An alleged cyber attacker from Turkey has been indicted in federal court in Chicago
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA
v.
IZZET MERT OZEK
Case No.
Violations: Title 18, United States
Code, Sections 1030(a)(5)(A),
(c)(4)(A)(i)(I), (c)(4)(A)(i)(VI), (c)(4)(B)
The SPECIAL MAY 2021 GRAND JURY charges:
1. At times material to this indictment:
a. Company A was headquartered in Chicago, Illinois.
b. Company A was an American multinational hospitality company
that managed and franchised luxury and business hotels, resorts, and vacation
properties.
c. Company A offered customers the ability to book hotel rooms at
its hotels through an online booking service at its website. The servers for Company
A’s website and online booking service were located in the Northern District of
Illinois.
d. In August 2017, the servers of Company A were the target of a
distributed denial-of-service (DDoS) attack.
e. As part of the DDoS attack, the attacker directed large amounts
of computer network traffic to Company A’s servers that hosted Company A’s website
and online booking service, causing available resources to be consumed by the attack
and resulting in no or few resources left to accommodate legitimate users.
2
f. The DDoS attack used the WireX botnet, which consisted of
compromised Google Android devices, to direct large amounts of network traffic to
Company A’s website, which included its website and online booking system.
g. In August 2017, during the DDoS attack, some legitimate users
were unable to complete bookings on Company A’s online booking system.
2. In or around August 2017, at Chicago, in the Northern District of Illinois
and elsewhere,
IZZET MERT OZEK,
defendant herein, knowingly caused the transmission of a program, information,
code, and command, and as a result of such conduct, intentionally caused damage
without authorization to a protected computer, belonging to Company A, and the
offense caused loss to 1 or more persons during a one-year period from the defendant’s
course of conduct affecting protected computers aggregating at least $5,000 in value,
and also caused damage affecting 10 or more protected computers during any oneyear period;
In violation of Title 18, United States Code, Sections 1030(a)(5)(A),
(c)(4)(A)(i)(I), (c)(4)(A)(i)(VI), (c)(4)(B), and 2.
3
FORFEITURE ALLEGATION
1. The allegations contained in this Indictment are incorporated by
reference for the purpose of alleging forfeiture pursuant to Title 18, United States
Code, Sections 982(a)(2)(B) and 1030(i).
2. Upon conviction of the computer fraud offense in violation of Title 18,
United States Code, Section 1030, set forth in this Indictment, defendant
IZZET MERT OZEK
shall forfeit to the United States of America:
a. pursuant to Title 18, United States Code, Sections 982(a)(2)(B)
and 1030(i), any property, real or personal, constituting, or derived from, proceeds
obtained directly or indirectly as a result of such offense; and
b. pursuant to Title 18, United States Code, Section 1030(i), any
personal property that was used or intended to be used to commit or to facilitate the
commission of such offense. The property to be forfeited includes, but is not limited
to: A sum of money equal to the proceeds derived from or obtained as a result of such
offense.
3. If any of the property described above, 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
4
e. has been commingled with other property which cannot be
divided without difficulty,
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title 18,
United States Code, Sections 982(b) and 1030(i).
All pursuant to Title 18, United States Code, Sections 982(a)(2)(B), 982(b)
and 1030(i), and Title 21, United States Code, Section 853.
A TRUE BILL:
FOREPERSON
______________________________________
UNITED STATES ATTORNEY
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA
v.
IZZET MERT OZEK
Case No.
Violations: Title 18, United States
Code, Sections 1030(a)(5)(A),
(c)(4)(A)(i)(I), (c)(4)(A)(i)(VI), (c)(4)(B)
The SPECIAL MAY 2021 GRAND JURY charges:
1. At times material to this indictment:
a. Company A was headquartered in Chicago, Illinois.
b. Company A was an American multinational hospitality company
that managed and franchised luxury and business hotels, resorts, and vacation
properties.
c. Company A offered customers the ability to book hotel rooms at
its hotels through an online booking service at its website. The servers for Company
A’s website and online booking service were located in the Northern District of
Illinois.
d. In August 2017, the servers of Company A were the target of a
distributed denial-of-service (DDoS) attack.
e. As part of the DDoS attack, the attacker directed large amounts
of computer network traffic to Company A’s servers that hosted Company A’s website
and online booking service, causing available resources to be consumed by the attack
and resulting in no or few resources left to accommodate legitimate users.
2
f. The DDoS attack used the WireX botnet, which consisted of
compromised Google Android devices, to direct large amounts of network traffic to
Company A’s website, which included its website and online booking system.
g. In August 2017, during the DDoS attack, some legitimate users
were unable to complete bookings on Company A’s online booking system.
2. In or around August 2017, at Chicago, in the Northern District of Illinois
and elsewhere,
IZZET MERT OZEK,
defendant herein, knowingly caused the transmission of a program, information,
code, and command, and as a result of such conduct, intentionally caused damage
without authorization to a protected computer, belonging to Company A, and the
offense caused loss to 1 or more persons during a one-year period from the defendant’s
course of conduct affecting protected computers aggregating at least $5,000 in value,
and also caused damage affecting 10 or more protected computers during any oneyear period;
In violation of Title 18, United States Code, Sections 1030(a)(5)(A),
(c)(4)(A)(i)(I), (c)(4)(A)(i)(VI), (c)(4)(B), and 2.
3
FORFEITURE ALLEGATION
1. The allegations contained in this Indictment are incorporated by
reference for the purpose of alleging forfeiture pursuant to Title 18, United States
Code, Sections 982(a)(2)(B) and 1030(i).
2. Upon conviction of the computer fraud offense in violation of Title 18,
United States Code, Section 1030, set forth in this Indictment, defendant
IZZET MERT OZEK
shall forfeit to the United States of America:
a. pursuant to Title 18, United States Code, Sections 982(a)(2)(B)
and 1030(i), any property, real or personal, constituting, or derived from, proceeds
obtained directly or indirectly as a result of such offense; and
b. pursuant to Title 18, United States Code, Section 1030(i), any
personal property that was used or intended to be used to commit or to facilitate the
commission of such offense. The property to be forfeited includes, but is not limited
to: A sum of money equal to the proceeds derived from or obtained as a result of such
offense.
3. If any of the property described above, 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
4
e. has been commingled with other property which cannot be
divided without difficulty,
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title 18,
United States Code, Sections 982(b) and 1030(i).
All pursuant to Title 18, United States Code, Sections 982(a)(2)(B), 982(b)
and 1030(i), and Title 21, United States Code, Section 853.
A TRUE BILL:
FOREPERSON
______________________________________
UNITED STATES ATTORNEY
