Page 8 of 40 19. Defendants KJ and Latinum provided information to and enticed Plaintiffs to invest in Tokens with an expectation of profits. Specifically, (a) Latinum’s website advertises itself as the “next-generation Bitcoin blockchain-based token, capable of massive transaction volume, digital asset management, cybersecurity, and transaction capacity.” Latinum’s website further states “Bitcoin Latinum asset backing is held in a fund model so that base asset value increases over time. It accelerates this asset back funds growth by depositing 80% of the transaction fee back into the asset fund.” (b) Latinum’s website currently offers its Tokens for “Pre-Sale” to the general public. (c) Latinum’s website advertises that the Token is currently listed on crypto exchanges under the ticker “LTNM.” (d) Latinum purports to target the “Media, Gaming, Cloud Computing, and Telecommunications Industries.” (e) Latinum’s website provides a “Bitcoin Latinum Investor Analysis” which includes projections, risks and mitigating factors, competition, and other indicia of a prospectus or private placement memorandum. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.8 Filed 02/01/22 Page 8 of 40
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