Page 31 of 40 139. Because Defendant KJ did not use the $541,045 for the purpose for which Plaintiffs transferred the funds, it would be inequitable and unjust for Defendants to retain the $541,045. 140. On October 26, 2021, after Plaintiffs invested $541,045 at an average per Token cost of $16.94 per Token, the Tokens purported to trade at $212.64 per Token on Crypto State, suggesting that the total value of Plaintiffs’ Tokens at that time $6,778,325.28. 141. Defendants’ failure to purchase Tokens resulted in a real-time and immediate loss to the Defendants of the opportunity to sell the Tokens for a gain of approximately $6,238,325.28. 142. As of January 25, 2022, the Tokens purported to be quoted and tradeable for $13.22 per Token on Digifinex, making the total value of Plaintiffs’ Tokens $421,414—or a loss of approximately $118,586 on the value of the Plaintiffs’ total initial investments. COUNT 11 Conversion (Against All Defendants) 143. Plaintiffs incorporate by reference all foregoing factual allegations as if fully set forth herein. 144. Per the agreements, Plaintiffs transferred a total of $541,045 to Defendant KJ to purchase and hold Tokens on Plaintiffs’ behalf. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.31 Filed 02/01/22 Page 31 of 40
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