Page 32 of 40 145. However, Defendant KJ never purchased and held Tokens on Plaintiffs’ behalf. 146. Defendants have not returned Plaintiffs’ $541,045. 147. Because Defendants did not use the $541,045 for the purpose for which Plaintiffs transferred the $541,045, the $541,045 belongs to Plaintiffs. 148. Defendants’ possession of the $541,045 is a wrongful exercise of dominion and control over property owned by Plaintiffs in a manner inconsistent with Plaintiffs’ rights as the money’s owner, and as a result, Plaintiffs have suffered damages. 149. 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, making the total value of Plaintiffs’ Tokens at that time $6,778,325.28. 150. Defendants’ failure to purchase the Tokens resulted in a real-time loss to the Defendants of the opportunity to sell the Tokens for a gain of approximately $6,238,325.28. 151. 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. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.32 Filed 02/01/22 Page 32 of 40
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