Page 26 of 40 101. Between September 2021 and January 2022, Defendants KJ and Latinum concealed that KJ never purchased Tokens on behalf of Plaintiffs, which was a material fact. 102. Defendants KJ and Latinum knew KJ never purchased the Tokens on behalf of Plaintiffs and knew that they concealed that information from Plaintiffs. 103. Defendants KJ and Latinum intentionally concealed from Plaintiffs that they never purchased the Tokens on behalf of Plaintiffs. 104. Defendants KJ and Latinum had a duty to disclose to Plaintiffs that KJ never purchased the Tokens on behalf of Plaintiffs. 105. Plaintiffs were unaware that Defendants never purchased the Tokens on their behalf and would have acted differently had they known that information. 106. As a result of Defendants’ concealment of the fact that Defendant KJ never purchased the Tokens on behalf of Plaintiffs, Plaintiffs suffered damages. COUNT 7 Fraudulent Inducement (Against Defendant KJ) 107. Plaintiffs incorporate by reference all foregoing factual allegations as if fully set forth herein. 108. From September 2021 through December 2021, Defendant KJ sent multiple text messages to Plaintiffs SJ, RJ, and FJ seeking to induce each to invest in Tokens with Defendant Latinum. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.26 Filed 02/01/22 Page 26 of 40
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