Page 29 of 40 transfer the $541,045 to Defendant KJ to purchase and hold a total of 31,877 Tokens on Plaintiff’s behalf. 123. Defendant KJ had no intention of purchasing and holding Tokens on Plaintiffs’ behalf. 124. Defendants never purchased and held Tokens on Plaintiffs’ behalf. 125. Defendants knew that Defendant KJ never purchased and held Tokens on the Plaintiffs’ behalf. 126. Plaintiffs were unaware that Defendant KJ never purchased Tokens for and on Plaintiffs’ behalf. 127. Plaintiffs were justified in relying on Defendant KJ’s previous text messages and the information on Defendant Latinum’s website to transfer a total of $541,045 to Defendant KJ to purchase and hold a total of 31,877 Tokens on Plaintiffs’ behalf. 128. As a result of Defendants’ false representations, Plaintiffs collectively transferred $541,045 to Defendant KJ, and Plaintiffs have suffered damages. COUNT 9 Breach of Contract (Against Defendant KJ) 129. Plaintiffs incorporate by reference all foregoing factual allegations as if fully set forth herein. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.29 Filed 02/01/22 Page 29 of 40
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