In or around the latter half of 2016, Defendants and their co-conspirators, through their ORGANIZATION-controlled personas, began to encourage U.S. minority groups not to vote in the 2016 U.S. presidential election or to vote for a third-party U.S. presidential candidate.
a. On or about October 16, 2016, Defendants and their co-conspirators used the ORGANIZATION-controlled Instagram account “Woke Blacks” to post the following message: “[A] particular hype and hatred for Trump is misleading the people and forcing Blacks to vote Killary. We cannot resort to the lesser of two devils. Then we’d surely be better off without voting AT ALL.”
b.On or about November 3, 2016, Defendants and their co-conspirators purchased an advertisement to promote a post on the ORGANIZATION-controlled Instagram account “Blacktivist” that read in part: “Choose peace and vote for Jill Stein. Trust me, it’s not a wasted vote.”