Page 30 of 40 130. The agreements between Defendant KJ and Plaintiffs were valid contracts between Defendant KJ and each of the Plaintiffs. 131. Pursuant to the agreements, Defendant KJ was to purchase and hold Tokens on Plaintiffs’ behalf. 132. Plaintiffs performed their obligations under the agreements in that they transferred a total of $541,045 to Defendant KJ to purchase and hold a total of 31,877 Tokens on Plaintiffs’ behalf. 133. Defendant KJ never purchased Tokens for Plaintiffs. 134. As a result of Defendants KJ’s material breach of the agreements, Plaintiffs have suffered damages. COUNT 10 Unjust Enrichment (Against All Defendants) 135. Plaintiffs incorporate by reference all foregoing factual allegations as if fully set forth herein. 136. Defendants KJ and Latinum conveyed a benefit on Defendants in that Plaintiffs transferred a total of $541,045 to Defendant KJ for Defendant Latinum to purchase and hold a total of 31,877 Tokens on Plaintiffs’ behalf. 137. However, Defendant KJ never purchased and held Tokens on Plaintiffs’ behalf. 138. Defendants have not returned Plaintiff’s $541,045. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.30 Filed 02/01/22 Page 30 of 40
RkJQdWJsaXNoZXIy NDMyMDk=