Page 20 of 40 69. Defendant Latinum’s same press release of January 10, 2022 claims that “Latinum currently trades publicly on” HitBTC, FMFW.com, Changelly, Changelly Pro, Lbank, DigiFinex, Hotbit, AAX and XT.com exchanges, claiming trading volume in the billions of dollars. The contention that Tokens “trade publicly” on any or all of these quotation media is materially false and misleading. 70. On or about January 25, 2022, an issuer for which the Chief Executive Officer of Defendant Latinum (“CEO”) served as Chairman and Co-Chief Executive Officer from the issuer’s inception as a blank check company through the Closing of the Business Combination, and for which the CEO continues to serve as a Director, filed a S-1 Registration Statement with the SEC (“S-1”). The S-1 discloses that, “[a]s of the date of this Prospectus, the [cryptocurrency wallet] supports [25 specifically enumerated] Cryptocurrencies and other Digital Assets.” The enumerated cryptocurrencies and other digital assets expressly include Bitcoin, Ethereum, USD Coin and Tether, among others. Noteworthy in its absence is Bitcoin Latinum. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.20 Filed 02/01/22 Page 20 of 40
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