Durham also writes that during Sussmann's trial, the government will establish that among the Internet data Tech Executive-1 and his associates exploited was domain name system (DNS) internet traffic pertaining to "(i) a particular healthcare provider, (ii) Trump Tower, (iii) Donald Trump's Central Park West apartment building, and (iv) the Executive Office of the President of the United States (EOP)."

Durham states that the internet company that Tech Executive-1 worked for "had come to access and maintain dedicated servers" for the Executive Office of the President as "part of a sensitive arrangement whereby it provided DNS resolution services to the EOP."

"Tech Executive-1 and his associates exploited this arrangement by mining the EOP's DNS traffic and other data for the purpose of gathering derogatory information about Donald Trump," Durham states.

The filing also reveals that Sussmann provided "an updated set of allegations" including the Russian bank data, and additional allegations relating to Trump "to a second agency of the U.S. government" in 2017.

Durham says the allegations "relied, in part, on the purported DNS traffic" that Tech Executive-1 and others "had assembled pertaining to Trump Tower, Donald Trump's New York City apartment building, the EOP, and the aforementioned healthcare provider."  

In Sussmann's meeting with the second U.S. government agency, Durham says he "provided data which he claimed reflected purportedly suspicious DNS lookups by these entities of internet protocol (IP) addresses affiliated with a Russian mobile phone provider," and claimed that the lookups "demonstrated Trump and/or his associates were using supposedly rare, Russian-made wireless phones in the vicinity of the White House and other locations."