According to the affidavit filed in support of the complaint, Aldawsari has been researching online how to construct an IED using several chemicals as ingredients. He has also acquired or taken a substantial step toward acquiring most of the ingredients and equipment necessary to construct an IED and he has conducted online research of several potential U.S. targets, the affidavit alleges. In addition, he has allegedly described his desire for violent jihad and martyrdom in blog postings and a personal journal.

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The affidavit alleges that on Feb. 1, 2011, a chemical supplier reported to the FBI a suspicious attempted purchase of concentrated phenol by a man identifying himself as Khalid Aldawsari. According to the affidavit, phenol is a toxic chemical with legitimate uses, but can also be used to make the explosive trinitrophenol, also known as T.N.P., or picric acid. The affidavit alleges that other ingredients typically used with phenol to make picric acid, or T.N.P., are concentrated sulfuric and nitric acids.

Aldawsari allegedly attempted to have the phenol order shipped to a freight company so it could be held for him there, but the freight company returned the order to the supplier and called the police. Later, Aldawsari falsely told the supplier he was associated with a university and wanted the phenol for “off-campus, personal research.” Frustrated by questions being asked over his phenol order, Aldawsari cancelled his order and later e-mailed himself instructions for producing phenol. The affidavit alleges that in December 2010, he successfully purchased concentrated nitric and sulfuric acids.

According to the affidavit, legally authorized electronic surveillance revealed that Aldawsari used various e-mail accounts in researching explosives and targets, and often sent emails to himself as part of this process. On Feb. 11, 2011, for instance, he allegedly e-mailed himself a recipe for picric acid, which the e-mail describes as a “military explosive.” He also allegedly sent himself an e-mail on Oct. 19, 2010 that contained information on the material required for Nitro Urea, how to prepare it, and the advantages of using it.

The affidavit alleges that Aldawsari also e-mailed himself instructions on how to convert a cellular phone into a remote detonator and how to prepare a booby-trapped vehicle using items available in every home. One e-mail allegedly contained a message stating that “one operation in the land of the infidels is equal to ten operations against occupying forces in the land of the Muslims.” During December 2010 and January 2011, Aldawsari allegedly purchased many other items, including a gas mask, a Hazmat suit, a soldering iron kit, glass beakers and flasks, wiring, a stun gun, clocks and a battery tester.

Two legally authorized searches of Aldawsari’s apartment conducted by the FBI in February 2011 indicated that the concentrated sulfuric and nitric acids; the beakers and flasks; wiring; Hazmat suit; and clocks were present in Aldawsari’s residence.

FBI agents also found a notebook at Aldawsari’s residence that appeared to be a diary or journal. According to the affidavit, excerpts from the journal indicate that Aldawsari had been planning to commit a terrorist attack in the United States for years. One entry describes how Aldawsari sought and obtained a particular scholarship because it allowed him to come directly to the United State and helped him financially, which he said “will help tremendously in providing me with the support I need for Jihad.” The entry continues: “And now, after mastering the English language, learning how to build explosives and continuous planning to target the infidel Americans, it is time for Jihad.”

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According to the affidavit, Aldawsari conducted research on various targets and e-mailed himself information on these locations and people. One of the documents he sent himself, with the subject line listed as “Targets,” allegedly contained the names and home addresses of three American citizens who had previously served in the U.S. military and had been stationed for a time at Abu Ghraib prison in Iraq.

In another e-mail titled “NICE TARGETS 01,” Aldawsari allegedly sent himself the names of 12 reservoir dams in Colorado and California. In another e-mail to himself, titled “NICE TARGETS,” he listed two categories of targets: hydroelectric dams and nuclear power plants. On Feb. 6, 2011, the affidavit alleges, Aldawsari sent himself an e-mail titled “Tyrant’s House,” in which he listed the Dallas address for former President George W. Bush. The affidavit also alleges that Aldawsari conducted research that could indicate his consideration of the use of infant dolls to conceal explosives and possible targeting of a nightclub with an explosive concealed in a backpack.