I understand your point but it misstates the issue: > For example, on or about December 26, 2018, SMITH emailed two coconspirators that, “We need to get a TON

I understand your point but it misstates the issue: > For example, on or about December 26, 2018, SMITH emailed two coconspirators that, “We need to get a TON of songs fast to make this work around the anti-fraud policies these guys are all using now. They are referring to anti-fraud policies as a general thing across all streaming platforms, not a specific named filter used by Spotify/Amazon/etc. Since they are referring to the policies by the intent rather than name or generically as ToS, this indicates an awareness that their behavior was ultimately fraudulent. I understand it would be very different if the conspirators said “evade Spotify’s dumb ToS policies” and later Spotify said “actually those aren’t mere ToS, those are anti-fraud policies.” That’s not what happened.