Page 28 of 40 on their behalf and with the expectation that Defendant KJ would transfer Tokens to Plaintiffs. 117. As a result of Defendants’ false representations that Defendant KJ would purchase and hold Tokens on behalf of Plaintiffs, Plaintiffs collectively transferred $541,045 to Defendant KJ and have suffered damages. COUNT 8 Fraudulent Misrepresentation (Against All Defendants) 118. Plaintiffs incorporate by reference all foregoing factual allegations as if fully set forth herein. 119. 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. 120. In detrimental reliance on Defendant KJ’s text messages and the investment-related materials provided on Defendant Latinum’s website, Plaintiffs were induced to invest in the Tokens. 121. Per the Defendants’ representations, Plaintiffs collectively transferred $541,045 to Defendant KJ to purchase and hold a total of 31,877 Tokens on Plaintiffs’ behalf. 122. Defendants intended for Plaintiffs to rely on Defendant KJ’s previous text messages and the investment materials on Defendant Latinum’s website to Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.28 Filed 02/01/22 Page 28 of 40
RkJQdWJsaXNoZXIy NDMyMDk=