UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION

UNITED STATES OF AMERICA

v.

HARDY LEE BROWNER

Case No. 20 CR 299

Violations: Title 18, United States Code, 

Section 1001(a)(2); and 1591(a)(1), (b)(2) 

and (c).

SUPERSEDING INFORMATION

COUNT ONE

The UNITED STATES ATTORNEY charges:

1. At times material to this information:

a. The Federal Bureau of Investigation was investigating possible 

violations of federal criminal law in connection with defendant HARDY LEE 

BROWNER’s communications with Individual A and defendant’s communications 

related to a foreign terrorist organization.

b. The following matters, among others, were material to that 

investigation:

• The individual or individuals that used the following Twitter accounts: 

@AhkTheBlackArab, @RightlyGuidedTA, @Ahkishaykh, and 

@ChocalateShaykh;

• Whether defendant communicated with Individual A, who used Twitter 

account name @AbuFarriss, which account publicly claimed allegiance to a 

foreign terrorist organization; and

FILED 12/30/2022

THOMAS G. BRUTON CLERK, U.S. DISTRICT COURT

E.C

JUDGE WOOD

MAGISTRATE JUDGE JANTZ

Case: 1:20-cr-00299 Document #: 80 Filed: 12/30/22 Page 1 of 3 PageID #:198
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• Whether defendant communicated with the following Twitter accounts: 

@AbuFarriss or @Dawla_NewsMedia.

2. On or about July 15, 2015, at Chicago, in the Northern District of 

Illinois,

HARDY LEE BROWNER,

defendant herein, did knowingly and willfully make a materially false, fictitious, and 

fraudulent statement and representation. The offense involved international 

terrorism in a matter within the jurisdiction of the Federal Bureau of Investigation, 

an agency within the executive branch of the Government of the United States. 

Specifically, the defendant stated to representatives of the Federal Bureau of 

Investigation that:

a. defendant did not use the following Twitter accounts: 

@AhkTheBlackArab, @RightlyGuidedTA, @Ahkishaykh, and @ChocalateShaykh;

b. defendant did not communicate with Individual A; and

c. defendant did not communicate with the following Twitter 

accounts: @AbuFarriss and @Dawla_NewsMedia.

Whereas, in truth and in fact, as defendant then well knew, these statements 

were false;

In violation of Title 18, United States Code, Section 1001(a)(2).

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COUNT TWO

The UNITED STATES ATTORNEY further charges:

Beginning on or about December 5, 2019, and continuing until on or about 

January 3, 2020, in the Northern District of Illinois, Eastern Division, and elsewhere,

HARDY LEE BROWNER,

defendant herein, in and affecting interstate commerce, knowingly patronized and 

solicited by any means a person, namely Minor A, having had a reasonable 

opportunity to observe Minor A, and knowing and in reckless disregard of the fact 

that Minor A had attained the age of 14 years old but had not attained the age of 18 

years old and would be caused to engage in a commercial sex act;

In violation of Title 18, United States Code, Sections 1591(a)(1), (b)(2) and (c).

Signed by Steven Dollear on behalf of the 

UNITED STATES ATTORNEY

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