Page 3 of 40 6. Defendant Bitcoin Latinum (“Latinum”) identifies itself on its website and in press releases that its principal place of business is located at 2100 Geng Road, Palo Alto, California 94303. A search of the online portal for the California Secretary of State, https://businesssearch.sos.ca.gov/, for “Bitcoin Latinum” reflects no such entity existing or authorized to do business in California. Additionally, a search of the online portal for the Santa Clara County (California) Clerk-Recorder for “Bitcoin Latinum” under fictitious business names (doing business as), https://scccroselfservice.org/web/search/DOCSEARCH184S2, reflects no such fictitious business name in Santa Clara County, the California County in which Palo Alto is located. JURISDICTION AND VENUE 7. Plaintiffs file this Complaint and institute these proceedings to recover damages that Plaintiffs sustained arising entirely out of Defendants’ KJ’s and Latinum’s unregistered and unqualified offers and sales of securities in violation of sections 5, 12(a)(1) and 15 of the Securities Act of 1933, 15 U.S.C. §77e, 77l(a)(1) and 77o (“Securities Act”); section 10(b), 15 U.S.C. §78j(b) of the Securities Exchange Act of 1934 (“Exchange Act”); and sections 25110, 25503, 25504 and 25401 of the California Corporations Code; false advertising and unfair competition under California law; and common law fraud, breaches of duties and unjust enrichment. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.3 Filed 02/01/22 Page 3 of 40
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