Complaints

SEC v. Timothy Page et al: Complaint

Complaint alleging securities fraud in U. S. Securities and Exchange Commission v. Timothy Page, described as a citizen of the United Kingdom; Trevor Page, described as a resident of the United Kingdom residing in the U.K., Switzerland, and Fiji; Ticino Capital Limited, described as a Maltese company "owned on paper by a Swiss attorney"; Wellesley Holdings Limited, of Hungary; Porrima Limited, of Hungary; Emergent Investment Company, of Hungary, and FJ Investments International Inc., of Utah, as Defendants, and Janan Page, described as a resident of the United Kingdom, Switzerland, and Fiji, as Relief Defendant, at the U. S. District Court for the Eastern District of New York.

SEC v. Daniel Cattlin et al: Complaint

Complaint alleging securities fraud in U. S. Securities and Exchange Commission v. Daniel Cattlin, described as a citizen and resident of the United Kingdom, and William Shupe, described as a "disbarred lawyer" residing in Utah, at the U. S. District Court for the Eastern District of New York.

Endurance Services Ltd. et al v. Westfield Insurance Company et al: Complaint

Complaint that "arises from Westfield’s mass hiring (colloquially known as a "lift-out") of a group of employees from Sompo International to join Westfield’s new specialty insurance arm, Westfield Specialty, in direct competition with their former employer" in Endurance Services Limited, of Delaware, and Sompo International Holdings Ltd., of Bermuda v. Westfield Insurance Company and Westfield Specialty Inc., both of Ohio, at the U. S. District Court for the Southern District of New York.

SEC v. Back to Green LLC et al: Complaint

Complaint alleging the defendants "defrauded investors through an illegal unregistered securities offering to share in the profits of a "green" gold and platinum mining venture operating in Ayapel, Colombia" in U. S. Securities and Exchange Commission v. Back to Green LLC, of Puerto Rico; José Jiménez Cruz, of Puerto Rico, and Manuel Portalatin Rivera, of Colombia, at the U. S. District Court for the District of Puerto Rico.

Radical Investments Ltd. v. Good Vibrations Entertainment LLC et al: Complaint

Complaint alleging a $6.7 million fraud involving "non-existent doses" of a COVID-19 vaccine "for the purpose of vaccinating nearly 300,000 citizens of the island of Barbados" in Radical Investments Ltd., described as a St. Lucia company based in Barbados v. Good Vibrations Entertainment LLC, of Florida; Alex Lee Moore, a.k.a. Flex Moore; Prestige Pegasus LLC, of Colorado; Moniladae Coley, a.k.a. Moniladai Coley; Charles Stein, .k.a. Charlie Stein, a lawyer in California; Davidovich Stein Law Group LLC, a law firm California, and RDS Cargo Group DWC LLC, described as a Polish company based in the United Arab Emirates, at the U. S. District Court for the Southern District of Florida.

Lindsey Crits et al v. Berger Singerman et al: Complaint

Complaint alleging "an illegal nationwide, advanced-fee, student loan debt elimination telemarketing scam, operated and devised by the Defendants, that leaves vulnerable debtors, like Plaintiffs, tens of thousands of dollars poorer, and worse, in exchange for broken promises about impossible legal services that never are, and never could be, actually performed" in Lindsey Crits, Evan Wendt, Elizabeth Ripoli, and Jennifer Coley v. GM Law Firm LLC, Chantel L. Grant, National Legal Staffing Support LLC, Gregory Fishman, Julie Queler, Kevin Mason, Resolvly LLC, Backend Resolve LLC, JG Factor LLC, P. Benjamin Zuckerman, and Berger Singerman LLP at the U. S. District Court for the Southern District of Florida.

SEC v. Simon Thurlow et al: Complaint

Complaint alleging fraud in U. S. Securities and Exchange Commission v. Simon Piers Thurlow, described as a citizen of the United Kingdom residing in New York; Roger Leon Fidler, Richard Oravec, Bradley Fidler, Bryce Emory Boucher, Joseph D. Jordan, and Western Bankers Capital Inc. at the U. S. District Court for the Southern District of New York.

CFTC v. Rudy Avila et al: Complaint

Complaint alleging a $5.35 million investment fraud in Commodity Futures Trading Commission v. Rudy Avila, a.k.a. Jose Rodolfo Avila Gutierrez, described as a resident of Texas; The L.I.F.T Group LLC, of Texas; CIG Internacional SA, a.k.a. Commodity Investment Group, a.k.a. CIG Internacional, a.k.a. CIG International, of Costa Rica; Trading Technologies Group SA, of Costa Rica; Trading Ventures Group LLC, described as a Texas company that claimed to have offices in Texas and London, England; Capital Ventures Group LLC, of Texas, and Ventures Group LLC, of Texas, at the U. S. District Court for the Northern District of Texas.

Sustainable Opportunities Acquisition Corp. v. Ethos Fund I LP et al: Complaint

Complaint in Sustainable Opportunities Acquisition Corp., now known as The metals company Inc., described as a Texas-based "special purpose acquisition company" that was formed in the Cayman Islands before re-domiciling to Canada v. Ethos Fund I LP, Ethos GP LLC, and Ethos DeepGreen PIPE LLC at the U. S. District Court for the Southern District of New York.

Ryan Cox v. Binance et al: Class Action Complaint

Class Action Complaint in Ryan Cox v. CoinMarketCap OpCo LLC, described as Delaware company that operates "a coin ranking site"; Binance Capital Management Co. Ltd., d.b.a. Binance and Binance.com, described as the operator of "a cryptocurrency exchange"; BAM Trading Services Inc., d.b.a. Binance.us; Changpeng Zhao, apparently a citizen of Canada and China; Catherine Coley, Yi He, and Ted Lin at the U. S. District Court for the District of Arizona.

GIC Private Ltd. v. Celgene Corporation et al: Complaint

Complaint alleging securities fraud in GIC Private Limited, which is "wholly-owned by the Government of Singapore" v. Celgene Corporation, Scott A. Smith, Terrie Curran, and Philippe Martin at the U. S. District Court for the District of New Jersey.

Best Meridian Insurance Company et al v. Lake Cecile Resort Inc. et al: Complaint

Complaint in Best Meridian Insurance Company and Best Meridian International Insurance Company SPC, of the Cayman Islands v. Lake Cecile Resort Inc., CCH FL 2 LLC, Citrus Capital Holdings LLC, Florida Department of Revenue, Keys Funding LLC – 1019, Keys Tax Funding LLC – 19, Kissimmee Utility Authority, Osceola County, a political subdivision of the State of Florida; Bruce Vickers, Osceola County Tax Collector, Premier Elevator Company Inc., Sunbelt Rentals, Inc., TLGFY, LLC, J.T. Shaw, Inc., and Tohopekaliga Water Authority at the U. S. Bankruptcy Court for the Middle District of Florida.

Jingjing Zhou v. Youbi Capital (Cayman) GP et al: Complaint

Complaint alleging breach of fiduciary duty and breach of contract in Jingjing Zhou, of Connecticut v. Youbi Capital (Cayman) GP, of the Cayman Islands; Yaofei Chen, of New Jersey; Hyejin Lee, of New Jersey, and Chen Li, of New York, at the U. S. District Court for the Southern District of New York.

Varda Burstein v. AutoLotto Inc. et al: Complaint

Complaint for $3 million alleging "an outrageous and blatant fraud" in Varda Burstein, a resident of Israel v. AutoLotto Inc., described as an Austin, Texas-based "online lottery company that generated revenue through state-sanctioned lotteries and charitable raffles", and Tony DiMatteo, of Texas, at the U. S. District Court for the Western District of Texas.

SEC v. Rivetz International SEZC et al: Complaint

Complaint alleging the sale of unregistered digital assets in U. S. Securities and Exchange Commission v. Rivetz Corp., of Delaware; Rivetz International SEZC, of the Cayman Islands, and Steven K. Sprague, described as a resident of the Cayman Islands and Massachusetts, at the U. S. District Court for the District of Massachusetts.

SEC v. Klaus Hofmann: Complaint

Complaint alleging "a multi-year expense management scheme by Kraft Heinz Company's procurement division to improperly reduce KHC's cost of goods sold and achieve costs savings targets that were externally touted to the market and internally tied to performance-based targets" in U. S. Securities and Exchange Commission v. Klaus Hofmann, of Zug, Switzerland, at the U. S. District Court for the Southern District of New York.

Christian Brothers Employee Retirement Plan et al v. Allianz Global Investors US LLC et al: Complaint

Complaint alleging "negligence and breach of contractual and fiduciary duties arising from misconduct related to the ERP's investment in the AllianzGI Structured Alpha U.S. Equity 500 Fund" in Christian Brothers Employee Retirement Plan and Dan Stremel v. Allianz Global Investors U.S. LLC, Allianz Global Investors U.S. Holdings LLC, Allianz SE, of Germany; Allianz Asset Management GmbH, of Germany; Allianz of America Inc., Allianz Asset Management of America Holdings Inc., Allianz Asset Management of America LLC, Allianz Asset Management of America L.P., and PFP Holdings Inc. at the U. S. District Court for the Southern District of New York.

SEC v. BitConnect et al: Complaint

Complaint alleging a securities fraud "that ultimately succeeded in obtaining more than 325,000 Bitcoin, or approximately $2 billion, from investors worldwide" in U. S. Securities and Exchange Commission v. BitConnect, described as "an unincorporated organization"; Satish Kumbhani, described as a citizen and resident of India; Glenn Arcaro, described as a citizen of the United States residing in California, and Future Money Ltd., of Hong Kong, at the U. S. District Court for the Southern District of New York.

Miami International Holdings Inc. et al v. Nasdaq Inc. et al: Complaint

Complaint alleging "that Nasdaq acted unlawfully to maintain and/or to obtain monopolies in the relevant markets and submarkets by engaging in acts of patent misuse, sham litigation, and other predatory conduct" in Miami International Holdings Inc., which, inter alia, owns the Bermuda Stock Exchange; Miami International Securities Exchange LLC, MIAX Pearl LLC, and Miami International Technologies LLC v. Nasdaq Inc., Nasdaq ISE LLC, and FTEN Inc. at the U. S. District Court for the District of Delaware.

SEC v. Howard Kleyman: Complaint

Complaint alleging securities fraud involving a "prime bank" scheme and entities in the Dominican Republic, Panama, United Kingdom, and USA in U. S. Securities and Exchange Commission v. Howard Kleyman, described as a lawyer in Minnesota at the timeof the alleged offense, at the U. S. District Court for the District of Minnesota.

USA v. Jorge Nobrega: Criminal Indictment

Criminal Indictment alleging conspiracy to violate the International Emergency Economic Powers Act, conspiracy to commit money laundering, and money laundering involving entities in Australia, Thailand, and Venezuela in USA v. Jorge Luis Nobrega Rodriguez at the U. S. District Court for the Southern District of Florida.

SEC v. Carl Jensen et al: Complaint

Complaint alleging "an ongoing offering fraud" involving "Chinese and Mexican and bearer bonds" that "has raised over $7 million from more than 75 investors" in U. S. Securities and Exchange Commission v. Carl Jensen, described as a citizen of Canada residing in Australia, and Stephen W. Gold, described as a citizen of the United Kingdom residing in California, as Defendants, and Kerry Margolis, described as a citizen of the United States residing in Germany, and Michael Hock, described as a citizen of the United States residing in California, as Relief Defendants, at the U. S. District Court for the Central District of California.

AmTrust North America Inc. v. Signify Insurance Ltd. et al: Complaint

Complaint alleging breach of contract in AmTrust North America Inc., on behalf of Technology Insurance Company Inc. and Security National Insurance Company v. Employers HR LLC, described as a Florida company based in New York, and Signify Insurance Ltd., of Bermuda, at the U. S. District Court for the Southern District of New York.

George Bachiashvili v. Charlie Shrem et al: Amended Complaint

Amended Complaint alleging fraud and unregistered securities regarding the sale of cryptocurrency tokens involving Delaware and Cayman Islands-domiciled Crowd Machine in George Bachiashvili v. Charlie Shrem and Roger Tichenor at the U. S. District Court for the Middle District of Florida.

SEC v. Medsis International Inc. et al: Complaint

Complaint alleging securities fraud in which the individuals defendants "told prospective investors Medsis had entered into large lucrative contracts with Central and South American customers" in U. S. Securities and Exchange Commission v. Medsis International Inc., described as a Delaware-domiciled, Florida-based subsidiary of Medsis Medical Systems SA, of Panama; Joshua Dax Cabrera, of Miami, Florida, and Paul Hess, of Braintree, Massachusetts, at the U. S. District Court for the District of Massachusetts.

George Assad v. Pershing Square Tontine Holdings Ltd. et al: Complaint

Derivative complaint alleging breach of the Investment Company Act of 1940 and The Investment Advisers Act of 1940 in George Assad, derivatively on behalf of Pershing Square Tontine Holdings Ltd. v. Pershing Square Tontine Holdings Ltd., described as being domiciled in Delaware, based in New York and "the largest special purpose acquisition company, or "SPAC", ever to have offered shares to the public", as Nominal Defendant, and Pershing Square TH Sponsor LLC, of Delaware; Lisa Gersh, Michael Ovitz, Jacqueline D. Reses, Joseph S. Steinberg, Pershing Square LP, of Delaware; Pershing Square International Ltd., of the Cayman Islands, and Pershing Square Holdings Ltd., of Guernsey, as Defendants, at the U. S. District Court for the Southern District of New York.

HSCM Bermuda Fund Ltd. v. 24 Capital LLC et al: Complaint

Complaint that "arises from HSCM's loans of more than $150,000,000.00 to Seeman Holtz Property and Casualty, Inc. and its successor entity Seeman Holtz Property and Casualty, LLC" in HSCM Bermuda Fund Ltd., of Bermuda v. 24 Capital LLC, Business Advance Team LLC, d.b.a. Everyday Capital, and Newco Capital Group VI LLC, all of New York, at the U. S. District Court for the Southern District of New York.

Subhash Patel v. Koninklijke NA et al: Class Action Complaint

Class Action Complaint alleging securities fraud in Subhash Patel v. Koninklijke N.A., of the Netherlands, described as the operator of "a health technology company in North America, Greater China, and internationally"; Frans van Houten, and Abhijit Bhattacharya at the U. S. District Court for the Eastern District of New York.

USA v. Jorge Nobrega: Criminal Complaint

Criminal Complaint alleging conspiracy to violate International Emergency Economic Powers Act, conspiracy to commit money laundering, and money laundering involving Petróleos de Venezuela SA, a.k.a. PDVSA, and "millions of dollars of transfers on behalf of the Venezuelan Government" in USA v. Jorge Nobrega at the U. S. District Court for the Southern District of Florida.

SEC v. GPL Ventures LLC et al: Complaint

Complaint "to halt the GPL Defendants' ongoing violations of the dealer registration requirements of the federal securities laws", including alleged fraud, that involves, inter alia, an unidentified "broker in the Cayman Islands" in U. S. Securities and Exchange Commission v. GPL Ventures LLC, GPL Management LLC, described as Delaware-domiciled, New York-based companies; Alexander J. Dillon, of New Jersey; Cosmin I. Panait, described as a citizen of Romania residing in New York; HempAmericana Inc., described as a Delaware-domiciled, New York-based company; Salvador E. Rosillo, of New York; Seaside Advisors LLC, of New Jersey, and Lawrence B. Adams, of New Jersey, at the U. S. District Court for the Southern District of New York.

Jeffrey Crass v. Yalla Group Ltd. et al: Class Action Complaint

Class Action Complaint alleging securities fraud in Jeffrey Crass v. Yalla Group Limited, described as a Cayman Islands-domiciled "voice-centric social networking and entertainment platform that operates mainly in the Middle East and Northern Africa", and Tao Yang at the U. S. District Court for the Southern District of New York.

Brian Kang et al v. Hybrid Trade Ltd. et al: Complaint

Complaint alleging theft, misappropriation, and securities fraud regarding the raising of $50 million "from investors based around the world, including within the United States" from the sale of "digital tokens" that were "neither registered with the United States Securities and Exchange Commission nor qualified for any exemption from registration with the SEC, thereby depriving investors of the benefit of the disclosures required by the federal securities laws" in Brian Kang, Skyblock LLC, Mid-Wilshire Consulting LLC, Prasad Hurra, David Kim, Blue Rock Group, Artemio Verduzo, David Kwon, and Young Jae Kwon v. Hybrid Trade Limited, described as operating from addresses in Hong Kong, Malta, and Singapore; Asia Digital Asset Exchange, described as operating from an address in Cyprus; Allysian Sciences, Apolo Ohno, a former Olympic speed skating champion; Rod Jao, Eugenio Pugliese, and Henry Liu at the U. S. District Court for the Central District of California.

Vickers Holding & Finance Inc. v. Chora Young LLP et al: Complaint

Complaint alleging legal malpractice in Vickers Holding & Finance Inc., a British Virgin Islands firm whose principal "is Elena Volkova, who is a citizen of the Netherlands" v. Chora Young LLP, a law firm in California, and Paul P. Young, an attorney, at the Superior Court of the State of California, for the County of Los Angeles.

Blackbird Capital LLC v. SION Trading FZE et al: First Amended Complaint

First Amended Complaint that "arises out of the Defendants' bad faith and fraudulent scheme, including a pattern of tortious and illegal misconduct and breaches of multiple contracts, related to a $25,000,000 loan Worth agreed to extend to Blackbird in connection with a planned real estate development project in Denver, Colorado" in Blackbird Capital LLC, described as "a real estate development company" in Iowa v. Worth Group Capital LLC, of Wyoming; Justin Ely, of Utah; Halls Law Office, of Idaho; Scotia International of Nevada, Inc., of Utah; Sion Trading FZE, of Ras Al Khaimah, in the United Arab Emirates; Max Warren Barber, of Utah; NaPo Limited, described as "a company located and incorporated in Bridgetown, Barbados, and Saint Lucia"; Nikolas Korakianitis, described as a citizen of Canada; GT Foundation, described as "a private interest foundation founded in Panama City, Panama" that "may have an office in London, England and/or New York", and Kumar Singh, of New York, at the U. S. District Court for the District of Utah.

Stephen Puleo et al v. Burgundy 523 Offshore Fund Ltd. et al: Complaint

Complaint alleging fraud by 122 investors, "many of whom are senior citizens", who are "among 261 individuals, who collectively invested $75.5 million to buy interests in a student housing project in reliance on a series of false statements in the offering documents made by the sponsor of the offering and a financier that facilitated the offering" in Stephen Puleo et al v. Patrick Nelson, of California; Nelson Partners LLC, of Utah; Axonic Capital LLC, of Delaware; Clayton Degiancinto, of New York; AxSPV LLC Series NB CRE Lender, of Delaware; AxSPV LLC Series SBL CRE Lender, of Delaware; AxSPV LLC Series ACO CRE Lender, of Delaware; Burgundy 523 Offshore Fund Ltd., of the Cayman Islands; Axonic Special Opportunities SBL Master Fund LP, of Delaware, and Axonic Credit Opportunities Master Fund LP, of the Cayman Islands, at the U. S. District Court for the Central District of California.

Platts v. Wood Mackenzie Ltd.: Complaint

Complaint "to recover actual damages for breach of the applicable licensing agreement, breach of the covenant of good faith and fair dealing, and misappropriation" in S&P Global Inc., d.b.a. Platts, described as a New York-based "independent information and services provider that observes, analyzes, and reports on the commodities and energy markets" v. Wood Mackenzie Limited, described as a United Kingdom firm that "provides consulting services and market research to the oil, gas, coal, metals, and mining industries, including reports on major companies operating in those areas, trends analysis and forecasts, and executive overviews", at the U. S. District Court for the Southern District of New York.

SEC v. Evarist Amah: Complaint

Complaint alleging fraud in which several of the victims were residents of Nigeria and Italy in U. S. Securities and Exchange Commission v. Evarist C. Amah, described as a New York-based investment adviser, at the U. S. District Court for the Southern District of New York.

Daniel Valenti v. Dfinity Foundation et al: Class Action Complaint

Class Action Complaint alleging a cryptocurrency-related fraud and sale of unregistered securities in Daniel Valenti, of Tampa, Florida v. Dfinity USA Research LLC, described as a Delaware company based in Palo Alto, California; Dfinity Foundation, of Switzerland, and Dominic Williams, of Palo Alto, California, at the U. S. District Court for the Northern District of California.

Frost & Miller v. Heaven’s Way Investment Trust et al: Complaint

Complaint alleging fraud in Frost & Miller LLP, a law firm based in New York v. Heaven's Way Investment Trust, of Georgia, USA; Rayshawn Delbridge, of New Jersey; Aaron Cain McKnight, of Texas; SubGallagher Investment Trust, of Wyoming; Ann Fox, described as a citizen of the United Kingdom residing in Wiltshire, England; Femi Omomo, described as a citizen of the United Kingdom residing in Horley, England, and Henderson & Jones Limited, of England, at the U. S. District Court for the Southern District of New York.

TCA Fund Management Group Corp. et al v. American Express Company et al: Complaint

Complaint "to recover fraudulent transfers" in Jonathan Perlman, as court-appointed Receiver of TCA Fund Management Group Corp., of Florida; TCA Global Credit Fund GP Ltd., TCA Global Credit Fund LP, TCA Global Credit Fund Ltd., TCA Global Credit Master Fund LP, all of the Cayman Islands, and TCA Global Lending Corp., of Nevada v. American Express Company, American Express National Bank, and American Express Travel Related Services Co. Inc. at the U. S. District Court for the Southern District of Florida.

Steve Klein v. Iterum Therapeutics Plc et al: Class Action Complaint

Class Action Complaint alleging fraud in Steve Klein v. Iterum Therapeutics Plc, described as an Irish "clinical-stage pharmaceutical company that engages in developing anti-infectives for multi-drug resistant pathogens in Ireland and the U.S."; Corey N. Fishman, and Judith M. Matthews at the U. S. District Court for the Northern District of Illinois.

SEC v. Frederick Sharp et al: Complaint

Complaint alleging "a sophisticated, multiyear, multi-national attack on the United States financial markets and retail United States investors by foreign and domestic actors" in which the defendants "schemed to sell fraudulently hundreds of millions of dollars in stocks in the United States markets" in U. S. Securities and Exchange Commission v. Frederick L. Sharp, described as a citizen of the United States; Zhiying Yvonne Gasarch, a.k.a. Zhiying Chen, described as a dual citizen of Canada and China; Courtney Kelln, Mike K. Veldhuis, described as a citizen of the Netherlands; Paul Sexton, described as a citizen of the United Kingdom; Jackson T. Friesen, Graham R. Taylor, described as a citizen of the United Kingdom, all residents of British Columbia, Canada; William T. Kaitz, of Maryland, and Avtar S. Dhillon, described as a citizen of Canada residing in Long Beach, California, at the U. S. District Court for the District of Massachusetts.

SEC v. Luis Carrillo et al: Complaint

Complaint alleging securities fraud involving shares in Aureus, Inc., Garmatex Holdings, Ltd., and OneLife Technologies Corp. and "a boiler room based in Medellin, Colombia" in U. S. Securities and Exchange Commission v. Luis Jimenez Carrillo, described as a citizen and resident of Mexico; Amar Bahadoorsingh, described as "a dual citizen of the United Kingdom and Canada" residing in Vancouver, Canada; Justin Roger Wall, and Jamie Samuel Wilson, each described as "a citizen and resident of the United Kingdom", as Defendants, and Haydee Yolanda Sanchez Diaz Monge, Martha Y. Jimenez Trust, and Charles A. Carrillo Trust, all of California, as Relief Defendants, at the U. S. District Court for the District of Massachusetts.