Legal Materials

The legal entities

The Arizona Cyber Warfare Range (AZCWR)

Founded 2012 - An Arizona non-profit (Business Registration). Founded after 10 years of the founders asking for someone to create such an entity. The initial location was in a compound in east Mesa, AZ. The Arizona FBI and others complained the location was hard for their people to train at. An introduction was made to the team at AZLabs at our request. Initial reception to the idea was cold but the Arizona FBI stepped in an advocated on our behalf and the AZLabs team and the City of Mesa agreed to allow us to relocate to the AZLabs facility.

Arizona Cyber Threat Response Alliance (ACTRA)

Founded 2013. An Arizona based 501c3 (Business Registration). Formed to support the expansions of the AZCWR by offering "corporate memberships". It also was tasked with fixing a challenging construct in the Infragard legal boundaries which only allowed for one way threat intelligence sharing. Everything the ACTRA was/is was given to Frank Grimmelmann during an arranged lunch meeting at Deer Valley airport in late 2012. The lunch meeting was arranged by the Arizona FBI. The AZ FBI wanted tosee the improvements to the Infragard program, bt the AZCWR founders indicated they could not meet the needs of both missions.

The City of Mesa

An incorporated city in Maricopa County.

The legal construct explained

The initial concern was the the potentially controversial AZCWR would be too fragile to survive a legal issue. Therefore the idea to house the leases and the initial equipment into a 3rd party would prevent the mission from being destroyed if a legal issue bankrupted the AZCWR. This is why the AZCWR housed the lease agreements and initial hardware donations with a 3rd party. Initially the 3rd party was going to be a 501c3 the AZCWR was forming. However, it fell through. We later found out the Frank Grimmelmann had contacted our attorney and stated that the FBI would be upset if the AZCWR had its own 501c3 instead of using ACTRA. We did not find out until it was too late. As the end of the year approached, the AZCWR was left with no choice but to accept Frank Grimmelmann's offer to house the equipment and leases for the AZCWR operations. For ACTRA's help, the AZCWR agreed to open and pay for an ACTRA room at AZLabs.

To fix liability to only the AZCWR, an indemnification to ACTRA was signed by the AZCWR. This indemnification ensured that no outside party could destroy the mission and the the cyber warfare range at AZLabs could never be shutdown do to legal/financial losses.


The AZCWR paid all of the expenses for ACTRA's presence at AZLabs and for the cyber warfare range at AZLabs. The check the AZCWR paid were to ACTRA which in turn would issue a check to the City of Mesa for the rents. The legal liability insurance was also paid for by the AZCWR.

The contracts

The contract between the AZCWRand ACTRA stated plainly the the AZCWR was the "sole operator" of the cyber warfare range at AZLabs.