Page 38 of 40 174. In purchasing Tokens through Defendant KJ—or believing that there was a purchase of Tokens through Defendant KJ, Plaintiffs relied on the misrepresentations made by Defendants. Had Plaintiffs known the truth about Defendants, and their business practices, as set forth above, then Plaintiffs would not have purchased Tokens from Defendant Latinum through Defendant KJ. 175. Plaintiffs have suffered an injury in fact, including the loss of money or property, as a result of Defendants’ unfair, unlawful and/or deceptive practices, as a result of the acts of Defendants set forth throughout this Complaint. Defendants received and continue to hold money and property belonging to Plaintiffs. 176. All of the wrongful and unlawful conduct alleged herein occurred, and may well be continuing to occur, in the conduct of Defendants’ business. Defendants’ wrongful conduct is part of a pattern or generalized course of conduct that appears to be perpetuated and repeated in the State of California, and, possibly, nationwide. 177. Plaintiffs have no adequate remedy at law for the injuries which Plaintiffs have suffered and will continue to suffer until such time as Defendants return all principal and pay damages to Plaintiffs. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.38 Filed 02/01/22 Page 38 of 40
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