Page 37 of 40 U.S.C. §§ 77e(a), 77e(c), and 77l(a)(1), section 10(b) of the Exchange Act, 15 U.S.C. §78j(b) and Rule 10b-5 thereunder; violation of federal criminal law, including 18 U.S.C. §1343, and sections 25110, 25503, 25504 and 25401 of the California Corporations Code. 171. Defendants also have violated the “unlawful” prong of California Business and Professions Code Section 17200 by their violations of California’s False Advertising Law (Bus. & Prof. Code §§ 17500, et seq.), as set forth above. 172. Defendants also have violated the “fraudulent” prong of California Business and Professions Code Section 17200 by making false and misleading statements regarding their purchase and sale of Tokens, refusal to provide evidence of Tokens and/or a digital wallet or wallets, and refusal to provide evidence of purchase and sale. 173. Defendants also have violated the “unfair” prong of California Business and Professions Code Section 17200 because the acts and practices set forth in this Complaint offend established public policy, violate federal and state law, cause disproportionate harm to investors. Defendants’ conduct also has prevented Plaintiffs and their representatives from making fully informed decisions about the implications of purchasing Tokens from Defendant Latinum through Defendant KJ. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.37 Filed 02/01/22 Page 37 of 40
RkJQdWJsaXNoZXIy NDMyMDk=