EVIN V. RYAN (CSBN 118321)
Jnited States Attorney
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
JNITED STATES OF AMERICA,
.- -
Plaintiff, j
1
v. 1
A R N CHAVET,
UET - Reckless
Damage to a Protected Corn uter Causing
Defendant. f
Loss Aggregating At Least 5,000
5 SAN FRANCISCO VENUE
1
INDICTMENT
?he Grand Jury charges:
it all times relevant to this Indictment:
I. The AltaVista Company (AltaVista) provided World Wide Web search capability
o users of the Internet. The htantt was a worldwide network of computer systems operated by
a
;ovemmental entities, corporations, universities and other entities. The World Wide Web w s a
hctionality of the Internet that allowed users of the Internet to share infoxmation. Information
I the World Wide W e b was displayed on web sites. Each web site was identified and accessed
n
b means of a unique address known as a Uniform Resource Locator (URL).
y
II . .
M D W N T
U.S.v. CHAVET]
2. In order to provide World Wide Web search capability to its users, AltaVista
maintaided a bank of 32 computers, which it named Trek1 through Trek32, respectively. The
Trek computers w r programmed using source code developed by AltaVista to "scour" the
ee
World Wide Web and to store information on themselves about new or modified URLs.
3. AltaVista assigned usernames and confidential passwords to designated
employees whose jobs required them to access Alta Vista's computen for legitimate eiployment
purposes. Non-employees and former employees of AltaVista were not authorized to access Alta
Vista's computers.
4. The defendant LAURENT CHAVET was employed by AltaVista as a computer
engineer from approximately June 1999 to approximately February 2002.
COUNT ONE: (18 U.S.C. $8 1030(a)(4) & 1030(c)(3)(A) -Unauthorized Access of a
Protected Computer with Intent to D e h u d and Obtaining Something of
Value)
5. The facts alleged in paragraphs 1 through 4 are realleged and incorporated herein
as if set forth in full.
6. On or about March 28,2002, in the Northern District of California and elsewhere,
the defendant
LAURENT CHAVET
did knowingly and with intent to defiaud, access a protected computer belonging to AltaVista, to
wit, the computer known as "repository2," without authorization and by exceeding authorized
access, and by means of such conduct did m e r the intended h u d and obtain something of
value, to wit, source code belonging to AltaVista.
All in violation of Title 18, United States Code, Sections 1030(a)(4) and 1030(c)(3)(A).
//I
I1 1
//I
Ill
Ill
Ill
INDICTMENT
[U.S. v. CHAVET]
COUNT TWQ: (1 8 U.S.C. ยง# 103O(a)(S)(A)(ii), 1030(a)(5)(B)(i) & 1030(c)(4)@)-
Reckless Damage to a Protected Computer Causing Loss Aggregating At
es
L a t $5,000)
7. The facts alleged in paragraphs 1 through 4 are realleged and incorporated herein
B if set forth in full.
8. On or about June 1,2002, in the Northern District of California and elsewhere, the
iefendant
LAURENT CHAVET
lid intentionally access a protected computer without authorization and as a result of such
:onduct recklessly caused damage, in that the defendant intentionally accessed the Trek
:omputers, and, as a result of such conduct, recklessly caused damage to those computers, which
Lamage caused losses aggregating at least $5,000 in value during a one-year period
All in violation of Title 18, United States Code, Sections 1030(a)(S)(A)(ii), 1030(a)(S)(B)(i)
nd 103O(c)(4)(B).
IATED: A TRUE BILL.
XVIN V. RYAN
rnited States Attorney
.OSS W. NADEL
'hief, Criminal Division
IDICTMENT
I.S. v. CHAVET]
ENDANT INFORMATION REL9TIVE TO A CRIMINAL ACTION IN U.S. DISTRICT COURT -
)MPLAINT INFORMATION INDICTMENT
I r Name of District Court, andlor Judge!Magistrate Location --
'FENSE CHARGED
8 U.S.C. 55 1030(a)(4) &
Zomputer
1
A) - Unauthorized Access of a
18 U.S.C. 55 1030(a)(5)(A)(ii),
n SUPERSEDING
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I
1
, -
,
L
NORTHERN DISTRICT W;CACIFORNIA
DEFENDANT- U.S.
n.
u4,df, . *
.
.
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.
&
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h C .a . r
B)(i) & 1030(c)(4)(B) - Reckless
a Protected Computer DISTRICT COURT NUMBER
~d II -- Maximum term of imprisonment
ine, 3 years of supervised release, and
special assessment.
i
?1 f DEFENDANT
J
IS NOT IN CUSTODY
PROCEEDING j been arrested, pending outcome
I Has not
omplaintant Agency, or Person (&Title, if any)
I 1) @ If not detained give date any prior summon
_ BUREAU OF INVESTIGATION 1 was served on above charges
2) Is a Fugitive
In is awaiting trial in another Federal or State
:, give name of court
i 3) / Is on Bail or Release from (show District)
ersonlproceeding is transferred from another
:t per (circle one) FRCrP 20, 21 or 40. Show
:
t IS IN CUSTODY
/ 4) On this charge
ja re~rosecution charges
of
,usly'dismissed which were
ssed on motion of:
I 5)
')
On another conviction
Awaiting trial on other
charges
} Fed'l 17 State
1
I
I
U.S. Att'y -
7 Defense
If answer to (6) is "Yes", show name of institution
irosecution relates to a
ing case involving this same
ldant
proceedings or appearance(s)
MAGISTRATE I 11 Has detainer
been filed?
yes
No
} If "Yes"
give date
CASE NO. filed
e U.S. Magistrate regarding
b
lefendant were recorded under
Office of Person
1 DATE OF
ARREST b
MonthIDayffear
I Information on KEVIN V. RYAN
1 Or... if Arresting Agency & Warrant were not 1
S FORM MonthlDayffear
u.S. Att'y Other U.S. Agency
DATE TRANSFERRED @ I
TO U.S. CUSTODY
'
. /
Asst. U.S. Att'y
assigned) KYLE F. WALDINGER This report amends A 0 257 previously submitted
ADDITIONAL INFORMATION OR COMMENTS \
SS:
] SUMMONS N O PROCESS* WARRANT Bail Amount: $50,000 1
I
If Summons, complete following:
C] Arraignment a Initial Appearance 'Where defendant previously apprehended on complaint, no new summons
or warrant needed, since Magistrate has scheduled arraignment
I
Defendant Address:
Before Judge: .. . -_
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