TRUE BILL:



                                ________________________________
                                F O R E P E R S O N



________________________________
UNITED STATES ATTORNEY


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

(transcribed for TELECOM Digest by)

Mike Godwin, UT Law School    
mnemonic@ccwf.cc.utexas.edu   
mnemonic@walt.cc.utexas.edu   
(512) 346-4190                

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