United States v. Bayless Cobb, D. Or. No. 3:25-cr-00323, information

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An information, Document 1 in United States v. Bayless Cobb, No. 3:25-cr-00323-IM, in the United States District Court for the District of Oregon, Portland Division, filed August 12, 2025. Count 1, Conspiracy to Commit Wire Fraud under 18 U.S.C. § 1349, alleges that beginning no later than February 2021 and continuing until at least March 2022, the defendant agreed with others to gather fraudulent business information so that the defendant or a co-conspirator could submit fraudulent Paycheck Protection Program (PPP) applications. It alleges that after the PPP loans were funded, co-conspirators paid the defendant a fee for submitting the applications. The information includes a forfeiture allegation, and its signature block shows s/ Meredith D.M. Bateman, Assistant United States Attorney.

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        Case 3:25-cr-00323-IM         Document 1          Filed 08/12/25   Page 1 of 3




                           UNITED STATES DISTRICT COURT

                                  DISTRICT OF OREGON

                                   PORTLAND DIVISION


UNITED STATES OF AMERICA                                   00323-AN
                                                   3:25-cr-___________________

              v.                                   INFORMATION

BAYLESS COBB,                                      18 U.S.C. § 1349

              Defendant.                           Forfeiture Allegation



                     THE UNITED STATES ATTORNEY CHARGES:

                                         COUNT 1
                            (Conspiracy to Commit Wire Fraud)
                                    (18 U.S.C. § 1349)

       1.     Beginning no later than February 2021 and continuing until at least March 2022,

in the District of Oregon and elsewhere, defendant BAYLESS COBB, and others known and

unknown to the United States Attorney, did agree to accomplish a common and unlawful plan to

commit wire fraud. Specifically, defendant agreed with others to gather fraudulent business

information for defendant or a co-conspirator to submit fraudulent Paycheck Protection Program

(“PPP”) applications on behalf of the named applicants.

                                  MANNER AND MEANS

       2.     To carry out their material scheme to defraud, defendant gathered fraudulent

business information from co-conspirators that defendant used or caused to be used to submit


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         Case 3:25-cr-00323-IM          Document 1         Filed 08/12/25        Page 2 of 3




PPP applications on behalf of his co-conspirators. Defendant and the co-conspirators knew the

applications contained fraudulent and material business information and that many of the

business entities did not exist.

        3.      After the PPP loans were funded, defendant’s co-conspirators paid defendant a fee

for submitting the fraudulent applications.

        4.      During the course of the conspiracy, defendant and others used, and caused to be

used, interstate wire communications to submit the fraudulent applications. Specifically, the

fraudulent applications were submitting using servers in Oregon and then routed to servers in

Virginia via wire.

        In violation of Title 18, United States Code, Section 1349.

                                   FORFEITURE ALLEGATION

        Upon conviction of the offense alleged in Count 1 of this Information, defendant

BAYLESS COBB shall forfeit to the United States of America, pursuant to 18 U.S.C. §

981(a)(l)(C) and 28 U.S.C. § 2461(c), any property, real or personal, which constitutes or is

derived from proceeds traceable to the violation.

        If any of the above-described forfeitable property, as a result of any act or omission of the

defendant:

        (a) cannot be located upon the exercise of due diligence;

        (b) has been transferred or sold to, or deposited with, a third party;

        (c) has been placed beyond the jurisdiction of the court;

        (d) has been substantially diminished in value; or

        (e) has been commingled with other property which cannot be divided without difficulty;

///

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        Case 3:25-cr-00323-IM           Document 1       Filed 08/12/25       Page 3 of 3




It is the intent of the United States, pursuant to 21 U.S.C. § 853(p) as incorporated by 28 U.S.C.

§ 2461(c), to seek forfeiture of any other property of said defendant up to the value of the

forfeitable property described above.



Dated: August 12, 2025                        Respectfully submitted,

                                              SCOTT E. BRADFORD
                                              United States Attorney


                                              s/ Meredith D.M. Bateman
                                              MEREDITH D.M. BATEMAN, OSB #192273
                                              Assistant United States Attorney




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