From the Complaint:

27. During the investigation, the FBI published a webpage that purported to recruit individuals to travel to Syria and join Jabhat al-Nusrah. In particular, the top portion of the webpage stated, "A Call for Jihad iri Syria," and depicted a photograph of an armed fighter. The website also included a purported Jabhat al-Nusrah training video that depicted individuals wearing masks and fatigues, and engaging in training, such as running with firearms. The website stated, among other things, "come and join your lion brothers of Jabhat Al-Nusra who are fighting under the true banner of Islam, come and join your brothers, the heroes of J abhat Al-Nusra." The website provided an email account as a point of contact, along with instructions:

We are aware of the kuffar's tricks and the behavior of their unjust governments. We also understand the risk of direct contact. Therefore you can contact us via email so that we provide you with the required information which will help you to set off for your jihad in Syria. Before sending us an email, create a new email that you have never used before and send the email to us from a public place.

After these instructions, the website stated:

After you arrive safely our Mujahedeen21 brothers will welcome you and then you will go through ten days Dawra Shar'ia (religious workshop) followed by an intensive course in physical and military training.

29. Also on or about March 28, 2013, Tounisi sent an email to the account listed on the website described above in Par. 27. Tounisi wrote:

My name is Abdullah and I am planning lnshaAllah to join my brothers in Syria in April. InshaAllah I'm going to buy two tickets one from Chicago to Istanbul and another from Istanbul to Gaziantep. I do not know what to do after I arrive in Gaziantep because I do not have any contact information. Can you please help me modify my plan if it needs modification and to prove the authenticity of this e-mail service. Please give me a reply as soon as possible.

30. On or about March 29, 2013, an online undercover FBI employee (OCE) sent Tounisi the following, in part:

Brother, Abdullah, We received your email. Our security procedures demand that you create .. a new email and start communicate through it. We have plans to move. you safely insha'Allah as you requested in your email. The below address email is the only way for you to communicate with us from now on and is created only for you.

32. On or about March 30, 2013, the OCE sent a follow-up email, warning Tounisi that he should not buy a one-way ticket because it would "raise suspicions." The OCE agreed, however, with Tounisi's plan to fly to Istanbul rather than Gaziantep. Later in the communication, the OCE asked Tounisi about his "money supply" and whether he was "able to fight."

33. On or about April 1, 2013, Tounisi responded to the OCE's email, stating, in part:

I knew about buying a roundtrip ticket but how am I supposed to travel from Istanbul to hear Syria without flying? And for how much? .... my money supply is not that high. Some brother are helping me pay for the hijra InshaAllah. Around April 6th I will have about $1396. ... Concerning my fighting skills, to be honest I do not have any. I'm very small (5 feet 6 inches, 120 pounds) physically but I pray to Allah that he makes me successful. Physical strength has no match when it faces Iman. May Allah make us of the Mumeneen.

34. On or about April 2, 2013, the OCE sent Tounisi an email assuring Tounisi that he need not worry about how to travel from Istanbul to the border of Syria. As the OCE explained, "We have moved brothers over here before so we know· exactly what we do from there. All you have to do is tell us what date you will arrive to Istanbul and we will take care of the rest and provide you with details insha'Allah." The OCE concluded the email stating:

We have trust in Allah that you wil~ fight and do your Jihad as a true mu'min .... As you know that Shahada is the ultimate desire of any Mujahid, so with that in mind, brother Abdullah, we ask if you are willing to be a shaheed if the will of the Allah comes upon you to be one?

39. ...The OCE wrote that, after Tounisi sent along his arrival information, the OCE would send Tounisi a bus ticket, which would enable Tounisi to travel "from Istanbul to a village where a brother will be waiting for you."

46. On or about April 10, 2013, Tounisi sent the OCE an email reporting that he had purchased the ticket:

I got the ticket this morning. InshaAllah ta'ala I will arrive in Istanbul Ataturk airport April 20 17:05/5:05 pm. Please explain the details of what to do next inshaAllah.

47. On or about April 11, 2013, the OCE sent Tounisi a response, stating, in part:

By the will of Allah you are closer to be joining your brothers of Jabhat AI Nusra on battlefields in Bilad AI Sham. It is very important that you keep this to yourself and not change the routine of your life. You must not do anything now to make suspicions. Few days before your travel we will email you the bus ticket and other details about your travel. ...

48. On or about April 11, 2013, Tounisi sent the OCE an email with two questions, asking, "Do I have to pay for the bus ticket?

52. On or about April 18, 2013, the OCE sent Tounisi an email with instructions about what Tounisi should do when he arrives in Istanbul. The email included as an attachment a bus ticket from Istanbul to Gaziantep,Turkey, with a scheduled departure of April 21, 2013, at 2:30 p.m. The OCE stated that a ''brother" would be waiting for Tounisi at the bus station in Gaziantep and described what he would be wearing.

54. On or about April 19, 2013, ·at approximately 7:39 p.m., FBI surveillance observed Tounisi at O'Hare International Airport. At approximately 8:29 p.m., surveillance observed Tounisi clear security and sit down in the gate area for his flight. Shortly thereafter, CBP officers approached Tounisi and asked him questions relating to his travel. According to the interviewing officers, Tounisi said, among other things: that he (1) was traveling to Turkey for sightseeing; (2) would be in Turkey for three and one half days; and (3) would not be visiting any other, countries. About five minutes after the interview, Tounisi was arrested by the FBI.

The charge against him:

On or about April 19, 2013, in the Northern District of Illinois, Eastern Division, and elsewhere, ABDELLA AHMAD TOUNISI, defendant herein:

knowingly attempted to provide material support and resources, namely, personnel, to a foreign terrorist organization, namely, al~Qaida in Iraq, designated as a foreign terrorist organization by the United States Department of State on or about October 15, 2004, and amended to include the alias Jabhat al-Nusrah on or about December 11, 2012, knowing that the organization was a designated terrorist organization and that the organization had engaged and was engaging in terrorist activity and terrorism, in violation of Title 18, United States Code, Section 2339B(a)(1).

According to a footnote in the Complaint:

According to a release issued by the Department of State on or about December 11, 2012, AQI's leader, Abu Bakr al-Baghdadi (aka, "Abu Du'a"), exercises control of both AQI and Jabhat al-Nusrah. Abu Bakr al-Baghdadi was designated a Specially Designated Global Terrorist by the State Department under Executive Order 13224 in or about October 2011.

While Tounisi had been associated with another would-be extremist who was charged with trying to bomb a nightclub in Chicago, the Complaint says Tounisi refused to participate in that plot. After his friend was arrested, he allegedly decided he would participate in the cause by joining overseas efforts rather than efforts directed at the U.S.

Tounisi was a close friend of an individual named Adel Daoud, who, on or about September 14, 2012, was arrested for attempting to detonate a bomb outside a bar in downtown Chicago. See United States v. Daoud, 12 CR 723. Tounisi and Daoud appeared to share an interest in violent jihad, a topic about which the two exchanged a number of emails, phone calls, and text messages.

The Complaint says Daoud discussed his nightclub plan with Tounisi who provided some ideas but declined to participate.

Ultimately, however, in mid-August 2012, Tounisi apparently decided against participating in the attack, in part because he believed the UC [working with Daoud] was associated with law enforcement. As Daoud explained to the UC, Tounisi sought instead to travel overseas to engage in violent jihad. Daoud opted to carry out the attack without Tounisi and, on September 14, 2012, he was arrested after attempting to detonate a bomb outside a bar in downtown Chicago.

Hours after Daoud's arrest, Tounisi was interviewed by FBI agents and admitted to assisting Daoud in target selection and acknowledged that he had contemplated traveling to Yemen to carry out jihad.

The FBI says Tounisi's interest in violent jihad continued, notwithstanding Daoud's arrest on terrorism charges. The support for this consists of the information the FBI learned from monitoring his internet searches, the You Tube videos he watched (logged onto from his home IP address) and emails.

It was on March 28, 2013, that Tounisi contacted the FBI undercover agent pretending to be a recruiter for violent jihad. By April 18, he had his bus ticket. On April 19, he went to O'Hare to board his flight to Turkey and was arrested.

Tounisi told the FBI in emails he had no contacts in Syria and no idea what to do once he got there.

I am going to buy two tickets one from Chicago to Istanbul and another from Istanbul to Gaziantep. I do not know what to do after I arrive in Gaziantep because I do not have any contact information and had no idea how to get from Turkey to Syria.

Without the bus ticket provided by the FBI, would he ever had gone through with his plan to buy a plane ticket to Turkey?

Wouldn't it have better for the FBI to respond to Tounisi's first contact with an e-mail that said something like:

You have fallen for a trap. We are the FBI. We will now be watching every move you make. We urge you to abandon whatever plans you are contemplating and read the following statute: 18 U.S.C., 18 USC 2339, Providing Material Support to Terrorists. It carries a 15 year prison sentence. It applies to those who would travel abroad to assist organizations the U.S. has declared to be terrorist organizations. Here is a list of those organizations.

It is not too late to change your mind. You are a U.S. citizen in college with a bright future. Please reconsider. Again, we will be watching you closely from this point forward.