Case 2:19-cr-00366-JVS Document 1 Filed 05/23/19 Page 1 of 10 Page ID #:1

ao9~ ~Re~. iiiaa~ CRIMINAL COMPLAINT ~ R G ~~ I N L

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

DOCKET NO
UNITED STATES OF AMERICA
v.
MAGISTRATE'S CASE NO.
TZU YANG LIN a1k/a ISAAC LIN ~ ~'~'

Complaint for violation of Title 21, United States Code, Section 841(a)(1),(b)(1)(A)(viii)

NAME OF MAGISTRATE JUDGE LOCATION

UNITED STATES
HONORABLE ROZELLA A. OLIVER MAGISTRATE JUDGE Industry, California

DATE OF OFFENSE PLACE OF OFFENSE ADDRESS OF ACCUSED (IF KNO N) FILED

CLERK, U.S. DISTRICT
COURT
May 20, 2019 Los Angeles County

COMPLAINANT'S STATEMENT OF FACTS CONSTITUTING THE OFFENSE OR VIOLATION:

[21 U.S.C. § g41~a~~1~, ~b~~1~~A~~V111~] ~YNTR,g

LDISTRICTOFCALIFO~NiA
DEF'U71'
On or about May 20, 2019, in Los Angeles County, California, within the Central District of California,
defendant TZU YANG LIN a/k/a ISAAC LIN knowingly distributed at least 500 grams of a mixture or
substance c$~ltait~ing a detectable amount of methamphetamine, in violation of Title 21, United States Code,
~ction 840(1.`);(b)(1)(A)(viii)

`~ -`' ,

N c:., .,c,~`
J ~ :~-~
~1C a:- ~
cap :~::r
;-~~ j-
N

BASIS OF COMPLAINANT'S CHARGE AGAINST THE ACCUSED:

(See attached affidavit which is incorporated as part of this Complaint)

MATERIAL WITNESSES IN RELATION TO THIS CHARGE: N~A

SIGNATi.JRE OF COMPLAINANT
Being duly sworn, I declare that the
foregoing is true and correct to the PAUL W.COX
best of my knowledge. oFFicinr. TITLE
Special Agent —FDA-OCI
Sworn to before me and subscribed in my presence,

SIGNATURE OF MAGISTRATE JUDGE~'> DATE

1 ~ ~ May 23, 2019

~~~ See Feral Rules of Criminal Procedure 3 and 54
AUSA Michael G. Freedman X0631 ~~C:Detention
 Case 2:19-cr-00366-JVS Document 1 Filed 05/23/19 Page 2 of 10 Page ID #:2

T TTTTT[fT Rf

I, Paul Cox, being duly sworn, declare and state as

follows:

I. PURPOSE OF AFFIDAVIT

1. This affidavit is made in support of a criminal

complaint against and arrest warrant for TZU YANG LIN a/k/a

ISAAC LIN, for a violation of Title 21, United States Code,

Section 841(a)(1), (b)(1)(A)(viii), distribution of in excess of

500 grams of a mixture or substance containing a detectable

amount of methamphetamine.

II. BACKGROUND FOR SPECIAL AGENT COX

2. I am a Special Agent for the Food and Drug

Administration-Office of Criminal Investigations (~~FDA-OCI") I

am currently assigned to the Kansas City Field Office, and am

the Seized Computer Evidence Recovery Specialist/Computer

Forensics Agent for the Kansas City Region. My current duties

include investigating violations of the Federal Food Drug and

Cosmetic Act and other violations of the United States Criminal

Code. I have been employed as a Special Agent since November

2012.

3. Prior to my current position with FDA-OCI, I was

employed as a Special Agent with the Department of Health and

Human Service (~~HHS") Office of Inspector General Computer

Crimes Unit, stationed at the Centers for Disease Control and

Prevention and the HHS Computer Security Incident Response

Center, and prior to that I was a Special Agent with the

 Case 2:19-cr-00366-JVS Document 1 Filed 05/23/19 Page 3 of 10 Page ID #:3

National Aeronautics and Space Administration-Office of

Inspector General (~~NASA-OIG") Computer Crimes Division,

stationed at the Jet Propulsion Laboratory.

4. I am a graduate of the following training programs:

Criminal Investigator Training Program and the Seized Computer

Evidence Recovery Specialist Program at the Federal Law

Enforcement Training Center (2013), Inspector General Criminal

Investigator Academy (2014), HHS Special Agent Basic Training

Program (2016), and the FDA-OCI Special Agent Training Program

(2018).

5. During my career, I have received specialized training

in the investigation of computer crimes, combating the

distribution of child pornography, the performance of digital

forensics, and investigating the sale of counterfeit,

adulterated, and misbranded drugs. Additionally, I have

presented training to other federal law enforcement officers in

the United States on the topic of cyber investigations and have

presented training on the investigation of the online sale of

counterfeit drugs to international law enforcement officials at

the Interpol Global Complex for Innovation in Singapore.

Through the course of my duties, I have conducted numerous

investigations into the distribution of counterfeit, misbranded,

and adulterated drugs and controlled substances via the dark web

and United States Postal Service, and personally executed

approximately 30 undercover purchases of drugs via the dark web

in exchange for cryptocurrency. Through the course of my duties

 Case 2:19-cr-00366-JVS Document 1 Filed 05/23/19 Page 4 of 10 Page ID #:4

I have participated in the execution of numerous search

warrants.

6. The facts set forth in this affidavit are based upon

m y personal observations, my training and experience, and

information obtained from various law enforcement personnel

(collectively referred to as "Agents") and witnesses. This

affidavit is intended to show merely that there is sufficient

probable cause for the requested warrant and does not purport to

set forth all of my knowledge of or investigation into this

matter. Unless specifically indicated otherwise, all

conversations and statements described in this affidavit are

related in substance and in part only.

III. SLJNIl~lARY OF PROBABLE CAUSE

7. The FDA-OCI is investigating the distribution of

adulterated and counterfeit amphetamine-based prescription drugs

on on a Darknetl Marketplace known as the Dream Market.

8. Beginning in or about April of 2018 FDA-OCI, and other

investigating agencies, began conducting undercover purchases of

tablets of purported Adderall from a darknet vendor, (referred

to in this affidavit as ~~VENDOR-1"), on various darknet

marketplaces. Laboratory analysis of the tablets delivered to

the addresses provided at the time of the undercover purchases

show that the purported Adderall were in fact counterfeit, and

1 The term Darknet Marketplace refers to commercial websites

that operate on darknets like Tor. Tor and other darknets are
networks of computers that utilize some of the same architecture
of the Internet, but which provide greater anonymity and the
obfuscation of user identities. Because of this anonymity,
Darknet Marketplaces are commonly used to facilitate illegal
transactions involving, among other things, drugs.
 Case 2:19-cr-00366-JVS Document 1 Filed 05/23/19 Page 5 of 10 Page ID #:5

contained methamphetamine. Through the course of the

investigation various postage, email and financial accounts were

identified as being utilized in the furtherance of the

distribution of the methamphetamine and linked to an unnamed co-

conspirator ("CC-1"), including numerous accounts established

using fraudulent identity documents bearing CC-1's likeness and

the name and personally identifiable information of another

individual, believed to be a victim (referred to as "VICTIM-1").

Investigation of online accounts show that CC-1, using his true

name or fraudulently using the VICTIM-1 identity, purchased

various supplies and equipment used for the manufacture of

counterfeit drugs, including counterfeit Adderall containing

methamphetamine. CC-1 further utilized various financial

accounts, in his true name or fraudulently utilizing the VICTIM-

1 identity, to receive large quantities of the same

cryptocurrency (bitcoin) used to purchase methamphetamine from

VENDOR-1. CC-1 utilized these financial accounts to convert

this cryptocurrency into U.S. currency, and then utilize some of

this U.S. currency for the purchase of postage.

9. During surveillance of CC-1, Agents observed CC-1

transferring boxes at numerous times to and from individuals

including Tzu Yang LIN. LIN was subsequently observed

depositing parcels at a USPS facility. A subsequent search of

the parcels deposited into the mail stream by LIN revealed

counterfeit Adderall containing methamphetamine.

 Case 2:19-cr-00366-JVS Document 1 Filed 05/23/19 Page 6 of 10 Page ID #:6

IV. STATEMENT OF PROBABLE CAUSE

10. Based upon my discussions with other law enforcement

officers, my training and experience, and my review of reports,

I know the following facts.

A. Use of Stamps.com to Purchase Postage to Distribute

Methamphetamine

11. From a series of undercover purchases, I have learned

that drugs sold by VENDOR-1 are, in many instances, sent to

buyers through the United States Postal Service (`C USPS").

12. Over the past six months, FDA-OCI, working with the

Drug Enforcement Administration (~~DEA"), the Federal Bureau of

Investigation ("FBI"), the United States Postal Inspection

Service ("USPIS"), and Homeland Security Investigations ("HSI")

has been investigating amphetamine-based prescription drugs

advertised and sold on Darknet Marketplaces, and distributed

using through the LISPS.

13. During the course of this investigation, Agents

operating in an undercover capacity have made purchases of drugs

from an unknown person or persons using the moniker VENDOR-1 on

the Dream Market. VENDOR-1 has made numerous listings for

amphetamine-based prescription drugs available for sale, without

a prescription, in exchange for bitcoin cryptocurrency. A

review of open-source intelligence related to VENDOR-1, reviews

found on the Dream Market vendor page associated with VENDOR-12,

2 From my training and experience, I know that Darknet

Marketplaces, and the Dream Market in particular, resemble other
legitimate e-commerce websites like Amazon or eBay in many
respects. For example, customers who purchase items from
 Case 2:19-cr-00366-JVS Document 1 Filed 05/23/19 Page 7 of 10 Page ID #:7

and discussions with other agents familiar with the

investigation indicate that an individual or individuals

utilizing the VENDOR-1 moniker has been operating on multiple

Darknet Marketplaces3 since at least 2017, is responsible for

more than 28,000 individual sales on Dream Market alone, and is

estimated to have grossed in excess of $8.8 million in sales.

14. On four occasions in April, May, and November 2018,

agents from FDA-OCI made undercover purchases of prescription

amphetamine drugs from VENDOR-1 on the Dream Market in exchange

for Bitcoin cryptocurrency. In each instance, a package was

delivered to the undercover agents at the address provided at

the time of purchase, and the contents of these purchases

appeared consistent with what was advertised for sale on the

Dream Market: amphetamine-based prescription drug tablets,

orange in color, bearing pill markings consistent with

prescription amphetamine-based drugs, specifically Adderall.

All of these drugs were purchased without prescriptions.

Preliminary laboratory testing by the FDA Forensic Chemistry

Center indicates that the drugs received do not contain the

vendors on the Dream Market can leave reviews for their

transactions. These reviews and the good or bad reputation
associated with them are one of the few metrics that allow
potential customer of illicit goods or services to anticipate
the likelihood that the anonymous seller will complete the
transaction.
3 From my training and experience, I know that monikers on
the Dream Market are unique, and thus the sales attributed to
VENDOR-1 on Dream Market are likely to all have involved the
same individual or individuals using that moniker. I also know
that it is common for one seller or seller group to sell on
multiple Darknet Marketplaces using the same moniker in order to
maintain the goodwill and trust associated with their online
vendor identity.
 Case 2:19-cr-00366-JVS Document 1 Filed 05/23/19 Page 8 of 10 Page ID #:8

active pharmaceutical ingredient contained in Adderall, but in

fact contain methamphetamine.

15. A review of the postage found on all three of the

undercover purchases shows that they are pre-printed postage

purchased through Endicia, a subsidiary of Stamps.com.

16. Analysis of the information associated with the

Stamps.com account used to ship the parcels containing

methamphetamine led Agents to identify CC-1 as the true account

holder of the Stamps.com account, who was later observed

conducting an exchange with LIN and transferring parcels.

B. MAY 20, 2019 SURVEILLANCE AND SEIZURE OF PARCELS

17. On May 20, 2019 at approximately 15:27, agents

conducting surveillance of a residence ("RESIDENCE-1") in the

area of Rowland Heights, California observed Tzu Yang LIN

through the open garage door of garage attached to the residence

and place a large plastic tote, dark in color, into the cargo

area of a vehicle.

18. At 15:52, agents observed LIN travel to the area of

the City of Industry Post Office, located at 15421 Gale Ave,

Industry, CA 91715. Agents observed LIN enter the Post Office

Business Mail Entry Unit (BMEU) LIN was observed depositing

numerous USPS Priority Mail envelopes into a USPS-owned bin from

the dark tote.

19. Agents subsequently secured the bin and retrieved

eighty-seven (87) USPS Priority Mail envelopes from the bin.

The parcels were found to bear Stamps.com postage bearing the

same meter number (~~METER-1") known to Agents to be associated

 Case 2:19-cr-00366-JVS Document 1 Filed 05/23/19 Page 9 of 10 Page ID #:9

with VENDOR-1 and all packages contained the same return

address.

20. Stamps.com METER-1 is the same meter number associated

with postage found upon parcels purchased by undercover law

enforcement officers, which was later found to contain

methamphetamine.

21. On May 21, 2019, the Honorable Steve Kim, United

States Magistrate Judge for the Central District of California,

authorized a search warrant for the eighty-seven (87) seized

parcels. A search of the eighty-seven (87) parcels revealed

approximately 1.573 kg of tablets in total, peach in color, oval

in shape, and bearing pill imprint "b 974" on one side and "30"

and a half tablet score on the reverse. These pills are

consistent with the tablets previously purchased by undercover

agents which laboratory testing revealed contained

methamphetamine. A field test of a sample of the tablets found

within these parcels presented a presumptive positive for

methamphetamine.

22. On May 21, 2019, the Honorable Steve Kim, United

States Magistrate Judge for the Central District of California,

authorized a search warrant for RESIDENCE-1.

23. On May 22, 2019, Agents executed the search warrant at

RESIDENCE-1 and encountered LIN, the sole occupant of the house,

in the hallway. During a subsequent search of RESIDENCE-1,

Agents located a large quantity of pills matching the

description of those seized the previous day. Agents know the

weight of the seized pills to be in far in excess of 500 grams.

Case 2:19-cr-00366-JVS Document 1 Filed 05/23/19 Page 10 of 10 Page ID #:10

24. Agents advised LIN of Miranda warnings and LIN agreed

to speak with Agents. LIN advised agents, in substance and in

part, that he was involved with at least one other individual in

a scheme to distribute the pills by mail, and that he had

packaged and dropped the pills observed by Agents on May 20, and

that he had received the pills currently in RESIDENCE-1 from CC-

1.

V. CONCLUSION

25. For all the reasons described above, there is probable

cause to believe that or about May 20, 2019, LIN violated Title

21, United States Code, Section 841(a)(1), (b)(1)(A)(viii),

distribution of in excess of 500 grams of a mixture or substance

containing a detectable amount of methamphetamine.

PAUL W. COX, Special Agent

Food and Drug Administration
Office of Criminal Investigations

Subscribed to and sworn before me

on May 23, 2019.

~~~ ~~
HON RABLE ROZELLA A. OLIVER
UNITED STATES MAGISTRATE JUDGE