A criminal complaint was unsealed in federal court in Brooklyn charging Donald Allen and Manuel Revolorio with conspiracy to commit wire fraud by seeking more than $4 million from a purported purchaser of personal protective equipment (“PPE”) that the defendants did not own nor otherwise have authorization to sell. According to court filings, as part of their fraudulent scheme, Allen and Revolorio misrepresented the nature of their business experience, their inventory of PPE and their right to resell PPE to purported purchasers of PPE. For example, the defendants created a website for their company, International Commerce and Investment Group (ICIG), falsely representing that since 2014 ICIG had worked closely with global traders, medical institutions and other companies to supply PPE. The defendants also falsely claimed that ICIG had contracts and agreements in place to resell millions of masks, and attempted to pressure a potential purchaser to wire more than $4 million to secure those masks. To reinforce their claim to have large supplies of PPE available for sale, the defendants displayed sealed and shrink-wrapped empty boxes at their office, which they represented were filled with masks. The defendants also displayed to an individual, posing as a representative of an investor, more than one million masks that were owned by an unrelated third party ― unbeknownst to the defendants, the “representative” was actually a federal law enforcement agent.