Verified Complaint — U.S. v. $205,242.23 in PayPal (W.D. Va.)

Summary

A Verified Complaint for Forfeiture In Rem against funds in PayPal, Inc. accounts, captioned United States of America v. Approximately $205,242.23 in PayPal, Inc. Account, Case 7:20-cv-00321-EKD, in the U.S. District Court for the Western District of Virginia, Roanoke Division, filed June 10, 2020 as Document 1. The United States seeks forfeiture under 18 U.S.C. §§ 981(a)(1)(A) and/or (D) of approximately $205,242.23, $128,868.73, $194,982.40 and $13,923.97 presently located in PayPal accounts. It alleges the funds came from a scheme in which individuals in China purported to sell face masks and N-95 respirators through the websites mygoodmask.com, greatmask.com and safetysmask.com, and purchasers never received any masks. It is signed by Assistant United States Attorney Krista Consiglio Frith and verified by an FBI special agent.

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“Verified Complaint — U.S. v. $205,242.23 in PayPal (W.D. Va.).” Original at www.justice.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-7-20-cv-00321-dkt-1-40b9c62e4b/, SHA-256 49435e3f3c54788150840be2bcc109eed44dd6099e6e08777da0c2ecf372cd44.

Full text

Case 7:20-cv-00321-EKD Document 1 Filed 06/10/20 Page 1 of 8 Pageid#: 1

UNITED STATES DISTRICT COURT
THE WESTERN DISTRICT OF VIRGINIA
ROANOKE DIVISION

UNITED STATES OF AMERICA, )
)
Plaintiff, ) Court No. 7:20CV00321
)
v. )
)
APPROXIMATELY $205,242.23 IN )
PAYPAL, INC. ACCOUNT NO. )
XXXXXXXXXXXXXXX2882, )
APROXIMATELY $128,868.73 IN )
PAYPAL, INC. ACCOUNT NO. )
XXXXXXXXXXXXXXX1839, )
APPROXIMATELY $194,982.40 IN )
PAYPAL INC. ACCOUNT NO. )
XXXXXXXXXXXXXXX2700, AND )
APPROXIMATELY $13,923.97 IN )
PAYPAL INC. ACCOUNT NO. )
XXXXXXXXXXXXXXX57714, )
)
Defendants. )

VERIFIED COMPLAINT FOR FORFEITURE IN REM

Now comes the plaintiff, United States of America, by and through its attorney, Krista

Consiglio Frith, Assistant United States Attorney, and brings this Complaint and alleges as follows

in accordance with Supplemental Rule G(2) of the Federal Rules of Civil Procedure:

NATURE OF THE ACTION

1. This is a civil action in rem brought to forfeit and condemn certain personal property

assets to the use and benefit of the United States, pursuant to 18 U.S.C. §§ 981(a)(1)(A) and/or

(D), for violations of 18 U.S.C. §§ 1956(a)(1)(B)(i) and 1957 and 18 U.S.C. §§ 1341 and 1343.

THE DEFENDANTS IN REM

2. The defendant property consists of the following property:

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Case 7:20-cv-00321-EKD Document 1 Filed 06/10/20 Page 2 of 8 Pageid#: 2

(a) Approximately $205,242.23, presently located in PayPal Inc. Account No.
XXXXXXXXXXXXXXX52882;

(b) Approximately $128,868.73, presently located in PayPal Inc. Account No.
XXXXXXXXXXXXXXX1839.

(d) Approximately $13,923.97, presently located in PayPal Inc. Account No.
XXXXXXXXXXXXXXX7714.

JURISDICTION AND VENUE

3. This Court has jurisdiction over an action commenced by the United States under 28

U.S.C. § 1345, and over an action for forfeiture under 28 U.S.C. § 1355(a).

4. This Court has in rem jurisdiction over the defendant property under 28 U.S.C.

§ 1355(b).

5. Venue is proper in this district pursuant to 28 U.S.C. §1355(b)(1) because acts giving

rise to this forfeiture occurred in this district.

6. Upon the filing of this Complaint, the plaintiff requests that the Court issue a Warrant

of Arrest and Seizure in rem pursuant to Supplemental Rule G(3)(b)(ii), which the plaintiff will

execute upon the property pursuant to 28 U.S.C. § 1355(d) and Supplemental Rule G(3)(c).

BASIS FOR FORFEITURE

7. The defendant property is subject to forfeiture pursuant to 18 U.S.C. § 981(a)(1)(A), as

the property was involved in a transaction or attempted transaction in violation of 18 U.S.C.

§§ 1956(a)(1)(B)(i) and 1957; and/or pursuant to 18 U.S.C. § 981(a)(1)(D), as property that

represents or is traceable to the gross receipts obtained, directly or indirectly, from a violation of

18 U.S.C. §§ 1341 and/or 1343.

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Case 7:20-cv-00321-EKD Document 1 Filed 06/10/20 Page 3 of 8 Pageid#: 3

FACTS

8. The Defendant Property was obtained from a fraudulent scheme, wherein

individuals in China purported to sell face masks and N-95 respirators to individuals in the United

States, including the Western District of Virginia, at inflated prices. The purchasers sent the sellers

money through PayPal, but the purchasers never received any masks.

9. Three websites were set up to sell N-95 respirators and other protective facemasks:

mygoodmask.com, greatmask.com, and safetysmask.com (“Fraudulent Websites”).

10. The Fraudulent Websites were set up in February and March 2020.

11. In February and March 2020, the cases of COVID-19 in the United States began to

rise and demand for N-95 respirators and other protective facemasks increased.

12. The Fraudulent Websites are registered to Fengling Xu, with an address in

Jacksonville, Florida, and the telephone number 626-515-6558.

13. Fengling Xu does not live at the address in Jacksonville, Florida.

14. The address in Jacksonville, Florida, belongs to individuals who have no

association with Fengling Xu or the Fraudulent Websites.

15. The telephone number associated with the Fraudulent Websites’ registration is a

Voice Over Internet Protocol number with no name associated with it.

16. The Fraudulent Websites provided false contact information for the sellers.

17. The Fraudulent Websites contained a “contact us” page listing a Winchester,

Virginia, address and the following telephone number: 540-450-4525.

18. The Winchester, Virginia, address belongs to individuals who have no association

with Fengling Xu or the Fraudulent Websites.

19. Payments for the masks ordered on the Fraudulent Websites went through PayPal.

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20. PayPal Account No. XXXXXXXXXXXXXXX2882 (Account No. 1) was opened

on February 9, 2020, by Yan Fei Wang and was associated with two phone numbers with the

country code for China: +86 18559322586 and +86 17100953855.

21. The Internet Protocol (IP) address used to setup PayPal Account No. 1 resolves to

China.

22. Payments for masks purchased through the Fraudulent Websites went to PayPal

Account No. 1.

23. The PayPal payments to PayPal Account No. 1 appeared on buyers’ credit card

statements as FMONLINESHO.

24. None of the individuals who sent money to PayPal Account No. 1 received the

masks they ordered from the Fraudulent Websites.

25. On April 20, 2020, PayPal closed Account No. 1 and froze the money in the

account.

26. As of June 4, 2020, PayPal Account No. 1 contained $205,242.23 in proceeds

obtained from the purported sale of masks from the Fraudulent Websites.

27. PayPal Account No. XXXXXXXXXXXXXXX1839 (Account No. 2) was opened

on February 2, 2020, by Fui Chi and was associated with two phone numbers with the country

code for China: +86 16525836224 and +86 17100951703.

28. The IP address used to setup PayPal Account No. 2 resolves to China.

29. Payments for masks purchased through the Fraudulent Websites went to PayPal

Account No. 2.

30. The PayPal payments to PayPal Account No. 2 appeared on buyers’ credit card

statements as FMONLINESHO.

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31. None of the individuals who sent money to PayPal Account No. 2 received the

masks they ordered from the Fraudulent Websites.

32. On March 29, 2020, PayPal closed Account No. 2 and froze the money in the

account.

33. As of June 4, 2020, PayPal Account No. 2 contained $128,868.73 in proceeds

obtained from the purported sale of masks from the Fraudulent Websites.

34. PayPal Account No. XXXXXXXXXXXXXXX82700 (Account No. 3) was opened

on January 1, 2020, by Meng Xuan Wang and was associated with two telephone numbers with

the country code for China: +86 18659488635 and +86 13062290174.

35. The IP address used to setup PayPal Account No. 3 resolves to China.

36. Payments from masks purchased through the Fraudulent Websites went to PayPal

Account No. 3.

37. The PayPal payments to PayPal Account No. 3 appeared on buyers’ credit card

statements as BESTONLINES.

38. None of the individuals who sent money to PayPal Account No. 3 received the

masks they ordered from the Fraudulent Websites.

39. On April 22, 2020, PayPal closed Account No. 3 and froze the money in the account.

40. As of June 4, 2020, PayPal Account No. 3 contained $194,982.40 in proceeds

obtained from the purported sale of masks from the Fraudulent Websites.

41. PayPal Account No. XXXXXXXXXXXXXXX7714 (Account No. 4) was opened

on February 10, 2020, by Yin Wen Jun and was associated with two telephone numbers with the

country code for China: +86 17100950088 and +86 17100956858.

42. The IP address used to setup PayPal Account No. 4 resolves to China.

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43. Payments for masks purchased through the Fraudulent Websites went to PayPal

Account No. 4.

44. The PayPal payments to PayPal Account No. 4 appeared on buyers’ credit card

statements as FMBESTONLIN.

45. None of the individuals who sent money to PayPal Account No. 4 received the

masks they ordered from the Fraudulent Websites.

46. On April 21, 2020, PayPal closed Account No. 4 and froze the money in the account.

47. As of June 4, 2020, PayPal Account No. 4 contained $13,923.97 in proceeds

obtained from the purported sale of masks from the Fraudulent Websites.

48. These facts and additional facts supporting this Complaint are stated in the attached

Declaration of Special Agent Theresa C. Hudson, Federal Bureau of Investigation, and are

incorporated by reference herein.

WHEREFORE, the United States of America respectfully requests that the Clerk of Court

issue a Warrant of Arrest in rem pursuant to Supplemental Rule G(3)(b); that due notice be given

to all parties to appear and show cause why the forfeiture should not be decreed; that judgment be

entered declaring the defendant property to be condemned and forfeited to the United States of

America for disposition according to law; and that the United States of America be granted such

other and further relief as this Court may deem just and proper, together with the costs and

disbursements of this action.

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Case 7:20-cv-00321-EKD Document 1 Filed 06/10/20 Page 7 of 8 Pageid#: 7

THOMAS T. CULLEN
United States Attorney

s/Krista Consiglio Frith
Krista Consiglio Frith
Virginia State Bar No. 89088

Michael A. Baudinet
Virginia State Bar No. 83633
Assistant United States Attorneys
310 First Street, S.W., Room 906
Roanoke, VA 24011
Phone: 540-857-2250
Fax: (540)857-2614
krista.frith@usdoj.gov
michael.baudinet@usdoj.gov

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