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		 IN THE UNITED STATES DISTRICT COURT FOR THE

			EASTERN DISTRICT OF VIRGINIA

                           Alexandria Division



UNITED STATES OF AMERICA                )
                                        )
	  v.                            )       Criminal No.
                                        )
                                        )       Counts 1-3: Computer
Intrusion
ERIC BURNS                              )       (18 U.S.C. $ 1030(a)(5)
     also known as "Zyklon"             )
                                        )
	  Defendant.                    )


				INDICTMENT

			May 1999 Term - At Alexandria, Virginia

				COUNT 1

	THE GRAND JURY CHARGES THAT:

	From on or about August 25, 1998, through on or about
January 22, 1998, in the Eastern District of Virginia and
elsewhere, ERIC BRUNS, also known as "Zyklon," defendant herein,
knowingly and intentionally cuased transmissions from a computer 
in Shoreline, Washington, of progress, information, codes, and 
commands, and as a result of such conduct, intentionally caused
damage without authorization to a computer of Electric Press,
Kerndon, Virginia, which was a protected computer used by and for
the United States Information Agency, and agency of the United 
States Government, and the conduct affected the use of the 
computer by and for the government and caused loss aggregating at
least $5,000 to at least one individual between August 25, 1998
and March 1, 1999.

(In violation of Title 18, United States Code, Section 
1030(a)(5)(A).)


				COUNT 2

	THE GRAND JURY CHARGES THAT:

	From on or about December 28, 1998, through on or about 
December 31, 1998, in the Eastern District of Virginia and
elsewhere, ERIC BURNS, also know as "Zyklon," the defendant
herein, knowingly and intentionally caused transmissions from a 
computer in Shoreline, Washington, of programs, information,
codes, and commands, and as a result of such conduct,
intentionally caused damage without authorization to a computer
of Computer Tech Services, doing business as LaserNet, in 
Fairfax, Virginia, which was a protected computer used in interstate
commerce and communication, and caused loss
aggragating at least $5,000 to at least one individual between 
December 28, 1998, and March 1, 1999.

(In violation of Title 18, United States Code, Section 
1030(a)(5)(A).)


				COUNT 3

	THE GRAND JURY CHARGES THAT:

	From on or about December 28, 1998, through on or about
January 11, 1999, in the Eastern District of Virginia and
elsewhere, ERIC BURNS, also known as "Zyklon," defendant herein,
knowingly and intentionally caused the transmission from a 
computer in Shoreline, Washington, of programs, information,
codes, and commands, and as a result of such conduct, 
intentionally caused damage without authorization to computers
operated by Issue Dynamics, Inc. in Alexandria, Virginia, and 
Washington, D.C., which were protected computers used in 
interstate commerce and communications, and caused loss 
aggragating at least $5,000 to at least one individual between
December 28, 1998, and March 1, 1999.

(In violation of Title 18, United States Code, Section 
1030(a)(5)(A).)

				A TRUE BILL:

				__________________________
				FOREPERSON
				UNITED STATES GRAND JURY

(signed)
______________________
Helen F. Fahey
United States Attorney

(signed)
______________________
Justin W. Williams
Assistant United States Attorney
Chief, Criminal Division

(signed)
______________________
Jack Henly
Assistant United States Attorney



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