UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
GOOGLE LLC,
Plaintiff,
v. Civil Action No. 1:21-cv-10260-DLC
DMITRY STAROVIKOV; ALEXANDER FILIPPOV;
Does 1–15,
Defendants.
Plaintiff Google LLC (“Google”) has sued Defendants Dmitry Starovikov, Alexander Filippov, and Does 1-15 associated with the Internet domains listed in the pleading set forth below. Google alleges that Defendants have deployed the Glupteba malware to form a botnet—a network of internet-connected devices, each of which is infected by the Glupteba malware—to steal personal login information from Google customers; to facilitate the use of unfunded credit cards to purchase ads; to sell disruptive ads to display on infected devices; to sell access to infected devices to relay, or “proxy,” communications; and to hijack computing power of infected devices to generate cryptocurrency. Google alleges that, through these actions, the Defendants have violated federal and state law. Google sought and received a preliminary injunction enjoining the Defendants from these and other activities and directing the registrars associated with Defendants' Internet domains to take all steps necessary to disable access to and operation of Glupteba-affiliated domains. Google intends to seek a permanent injunction and other equitable relief. Full copies of the pleading documents, related filings, and orders from the Court are available below.
NOTICE TO DEFENDANT: READ THESE PAPERS CAREFULLY! You must “appear” in this case or the other side will win automatically. To “appear” you must file with the court a legal document called a “motion” or “answer.” The “motion” or “answer” must be given to the court clerk or administrator within 21 days of the date of first publication specified herein. It must be in proper form and have proof of service on Google's attorney, Laura Harris, King & Spalding LLP, 1185 Ave. of the Americas, 34th Floor, New York, NY 10036. If you have questions, you should consult with your own attorney immediately.
DECLARATIONS AND EXHIBITS TO GOOGLE'S COMPLAINT
APPLICATION FOR EMERGENCY TRO AND PRELIMINARY INJUNCTION
Motion for a Temporary Restraining Order
SERVICE, DEFAULT, AND RELATED FILINGS
Proposed Certificate of Default
Google’s Request for Entry of Default
Declaration of L. Harris ISO Entry of Default
Clerk’s Certificate of Default
Defendants’ Motion to Set Aside Entry of Default
A. Filippov Declaration ISO Motion to Set Aside Entry of Default
D. Starovikov Declaration ISO Motion to Set Aside Entry of Default
Proposed Final Default Judgment and Order for Permanent Injunction