Page 17 of 40 D. Defendants Induced Plaintiff Farid Jamardov to Invest in Tokens 56. In or about October 2021, Defendant KJ induced FJ to invest in Latinum Tokens. Initially, when KJ discussed the Tokens with FJ, KJ informed FJ that FJ would receive his Tokens the next day, after FJ transferred the funds for the investment. Following that, FJ asked Defendant KJ whether there would be any restrictions on when FJ could sell or trade the Tokens; KJ represented to FJ that KJ assumed there were none. In a series of text message exchanges on or about October 21, 2021, KJ asked FJ for an investment of $200,000 at $14 per Token because KJ claimed that he (KJ) was only $110,000 away from reaching his targeted sales total of Tokens and getting a bonus in connection with such sales. KJ further told FJ that he would be able to immediately sell the Tokens for a profit at $20 per Token. 57. FJ understood that KJ’s reference to KJ’s sales total and expectation of a bonus was that KJ was receiving a commission in connection with KJ’s offer and sale of Tokens by and for Latinum. 58. On or about October 21, 2021, FJ wire transferred $101,045 to KJ as an investment in approximately 6,734 Tokens at $15 per Token. Via text message, KJ then informed FJ that KJ does not know when the Tokens will be in FJ’s digital wallet for FJ. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.17 Filed 02/01/22 Page 17 of 40
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