> Prosecutors showed that each of those shell companies involved the production of notarized affidavits in the names of people who didn’t exist. As a result, the government was able to charge Golestan with 20 counts of wire fraud — one for each payment made by the phony companies that bought the IP addresses from ARIN.

Golestan created 20 companies under false names. And wrote 1 check from each company. Which means 20 cases of (money) wire fraud.

What’s funny here is the chain of laws used to get to a prosecution. Apparently creating twenty companies under twenty false names was not illegal enough.