Page 27 of 40 109. In detrimental reliance on KJ’s representations and investment-related materials on the Bitcoin Latinum website to which KJ directed Plaintiffs to induce Plaintiffs’ investments, Plaintiffs made a series of wire transfers to KJ for the purpose of Plaintiffs investing in the Tokens. 110. Based on these representations, Plaintiffs collectively invested a total of $541,045 in a total of 31,877 Tokens. 111. Defendants intended for Plaintiffs to rely on KJ’s text messages and Latinum’s website to invest in Tokens. 112. Defendant KJ had no intention of purchasing and holding the Tokens on Plaintiffs’ behalf. 113. Defendant KJ never purchased and held Tokens on the Plaintiffs’ behalf. 114. Defendants KJ and Latinum knew that Defendant KJ never purchased and held Tokens on Plaintiffs’ behalf. 115. Plaintiffs were not aware that Defendant KJ never purchased Tokens on their behalf. 116. Plaintiffs were justified in relying on Defendant KJ’s previous text messages and the information provided on Latinum’s website to transfer a collective total of $541,045 to Defendant KJ to purchase a total of 31,877 Tokens Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.27 Filed 02/01/22 Page 27 of 40
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