Smallfries
Citizen
- Joined
- Jan 1, 2025
- Messages
- 2
- Thread Author
- #1
Case Filing
IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION
lcn (Represented by Dragon Law Firm)
Plaintiff
v.
Blazora Corporation
Defendant
Nexalin
Agent of the Defendant
COMPLAINT
The Plaintiff complains against the Defendant as follows:
Blazora Corporation (allegedly formerly known as Easy Corporation) has failed to pay out owed interest. At the time of writing, Blazora Corporation owes two months of interest to lcn, totaling $13,034.
In addition, Blazora has breached the implied contract between company and stakeholder, misrepresented its offer to the investing public and bondholders, committed fraud in the omission of supposed terms of the bond, fraudulently manipulated the market for its own gain, and authorized false and misleading advertising.
The wide range and high dollar value of these offenses, as well as the high public standing of the parties, has and continues to warrant a high level of scrutiny. As a matter of great public interest, President lcn humbly asks the court to observe this case as the highly volatile and important case that it is, and take this as an opportunity to set precedent and greatly disincentivize fraudulent, contract-breaching, and otherwise anti-social or outrageous behavior that is destabilizing to the general welfare.
I. PARTIES
1. Lcn (Plaintiff & Bondholder)
2. Nexalin (Agent of Defendant)
3. Blazora Corporation (Defendant)
II. FACTS
1. On 23 September 2024, Nexalin founded Easy Corporation and listed a bond with a face value of $1,000,000 on The Exchange, a stock exchange hosting several business ventures and entities based in Redmont. This bond was listed under the CUSIP number “EZC24-6M”. (P-004)
2. On 25 September 2024, lcn purchased 931 shares of this bond in five separate transactions at a market price of $39,299.56. The bonds have a face value of $100 each, totalling $93,100. (P-001–003) The bonds held a monthly interest rate of 7.0% and were said to have a maturity date of 1 January 2025. The official issuing date was 1 October 2024. (P-004)
3. On 5 November 2024, lcn privately dm’d Nexalin to ask for interest to be paid. Nexalin responded simply with, “Yeah.” Interest was not paid. (P-005)
4. After all of October and November passed without payment, on 15 December 2024, lcn publicly asked in The Exchange general chat: “@nexalin interest plz #ezc24-6m,” to which Nexalin quickly replied, “Will go out today.” Interest was not paid. (P-006)
5. Later that day, an announcement from Exchange CEO Stoppers (presumably at the behest of Nexalin) said that Easy Corporation “Has been taking aggressive steps to prepare for launch,” and they “Plan[ned] to launch by summer 2025.” (P-015)
6. On 16 December 2024, an announcement from Exchange CEO Stoppers (presumably at the behest of Nexalin) reached out to officially begin a bondholder’s vote as to the matter of extending the bond’s interest payments by six months. (P-010)
7. On 22 December 2024, Nexalin filed a Corporation Registration for Blazora Corporation. (P-016) The documents of this incorporation do not list Easy Corporation in any capacity, nor is there any office announcement on the Easy Corporation (now Blazora Corporation) discord server or the Easy Corporation bond (now Blazora Corporation bond). (P-018, showing that the server had a message dated 23 September 2024 when Easy Corporation was made, and an unedited information bulletin proving the server was originally Easy Corporation; P-019, showing the Blazora discord's announcements channel, with no announcement of the switch from Easy Corporation to Blazora)
8. On 30 December 2024, an announcement from Exchange CEO Stoppers (presumably at the behest of Nexalin) said that the previous vote to extend the duration of the bond had passed, and it would be extended for six months. At this time, Stoppers also announced that “[The] bond and the issuing company (Easy Corporation) have both been named to Blazora.” (P-010) Nowhere in the publicly shown terms for the bond was this shown to be a potential option. (P-004) Approximately ten minutes later, the first (of nine) interest payments were paid out. (P-007)
9. On 31 December 2024, a conference room within Dragon Law Firm was created to ask the Defendant’s agent, Nexalin, to resolve the breach of contract up to that point. Nexalin did not respond. (P-014)
10. On 2 January 2025, an attorney for lcn made an official demand for relief, stating lcn’s willingness to resolve the matter amicably if: (1) immediate payment of all overdue interest was met, (2) a formal explanation of the delays and assurance of compliance going forward was provided, and (3) reimbursement of lcn’s legal fees. Nexalin did not respond. (P-014) Later that day, Exchange CEO Stoppers announced that Blazora Corporation had officially paid its second of nine interest payments. (P-012, P-008)
11. On 6 January 2025, the attorney representing lcn pinged Nexalin. Nexalin responded with, “We are all caught up on bond payments.” The attorney responded, “No, you are still missing the bond payment for the first of January.” Nexalin did not respond, but instead left the discord. (P-014)
12. Later that day, Exchange CEO Stoppers posted that the reason for the failure to pay the third owed month was that the bond’s terms gave them the right to disallow interest to be charged in October, with the first month where interest would be accrued being November. The above terms were provided in the form of a screenshot to a restricted channel, and dated to 23 September 2024, when the bonds were first listed. These newly revealed terms also said that interest will be paid at the end of each month, and that the bond term was to last from 1 October 2024 to 31 March 2025, a period of six months. This is contradictory to the listing information, which said the bond would mature on 1 January 2025. The Exchange claimed they would “[Take] full responsibility for any inconvenience caused by our failure to adequately communicate these terms.” (P-011, P-009)
13. As of 13 February 2025, neither the interest payment for the Month of January, due 31 January 2025 according to the newly revealed terms, nor the fourth interest payment (presumably for October) has been paid. (P-017, showing the final discord announcements for the bond.) lcn still holds their 931 bond shares. (P-013)
III. CLAIMS FOR RELIEF
1. lcn and Defendant entered into an implied contract upon the purchase of the bonds. According to the Contracts Act § 4, the five elements necessary to enter into a contract are: (a) Offer, (b) Acceptance, (c) Consideration, (d) Intent, and (e) Capacity. Contracts do not need to be written out expressly, but can be implied. According to § 6 of the Act, a contract that meets those requirements is valid and enforceable. According to § 7 of the Act, a breach of contract may result in remedies of damages, specific performance, or other equitable relief. The implied contract between the seller and the buyer of bonds listed publicly on an exchange promotes clarity of terms and—most importantly—a promise to pay interest on those bonds. This promise has been broken, and Blazora has breached as a matter of law.
2. Four full months have elapsed since lcn purchased the bond shares. Under the publicly presented terms of the bond, four months of interest should have been paid as of 13 February 2025. Only two have been paid, in late December and early January. Two more months are owed.
3. According to the Contracts Act § 8, Misrepresentation “Happens when a false statement induces another party to enter into a contract.
. . .
Remedies for misrepresentation may include rescission, damages, or other appropriate relief." lcn was induced by false public statements authorized by Blazora in the publicly presented bond terms at the time of purchasing the bond shares.
4. According to the Commercial Standards Act § 6, Fraud is the “Intentional or reckless misrepresentation or omission of an important fact . . . to a victim who justifiably relies on that misrepresentation; and the victim . . . suffered actual, quantifiable injury or damages as a result of the misrepresentation or omission.” This carries a fine of up to $10,000 plus damages. lcn was damaged by fraud when they justifiably relied upon a misrepresentation and made financial decisions with that misrepresentation in mind.
5. According to the Commercial Standards Act § 6, False Advertising is “The act of authorizing a false advertisement for publication.” The maximum fine for this offense is $5,000. lcn was damaged by the false advertisement authorized by Blazora, advertising their bonds as more valuable than they truly were through the omission of unfavorable terms to potential bondholders.
6. According to the Commercial Standards Act § 6, Misleading Advertising is “The act of authorizing a misleading advertisement for publication.” The maximum fine for this offense is $5,000. lcn was damaged by the misleading advertisement authorized by Blazora, misleading them into believing the bonds would mature at a certain date and would have a certain and specific amount of interest payments granted by that date.
7. According to the Commercial Standards Act § 8, Market Manipulation is “The act of fraudulently inflating or deflating the value of a company or asset of which you have a responsibility for.” This carries a fine of up to $10,000 plus damages. In Blazora's act of manipulating the market through the omission of key facts in their public terms which would lower the fundamental value of the asset, lcn was damaged as they were induced to purchase that inflated asset.
IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:
1. $16,526.06 of compensatory damages as a direct result of the breach of contract, following Blazora Corporation’s failure to pay two months of interest, further includes the combined future value of each of the two months where no owed interest was paid, if lcn had received and then reinvested the interest at the time of their payment. Calculated by taking the amounts owed, multiplying each by the formula "x * (1.07)^t", where x is the interest per month owed and t is the amount of time in months from the first two missed payments to now (October and November, four and three months respectively), and adding them together.
2. $25,000 of punitive damages due to Misrepresentation by Defendant as defined by the Contracts Act. $5,000 for each time lcn and Defendant entered into a contract through the former’s purchase of bonds due to misrepresentation(s) made by Defendant.
3. $50,000 of punitive damages due to Fraud by Defendant as defined by the Commercial Standards Act. $10,000 for each of the five times lcn justifiably relied upon a misrepresentation(s), and lcn suffered actual, quantifiable injury.
4. $5,000 of punitive damages due to False Advertising by Defendant as defined by the Commercial Standards Act. $5,000 for each time Defendant authorized a false advertisement for publication.
5. $5,000 of punitive damages due to Misleading Advertising by Defendant as defined by the Commercial Standards Act. $5,000 for each time Defendant authorized a misleading advertisement for publication.
6. $10,000 of punitive damages due to Market Manipulation by Defendant as defined by the Commercial Standards Act. $10,000 for each time Defendant fraudulently inflated or deflated a company or asset of which they had a responsibility for.
7. $100,000 of punitive damages due to the Defendant’s flagrant, obscene, and outrageous violation impacting the officeholder of the most powerful position in the nation that so shocks the conscience and is so monstrous in orchestration that no reasonable person could see it as anything except manifestly against the public interest, requiring sharp and steep correction. Blazora has had several reminders of the owed interest, has not attempted any dialogue, and has totally refused any attempt at negotiation. This brazenly fraudulent and outrageous act towards an upstanding citizen and highly regarded politician indicates that individuals with less ability for legal action than lcn may face similar outrageous behavior, and it is the responsibility of the court to correct this injustice through harsh punitive damages. The naked and unashamed abuse of economic power in a poorly regulated field must not be tolerated. Taken as a whole, these punitive damages are not just about punishing Blazora and restitution for lcn, but to send a clear and firm message that financial misdeeds are not tolerated within our legal system, and that the average citizen can feel safe investing in the future of Redmont.
8. $63,457.82 in legal fees as stipulated by the Legal Damages Act § 9.
V. EVIDENCE
By making this submission, I agree I understand the penalties of lying in court and the fact that I am subject to perjury should I knowingly make a false statement in court.
DATED: This thirteenth day of February 2025
