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CONTINUATION OF COMPLAINT
1. My name is Bruce D. Fowler. I am a Special Agent (SA) with the Federal Bureau of
Investigation (FBI), and have served as such for over six years. I am currently assigned to the
Lansing Resident Agency of FBI Detroit Division, and my duties include investigating
2. In 2013, I opened an investigation into the activities of Dr. Ning Xi, who is a citizen of
China, a Permanent Resident of the United States, and a former resident of Michigan. He is
also a world-renowned expert in the field of robotics, nano-sensors and devices, and intelligent
control and systems. My investigation of Xi began when he was a professor of Electrical and
Computer Engineering at Michigan State University (MSU), and was originally focused on
whether he had fraudulently obtained federal research grants from the National Science
Foundation (NSF) by omitting information about his receipt of funds from the State Key
of the Peoples Republic of China (PRC). Over time, the investigation produced evidence that
Xi had defrauded both MSU and the Institute of Electrical and Electronics Engineers (IEEE), a
and from review of documents and interviews of people with direct knowledge of events.
Because it is provided for the limited purpose of demonstrating probable cause to believe Xi
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The IEEE is a professional organization with worldwide membership that enjoys international
prestige within the scientific community. Its membership of over 420,000 engineers resides in
over 160 countries, and it sponsors conferences, professional and educational activities, and
publications.
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has committed wire-fraud, in the Western District of Michigan and elsewhere, this summary
4. Xi was first employed by MSU in 1997, and he eventually rose to the position of
Distinguished Professor and Director of the Robotics and Automation Laboratory. Beginning
in January 2011, Xi went on sabbatical leave from MSU to assume an administrative position at
City University of Hong Kong (CUHK) as the Chair Professor of Mechanical Engineering.
Although Xi initially requested a one-year leave of absence, he extended his sabbatical each
MSU officials to confirm that Xi was no longer employed at MSU. In further discussions with
CUHK, MSU became aware that Xi had obtained a tenured professor’s position at CUHK.
According to CUHK policy, employees could only hold one tenured position at a time. MSU
officials advised CUHK that Xi was still a tenured professor at MSU, and also communicated a
demand to Xi that he return and resume his duties at MSU. Xi resigned from CUHK and
5. MSU conducted an internal investigation of Xi's activities, and concluded that he had
by failing to disclose his Chinese affiliations, research and funding in federal grant applications
he had submitted to the NSF, and suspended him without pay for three weeks in the Fall of
2014. The following year, MSU officials discovered information indicating that Xi had
accepted a second position at the University of Hong Kong as the Chair Professor for the
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Xi had received 50% salary from MSU during 2011, and was then in a no-pay status with
MSU until he returned in 2014.
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policy. Xi was uncooperative when questioned, his superiors recommended that he receive a
six-month suspension from MSU, and Xi responded by tendering his resignation in October
2015.
5. In January 2016, I was informed by a confidential source at MSU that, according to the
open-source University of Hong Kong website, Xi had been appointed as the Chair Professor of
Robotics and Automation, as well as the Director of the Emerging Technologies Institute.
6. Xi returned to the United States through San Diego on 13 Feb. 2016, and was
interviewed by the FBI upon arrival. Xi stated that he resides in both China, at the Royal Park
Hotel in Hong Kong, and in the United States at his residence in Okemos, Michigan. Xi stated
that he was employed at the University of Hong Kong, and denied any affiliation with any other
Chinese university or research institution. He stated that he had worked with the Chinese
Academy of Sciences (CAS) in the past, but denied that he had been paid by CAS or by any
other entity associated with the PRC. Xi denied that he had ever intentionally omitted
disclosing any foreign research affiliations, funding, or foreign salary when he applied for U.S.
Government research grants, and stated that if he had forgotten to include any such information,
NSF should have known he was working with another foreign agency because this information
7. Grant applications submitted by Xi to MSU were obtained by NSF from MSU pursuant
to administrative subpoenas served in April 2015. NSF review of those documents, and
interviews of the NSF program managers who awarded the grants to Xi, disclosed that Xi had
not disclosed his foreign affiliations and income in his federal grant applications to NSF.
8. Xi also told the interviewing agents that he had received between $100,000 - $200,000
in reimbursements from IEEE, and that those reimbursements had been paid by numerous
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9. To date, the investigation has disclosed that Xi received approximately $1.2 million in
reimbursements from IEEE based on claims he submitted since 2009. Nearly all of the
reimbursement checks that Xi received from IEEE were signed by Weihua Sheng. Sheng, who
is also a Chinese citizen, was a doctoral student of Xi's at MSU, and he is now a professor at
Oklahoma State University. Sheng also served as the Treasurer for ten different IEEE
conferences, seven of which were chaired by Xi. Each conference put on by IEEE has its own
bank account, and two persons are authorized to draft checks on that account: the conference
10. After his separation from MSU, Xi continued to submit requests for travel
reimbursements to MSU, prompting persons in the travel-claim system to review the validity of
Xi’s reimbursement requests. On or about 15 Dec. 2016, I was provided with several batches
of disbursement vouchers for travel reimbursements that MSU had paid out to Xi. My review
of those documents determined that a significant percentage of the receipts that Xi had
submitted to MSU as justification for travel reimbursements appeared to have been fabricated,
were for charges that had already been refunded to Xi’s credit cards by various airlines, were
for fares that had been exchanged for different flights, and/or were for expenses that had
already been reimbursed by IEEE. Ticket numbers and booking codes on documents that Xi
submitted to MSU were cross-checked against information provided by IEEE, United Airlines,
Delta Airlines, Orbitz, Chase Bank and American Express. This process demonstrated that the
same unique ticket numbers appeared repeatedly in receipts that Xi submitted for different
travel reimbursements from both MSU and IEEE, those ticket numbers routinely did not appear
on the credit card statements for accounts that Xi claimed to have used to pay for the tickets,
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and the records of the airlines in question either a) did not contain those ticket numbers; b)
showed that Xi had not traveled on those ticket numbers; c) showed that Xi had been refunded
by the airline for those ticket numbers; or d) showed that those ticket numbers had been
11. During 2015 and 2016, I obtained voluminous documents from IEEE through grand jury
process. These documents included the June 2016 production of a Final Internal Audit Report
on the 2014 IEEE International Conference on Robotics and Automation (ICRA), which was
held in Hong Kong from 31 May to 7 June 2014 and was chaired by Xi. The report included the
following findings:
a. Travel expenses for other conferences (2011 IROS, 2012 IROS, 2013 IROS,
2014 IROS and 2014 NEMS) were paid to the Conference Chair, Ning Xi, from the 2014 ICRA
concentration banking account (travel expenses included trips to San Francisco, Chicago,
Hawaii, Toronto, Hungary, Bangkok, Beijing, Australia, Macau, Taipei, Portugal, Germany).
No expense reports nor any business purpose was provided for any trips taken facilitating the
commingling of funds for multiple conferences in a period of 4 years. In addition, there were
separate checks each under $25,000 (expenses included lodging, meals, transportation, cruises,
was inadequate. There were no expense reports provided by the Conference Chair. The
business purpose was not stated and a list of attendees was not provided for entertainment/meal
expenses for more than one person. However, with regards to expense reimbursement, clear
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instructions were provided to other volunteers and the appropriate documentation was received.
d. Expenses were not claimed in a timely manner, several were three to four years
in arrears. Expenses for multiple trips with some spanning three to four years were submitted
together for reimbursement (such expenses go back as far as 2011, 2012, 2013 and 2014).
e. Gift items were purchased by the Conference Chair (including IPads, IPhone 6
plus, IPad accessories, computer adapters, liquor, Swarovski crystal items, hand truck,
supermarket items, etc.), with no business purpose stated on the receipts, nor was a list of
recipients provided.
Chair for multiple trips after the 2014 ICRA conference concluded. No detail for the same was
12. In October 2016, IEEE provided a flash drive containing evidence related to
reimbursements that IEEE had paid to Xi. The flash drive included a spreadsheet detailing the
payment amounts for 27 checks provided to Xi for the 2014 ICRA conference, all of which had
been signed by Weihua Sheng as Conference Treasurer. The checks totaled $470,139.69.
13. In December 2016, I received documents from IEEE related to reimbursements paid to
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o Total: $1,078,593.67
14. Michael Lindsay, a partner at the law firm of Dorsey & Whitney, LLP, which represents
IEEE as outside legal counsel, informed me that Xi was an organizer of approximately nine
IEEE conferences, some of which occurred before the time frame indicated in the subpoena.
15. During March 2017, I received and reviewed additional records from United and Delta
airlines. My review of these records disclosed that ticket receipts submitted by Xi did not
match flight information stored in the United and Delta Airlines databases. In many instances,
neither United nor Delta had any information pertaining to ticket numbers that Xi claimed he
16. The investigation has assessed more than $429,000 in fraudulent activity associated with
the reimbursements from IEEE and MSU paid to Xi between 1 Jan. 2011 and 31 Jan. 2016. Xi
ultimately received and deposited several dozens of checks from MSU and IEEE into his
MSUFCU accounts; these funds were typically used to pay off significant credit card debt,
primarily to American Express and Chase. The fraudulent activity includes reimbursements
receipt being purchased and then refunded or voided, or some other material falsehood that was
used in Xi’s scheme to defraud. For reimbursements from IEEE, Xi’s fraudulent
reimbursement requests caused money to be wired from IEEE accounts to Xi’s personal
account at MSUFCU. For reimbursements from MSU, Xi also electronically signed the
fraudulent reimbursement requests and often provided his approval and verification of
authenticity for the requests via email, which also caused money to be wired from MSU