Page 19 of 40 E. Continuing Fraudulent Inducement to Invest in Tokens 65. Throughout the period September 2021 through the present, Defendant Latinum has issued and continued to issue, and publish on its website, press releases that are designed, at least in part, to induce investors and potential investors to invest in Tokens and to lull investors and potential investors to believe that the securities that Defendant Latinum was and purports to issue have value. 66. As recently as January 10, 2022, Defendant Latinum issues a press release claiming to partner with a Grammy-nominated recording artist to acquire what purports to be a non-fungible token in “Cyber Yachts.” The website identified in Defendant Latinum’s press release is only a colorful landing page with no information. 67. Latinum’s website, further to create the appearance of credibility to potential investors, claims to have entered into relationships of different forms with, inter alia, Vast Bank, LBank Exchange, Quavo, OSO ATMs to install ATMs in the United States, AAX Exchange, Hotbit Exchange, HitBTC, Changelly, GK8, Bitmart, XT.com, FMFW.io, DigiFinex Exchange, Monsoon Blockchain, Crypto Climate Accord, H. Wood Group, and CoinMarketCap. 68. On November 1, 2017, the SEC published the “SEC Statement Urging Caution Around Celebrity Backed ICOs” at https://www.sec.gov/news/publicstatement/statement-potentially-unlawful-promotion-icos. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.19 Filed 02/01/22 Page 19 of 40
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