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Criminal Complaint — United States v. Desmond Fodje Bobga (Dkt. 3)

Summary

A sealed Criminal Complaint filed 06/30/20 as Document 3 in United States of America v. Desmond Fodje Bobga, Case No. 2:20-mj-01365-MPK (20-1365m), U.S. District Court for the Western District of Pennsylvania, before Maureen P. Kelly, U.S. Magistrate Judge. The complaint lists violations of 18 U.S.C. § 1349 (Fraud Conspiracy), 18 U.S.C. § 1343 (Wire Fraud), 18 U.S.C. § 505 (Forging and Counterfeiting the Seal of a Court of the United States) and 18 U.S.C. § 1028A (Aggravated Identity Theft). Attachment A alleges that from in and around June 2018 the conspirators offered puppies and other animals for sale on websites, claimed transport was delayed and needed additional money, and never delivered the animal. The affidavit of FBI Special Agent Joseph J. Ondercin follows.

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Cite this document

“Criminal Complaint — United States v. Desmond Fodje Bobga (Dkt. 3).” Original at www.justice.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-2-20-mj-01365-dkt-3-701d7cd75c/, SHA-256 37bfeebdfa13ab895160b4a193ab7d40e7cb588d0f1219bf47e921d8d2e44914.

Full text

     Case 2:20-mj-01365-MPK .SEALED* Document 3 *SEALED* Filed 06/30/20 Page 1 of 4
AO 9l (Rev. I l/l l) Cnmind Complaanl



                                        UNrrgo Srerps DrsrRrcr Counr
                                                                for the
                                                  Weslem District of Pennsylvania

                 United States of America                           )
                                                                    )
                                                                    )       Case No
                                                                    )                 20-1365m IUNDER SEALI
                DESMOND FODJE BOBGA                                 )
                                                                    )
                                                                    )
                          Delendan!g


                                                 CRIMINAL COMPLAINT
         I, the complainant in this case, state that the following is true to the best ofmy knowledge and belief.
On or about the date(s)     of           June 2018 to the present         in the countv of                 Beaver         in the
     Western District of                   Pennsylvania        , the defendant(s) violated:

            Code Section                                                      Ofense Descriplion
18 U.S.C. S 1349                                Fraud Conspiracy

18 U.S.C. S 1343                                Wre Fraud

18 U.S.C. S 505                                 Forging and Counterfeiting the Seal ofa Courl oflhe United States

18 U.S.C. S 1028A                               Aggravated ldentity Theft
(SEE ATTACHMENT A)                              (SEE ATTACHMENT A)

         This criminal complaint is based on th€se facts:
                                   (See Affidavit in Support of Complaint)




         d Continued on the attached sheet.
                                                                                              /s/ Joseph J. Ondercin
                                                                                               Conplainant's si gnanre

                                                                                               Joseph J. Ondercin
                                                                                                Printed nome and title

Swom to before me and signed in my presence


Date:            06t30t2020
                                                                                                 Judge's signahtre

Cily and state                   Pittsburgh, Pennsylvania                    MAUREEN P. KELLY, U,S. MAGISTRATE JUDGE
                                                                                               Printed n<rnte and title
Case 2:20-mj-01365-MPK *SEALED* Document 3 *SEALED* Filed 06/30/20 page 2 of 4




                                      ATTACHMENT A
                                  TO CRIMINAL COMPLAINT


 Count l:       From in and around June 2018. and continuing to the present, in the countries of

 Romania and Cameroon and in the Westem District ofPennsylvania and elsewhere, the defendant,

 DESMOND FODJE BOBGA, knowingly and willfully did conspire, combine, confederate, and

 agree with other persons to commit an offense against the United States, that is, wire fraud, in

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

                As part ofthe manner and means ofthe conspiracy, the conspirators offered puppies

 and other animals for sale on websites on the Intemet, the conspirators communicated by wire with

 potential victims to induce the potential victims to purchase the puppy or other animal, the

 conspirators claimed that the transport of the puppy or other animal was delayed and needed

 additional monies to effectuate the transport, the conspirators received money directly and

 indirectly through wire communications fiom the victims, and the conspirators never delivered the

 puppy or other animal.

                In violation ofTitle 18, United States Code, Section 1349.




 Counts 2-10: On or about the dates set forth below, in Romania and in the Westem District of

 Pennsylvania and elsewhere, the defendant, DESMOND FODJE BOBGA, for the purposes of

 executing and attempting to execute the scheme and artifice to defraud, did cause to be transmitted

 in foreigrt and/or interstate commerce, by means of a wire communication, monetary wire transfers

 with each wire transfer being a separate count, the following:

      Count        On or about Date
                        of Wire
         ')        3fi3/2020           The defendant, DESMOND FODJE BOBGA, caused
                                       Victim- l to wire, via Westem Union, $950 from Rochester,
Case 2:20-mj-01365-MPK *SEALED* Document 3 "SEALED* Filed 06/30/20 Page 3 of 4




                                       Pennsylvania to Romania
        l          3^412020            The defendant, DESMOND FODJE BOBGA, caused
                                       Victim-l to wire, via western Union, $1500 lrom New
                                       Brighton, Pennsylvania to Romania
        4          311712020           The defendant, DESMOND FODJE BOBGA, caused
                                       Victim- l to wire, via Western Union, $2000 from Beaver
                                       Falls, Pennsylvania to Romania
        5          3/17t2020           The defendant. DESMOND FODJE BOBGA. caused
                                       Victim-l to vvire. via Western Union. $950 from Monaca,
                                       Pennsylvania to Romania
        6          3/19/2020           The defendant, DESMOND FODJE BOBGA, caused
                                       Victim- l to wire, v ia Western Union, $600 from Rochester,
                                       Pennsylvania to Romania
        7          3/21/2020           The defendant. DESMOND FODJE BOBGA. caused
                                       Victim-l to wire. via westem Union. $500 from New
                                       Brighton. Pennsylvan ia to Romania
        8          312912019           The defendant, DESMOND FODJE BOBGA, caused
                                       Victim-3 to wire, via MoneyGram. $600 from Indiana.
                                       Pennsylvania to an individual with the initials J.J. in
                                       Maryland
        9          4t24t20t9           The defendant, DESMOND FODJE BOBGA. caused
                                       Victim-5 to wire, via MoneyGram, $600 from Frazer
                                       Township, Pennsylvania to an individual with the initials
                                       W.M. in Virginia
        l0        4/27t7019            The defendant, DESMOND FODJE BOBGA, caused
                                       Victim-5 to wire, via MoneyGram, $900 from Frazer
                                       Township, Pennsylvania to an individual with the initials
                                       E.B. in Florida

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




 Count 11:     On or about March 29, 201 9, in the Westem District of Pennsylvania and

 elsewhere, the defendant, DESMOND FODJE BOBGA, did knowingly concur in using. that is,

 sending to Victim-3 located in the Western District ofPennsylvania, a lorged and counterfeit seal

 of a court ofthe United States, that is, the Supreme Court ofthe United States, and a forged and

 counterfeit signature ofthe Clerk ofthe Supreme Court, a court officer. on a document purporting

 to have been issued by the Supreme Court of the United States for the purpose of authenticating

 the document. knowing such seal and signature to be forged and counterfeit, said document
Case 2:20-mj-oL365-MPK *SEALED* Document 3 *SEALED* Filed 06/30/20 Paqe 4 ot 4




 claiming to guarantee the refund of $850.00 for the safe delivery of a dog.

                In violation ofTitle 18. United States Code. Section 505.




 Count 12:      On or about March 29, 2019, in the Westem District of Pennsylvania and

 elsewhere, the defendant, DESMOND FODJE BOBGA, during and in relation to the felony

 violation of wire fraud did knowingly transfer, without lawful authority, a means of identification

 of another person, namely, the signature ofthe former Clerk ofthe Supreme Court ofthe United

 States.

                ln violation of Title 18, United States Code, Section 1028A(a)(l).
   Case 2:20-m.l-01365-MPK *SEALED* Document               4 Filed 06/30/20 Page 1 of 25


                      IN THE UNITED STATES DISTRICT COUR'T
                   FOR THE WESTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMt]RICA                    )
                                             )
                                             )
                                             )       Magistrate No. 20-l 365M
                                             )
                                             )
DESMOND FODJE BOBCA                          )


                        AF}'IDAVIT IN SUPPORT OF COMPLAINT

       I, Special Agent Joseph J. Ondercin, being first duly swom, hereby depose and state as

follows:

                     INTRODUCTION AND AGENT BACKGROUND

       I   .   I am a Special Agent (SA) with the Federal Bureau of Investigation (FBI) and have

been so employed since Novemberof2005. I am currently assigned to the Piftsburgh Division of

the FBI, computer intrusion squad. In this capacity, I am charged with investigating possible

violations of federal criminal law. By vi*ue of my FBI employment, I perform and have

performed a variety of investigative tasks, including functioning as a case agent on access device

fraud, computer fraud, and wire fraud cases. I have received training in the conduct of access

device fraud, computer fraud, and wire fraud investigations. I have also received training and

gained experience in interviewing and interrogation techniques, the execution of federal search

warrants and seizures, and the identification and collection of computer-related evidence. ln

addition, I have personally participated in the execution of federal search warrants involving the

search and seizure of computer equipment.

       2.      The information contained in this affidavit is based upon my personal knowledge,

knowledge obtained during my participation in this investigation, knowledge obtained from other

individuals including other law enforcement personnel and others who have personal knowledge


                                                 I
     Case 2:20-mj-01365-MPK *SEALED* Document               4 Filed 06130120 Page 2 ot 25


of the events and circumstances described herein, knowledge obtained from my review of

documents, electronic records, and other evidence related to this investigation, and knowledge

gained through my training and experience. Because this affidavit is being submitted for the

limited purpose of establishing probable cause in support of a criminal complaint, I have not

included every detail of every aspect ofthe investigation. Rather, I have set forth only those facts

that I believe are necessary to establish probable cause.

        3.     This Affidavit is in suppo( of an application for a criminal complaint against and

an arrest warrant for DESMOND FODJE BOBGA. As set forth herein, there exists probable cause

to believe that DESMOND FODJE BOBGA has violated Title 18, United States Code, Sections

1349 (Fraud Conspiracy), 1343 (Wire Fraud), 505 (Forging Seal of Court), and 1028,{

(Ag$avated Identity Theft).

                                    SUBJf,CT IDENTIFIERS

       4.      DESMOND FODJE BOBGA C'FODJE BOBGA"), born in 1992, is a citizen ofthe

Republic of Cameroon who is in the country of Romania on a visa to attend Babeq-Bolyai

University in Cluj, Romania. FODJE BOBGA has a Republic of Cameroon passport, number

0864425, expiring September 19, 2023.

                                      PROBABLE CAUSE

A.     Overview

       5.      The FBI is investigating an intemet fraud scheme wherein the criminal actors,

including FODJE BOBGA and co-conspirators, advertise goods/products/items online, receive

payment for the adve(ised goods/products/items, and intentionally do not deliver said

goods/products/items. As described below, this scheme, for years, involved the purported sale of

pets to the American public. The perpetrators used false and fraudulent promises and documents




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   Case 2:20-mj-01365-M PK .SEALED* Document                4 Filed 06/30/20 Page 3 of 25


regarding shipping fees, and more recently, coronavirus exposure, to extract successive payments

from victims.

       6.       Based on my training and experience, your Affiant knows these intemet fraud

schemes often require the use ofnumerous websites and email accounts. After a website and email

account are used to defraud a few individuals, the website and email account are often reported to

consumer protection agencies and flagged as fraudulent. As a result, other potential consumers

are able to leam that the website or email account is associated with the fraud and avoid purchasing

from said website and/or email account. Thus, criminal actors involved in this type of intemet

fraud scheme often use a particular website and/or email account for a few customers and then

create and use another website and/or email account to target new potential customers.

       7.       Based on my training and experience, your Affiant also knows that criminal actors

involved in this type of intemet fraud scheme prefer customers to pay through means that can

obscure the recipient's identity to avoid law enforcement detection. As a result, criminal actors

involved in this type of intemet fraud scheme prefer money transfers (e.g., Westem Union,

MoneyGram, etc.) or cryptocurrency (e.g., Bitcoin). These criminal actors often communicate

how payment should be made through electronic means with the victim customer.

       8.       The instant fraud scheme involves the false and fraudulent online sale of pets to

American consumers. Because the fraud scheme predominately (though not exclusively) involves

the sale of puppies, it is often known as a pet adoption scam or puppy scam. Specifically, the

individuals created websites to advertise puppies or other animals for sale, communicated with

potential customers, obtained payment for alleged sale, and provided nothing in retum. Using

multiple telephone numbers and email accounts, including (434) 214-8514 and

unitedpetsafe2009@gmail.com, FODJE BOBGA sent electronic communications, through
     Case 2:20-mj-01365-MPK *SEALED* Document               4 Filed 06/30/20 Page 4 of 25


interstate and/or foreign commerce, to hundreds of target victims across the United States. Some

of those communications contained false and fraudulent representations to induce the target

victims to pay hundreds ofdollars for a puppy. (Attached exhibit I and exhibit 2 are screenshots

of a website to which FODJE BOBGA directed numerous targeted victims to view puppies that he

fraudulently claimed to sell. Exhibit I is a screenshot ofthe website as it fits in the web browser

when initially accessed. Exhibit 2 captures the entire selection of advertised puppies at the time

that your Affiant inspected the website). Other communications contained false and fraudulent

representations to induce victims who had already paid lor the "puppy" to send hundreds, and

sometimes thousands, of additional dollars in "refundable fees" relating to the puppy's shipping,

vaccination, and coronavirus quarantine. FODJE BOBGA directed some ofthose payments to be

sent in his own name. He directed some other payments to be sent in the names of fellow African

students in Romania.

       9.        As part ofthis investigation, your Affiant has interviewed a number ofvictims and

potential victims of this puppy scam. Based on intemational and/or interstate electronic

communications obtained in this investigation, from June 2018 to the present, FODJE BOGBA

and his co-conspirators communicated with these victims and potential victims to fraudulently

induce them to send money, through intemational and or interstate wires, for puppies or other

animals that were never delivered. A few of the victims are highlighted below.

B.     Victim-l

        10. On two occasions, with the most recent being May 6, 2020, your Affiant
interviewed Victim-1, a resident of New Brighton, Pennsylvania, which is located in the Western

District of Pennsylvania.

        I   l.   In March 2020, Victim-l performed an internet search for a puppy to purchase for



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   Case 2:20-m.i-01365-MPK *SEALED. Document               4 Filed 06i30/20 Page 5 of 25


her mother. Victim- l came upon a web site offering mini dachshunds for sale where she submitted

a form requesting information. On approximately March ll,2020, Victim-l was contacted by

text message from the phone number (832) 843-9680 from an individual purportedly named

"Hector CANTU." *CANTU" indicated that the dog, purportedly named "Pansy," was still

available and that the price would be $500 to include shipping, which Iater changed to $600. As

instructed by "CANTU," Victim-l obtained $600 in Walmart gift cards and sent pictures of the

cards with the PIN number exposed to'CANTU." Victim-l sent these pictures by text message

from her phone, which was located in the Westem District of Pennsylvania, to the phone number

(832) 843-9680.   r




       12. Victim-l then received an email from the email account
dachshundshome99@gmail.com containing a Transfer of Ownership document. Victim-l was

informed that Pansy would be shipped by plane through an entity called "Pets Fly America" from

Houston, Texas to Pittsburgh, Pennsylvania with an expected arrival date of March 13,2020.

Dachshundshome99@gmail.com provided Victim- I with a tracking number for Pets Fly

America's website that allegedly allowed her to monitor the status ofPansy's transport.

       13. Victim-l then received text messages from an unnamed subject at phone number
(434) 214-8514 indicating that the subject was involved in the shipping ofthe puppy. According

to the text messages, the sender claimed that several issues came up with the transport of Pansy

which resulted in the dog being stopped over in Oklahoma. According to the sender, one ofthe

issues included Pansy being quarantined due to being exposed to COVID-19 on the flight. As a

result, the sender indicated that Victim-l needed to send additional fees to ensure Pansy's safe

transport including the need for an air conditioned shipping crate and insurance fees. The false



I The area code (832) is associated with the Houston, Texas area.

                                                5
      Case 2:20-mj-0l365-MPK *SEALED* Document                  4 Filed OGl30l20 Page 6 of 25


representations contained in these text messages induced Victim-l to send numerous intemational

wire transfer payments through Western Union, from locations in the Commonwealth of

Pennsylvania to receivers located in the country of Romania, in the hopes of having Pansy

transported safely. The below chart lists some of these international wires. Ultimately, no dog

arrived, and Victim-l received no refund.

    Amount       Sent Date   Sent Location       Reccive Date       Receive Loc.   Recci\e lnitials

    $950         3/13120     Rochester, PA       3ll4/20            Romania        A.L.F

    $1500        3/14/20     New Brighton. PA    3ll5/20            Romania        N.G.N

    $2000:       3/16t20     Rochester. PA       3lt6120            Romania        E.N.C

    s2000        3/17 /20    Beaver Falls. PA    3117 t20           Romania        B,T.N,

    $9s0         3/17 /20    Monaca, PA          3^8/20             Romania        B.T,N

    $(r00        3/19/20     Rochester. PA       3/t9t20            Romania        v.T.F'

    s-s00        3/21/20     New Brighton, PA    3l2t/20            Romania        M.G.A



             14. As part ofthis investigation, law enforcement obtained, by search warrant, Google
records associated with the email account joebahTT@gmail.com.

             15. According to Google subscriber records, the joebahTT @gmail.com account uses
Google Voice, which is a voice-over-internet-protocol ("VolP") product that provides calling and

text messaging services for customers through their Google accounts. Specifically,
joebahTT @gmail.com uses Google Voice with a user phone number of (434) 214-8514. As part


ofthe records provided, Google provided over 12,000 inbound and outbound text messages forthe

Google Voice phone number (434) 214-8514, including over 900 text messages that were

exchanged with Victim-l's phone number between March 13, 2020, and March 2l,2020, that

fraudulently induced Victim-l to lose $9,100.



2
    This transaction was sent by Victim-l's friend on her behalf.

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   Case 2:20-mj-o1365-MPK *SEALED* Document              4 Filed 06/30/20 Page 7 of 25


         16. Google subscriber records for email account joebahTT@gmail.com also listed a
recovery email of fodjebobgal @gmail.com. Based on my training and experience, your Affrant

knows that a recovery email is a method by which an account user can be reached to, among other

things, recover access to an account when the user forgets the account password. Based on my

training and experience, your Affiant knows that an account and its recovery email are likely

controlled by the same person and/or organization.

         17. As part ofthis investigation, law enforcement obtained, by search warrant,
Google records associated with the email account fodjebobgal @gmail.com. Those records show

the user of the fodjebobgal @gmail.com email account to be FODJE BOBGA in the following

ways, among others:

               a.      The contents of the fodjebobgal @gmail.com email account included

numerous emails relating to FODJE BOBGA's attendance of Babeq-Bolyai University. An email

sent from fodjebobgal @gmail.com, dated October 2, 2019, related to his admission at the

University contained numerous attachments, including a photograph of FODJE BOBGA's

Cameroonian passport and FODJE BOBGA's letter of acceptance to Babeq-Bolyai University

from the Romanian Ministry of National Education.

               b.      An email was sent from fodjebobgal @gmail.com, dated February 21,2020,

to an email address with the domain for a Romanian bank. The message indicated that the user's

name was Fodje Bobga Desmond, who was trying to open an account. Attached to the message

was a copy of a Taxpayer's Card from the Republic ofCameroon in the name ofDesmond Fodje

Bobga.

               c.     An email sent from fodjebobgal @gmail.com, dated March I1,2020, stated

that the user was "Fodje Bobga Desmond," as "the representative ofthe African students." The



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     Case 2:20-mj-0L365-MPK *SEALED. Document                4 Filed OOl3Ol2O Page 8 of 25


message provided a list ofthe names of other classmates. Two of those names appear to match

the names of two ofthe receivers to whom (434) 214-8514 had directed Victim-l to send money.

(The money transfer to one of them is reflected on the above chart under the initials V.T.F. Victim-

I's attempted payment to the other was unsuccessful.)

               d.      An email was sent from fodjebobgal @gmail.com, dated March 21,2020,

to an email address with the domain for Babeq-Bolyai University, relating to "covidl9." The

message stated that the sender was Fodje Bobga Desmond from Cameroon, was a political science

student, and was going to remain in Cluj.

        18. The Google photos archive for fodjebobgal @gmail.com contained two images of
interest. First, in a folder named "2020-01-08- 10," was a photo containing a picture of a

Cameroonian passport. The second, in a folder named "2020-01-l3," contained a picture ofa

Universitatea Babes Bolyai social service ID card. The two names on the two depicted documents

appear to match the names of two other listed receivers of fraudulently obtained funds from

Victim-1, as reflected in the above chart under the initials A.L.F. and E.N.C., respectively.

C.      Victim-2

        19. On May 7,2020 your Affiant interviewed Victim-2, who is a resident of Fruitland,
Iowa.

        20.    ln March 2020, Yictim-2 was searching online to purchase a puppy for herself.

Victim-2 came upon a web site offering mini dachshunds for sale where she submitted a form

requesting information. On approximately March 4, 2020, Victim-2 was contacted by text

message from the phone number (832) 843-9680 from an individual purportedly named "Hector

CANTU." "CANTU" indicated that the puppy, purportedly named "Tina," was still available and

that the price would be $600 with shipping. On March 5,2020, Victim-2 made a $300 deposit.



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   Case 2:20-mj-01365-MPK *SEALED* Document                4 Filed 06130120 Page I of 25


As instructed by "CANTU," Victim-2 obtained $300 in Walmart gift cards and sent pictures of the

cards with the PIN number exposed to "CANTU."

       21.     On March 6, 2020, Victim-2 received an email from the email account

dachshundshome99@gmail.com        containing a Transfer of Ownership document for Tina that

needed to be signed and retumed, which Victim-2 did. On March 9, 2020, by text messages,

"CANTU" provided a tracking number that allegedly can be used on the Pets Fly America website

to monitor the status of Tina's transport. On March 9,2020,Yictim-2 made the remaining $300

payment. As instructed by "CANTU," Victim-2 obtained $300 in Walmart gift cards and sent

pictures of the cards with the PIN number exposed to "CANTU." However, "CANTU" advised

that the Walmart gift cards were not activated. As a result, on the same date, Victim-2 sent an

additional $300 by Zelle, which is a digital payment system that is associated with numerous U.S.

banks, to an account associated with the email address jordonjamerson@gmail.com.

       22. After this payment was made, Victim-2 received an email from
petsflyamerica@outlook.com advising that the puppy had arrived in Chicago, Illinois. The email

advised that the puppy was lacking the appropriate insurance coverage, which required a $950

refundable payment. On March 10,2020, Victim-2 made the $950 payment through PayPal, an

electronic payment system, to a PayPal account associated with the email address of

infosalesdepartment@fastservice.com. Victim-2 received an email indicating that an individual

named Desmond Fodje Bobga refunded this PayPal transaction with the use ofa PayPal account

associated with the email address lovelyteacupchihuahual @gmai[.com. According to Victim-2,

she was informed that there was an issue with the PayPal transaction that caused this refund, and

that she must send payment by wire transfer through Western Union. On March 12,2020, Y ictim-




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  Case 2:20-mi-01365-MPK *SEALED* Document                4 Filed OG|SO|2O Page 10 of 25


2 sent, from lowa, a wire transfer through Western Union in the amount of $950 to an individual

named Desmond Fodje Bobga with a destination of Romania.

       23.     Subsequent to this payment, Victim-2 continued communication with the email

account petsflyamerica@outlook.com. In addition, Victim-2 communicated by text message with

the phone number (434) 214-8514 concerning the shipment ofTina. On March 12,2020, Victim-

2 received another email from petsflyamerica@outlook.com asserting that an additional $890 was

needed for vaccines and an AC crate, which would be refunded to Victim-2 upon delivery ofthe

puppy. On March 12, 2020, Victim-2 sent, from Iowa, a wire transfer through Westem Union in

the amount of$890 to an individual named Desmond Fodje Bobga with a destination of Romania.

       24.     Subsequent to this payment, the Victim-2 received an additional email from

petsflyamerica@outlook.com asserting that another $ I ,500 was needed for a USDA (United States

Department of Agriculture) pet and livestock permit, which would be fully refunded to Victim-2

upon delivery. At this point, Victim-2 refused to make any additional payment and requested a

refund. Victim-2 has not received any refund for the fees paid, and no dog was delivered.

       25.     On May 7, 2020, your Affiant reviewed the tracking number provided to Victim-2

for Tina on the web site www.petsflyamerica.com. According to the website associated with this

tracking number, the shipper was listed as Hector CANTU of Rosenberg, Texas with the phone

number of (832) 843-9680 and an email address of dachshundshome99@gmail.com. The

shipment information indicated that a female dachshund puppy named Tina was being shipped by

air freight to Victim-2 in lowa with an expected arrival date of March 9, 2020.

       26. As discussed above, pursuant to a search warrant, Google provided records
associated with the Google Voice number (434) 214-8514. Among the inbound and outbound text

messages for Google Voice phone number (434) 214-8514 were over I 00 text messages that were




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   Case 2:20-mj-01365-MPK .SEALED* Document                4 Filed 06130120 Page 11 of 25


exchanged with Victim-2's phone number between March 9,2020, and March 15, 2020, that

fraudulently induced Victim-2 to lose $1,840.

       27.     Also, as discussed above, the Google subscriber records for email account

joebahTT@gmail.com listed a recovery email of fodjebobgal @gmail.com. According to Coogle

records, the fodjebobgal @gmail.com email account vr'as linked by shared cookie to

lovelyteacupchihuahual @gmail.com. Based on my training and experience, your Affiant knows

that a cookie is data issued by a website and then stored on a user's computer that is recognized

by the issuer (e.g., Google) when a computer visits that particular website or logs into an account

associated with the issuer. Through the use of cookies, Google can identify various Google

accounts that have been accessed by the same electronic device(s). Oftentimes, shared cookies

amongst email accounts are evidence that the same person or organization controls the email

accounts. Because fodjebobgal @gmail.com and lovelyeacupchihuahua         I @gmail.com are linked


by a shared cookie, the two email accounts were accessed by the same electronic device.- The

shared cookies link and the recover email link among the fodjebobgal @gmail.com,

joebahTT@gmail.com, and lovelyeacupchihuahual@gmail.com            accounts establishes probable

cause that these email accounts are controlled by the same individual, that is, FODJE BOBGA.

       28.     Moreover, outbound text messages from the Google Voice number (434) 214-8514

directed two other puppy scam victims to make PayPal payments to "Desmond Fodje" at

lovelyteacupchihuahual @gmail.com.

D.     Victim-3

       29.    On April 1,2020, your Affiant interviewed Victim-3, a resident of Marion Center,

Pennsylvania, which is located in the Westem District of Pennsylvania.

       30.     In March 2019, Victim-3 searched the Intemet for a tea cup Chihuahua in hope of



                                                il
  Case 2:20-mj-01"365-MPK *SEALED* Document                 4 Filed 06130120 Page 72 oI 25


finding a pet to purchase. Victim-3 located a puppy on a web site and submitted a form requesting

additional information. Victim-3 was contacted by email and was provided a phone number for

contact. She agreed to purchase a tea cup Chihuahua for $600. Based on the instructions that she

was provided, on March 29,2019, Victim-3 sent, from the Indiana, Pennsylvania, a wire transfer

through MoneyGram in the amount of $600 to an individual named John Jefferson with a

destination of Maryland.

       31. After making this payment, Victim-3 was contacted by email. This email claimed
to be involved in the shipment ofthe Chihuahua and claimed that an additional $800 payment was

necessary for the shipping ofher puppy. Victim-3 was suspicious ofthis email and refused to send

additional money. Victim-3 did not receive any refund for fees paid, and no dog was delivered.

       32. As part ofthis investigation, law enforcement obtained, by search warrant, Google
records associated with the Google Voice telephone number (434) 298-4502 and the email account

unitedpetsafe2009@gmai l.com.

       33. Google Voice records for (434) 298-4502 show three calls with Victim-3's
telephone number on March 29, 2019. According to the Google records for the

unitedpetsafe2009@gmail.com email account, this account was used to communicate with Victim-

3 conceming the false transport ofa tea cup Chihuahua puppy. Specifically, there was a March

29,2019 email from unitedpetsafe2009@gmail.com to Victim-3 with the subject line "* URGENT

CRATE AND VACCINE NEEDED FOR YOUR FEMALE TEACUP CHIHUAHUA PUPPY

SNOWWHITE*." The message contained a headerofUnited Petsafe Shippers. The body ofthe

email, addressed to Victim-3, claimed that an additional $850 refundable fee would be needed for

an AC ventilated crate and vaccine service for the puppy in order to facilitate the air transport. The

fees would supposedly be refunded upon pickup of the puppy at the airport. Attachments to the




                                                  t2
   Case 2:20-mj-01365-MPK *SEALED* Document                4 Filed 06/30/20 Page 13 of 25


email included pictures ofpet transport crates. The email was signed "Manager United Petsafe

Richard LifIIon TEL: (361) 441-0347;'

       34. Also attached to the email from unitedpetsafe21l9@gmail.com to Victim-3 was a
document entitled, "Refundable Crate and Vaccine Guarantee Document." The document

purported to have been issued by the "Supreme Court ofthe United States of America" and bore

the seal of the Court, along with the signature ol"William K. Suter," as Clerk of the Court. Dated

March 29,2019, the document claimed that "with the pyramid insurance in affiliation with

supreme court of the United States of America (USA) and the (USDA) ensures the refunds of

850.00USD to [name of Victim-3] and safe delivery of her female teacup Chihuahua puppy in

question at her home address."

       35.     From my review of information on the official website ofthe Supreme Court, your

Affiant knows that William K. Suter was the l9th Clerk of the Court and that he retired in 2013.

The Clerk ofthe Supreme Court has since been Scott S. Harris. Therefore, the document bears a

forged or counterleit seal ofthe Supreme Court and a forged or counterfeit signature (i.e., a means

of identification) of the Clerk of the Court. Additionally, the document was forged and
counterfeited for the purpose offalsely authenticating the document and the demand for $850.00.

       36. Also located in the mailbox of unitedpetsafe20O9@gmail.com was an unsent draft
email that was dated March 17, 2020. This draft email contained the name, address, phone, and

email address of Victim-l as well as the name (i.e., "Hector Cantu"), address, phone number, and

email address ofthe purported seller ofthe puppy to Victim-1.

       37.     Google subscriber records for email account unitedpetsafe2OO9@gmail.com list a

recovery email of fodjebobgal @gmail.com. Thus, fodjebobga I @gmail.com is the recovery email

for both unitedpetsafe2009@gmail.com and joebahTT@gmail.com. Again, based on my training



                                                13
  Case 2:20-mj-01365-MPK *SEALED* Document                4 Filed 06130120 Page L4 oI 25


and experience, your Affiant knows that a recovery email is a method by which an account user

can be reached to, among other things, recover access to an account when the user forgets the

account password. Based on my training and experience, your Affiant knows that an account and

its recovery email are likely controlled by the same person and/or organization. In this case, that

individual is FODJE BOBGA.

       38.     Additional evidence demonstrates that the unitedpetsafe2009@gmail.com email

address is used by FODJE BOBGA. A message dated approximately October 2, 2019, was sent

from unitedpetsafe2009@gmait.com to fodjebobgal @gmail.com and contained a pdf titled,

"confirmation FODJE BOBGA DESMOND.pdf." The document was a confirmation letter, dated

September 16,2019, from Babeq-Bolyai University in Romania, for FODJE BOBGA to attend

Babeq-Bolyai University.

       39.     Furthermore, IP addresses associated with fodjebobga I @gmail.com,

joebahTT @gmail.com, and unitedpetsafe2009@gmail.com are consistent with FODJE BOBGA's

Cameroonian origin and current stay in Romania. For example, on or about April 8,2020,

fodjebobgal @gmail.com and unitedpetsafe20O9@gmail.com were accessed, within six seconds

ofeach other, from the same IP address, which based on an IP address lookup is assigned to Babeq-

Bolyai University. On or about February 14, 2020, fodjebobgal@gmail.com,
joebahTT@gmaiL com, and unitedpetsafe2009@gmail.com were all accessed, within a ten-second

period, from the same IP address, which based on an IP address lookup is assigned to a Romanian

telecommunications provider. Similarly, on or about January 10, 2020, all three email accounts

were accessed, within a 38-second period, from the same IP address, which based on an lP address

lookup is assigned to a Romanian telecommunications provider. And on or about October 12,

20'19, all three email accounts were accessed at the same time from the same IP address, which




                                                t4
  Case 2:20-mj-01365-MPK .SEALED* Document                 4 Filed 06130120 Page 15 of 25


based on an IP address lookup is assigned to a Cameroonian telecommunications provider.

E.     Victim-4

        40. The telephone number (361) 441-0347, which was in the signature block of the
fraudulent email sent from unitedpetsafe2009@gmail.com to Victim-3 on March 29,2019, as

discussed above, appears to be controlled by a co-conspirator of FODJE BOBGA. As described

below, FODJE BOBGA and the co-conspiratorjoined together to defraud another victim referred

to below as "Victim-4."

       41. On June 5,2020, your Affiant interviewed Victim-4, a resident of Dallas, Texas.
       42.     In February 2020, Victim-4 and his girlfriend were looking to purchase a dog. The

girlfriend located a website and completed a form to get more information. Victim-4 and his

girlfriend had contact with telephone number (434) 214-8514, which was the individual that was

allegedly selling the dog. The pair agreed upon a dog named Snow White. Victim-4

communicated with (434) 214-8514 to complete the sale transaction and used PayPal to send

approximately $950.

       43. The seller claimed to use a service named Pets Fly America for shipment and
provided a web site and tracking number. Thereafter, Victim-4 was contacted by a second number,

(361) 441-0347, alleged to be the shipper of the dog. This alleged shipper claimed that issues

arose in the shipment of the dog and requesting an additional $850 was needed for a health

certificate. Victim-4 paid the amount via Zelle to a person with the initials R.P. Thereafter, this

alleged shipper informed Victim-4 that the payment did not go through due to the wrong name

being listed. Victim-4 confirmed with his bank that the payment was successfi.rl, but the alleged

shipper insisted the payment needed to be resent with the proper name. In an effort to resolve any

issues conceming the sale and transport ofthe dog, Victim-4 started a group text to the two phone




                                                l5
  Case 2:20-mj-01365-MPK *SEALED" Document                4 Filed 06130120 Page 16 of 25


numbers that he communicated with conceming the dog, which were the phone numbers (434)

214-8514 and(361) 441-0347. Victim-4 refused to resend the $850 payment. Ultimately, no dog

was delivered and no refund was received.

       44. As discussed above, pursuant to a search warrant, Google provided records for
Google Voice number (434) 214-8514. Among the inbound and outbound text messages for

Google Voice phone number (434) 214-8514 were over 100 text messages that were exchanged

with Victim-4's phone number between February 26, 2020, and February 28, 2020, that

fraudulently induced Victim-4 to lose $1,500.

       45. Also among the text messages for Google Voice phone number (434) 214-8514
was a group conversation on February 28,2020, with Victim-4's phone number and (361) 441-

0347, wherein Victim-4 inquired about the excuses for non-delivery of the puppy. FODJE

BOBGA, through (434) 214-8514, falsely claimed delay due Victim-4's bank, writing, "i have

been totally confused stressed up. being accused for something i do not know." The response from

(361) 441-0347 to Victim-4 was, "Can you be patient so we get this sorted out?"

       46. Separately, call detail records for Google Voice phone number (434) 214-8514
show five calls from (361) 441-0347. One call, on March 14,2020,lasted 33 seconds. Four calls

in April 2020 were missed. These circumstances indicate that (361) 441-0347 was controlled by

a subject other than FODJE BOBGA, as part ofand in furtherance oftheirjoint puppy scam.

F.     Victim-S

       47.     On May 28, 2020 and June 9,2020, your Affiant interviewed Victim-5, a resident

of Cheswick, Pennsylvania, which is located in the Westem District of Pennsylvania.

       48.     In April 2019, Victim-s searched online to purchase a chihuahua and located a web

site offering a dog named Bentley for sale. Victim-S sent a request for more information via email




                                                t6
  Case 2:20-mj-01365-MPK .SEALED. Document                4 Filed 06/30/20 Page 17 of 25


and provided her contact phone number. Victim-s was contacted by telephone number (434) 298-

4502 and an agreement was made to purchase Bentley for $600. Based on the alleged seller's

instructions, on approximately April 24, 2019, Victim-5 sent $600 via MoneyGram from a

Walmart in Frazer Township, Pennsylvania to a person with the initial F.R. in the Commonwealth

of Virginia. Upon being informed by the seller that there was a problem with the payment, Victim-

5 cancelled the original payment. On approximately Aprll24,20l9, Victim-5 sent a new payment

of $600 via MoneyGram from a Walmart in Frazer Township, Pennsylvania to a person with the

initials W.M. in Virginia.

       49. Thereafter, Victim-S was contacted by the alleged shipper through text and voice
call from telephone number (361) 441-0347. The alleged shipper claimed that transportation

issues arose and indicated that a payment of $900 was needed to provide a special cage for the dog


to breathe in cargo transport. Pursuant to the alleged shipper's instruction, on April 27,2019,

Victim-5 sent $900 via MoneyGram from a Walmart in Frazer Township, Pennsylvania to another

individual in Pennsylvania. Based on an unknown issue reported by the alleged shipper, the

payment had to be resent. OnAprt27,2019, Victim-S sent $900 via MoneyGram from a Walmart

in Frazer Township, Pennsylvania to an individual with the initials E.B. in the State of Florida.

Subsequently, Victim-5 received a text from an unknown number indicating that a USDA permit

was needed for the chihuahua puppy at a cost of$650-$2,200. Victim-5 refused to provide any

additional payments and confronted the alleged shipper by phone. Nevertheless, no dog was

delivered and no refund was provided.

       50. As discussed above, pursuant to a search warrant, Google provided records for
Google Voice number (434) 298-4502. Among the nearly 20,000 inbound and outbound test

messages for (434) 298-4502 were over 100 messages exchanged with victim-5's phone number




                                                t1
  Case 2:20-mj-01365-MPK *SEALED* Document               4 Filed OGl3Olzo Page 18 of 25


between April 21,2019, and April 27,2019, that induced Victim-5 to lose $1,500.

G.     Victim-6

       51. On May 29, 2020, your Affiant interviewed Victim-6, a resident of Pittsburgh,
Pennsylvania, which is located in the Western District of Pennsylvania.

       52. Victim-6 was searching on-line to purchase a puppy in early January 2020 and
located a website that advertised multiple available dogs for sale. Victim-6 requested more

information from the website concerning a puppy. Victim-6 was contacted by the alleged seller

and had contact via telephone and text. Victim-6 became suspicious of the alleged seller based

upon the communications and did not send any payments.

       53. As discussed above, pursuant to a search warrant, Google provided records for
Google Voice number (434) 214-8514. Among the inbound and outbound text messages for

Google Voice phone number (434) Zl4-8514 were 55 text messages that were exchanged with

Victim-6's phone number between January 23,2020, and January 24,2020, that attempted to

induce Victim-6 to pay for a "puppy."

                                        CONCLUSION

       54. Based on the above information, your Affiant submits that probable cause exists
that DESMOND FODJE BOBGA has violated Title 18, United States Code, Sections 1349 (Fraud

Conspiracy), 1343 (Wire Fraud), 505 (Forging Seal ofCourt), 1028A (Aggravated Identity Theft).




                                               l8
   Case 2:20-mj-01365-MPK *SEALED* Document                   4 Filed OGl3OlzO Page 19 of 25


          The above information is true and correct to the best ofmy knowledge, information, and
belief.


                                                      Respectful ly subm itted,

                                                  /s/ Joseph J. Ondercin
                                                  Joseph J. Ondercin
                                                   Special Agent,
                                                   Federal Bureau of Investigation

Subscribed and swom to before me
this 30th day ofJune,2020


MAUREEN P. KELLY
United States Magistrate Judge




                                                 t9
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                                     AVAILABLE PUPPIES
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                            => Health Certlllcate



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                                                                                                          Name. . . Nora
                                                            /                                             Current Status: Avallable
                                                                                                          Gender: Female
                                                                                                          Age: 10 Weeks

                                                       d                                                  Prlce : 1450
                                                                                                          All Breed Reglstratlon papers,FULL
                                                                                                          Reglstratlon, Pedlgree, Health record, 1 year
                                                                                                          health guarantee, Health certlflcate, puppy
                                                                                                          travellng crate and play to)6.Current on
                                                                                                          shots/vacclnes and dewormlng.
                                                      \.\
                                                  a                         -r'




                                                                                                          Name. Teeny Llly
                                                                                                          Current Status: Avallable
                                                                                                          Gender: Female
                                                                                                          Age: 9 Weeks
                                                                                                          Prlce : 1450
                                                                                                          All Breed Reglstratlon papers,FULL
                                                                                                          Reglstratlon, Pedlgree, Health record, I year
                                                                                                          health guarantee, Health certlflcate, puppy




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                                                                                                          shots/vacclnes and de$rormlng.



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                                                      LED* Document 4 Filed OGl3Ol20 Page 2L ot 25

                                  r-! I                Name. . . Nora
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                                                  I    Current Status: Available
                                                       Gender: Female
                                                       Age: I 0 Weeks
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                                          J            Prlce : $45o
                                                       All Breed Reglstration papers,FULL
                                                       Reglstratlon, Pedlgree, Health record, 1 year
                            Nr                         health guarantee, Health certlflcate, puppy
                                                       traveling crate and play toys.Current on
                                                       shotslvacci nes and dewormlng.
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                                                       Name. Teeny Llly
                                                       Current Status: Available
                                                       Gender: Female
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                                 .r                    A8e: 9 Weeks
                                                       Prlce : $450
                                                       All greed Reglstration papers,FULL
                                                       Re8lstratlon, PedlSree, Health record, 1 year
                                                       health guarantee, Health certificate, puppy
                                 -:                    traveling crate and play toys(urrent on
                            I                          shots/vacclnes and daivormlng.
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            Case 2:20-mj-01365-MPK *SEALED* Document   4 Filed 06130120 Page 22 ot 25

                                             Name: Snow Whlte
                                             current Status: Available
    /
                      I                      Gender: Female
                          D                  Age: 9 weeks

             I ll t           F!             Prlce : $450
                                             All Breed Reglstratlon papers,FuLL
                                             Reglstratlon, Pedlgree, Health record, I year
                                             health guarantee, Health certlflcatE puppy
                                             travellng crate and play toys.Current on
                                             shots/vaccines and dewormhg,
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                                      1
                              .rI


                                             Name Bentley
                                             Current Status: Available
                                             Gender: Male
        /                                    Age: 9 Weeks


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            a?
                                             Prlce : $450
                                             All Breed Retlstration papers,FULL
                                             Registration, PediBree, Health record, 1 year
                                             health guarantee, Health certlficate, puppy
                      L.rr                   traveling crate and play toys.Current on
                                             shots/vaccines and deworming,
                 )
                      Case 2:20-mi-01365-MPK *SEALED* Document 4 Filed 06130120 Page 23 of 25



                      \                                                      Name ; Bentley
             \:           \
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                                                                             Current Status: Available
                                                                             Gender: Male
                                                                             Age: 9 Weeks
                              t                                              All Breed Registration papers,FULL
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                                          a                                  Registration. Pedigree, Health record, 1 year
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                                                                             shotYvaccines and deworming.
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                                      \                                      Gender: Mele
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         \                            a .-i L                                A8e: 10 Weeks
                                                                             Prlce : 3450

                                                            \                All Breed ReBlstratlon papers, FULL
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                                      I                                      health guarantee, Health certlflcate, puppy
                                                                             travellng crate and play toys,Current on

                              Y L                 I



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                          I                                                  shots/vacclnes and derrvormlng.

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                                                                \
                      Case 2:20-mj-01365-MPK *SEALED* Document    4 Filed OOl3Ol2O Page 24 of 25

                 .)5-                          :r.'
                *
                                                      Name: Panda
                                                      Current Statu5; Avallable
                                                      Gender: Male


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                                   !
                                       a
                                                      Age: 8 Weeks
                                                      Price : 3450
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                        -                             Retistration, Pedigree, Health record, 1 year
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                                                      traveling crate and play toys.Current on
                                                      shots/vacclne5 and deworming.



        7



                                                      Name : Tommy
                                       7              current status: Avallable
                                                      Gender: Male
7                 \/                                  Age: l0 Weeks
                                                      Prlce : $450
                            l*- -          t
                                       F,             All Breed Reglstration papers,FULL
                                                      Registratlon, Pedl8ree, Health record, I year
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                                                                Conl6ot Ur
           Case 2:20-mj-01365-MPK *SEALED* Document                4 Filed 06/30/20 Page 25 of 25

Woo Chihuahua PuPPY              l{dna   Aboul   Avallable   fuppe5 PrvaryPolky lc5E noald        Conla(t Ut



                                                             Age: 9 Weeks
                                                             Prlce : 1450
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                                                             Reglstratlon, Pedlgree, Health record, I year
                                                             health Euarantee, Health (erttflcate, puppy
                                                             travellng crate and play toys.Current on
                                                             shots/vac(lnes and dewormhg.

                                E                                      C,olrtdot U6




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                                                         Name: Dan and Melody
                                                         sratus: Avallable




       a   f,        II
                     rD .o     rffi                      Gender: Female and Female
                                                         Age: 9 Weeks
                                                         Prlce : t45o
                                                         All Breed ReSlstration papers,FULL
                                                         Retlstratlon, Pedltree, Health record, 1 year
                 ,
                                                         health Suarantee, Health certlflcate. puppy
       AEb                                               travelint crate and play to)6.Current on
                                                         shots/vacclnes and dewormlng.




     (o zozo Woo Chihuahua PUPPy                                                                t,


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