Smallfries
Citizen
- Joined
- Jan 1, 2025
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Case Filing
IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION
MegaMinerM (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, and has not paid back its allegedly called bond. At the time of writing, Blazora Corporation owes three full months of interest to MegaMinerM, totalling $70,402.
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, falsely advertised, and authorized misleading advertising.
This case mirrors a previous case where former President lcn sued the same company over the same bond and a similar failure to pay. There are four key differences here, however. First, two months have elapsed since the alleged wrongdoing, adding treble time to the duration in controversy in that case. Second, the amount of shares is nearly 150% greater, showing a great magnitude of investment. Third, the Defendant in this case was put on notice by that case, being Defendant there as well, and should have known to promptly pay the remainder of the interest, but did not. This is inexcusable and outrageous. Finally, the Defendant—perhaps illegally—called the bond they promised would extend until July. Even if accepted as legal, this bond has not been paid back the last two weeks, and the Defendant continues to enjoy the benefits of the bond investment, interest-free. This cannot stand.
In the previous case, the court agreed that the wide range and high dollar value of those offenses should, did, and continued to warrant a high level of scrutiny. The Plaintiff’s counsel in that case humbly petitioned the court for steep punitive damages in order to correct the anti-social behavior on display by the Defendant, and the court readily agreed with no hesitation. It appears even that steep amount did not dissuade the Defendant from his outrageous behavior, and MegaMinerM pleads with the court to follow precedent and put an end to this farce once and for all by levying the award requested below, both to firmly educate the Defendant on his errors, and to serve as an example forever to those that would commit such reprehensible offenses in the future. The Plaintiff here has seen the Defendant refuse to own up to their contractual obligations and even a refusal to amicably negotiate, and has no choice but to file suit here now.
I. PARTIES
1. MegaMinerM (Plaintiff & Bondholder)
2. Nexalin (Agent of Defendant)
II. FACTS
1. On 23 September 2024, Nexalin founded Easy Corporation and thereafter 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”.
2. On 27 September 2024, MegaMinerM purchased 2,604 shares of this bond through a market buy order. The bonds have a face value of $100 each, totalling $260,400. 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.
3. On 5 November 2024, fellow bondholder lcn privately dm’d Nexalin to ask for interest to be paid. Nexalin responded simply with, “Yeah.” Interest was not paid.
4. After all of October and November passed without payment, on 15 December 2024 fellow bondholder 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.
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.”
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.
7. On 22 December 2024, Nexalin filed a Corporation Registration for Blazora Corporation. 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).
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.” Nowhere in the publicly shown terms for the bond was this shown to be a potential option. Approximately ten minutes later, the first (of nine) interest payments were paid out.
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 in lcn v. Blazora Corporation, [2025] FCR 18 up to that point. Nexalin did not respond.
10. On 2 January 2025, an attorney for fellow bondholder 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. Later that day, Exchange CEO Stoppers announced that Blazora Corporation had officially paid its second of nine interest payments.
11. On 6 January 2025, the attorney representing fellow bondholder 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, and instead left the discord.
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 on 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.”
13. On 13 February 2025, fellow bondholder lcn filed suit against Blazora Corporation alleging $274,983.89 in damages.
14. On 25 February 2025, Judge Dartanboy of the Federal Court of Redmont issued summary judgment in favor of the Plaintiff, agreeing that there were no material facts at issue. All damages were upheld, except one portion of the compensatory damages and part of the legal fees. The Judge in that case awarded $233,752.48 in damages, not diminishing any punitive damages.
15. Two days later, on 27 February 2025, Exchange CEO Stoppers announced Defendant had “called” the bond, and had promised that “all interest due to-date along with the bond’s principal” would be paid.
16. On March 8 2025, Plaintiff asked in the Public Exchange General Chat "when will bondholders be paid out?" Later that day, he pinged Defendant's agent. The Agent never responded.
17. As of 17 March 2025, no additional interest past the second payment two and a half months prior nor the principal has been paid.
18. The bond was promised to mature on 1 July 2025. This is four extra months of interest, bringing the total interest payments had the contract been fulfilled to $163,505.
III. CLAIMS FOR RELIEF
1. MegaMinerM and Defendant entered in to an implied contract upon the purchase of the bonds. According to the Contracts Act § 4, the five elements necessary to enter in to 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.
2. 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.”
3. 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.
4. 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.
5. 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.
6. 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.
7. Plaintiff and Defendant entered into another contract on 30 December 2024, when the vote extended the bond’s terms to 1 July 2025. The terms of this agreement stated that “[Defendant’s bond’s] interest payments have been extended by an additional 6 months to 1 July 2025. This means an additional interest payment for each month during the extended period.” This contract does not mention the bond being callable, and after this binding vote the Defendant did not have a right to call until the bond had fully matured. The Plaintiff is owed compensatory damages up until the contractual maturation of the bond.
IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:
1. $70,402 of compensatory damages as a direct result of the breach of contract, following Blazora Corporation’s failure to pay three months of interest, further including the combined future value of each of the three months where no owed interest was paid, if MegaMinerM 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 last paid-for month until now (that being November, so December, January, and February), and adding them together. This is done one more time for the half of the month of March that the bond has remained unpaid, in compensation for Defendant illegally and immorally retaining the bond value for interest-free loans.
2. $97,555 of compensatory damages as a result of the breach of the second contract produced by the announcement of the extension of the bond to 1 July 2025 and then its unceremonious and illegal breach on 27 February 2025. Had the bond fulfilled the last four months of promised interest, the Plaintiff would have earned four extra interest payments. This amount further includes the combined future value of those four months of interest, assuming MegaMinerM 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 February until July, and adding them together.
3. $260,400 of compensatory damages as a result of withholding the face value of the bond from MegaMinerM. Plaintiff is entitled to this as a matter of law, as this is the value of the bonds held in his name.
3. $125,000 of punitive damages due to Misrepresentation by Defendant as defined by the Contracts Act. In lcn v. Blazora Corporation, [2025] FCR 18, this amount was $25,000, $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. Here, that amount is multiplied by five due to the difference in compensatory values between the plaintiff in that case and this one being roughly five and a third greater. This takes into account the three times increase in missed payments, time and a half’ing of face value of held bonds, and the Defendant being previously put on notice. It should also be noted that because the Plaintiff purchased all of their shares in one market order, and the damages in lcn were calculated based on the amount of orders, Plaintiff here would get less than the Plaintiff in that case, despite arguably suffering far more in quantity of shares and length of time. As a result, Plaintiff argues that the amount of orders to purchase the shares should not matter, as buying all of the shares in one go would produce one amount of damages, and buying each of the over 2,000 shares one by one would produce a value in the tens of millions. For consistency, the court should use the method described above.
4. $250,000 of punitive damages due to Fraud by Defendant as defined by the Commercial Standards Act. In lcn v. Blazora Corporation, [2025] FCR 18, this amount was $50,000, $10,000 for each of the five times lcn justifiably relied upon a misrepresentation(s), and lcn suffered actual, quantifiable injury. Here, that amount is multiplied by five due to the difference in compensatory values between the plaintiff in that case and this one being roughly five and a third greater. This takes into account the three times increase in missed payments, time and a half’ing of face value of held bonds, and the Defendant being previously put on notice. It should also be noted that because the Plaintiff purchased all of their shares in one market order, and the damages in lcn were calculated based on the amount of orders, Plaintiff here would get less than the Plaintiff in that case, despite arguably suffering far more in quantity of shares and length of time. As a result, Plaintiff argues that the amount of orders to purchase the shares should not matter, as buying all of the shares in one go would produce one amount of damages, and buying each of the over 2,000 shares one by one would produce a value in the tens of millions. For consistency, the court should use the method described above.
5. $25,000 of punitive damages due to False Advertising by Defendant as defined by the Commercial Standards Act. In lcn v. Blazora Corporation, [2025] FCR 18, this amount was $5,000, $5,000 for each time Defendant authorized a false advertisement for publication. Here, that amount is multiplied by five due to the difference in compensatory values between the plaintiff in that case and this one being roughly five and a third greater. This takes into account the three times increase in missed payments, time and a half’ing of face value of held bonds, and the Defendant being previously put on notice.
6. $25,000 of punitive damages due to Misleading Advertising by Defendant as defined by the Commercial Standards Act. In lcn v. Blazora Corporation, [2025] FCR 18, this amount was $5,000, $5,000 for each time Defendant authorized a misleading advertisement for publication. Here, that amount is multiplied by five due to the difference in compensatory values between the plaintiff in that case and this one being roughly five and a third greater. This takes into account the three times increase in missed payments, time and a half’ing of face value of held bonds, and the Defendant being previously put on notice.
7. $50,000 of punitive damages due to Market Manipulation by Defendant as defined by the Commercial Standards Act. In lcn v. Blazora Corporation, [2025] FCR 18, this amount was $10,000, $10,000 for each time Defendant fraudulently inflated or deflated a company or asset of which they had a responsibility for. Here, that amount is multiplied by five due to the difference in compensatory values between the plaintiff in that case and this one being roughly five and a third greater. This takes into account the three times increase in missed payments, time and a half’ing of face value of held bonds, and the Defendant being previously put on notice. It should also be noted that because the Plaintiff purchased all of their shares in one market order, and the damages in lcn were calculated based on the amount of orders, Plaintiff here would get less than the Plaintiff in that case, despite arguably suffering far more in quantity of shares and length of time. As a result, Plaintiff argues that the amount of orders to purchase the shares should not matter, as buying all of the shares in one go would produce one amount of damages, and buying each of the over 2,000 shares one by one would produce a value in the tens of millions. For consistency, the court should use the method described above.
8. $400,000 of punitive damages due to the Defendant’s flagrant, obscene, and outrageous violations of the law and basic moral and commercial decency. Defendant was previously fined $100,000 for a previous similar violation. Given that the Defendant evidently did not learn their lesson in that case, and the trebling of months elapsed in this case, and the breach of a second contract, and the interest of the court in harshly discriminating against this behavior, and more then quintuple the compensatory damages in this case, and the horrendous implications of allowing one to hold on to called bond principals for interest-free loans, Plaintiff feels it is fair to allow for a four-fold increase in punitive damages to discourage Defendant and other anti-social actors once and for all. Plaintiff maintains that the court was correct in lcn v. Blazora Corporation, [2025] FCR in their ruling that the conduct of Defendant there “so shocked the conscience and was so monstrous in orchestration that no reasonable person could see it as anything except manifestly against the public interest, requiring sharp and steep correction.” Despite repeated previous reminders, petitions by that Plaintiff and this one, and a high-value court case, Defendant has taken zero interest in rectifying their behavior. These punitive damages further take into account the theft of interest from the end of February until now, and theft from voiding the second contract with no recourse. The court must put an end to this anti-market activity with zealous urgency.
9. $391,007.10 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 seventeen day of March 2025
