33 Case 1:18-cr-00457-AMD Document 126 Filed 02/13/20 Page 33 of 56 PageID #: 1381 response to the investigation, HUAWEI and HUAWEI DEVICE USA made efforts to move witnesses with knowledge about HUAWEI’s Iran-based business to the PRC, and beyond the jurisdiction of the U.S. government, and to destroy and conceal evidence in the United States of HUAWEI’s Iran-based business. By impeding the government’s investigation, HUAWEI and HUAWEI DEVICE USA sought to avoid criminal prosecution with respect to HUAWEI’s Iran-based activities, which would subject HUAWEI and its U.S. affiliates and subsidiaries, including HUAWEI DEVICE USA, to the threat of economic harm. COUNT ONE (Racketeering Conspiracy) 88. The allegations contained in paragraphs one through 87 are realleged and incorporated as if fully set forth in this paragraph.
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