The sanctions applied by the European Commission onto the American companies Apple, Facebook, Microsoft, Qualcomm and Google may be proven illegal in relation to RICO law. The European Commission has violated legal doctrines and is a corrupt body.
Below is a text of the complaint sent to the office of Chairman of the U.S. Securities and Exchange Commission.

February 4, 2019

Andrеi Sumаr
Rue de la Victoire, 158
1060 Brussels, Belgium
Mob.: +32 4656 79 423

Mr Jay Clayton
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Subject: Complaint against the inaction of the Board of Directors of Qualcomm Inc. regarding appealing on the grounds of the RICO law against sanctions applied to Qualcomm Inc. by the European Commission.

(Sent by post (tracking number of the Belgian post is RF069061185BE) and email to

Dear Mister Chairman,
On December 20, 2018 I sent you a letter providing grounds for the point of view that the sanctions applied by the European Commission onto the American companies Apple, Facebook, Microsoft, Qualcomm and Google may be proven illegal.

Now I submit this complaint against the Board of Directors of Qualcomm Inc. as a stockholder of Qualcomm Inc.

In 2018, Qualcomm Inc. was fined 1 billion euros by the European Commission for violation of the EU Competition Act. However, the sanctions of the European Commission can be proven illegal. In November 2018, I sent information to the Board of Directors of Qualcomm Inc. which proves that the European Commission had violated legal doctrines and is a corrupt body. I called the Board to appeal against the sanctions of the European Commission. I sent this information to:

  • email addresses specified on the official website of Qualcomm Inc.;
  • representatives of the management of Qualcomm Inc. who are my LinkedIn contacts;
  • delivered a letter to the Brussels office of Qualcomm Inc. to one of the heads of this office.

Unfortunately, there was no reaction on my information. I think that giant US companies do not want to spoil relations with the European authorities and sue the European Commission. It turned out that these companies prefer to silently agree with the EU authorities by lobbying method. The top of the lobbyists list (doing in the EU) includes American companies. Such policy of Qualcomm Inc. violates the rights of the stockholders.

To protect the interests of Qualcomm Inc. investors, I ask you to call the Board of Directors of Qualcomm Inc. to appeal against the sanctions of the European Commission in an American court on the grounds of the federal Racketeering Influenced and Corrupt Organizations (RICO) law.

The application of the RICO law is justified by the following circumstances:

The European Commission had falsified its report on Schengen visas traffic. In November 2016, the report was presented to the European Parliament, which was investigating the issue. In its report, the European Commission replaced the main subject from “Schengen visas traffic” to “national visas traffic”. This deliberate substitution allowed the Commission to make a statement that the EU authorities are not competent in the matter raised. This way, by cheating the Parliament, which is a body competent to control the Commission, the Commission avoided investigation of this crime and hid the criminals. The detailed information and proofs are available at The reasons of the behavior of the Commission in the case with Schengen visas traffic are not clear. However, it should be taken into account that this illegal business is still flourishing in Eastern Europe, Africa and Asia and brings tens of millions euros per year to its organizers. There are representatives of the EU authorities and individuals close to them among the organizers of this business.

For the first time, a major scandal in connection with Schengen visas traffic occurred in Europe in 2011. Then the police of four EU countries - Germany, France, Denmark and Spain - got on the trail of the organizers of Schengen visas traffic. In this case, the European Commission did not take steps to investigate the crime and bring the participants to justice. As a result, since 2012, Schengen visas traffic has spread to new countries and began to bring even more revenue to its organizers. In December 2014, a witness was killed near Warsaw, Poland who could point to the organizers of Schengen visas traffic (the murder is mentioned in the report of the Commission presented to the European Parliament). The European Commission shares the responsibility for this murder.

There has been psychological and physical pressure exerted on the participants of the Schengen visas traffic investigation aimed to intimidate and force to abandon the attempts to make this crime public. Acts of intimidation take place even in Brussels. The Belgian Federal Police and Crown Prosecutor are not taking any measures to investigate or stop the acts of intimidation. Probable reason for the inaction of the Belgian authorities is the influence of the European Commission.

In 2015, the Belgian Federal Police opened the case No BR.20.LL.132178/2015 about Schengen visas traffic. The investigator said the case would be forwarded to Europol for investigation. In fact, the case has never been forwarded to Europol and the investigation of Schengen visas traffic was not continued. The most likely reason for this is the influence of the European Commission on the Belgian police.

In 2016, the French Legal Police sent our information about Schengen visas traffic to Europol. In order to maintain contact with Europol, I sent a letter to the Director of Europol, informing about the change of my address. The representative of Europol signed the documents of Belgian and Dutch post confirming the delivery of my letter. Later it turned out that the signature shown on the Holland Post website (where Europol is located) differs from the signature on the Belgian Post document, which was delivered to me in Brussels. Different signatures prove that the letter has not been delivered to Europol. This example shows that the criminals manipulate mail correspondence. There also were other cases of manipulation of postal, electronic and telephone communications, as well as bank cards. In some cases registered letters were not delivered to their addressees and just disappeared.

In Brussels, the lawyers of the law firms “Louis European Law” and “Deprevernet”, to which we had appealed to initiate a legal process against the European Commission, were bribed. At first, both firms agreed to represent our side. However, they refused to do so later. As “Deprevernet” explained in its letter, the refusal was due to a conflict of interest. This means that these firms had been hired by the European Commission, which manages a huge budget and can offer high fees to the lawyers. In this situation, the European Commission acted illegally.

European Anti-fraud Office (OLAF), which is a structural part of the European Commission, may be involved in the collection of information, based on which the European Commission imposed sanctions on US companies. There is reason to believe that the OLAF is also a corrupt body. OLAF refused to initiate investigation of the Schengen visas traffic and of the fraud with extra rewards for fictitious activities paid to the deputies of the European Parliament. These decisions of OLAF are contrary to the statute of this body. Currently, we are completing collection of the dossier on the OLAF activities.

The European Commission blamed several American companies for violation of the competition law and imposed a significant fine. At the same time, the Commission is responsible for execution of other EU laws, for example the “Community Code on Visas” (Regulation (EC) 810/2009). We can see that in one case which is related to the competition law, the Commission seeks to receive excess income in the EU budget and imposes huge fines for violations. In another case related to the code on visas, the Commission itself commits a violation (falsification of the report) to hide a serious crime, the Schengen visa fraud. This proves that the European Commission has violated legal doctrines. Other examples above prove that the European Commission is a corrupt body. This way, the activities of the European Commission and OLAF are subject to the RICO law.

The offenses committed by the European Commission or where it could be involved are not limited to the mentioned examples.

Dear Sir,
Being a stockholder of Qualcomm Inc., I represent the non-profit organization “Justice for all in Europe” ASBL located in Brussels. We are a non-political organization and our goal is to make public the cases of corruption in the EU bodies. “Justice for all in Europe” ASBL owns the rights to the dossier containing detailed information, documents and other proofs on all of the cases of corruption mentioned above. This dossier consists of more than 1000 pages of documents and will be presented in court during the lawsuit against the European Commission.

Soon, other stockholders of Qualcomm Inc. will join this complaint as well as stockholders of other American companies who suffered from the European Commission sanctions. These stockholders consider themselves victims of the illegal activity of the European Commission.

I testify my respect to you and to the U.S. Securities and Exchange Commission and I ask you to provide your opinion on the issue of sanctions of the European Commission to me within 7 days. Your opinion will help me and other stockholders to decide on further measures which we will have to take against the European Commission. Please also tell me the reference number of my complaint and the contact data of a representative of your commission with whom I can keep in touch.

Sincerely yours,
Andrеi Sumаr