UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK GOOGLE LLC, Plaintiff, v. DOES 1–25, Defendants. Civil Action No.: COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF Case 1:26-cv-04982-VMDocument 1Filed 06/12/26Page 1 of 66
2 Plaintiff Google LLC (“Google”), by and through its attorneys, brings this Complaint against Does 1–25 (the “Defendants”) for injunctive relief and damages. Google alleges as follows: INTRODUCTION 1.Defendantsareagroupofforeign-basedcybercriminalswhohavemade sophisticated fraud as simple as a few clicks of the mouse. They built, maintain, and use a turn- key, online software suite that enables criminals, regardless of technical skill, to publish fraudulent websites designed to rob victims and enrich themselves. With this “phishing-for-dummies” software—called “Outsider”—fraud that previously required technical sophistication is readily accessible. And the threat is only growing with the use of artificial intelligence (“AI”). In late 2025, phishing attacks generated using AI reportedly increased more than fourteenfold and now account for over half of all reported phishing incidents.1Google is suing to disrupt this criminal enterprise and to protect its users and the online ecosystem they use every day. 2.As with prior phishing scams, the fraud typically starts with a text message. But where prior scams lured victims with messages alerting them to missed packages or overdue highway tolls, these latest scams attempt to dupe victims by alerting them to a purported problem with their brokerage account, or insisting they are eligible for rewards through their mobile phone carrier. The text then links to a website that mimics the purported source of the text—for example, the investment manager or phone carrier—and then dupes victims into disclosing personal and financial information. Of course, the website is a fake, and the information goes to the scammers, who exploit it for their own criminal gain. 1EliotBaker&MaximeCartier,PhishingTrendsReport2026,Hoxhunt(2026), https://tinyurl.com/3c485zwv. Case 1:26-cv-04982-VMDocument 1Filed 06/12/26Page 2 of 66
3 3.This type of scam is called a phishing attack. The key to the phishing attacks at issue in this action is Outsider, the powerful phishing software created by Defendants. For a subscription fee as low as $88 a week, the Outsider “phish kit” allows its users to create fraudulent websites, launch phishing campaigns, and steal victims’ credit card numbers, bank account credentials, and personal data. The criminal enterprise in this case (the “Outsider Enterprise” or “Enterprise”) includes the creators and administrators of this kit, as well as the criminals who license and use it to perpetrate these scams. 4.Like other phish kits, Outsider offers more than 290 pre-built templates that mimic the legitimate websites of trusted institutions—from financial services providers that maintain brokerage accounts, to wireless telephone service providers, government agencies, and retailers. It also provides real-time keystroke logging, and even a sleek performance dashboard to track the success of a criminal’s phishing campaign—all from a single interface. The Enterprise also created and maintains an online community of discussion forums where members of the criminal Enterprise can identify other members with necessary skillsets (such as mass-texting or harvesting incoming financial information) and collaborate to execute a particular attack. 5.As a result, a criminal with no programming knowledge can, for example, generate a near-perfect replica of a cellular provider’s website in minutes, coordinate to send “bait” text messages to thousands of targets, and begin harvesting stolen data with little effort. Indeed, the Outsider software has been used to create over a million phishing websites to swindle innocent victims out of millions of dollars. 6.As if Outsider’s plug-and-play simplicity were not alarming enough, the Enterprise has made the tool even more powerful by providing step-by-step instructions on how Outsider can weaponize AI-generated code. Following those instructions, Enterprise members can use AI tools Case 1:26-cv-04982-VMDocument 1Filed 06/12/26Page 3 of 66
