`
`
`RANDY S. GROSSMAN
`Acting United States Attorney
`MELANIE K. PIERSON
`SABRINA L. FEVE
`Assistant U.S. Attorneys
`California Bar No. 112520/226590
`Office of the U.S. Attorney
`880 Front Street, Room 6293
`San Diego, CA 92101
`Tel: (619) 546-7976
`Fax: (619) 546-0631
`Email:Melanie.Pierson@usdoj.gov/Sabrina.Feve@usdoj.gov
`
`Attorneys for United States of America
`
`
`UNITED STATES DISTRICT COURT
`
`SOUTHERN DISTRICT OF CALIFORNIA
`
`UNITED STATES OF AMERICA,
`Case No. 18-CR-4683-GPC
`
`Plaintiff,
` N F O R M A T I O N
`v.
` (Superseding)
`JACOB BYCHAK (1)
`
`MARK MANOOGIAN (2), and
`18 U.S.C. §1037(a)(5) and (b)(3)
`MOHAMMED ABDUL QAYYUM, (3)
`Electronic Mail Fraud
`
`18 U.S.C. §2 – Aiding and Abetting
`Defendants.
`
`
`The United States Attorney charges that:
`COUNT 1
`
` I
`
`
`On or about between December 2010 and September 2014, within
`the Southern District of California, defendants JACOB BYCHAK and
`MARK MANOOGIAN conspired together and with others to knowingly and
`falsely represent themselves to be the registrant and legitimate
`successor in interest to the registrant of 5 or more Internet
`Protocol addresses, and intentionally initiate the transmission of
`multiple commercial electronic mail messages from such addresses,
`
`
`
`
`
`
`
`18-CR-4683-GPC
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`
`
`
`
`Case 3:18-cr-04683-GPC Document 473 Filed 06/10/22 PageID.7201 Page 2 of 2
`
`
`
`in and affecting interstate commerce, in violation of 18 U.S.C.
`§1037(a)(5) and (b)(3), a misdemeanor.
`
`
`
`COUNT 2
`On or about between December 2010 and September 2014, within
`the Southern District of California, defendant MOHAMMED ABDUL
`QAYYUM did knowingly and falsely represent himself to be the
`registrant and legitimate successor in interest to the registrant
`of 5 or more Internet Protocol addresses, and intentionally
`initiate the transmission of multiple commercial electronic mail
`messages from such addresses, in and affecting interstate
`commerce, in violation of 18 U.S.C. §1037(a)(5) and (b)(3), and 18
`U.S.C. §2, a misdemeanor.
`
`DATED: June 8, 2022 Respectfully submitted,
`
`RANDY S. GROSSMAN
`United States Attorney
`
`
`
`Melanie K. Pierson
`Assistant United States Attorney
`
`/s/Sabrina L. Fève
`Assistant United States Attorney
`
`
`
`
`___________________
`
`
`
`
`_______________________
`
`
`
`
`2
`
`
`
`18-CR-4683-GPC
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`
`

Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ ChargeStill Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.

This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.

One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site