Lawsuit: In Session Privacy Matters (Class Action Group) v. Vanguard Securities LLC [2025] FCR 36

[ToadKing]

Case Filing

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION

Privacy Matters Collective (Class Action Group Represented by Mezimori)
Plaintiff

v.

VANGUARD SECURITIES LLC
Defendant

COMPLAINT
The Plaintiff complains against the Defendant as follows:

Privacy Matters Collective bring this action against Vanguard Securities LLC for multiple violations of the Privacy Act in connection with their Vanguard Market Access (VMA) service.
Since the launch of VMA, till 11/04/2025, Vanguard Securities LLC systematically violated privacy regulations affecting all VMA users by:

1. Falsely claiming a Privacy Policy exists when none was provided. Upon logging into VMA, users are explicitly told "By logging in, you agree to our Terms of Service and Privacy Policy" (P-001), yet no Privacy Policy existed or was accessible anywhere on their platform or Discord server.

2. Deliberately misleading users about privacy disclosures. The VMA Terms of Service explicitly states that the "second part" of their documentation contains "Disclosures" that explain "how your personal information is handled by the firm" (P-004), but no such section exists.

3. Accessing and sharing users' financial information without proper disclosure or consent. VMA had access to Discover Bank account details (including account numbers and balances) as shown in exhibit P-003, despite being a legally separate entity from Vanguard National Bank as clearly shown in Vanguard's own corporate structure (P-005).

4. Denying users the ability to understand or control how their data is used. The VMA interface directly displays private banking information as evidenced in both the JSON data (P-006) and banking interface (P-002), without providing any mechanism to control this access or understand how data is being processed.

5. Failing to provide any mechanism for users to access their own information, correct errors, or submit complaints about data handling as required by law.

I. PARTIES
1. T04DS74 (aka ToadKing) (Plaintiff)
2. Vernicia (Plaintiff)
3. FTLCEO (Plaintiff)
4. KingBOB99878 (Plaintiff)
5. lucaaasserole (aka Luca) (Plaintiff)
6. Naezaratheus (Plaintiff)
7. Nimq_ (Plaintiff)
8. bardiya_king (Plaintiff)
9. Vanguard Securities LLC (Defendant)

II. FACTS
1. Vanguard Market Access, operated by Defendant, requires users to agree to Terms of Service and a Privacy Policy upon login, stating "By logging in, you agree to our Terms of Service and Privacy Policy" (P-001).

2. No Privacy Policy existed or was accessible to users, despite being explicitly referenced at login. This has been confirmed by a VMA executive who admitted: "We are working on one" (P-007).

3. Defendant's Terms of Service claimed there was a "Disclosures" section containing "how your personal information is handled by the firm," but this section does not exist (P-004).

4. Defendant has direct access to users' Discover Bank account information, including account numbers, balances, and transaction details, as evidenced by the VMA interface showing a Plaintiff's account balance of RD$50,000.00 and account number 548-775 (P-002, P-003, P-006).

5. When using Defendant's services, users were not given choices regarding account types or data sharing options as claimed in the Terms of Service.

6. Defendant and Discover Bank are separate legal entities as shown in Vanguard's corporate structure (P-005), yet share sensitive financial information without proper disclosure or consent mechanisms.

7. As defined by Executive Order 24/23, personal identifiable information (PII) is "any information related to an identifiable person". The Defendant collects PII including account numbers and balances and didn't provide users access to information about how this data is collected, stored, or shared, as evidenced by the JSON data response (P-006).

8. Defendant's Terms of Service section "Sweep Program" implied user choice between different account types and data handling options (P-004), but no such choice was provided.

9. These practices affected all VMA users in a uniform manner.

III. CLAIMS FOR RELIEF
1. Violation of Privacy Act Section 5(1)(a): Defendant failed to inform users "why personal information is being collected, how it will be used and who it will be disclosed to" despite claiming to have documentation on this topic (P-001, P-004).

2. Violation of Privacy Act Section 4(2): Defendant failed to provide access to "how private information is collected and stored" while still collecting such information (P-006).

3. Violation of Privacy Act Section 5(1)(c-e): Defendant failed to provide mechanisms for users to access their personal information, correct incorrect information, or make complaints about mishandling.

4. Violation of Privacy Act Section 9(1): Defendant used and disclosed personal information between separate legal entities without proper exceptions or user consent, as demonstrated by data sharing between VMA and Discover Bank (P-002, P-003, P-005, P-006).

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:

1. Compensatory damages for the Class calculated at $25,000 per Class member for improper handling and sharing of sensitive financial data;
2. Punitive damages for the Class calculated at $25,000 per Class member for deliberately misleading users by referencing non-existent privacy disclosures and policies;
3. 30% of the total case value, as provided by Section 9 of the Legal Damages Act.

EVIDENCE:

Spoiler: P-001. Screenshot of VMA login page referencing a non-existent Privacy Policy

Spoiler: P-002. Screenshot of VNB Discord Bot showing Discover Bank account information (account 548-775 with balance of $50,000.00)

Spoiler: P-003. Screenshot of VMA interface showing access to Discover Bank account information (account 548-775 with balance of $50,000.00)

Spoiler: P-004. Copy of VMA Terms of Service referencing non-existent "Disclosures" section

Copy (as of 09/04/2025)

VMA ToS (as of 09/04/2025)

HOW THIS BOOKLET WORKS The Vanguard Market Access Accounts Agreement and Disclosures Booklet (Booklet) is for clients of Vanguard Market Access (VMA). It contains the general terms and conditions, account agreements and disclosures that apply to the accounts offered by VMA through Vang...

docs.google.com

Spoiler: P-005. Screenshot of Vanguard corporate structure showing legal separation between entities

Spoiler: P-006. Screenshot of a JSON data API response from the website, showing account details accessible by Defendant

Spoiler: P-007. Screenshot of admittance by VMA executive that with relation to the Privacy Policy: "We are working on one"

Spoiler: P-008. Collection of consent forms from Class members authorizing representation in this matter

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 11th day of April 2025

 

[ColonelKai]

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
ORDER OF THE COURT

Case [2025] FCR 36
Between:
Privacy Matters Class Action Group
v.
Vanguard Securities

ORDER FOR INTERROGATORIES

The court hereby orders the plaintiff of the case as listed above to specify a person responsible for the defendant organization so that the court may issue a summons. If such information is unavailable to the plaintiff, a statement of such is acceptable by the court. The plaintiff has 24 hours to comply with this order.

Dated this 18th of April, 2025.

 

[Vernicia]

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
ORDER OF THE COURT

Case [2025] FCR 36
Between:
Privacy Matters Class Action Group
v.
Vanguard Securities

ORDER FOR INTERROGATORIES

The court hereby orders the plaintiff of the case as listed above to specify a person responsible for the defendant organization so that the court may issue a summons. If such information is unavailable to the plaintiff, a statement of such is acceptable by the court. The plaintiff has 24 hours to comply with this order.

Dated this 18th of April, 2025.

Vanguard Securities LLC is by our information managed and owned by Nexalin

 

[Vernicia]

During lawsuite filling and this date , it was sold to Stoppers , i am adding screenshot to support this development

 

[ColonelKai]

Writ of Summons

@Stoppers is required to appear before the Federal Court in the case of Privacy Matters (Class Action Group) v. Vanguard Securities LLC [2025] FCR 36

Failure to appear within 72 hours of this summons will result in a default judgement based on the known facts of the case.

Both parties should make themselves aware of the Court Rules and Procedures, including the option of an in-game trial should both parties request one.

 

[Avaneesh2008]

Your honor,

We will like to notify the court that Stoppers/Cope Holdings LLC isn't the legal owner of Vanguard Securities LLC and is not the correct representative for the defendant for this case. We ask the court to summon Nexalin as the correct plaintiff as he owns Vanguard Securities LLC through Vanguard & Co.

 

[ColonelKai]

Your honor,

We will like to notify the court that Stoppers/Cope Holdings LLC isn't the legal owner of Vanguard Securities LLC and is not the correct representative for the defendant for this case. We ask the court to summon Nexalin as the correct plaintiff as he owns Vanguard Securities LLC through Vanguard & Co.

However, Stoppers/Cope Holdings LLC is the owner company of Vanguard Securities correct? Can you please provide evidence as to Nexalin still being the main owner of defendant organisation to clear up the confusion?

 

[Avaneesh2008]

As shown in the acquisition press release presented by the plaintiff, Cope Holdings has bought the technology behind Vanguard Market Access. However, Cope Holdings has not bought the Vanguard Securities LLC company itself. Vanguard Market Access is just a part of Vanguard Securities rather than the company itself.

 

[ColonelKai]

Writ of Summons

@Nexalin is required to appear before the Federal Court in the case of Privacy Matters (Class Action Group) v. Vanguard Securities LLC [2025] FCR 36.

Failure to appear within 72 hours of this summons will result in a default judgement based on the known facts of the case.

Both parties should make themselves aware of the Court Rules and Procedures, including the option of an in-game trial should both parties request one.

 

[Nexalin]

Present

 

[ColonelKai]

Thanks for the timely response - I did not even have time to post the discord summons.

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
ORDER OF THE COURT

Case [2025] FCR 36
Between:
Privacy Matters, Class Action Group
v
Vanguard Securities, LLC

The defendant as summoned hereby must produce within 72 hours a response to the complaint provided above inline with the requirements set forward by the Court Rules and Procedures. Failure to meet the deadline may result in contempt of court or other remedies to the opposing counsel.

@Nexalin
This 23rd of April, 2024

 

[Dartanboy]

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO DISMISS

Whilst technically not falling under Rule 5.7 - Failure to Include Party, the Defense alleges that the Plaintiffs' Counsel has fabricated the list of Plaintiffs. We believe this egregious violation is worthy of dismissal with prejudice.

Evidence:

Spoiler: At least one named Plaintiff did not consent to representation

 

[Dartanboy]

Proof of Retainer by Vanguard:

Spoiler: Retainer

 

[Vernicia]

Your Honour, I'd like to request a side bar.

 

[Vernicia]

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO STRIKE

The Plaintiff respectfully moves this Court to strike KingBOB99878 from the list of class members in this action and to allow the case to proceed with the remaining plaintiffs. This motion is made in good faith to resolve any procedural issues while preserving the substantive claims of the remaining class members.

1. There exists conflicting evidence regarding whether KingBOB99878 consented to join this class action lawsuit. While Plaintiff has a screenshot showing consent was provided, the Defendant has presented contradictory evidence suggesting otherwise.

2. Rather than contesting this factual dispute which cannot be definitively resolved due to the deletion of original messages, Plaintiff voluntarily moves to remove KingBOB99878 from the class to ensure procedural integrity.

3. The remaining plaintiffs (T04DS74, Vernicia, FTLCEO, lucaaasserole, Naezaratheus, Nimq_, and bardiya_king) have all provided valid and documented consent to join this class action and authorize representation.

4. The Court may, at its discretion, verify the consent of any remaining class members individually if it deems necessary, but this can and should be done without dismissing the entire action.

5. The Privacy Act violations alleged in this case affected all VMA users in substantively identical ways, and the claims of the remaining plaintiffs are sufficient to maintain this action as a class proceeding.

6. Dismissal of the entire action with prejudice would constitute a disproportionate and unjust response to what is, at most, a procedural issue regarding a single class member.

WHEREFORE, the Plaintiff respectfully requests that this Court:
1. Strike KingBOB99878 from the list of class members; and
2. Allow this action to proceed with the remaining class members.

DATED: This 24th day of April 2025

 

[Dartanboy]

Case Filing

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION

Privacy Matters Collective (Class Action Group Represented by Mezimori)
Plaintiff

v.

VANGUARD SECURITIES LLC
Defendant

COMPLAINT
The Plaintiff complains against the Defendant as follows:



I. PARTIES
1. T04DS74 (aka ToadKing) (Plaintiff)
2. Vernicia (Plaintiff)
3. FTLCEO (Plaintiff)
4. KingBOB99878 (Plaintiff)
5. lucaaasserole (aka Luca) (Plaintiff)
6. Naezaratheus (Plaintiff)
7. Nimq_ (Plaintiff)
8. bardiya_king (Plaintiff)
9. Vanguard Securities LLC (Defendant)

II. FACTS
1. Vanguard Market Access, operated by Defendant, requires users to agree to Terms of Service and a Privacy Policy upon login, stating "By logging in, you agree to our Terms of Service and Privacy Policy" (P-001).

2. No Privacy Policy existed or was accessible to users, despite being explicitly referenced at login. This has been confirmed by a VMA executive who admitted: "We are working on one" (P-007).

3. Defendant's Terms of Service claimed there was a "Disclosures" section containing "how your personal information is handled by the firm," but this section does not exist (P-004).

4. Defendant has direct access to users' Discover Bank account information, including account numbers, balances, and transaction details, as evidenced by the VMA interface showing a Plaintiff's account balance of RD$50,000.00 and account number 548-775 (P-002, P-003, P-006).

5. When using Defendant's services, users were not given choices regarding account types or data sharing options as claimed in the Terms of Service.

6. Defendant and Discover Bank are separate legal entities as shown in Vanguard's corporate structure (P-005), yet share sensitive financial information without proper disclosure or consent mechanisms.

7. As defined by Executive Order 24/23, personal identifiable information (PII) is "any information related to an identifiable person". The Defendant collects PII including account numbers and balances and didn't provide users access to information about how this data is collected, stored, or shared, as evidenced by the JSON data response (P-006).

8. Defendant's Terms of Service section "Sweep Program" implied user choice between different account types and data handling options (P-004), but no such choice was provided.

9. These practices affected all VMA users in a uniform manner.

III. CLAIMS FOR RELIEF
1. Violation of Privacy Act Section 5(1)(a): Defendant failed to inform users "why personal information is being collected, how it will be used and who it will be disclosed to" despite claiming to have documentation on this topic (P-001, P-004).

2. Violation of Privacy Act Section 4(2): Defendant failed to provide access to "how private information is collected and stored" while still collecting such information (P-006).

3. Violation of Privacy Act Section 5(1)(c-e): Defendant failed to provide mechanisms for users to access their personal information, correct incorrect information, or make complaints about mishandling.

4. Violation of Privacy Act Section 9(1): Defendant used and disclosed personal information between separate legal entities without proper exceptions or user consent, as demonstrated by data sharing between VMA and Discover Bank (P-002, P-003, P-005, P-006).

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:

1. Compensatory damages for the Class calculated at $25,000 per Class member for improper handling and sharing of sensitive financial data;
2. Punitive damages for the Class calculated at $25,000 per Class member for deliberately misleading users by referencing non-existent privacy disclosures and policies;
3. 30% of the total case value, as provided by Section 9 of the Legal Damages Act.

EVIDENCE:

Spoiler: P-001. Screenshot of VMA login page referencing a non-existent Privacy Policy

Spoiler: P-002. Screenshot of VNB Discord Bot showing Discover Bank account information (account 548-775 with balance of $50,000.00)

Spoiler: P-003. Screenshot of VMA interface showing access to Discover Bank account information (account 548-775 with balance of $50,000.00)

Spoiler: P-004. Copy of VMA Terms of Service referencing non-existent "Disclosures" section

Copy (as of 09/04/2025)

VMA ToS (as of 09/04/2025)

HOW THIS BOOKLET WORKS The Vanguard Market Access Accounts Agreement and Disclosures Booklet (Booklet) is for clients of Vanguard Market Access (VMA). It contains the general terms and conditions, account agreements and disclosures that apply to the accounts offered by VMA through Vang...

docs.google.com

Spoiler: P-005. Screenshot of Vanguard corporate structure showing legal separation between entities

Spoiler: P-006. Screenshot of a JSON data API response from the website, showing account details accessible by Defendant

Spoiler: P-007. Screenshot of admittance by VMA executive that with relation to the Privacy Policy: "We are working on one"

Spoiler: P-008. Collection of consent forms from Class members authorizing representation in this matter

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 11th day of April 2025

Objection

PERJURY

They have included a supposed screenshot of KingBOB99878 consenting (In P-008), but the screenshots provided by KingBOB99878 himself show this did not happen.

This suggests the evidence was forged.

 

[Dartanboy]

Answer to Complaint

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
ANSWER TO COMPLAINT

Privacy Matters Class Action Group
Plaintiff

v.

Vanguard Securities LLC
Defendant

I. ANSWER TO COMPLAINT
1. AFFIRM that "Vanguard Market Access, operated by Defendant, requires users to agree to Terms of Service and a Privacy Policy upon login, stating "By logging in, you agree to our Terms of Service and Privacy Policy" (P-001)."

2. AFFIRM that "No Privacy Policy existed or was accessible to users, despite being explicitly referenced at login. This has been confirmed by a VMA executive who admitted: "We are working on one" (P-007)."

3. AFFIRM that "Defendant's Terms of Service claimed there was a "Disclosures" section containing "how your personal information is handled by the firm," but this section does not exist (P-004)."

4. AFFIRM that "Defendant has direct access to users' Discover Bank account information, including account numbers, balances, and transaction details, as evidenced by the VMA interface showing a Plaintiff's account balance of RD$50,000.00 and account number 548-775 (P-002, P-003, P-006)."

5. AFFIRM that "When using Defendant's services, users were not given choices regarding account types or data sharing options," however DENY that this was required by the Terms of Service.

6. NEITHER AFFIRM NOR DENY that "Defendant and Discover Bank are separate legal entities as shown in Vanguard's corporate structure (P-005), yet share sensitive financial information without proper disclosure or consent mechanisms," NOTING that they are subsidiaries of the same company: Vanguard & Co.

7. AFFIRM that Executive Order 24/23 defines "personal identifiable information (PII) is "any information related to an identifiable person". The Defendant collects PII including account numbers and balances and didn't provide users access to information about how this data is collected, stored, or shared, as evidenced by the JSON data response (P-006)," however NOTE that Executive Orders are defined by the Constitution as "A lawful directive issued by the President in the pursuit of his or her duties. Executive Orders must only be used as a mechanism by which the President can exert powers expressly granted to the Executive within the Constitution." which means that this definition is narrowly tailored to information being handled by the Executive Branch of Redmont's Government.

8. DENY that "Defendant's Terms of Service section "Sweep Program" implied user choice between different account types and data handling options (P-004), but no such choice was provided."

9. AFFIRM that "These practices affected all VMA users in a uniform manner."

II. DEFENSES

ON THE FACTS
1. In regards to the Options of Facts 8 and 5, the Terms of Service clearly stated "These options, which vary by Account type and/or with whom you opened your Brokerage Account, may include ..." (emphasis added).

This does not necessitate multiple options.

2. The Terms of Service clearly stated "Unless you select an available alternative, you authorize VMA to use the Vanguard Market Access Deposit Account for your sweep option."

Since there were no available alternatives, users did not select an available alternative, and authorized VMA to use the Vanguard Market Access Deposit Account option, which clearly stated: "Balances in all your like-titled deposit accounts with Discover Bank, including your Deposit Account balances will be aggregated for insurance purposes."

This is a clear statement of the information being used, how it used, and an agreement of these purposes.

ON THE CLAIMS FOR RELIEF
3. Privacy Act Section 5(1)(a) does not necessitate that Defendant "inform users why personal information is being collected, how it will be used and who it will be disclosed to" rather it necessitates that users have the right to "know why your personal information is being collected, how it will be used and who it will be disclosed to" which, by simply opening a Support ticket and asking, this knowledge would be given to them.

Plaintiffs opting to ignore their ability to simply ask a question does not make Defendant liable (see precedent: Lawsuit: Adjourned - The_Donuticus v. GER et al. [2022] SCR 18 | Lawsuit: Adjourned - xxTigOlBittiesxx and LTSlade v. Department of Justice [2021] SCR 16).

4. Privacy Act Section 4(2) does not necessitate that Defendant "provide access to how private information is collected and stored" rather it simply states that "Access to how your private information is collected and stored" is a "Privacy Principle" without stating anything else on the matter. Regardless, if Plaintiffs would simply ask, this information would be given to them.

5. Privacy Act Section 5(1)(c-e) were not violated, as Plaintiffs are able to do these by simply opening a Support ticket. Furthermore, it is the Defendant's interpretation of Section 5(1)(e) that this reserves the right to complain about the organization to a higher entity, such as the DoC or the Courts, not to complain to Vanguard Securities, although this would have been permitted.

6. Privacy Act Section 9(1) was not violated, as data was collected and used solely by Vanguard & Co, and its subsidaries which are part of the same corportate structure, and thus all one company.

Furthermore, even if they were separate entities, users agreed for data to be shared with Discover Bank.

And even furthermore, even if users didn't agree and these were separate entities, users, by providing their information and using the system and withdrawing and depositing through Discover Bank, offer IMPLIED CONSENT to this sharing of information, which is a Common Law concept.

ON DAMAGES
7. Even if we pretend Vanguard disobeyed the law, which they did not, "Compensatory damages for the Class calculated at $25,000 per Class member for improper handling and sharing of sensitive financial data;" cannot be awarded, as the Plaintiffs have failed to offer evidence of an actual, quantifiable damage.

8. Even if we pretend Vanguard disobeyed the law, which they did not,"Punitive damages for the Class calculated at $25,000 per Class member for deliberately misleading users by referencing non-existent privacy disclosures and policies;" cannot be awarded, as a mistake left over from a boiler-plate Terms of Service is not a deliberate misrepresentation, and lacks the requisite "outrageous" condition for Punitive Damages, and the Plaintiffs have failed to offer proof that this was deliberate, and in fact as Nexalin is seen confirming the lack of a Privacy Policy and states that they are working on one, it shows even clearer that this was a small mistake, not a deliberate misrepresentation.

9. The Defendant would like to remind the Court that Legal Fees are always given to the prevailing party of a case, without necessitating a countersuit.

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 24th day of April 2025.

 

[ColonelKai]

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
ORDER OF THE COURT

Case [2025] FCR 36
Between:
Privacy Matters, Class Action Group
v
Vanguard Securities, LLC

REGARDING CONSENT FORM AT DISPUTE
The court acknowledges that the evidence presented by both sides is valid. The court concurs with the plaintiff and the argument made within their motion to strike dated April 25th, and grants them the the remedies sought within. Additionally, the court dismisses both the Motion to Dismiss and the Objection on the grounds of Perjury. The justification to the former is hereby deferred to the aforementioned motion. The perjury objection is denied on the grounds that perjury is a criminal charge, and therefore the courts shall apply the burden of proof standards that any criminal charge is held to. The court finds that it is both possible that the evidence may have been fabricated, and that the message simply may have been deleted by the allegedly consenting person. However, the movant has not materialized any evidence or supporting material to push the probability of the former over the balance of probabilities let alone beyond a reasonable doubt.

Furthermore, the court is concerned with the actions of the defendant in regards to their communications with the class action group as listed in the filing. The court hereby warns the defendant to not engage in direct communications with the clients, and if necessary, to communicate through their agreed and legally recognized counsel. The court does not find an issue if the communication was initiated by the clients themselves. This is not a punishment, but simply a reminder. Failure to abide by these rules may threaten the integrity of the case and result in a contempt charge.

Filed this 25th of April, 2025
@Dartanboy @Vernicia @ToadKing

Spoiler: Attachment: Motion to Strike by Plaintiff

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO STRIKE

The Plaintiff respectfully moves this Court to strike KingBOB99878 from the list of class members in this action and to allow the case to proceed with the remaining plaintiffs. This motion is made in good faith to resolve any procedural issues while preserving the substantive claims of the remaining class members.

1. There exists conflicting evidence regarding whether KingBOB99878 consented to join this class action lawsuit. While Plaintiff has a screenshot showing consent was provided, the Defendant has presented contradictory evidence suggesting otherwise.

2. Rather than contesting this factual dispute which cannot be definitively resolved due to the deletion of original messages, Plaintiff voluntarily moves to remove KingBOB99878 from the class to ensure procedural integrity.

3. The remaining plaintiffs (T04DS74, Vernicia, FTLCEO, lucaaasserole, Naezaratheus, Nimq_, and bardiya_king) have all provided valid and documented consent to join this class action and authorize representation.

4. The Court may, at its discretion, verify the consent of any remaining class members individually if it deems necessary, but this can and should be done without dismissing the entire action.

5. The Privacy Act violations alleged in this case affected all VMA users in substantively identical ways, and the claims of the remaining plaintiffs are sufficient to maintain this action as a class proceeding.

6. Dismissal of the entire action with prejudice would constitute a disproportionate and unjust response to what is, at most, a procedural issue regarding a single class member.

WHEREFORE, the Plaintiff respectfully requests that this Court:
1. Strike KingBOB99878 from the list of class members; and
2. Allow this action to proceed with the remaining class members.

DATED: This 24th day of April 2025

Spoiler: Attachment: Motion to Dismiss by Defendant

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO DISMISS

Whilst technically not falling under Rule 5.7 - Failure to Include Party, the Defense alleges that the Plaintiffs' Counsel has fabricated the list of Plaintiffs. We believe this egregious violation is worthy of dismissal with prejudice.

Evidence:

Spoiler: At least one named Plaintiff did not consent to representation

View attachment 54600

Spoiler: Attachment: Objection on the grounds of Perjury by Defendant

Objection

PERJURY

They have included a supposed screenshot of KingBOB99878 consenting (In P-008), but the screenshots provided by KingBOB99878 himself show this did not happen.

This suggests the evidence was forged.

---

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
ORDER OF THE COURT

Case [2025] FCR 36
Between:
Privacy Matters, Class Action Group
v
Vanguard Securities, LLC

DISCOVERY
The court hereby enters the discovery period to last no more than 72 hours if not subject to extensions. The court reminds the defendant of rule 3.6 if it may become relevant due to an amendment by the plaintiff.

Filed this 25th of April, 2025
@Dartanboy @Vernicia @ToadKing

 

[ColonelKai]

Your Honour, I'd like to request a side bar.

Is this request still valid, and if so, the court asks the movant to justify their request.

 

[Dartanboy]

Furthermore, the court is concerned with the actions of the defendant in regards to their communications with the class action group as listed in the filing. The court hereby warns the defendant to not engage in direct communications with the clients, and if necessary, to communicate through their agreed and legally recognized counsel. The court does not find an issue if the communication was initiated by the clients themselves. This is not a punishment, but simply a reminder. Failure to abide by these rules may threaten the integrity of the case and result in a contempt charge.

Your honor, this paragraph suggests that the Defense reached out to these individuals.

We ask to respond.

 

[ColonelKai]

Your honor, this paragraph suggests that the Defense reached out to these individuals.

We ask to respond.

Response denied. I apologise of the insinuation. I had tried to clarify that I was not alleging that the defence had done such actions ("The court does not find an issue if the communication was initiated by the clients themselves. This is not a punishment, but simply a reminder." not a warning) but that such actions will, if caught, be punished. I dont think this is a well established rule or precedence so I thought I'd make sure.

 

[Vernicia]

Is this request still valid, and if so, the court asks the movant to justify their request.

Sidebar is no longer required.

 

[Vernicia]

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR SUMMARY JUDGEMENT

The Plaintiffs move for summary judgment based on the following undisputed material facts AFFIRMED by the Defendant in their Answer to Complaint:

UNDISPUTED MATERIAL FACTS:

1. Defendant required users to agree to a Privacy Policy upon login, stating "By logging in, you agree to our Terms of Service and Privacy Policy" (Answer 1)

2. No Privacy Policy existed for a period of at least four months (Answer 2)

3. A VMA executive admitted no Privacy Policy existed, stating "We are working on one" (Answer 2)

4. Defendant's Terms of Service falsely claimed there was a "Disclosures" section containing "how your personal information is handled by the firm" (Answer 3)

5. Defendant had direct access to users' Discover Bank account information, including account numbers and balances (Answer 4)

6. Users were not given choices regarding account types or data sharing options (Answer 5)

7. Defendant collected personal identifiable information (PII) including account numbers and balances (Answer 7)

8. These practices affected all VMA users in a uniform manner (Answer 9)

LEGAL VIOLATIONS ESTABLISHED:

1. Violation of Privacy Act Section 5(1)(a): Users were denied their right to "know why personal information is being collected, how it will be used and who it will be disclosed to"

2. Violation of Privacy Act Section 4(2): Users were denied "Access to how private information is collected and stored"

3. Violation of Privacy Act Section 9(1): Personal information was shared between legally separate entities without proper disclosure or consent

PRAYER FOR RELIEF:

Based on these undisputed material facts establishing Privacy Act violations as a matter of law, Plaintiffs request:

1. Summary judgment on liability
2. Punitive damages of $20,000 per Plaintiff
3. 30% case value in legal fees, as provided by Section 9 of the Legal Damages Act.

DATED: This 25th day of April 2025

 

[Dartanboy]

Objection

BREACH OF PROCEDURE

A Motion for Summary Judgement should not include additional arguments (see "Legal Violations Established").

The Defense might not oppose Summary Judgement, but agreeing with this Motion would suggest agreement with these false claims.

 

[Vernicia]

Pursuant to Rule 4.7 (Request for Discovery, Opposing Party Movement), the Plaintiff requests the Defendant to produce the following materials relevant to the case:

1. All organizational charts showing the corporate relationship between Vanguard Securities LLC and Discover Bank from January 2025 to April 11, 2025.

2. All documentation, policies, procedures, or technical diagrams showing how user financial data is shared between Vanguard Securities LLC and Discover Bank.

3. All internal communications (including but not limited to: messages, chat logs, meeting minutes) mentioning "privacy policy" from January 2025 to April 11, 2025.

4. Any drafts of privacy policies created or worked on prior to April 11, 2025.

5. Documentation of when VMA executives first became aware that no Privacy Policy existed while users were being required to agree to one.

6. Statistics showing total number of users who accessed VMA services between launch and April 11, 2025.

7. Documentation showing the total volume of financial transactions processed during the period without a Privacy Policy.

 

[Vernicia]

Pursuant to Rule 4.8 (Interrogatories), the Plaintiff submits the following interrogatories which the Defendant must answer truthfully and to the best of their ability:

1. When did Vanguard Securities LLC first become aware that it was operating without a Privacy Policy while requiring users to agree to one at login?

2. What specific steps, if any, did Vanguard Securities LLC take to comply with Privacy Act requirements prior to April 11, 2025?

3. Why did Vanguard Securities LLC continue to display "By logging in, you agree to our Terms of Service and Privacy Policy" after becoming aware no Privacy Policy existed?

4. What decision-making process led to the creation of a Privacy Policy on April 11, 2025, and why wasn't this done at launch?

5. Does Vanguard Securities LLC maintain that implied consent is sufficient for sharing financial data between legally distinct entities, and if so, on what legal basis?

 

[Vernicia]

Pursuant to Rule 4.9 (Witness Protocol), the Plaintiff submits the following witness list:

1. Nexalin - Executive of Vanguard Securities LLC
2. Stoppers - VMA Interface Designer/Developer

 

[Vernicia]

Pursuant to Rule 3.3 (Amendment to Complaint), the Plaintiff amends their complaint to modify the parties as follows:

I. PARTIES
1. T04DS74 (aka ToadKing) (Plaintiff)
2. Vernicia (Plaintiff)
3. FTLCEO (Plaintiff)
4. lucaaasserole (aka Luca) (Plaintiff)
5. Naezaratheus (Plaintiff)
6. Nimq_ (Plaintiff)
7. bardiya_king (Plaintiff)
8. Vanguard Securities LLC (Defendant)

This amendment removes KingBOB99878 from the list of plaintiffs in accordance with the Court's Order dated April 25, 2025, which granted our Motion to Strike.

All other elements of the original complaint remain unchanged.

 

[Dartanboy]

1. All organizational charts showing the corporate relationship between Vanguard Securities LLC and Discover Bank from January 2025 to April 11, 2025.

We oppose this because it is unclear and briad. Showing all "corporate relationship" would be an immensely over-encumbering task. Under Rule 4.7, we ask the Judge to deny this request.

2. All documentation, policies, procedures, or technical diagrams showing how user financial data is shared between Vanguard Securities LLC and Discover Bank.

We oppose this because such documents, if they exist, are proprietary information that shall not be made public. Under Rule 4.7, we ask the Judge to deny this request.

3. All internal communications (including but not limited to: messages, chat logs, meeting minutes) mentioning "privacy policy" from January 2025 to April 11, 2025.

We oppose this because such conversations, if they exist, are proprietary information that shall not be made public. Under Rule 4.7, we ask the Judge to deny this request.

4. Any drafts of privacy policies created or worked on prior to April 11, 2025.

We oppose this because it is irrelevant. Privacy Policy drafts were never in effect and have no bearing on this case. Under Rule 4.7, we ask the Judge to deny this request.

5. Documentation of when VMA executives first became aware that no Privacy Policy existed while users were being required to agree to one.

We oppose this because it is impossible to show when someone "became aware" of something. This takes place in the mind, and it cannot be documented. Under Rule 4.7, we ask the Judge to deny this request.

6. Statistics showing total number of users who accessed VMA services between launch and April 11, 2025.

We oppose this because it is irrelevant. The number of users is not relevant to this case. Under Rule 4.7, we ask the Judge to deny this request.

7. Documentation showing the total volume of financial transactions processed during the period without a Privacy Policy.

We oppose this because it is irrelevant. The volume of transactions processed is not relevant to this case. Under Rule 4.7, we ask the Judge to deny this request.

 

[Dartanboy]

Pursuant to Rule 4.8 (Interrogatories), the Plaintiff submits the following interrogatories which the Defendant must answer truthfully and to the best of their ability:

1. When did Vanguard Securities LLC first become aware that it was operating without a Privacy Policy while requiring users to agree to one at login?

2. What specific steps, if any, did Vanguard Securities LLC take to comply with Privacy Act requirements prior to April 11, 2025?

3. Why did Vanguard Securities LLC continue to display "By logging in, you agree to our Terms of Service and Privacy Policy" after becoming aware no Privacy Policy existed?

4. What decision-making process led to the creation of a Privacy Policy on April 11, 2025, and why wasn't this done at launch?

5. Does Vanguard Securities LLC maintain that implied consent is sufficient for sharing financial data between legally distinct entities, and if so, on what legal basis?

Objection

BREACH OF PROCEDURE

Rule 4.8 requires that Interrogatories are asked 72 hours prior to the end of Discovery, which these were not.

We ask they are struck.

 

[Dartanboy]

6. Naezaratheus (Plaintiff)

Motion

MOTION TO STRIKE

Naezaratheus is deported and cannot be a Plaintiff. We ask he be struck from the list as well.

Spoiler: Proof

 

[ToadKing]

Filing made in error

 

[Nim]

We oppose this because it is unclear and briad. Showing all "corporate relationship" would be an immensely over-encumbering task. Under Rule 4.7, we ask the Judge to deny this request.


We oppose this because such documents, if they exist, are proprietary information that shall not be made public. Under Rule 4.7, we ask the Judge to deny this request.



We oppose this because such conversations, if they exist, are proprietary information that shall not be made public. Under Rule 4.7, we ask the Judge to deny this request.



We oppose this because it is irrelevant. Privacy Policy drafts were never in effect and have no bearing on this case. Under Rule 4.7, we ask the Judge to deny this request.



We oppose this because it is impossible to show when someone "became aware" of something. This takes place in the mind, and it cannot be documented. Under Rule 4.7, we ask the Judge to deny this request.



We oppose this because it is irrelevant. The number of users is not relevant to this case. Under Rule 4.7, we ask the Judge to deny this request.



We oppose this because it is irrelevant. The volume of transactions processed is not relevant to this case. Under Rule 4.7, we ask the Judge to deny this request.

Your honour, I am a practising Barrister with Mezimori and co-counsel to this case.

PLAINTIFF'S RESPONSE TO DEFENDANT'S OPPOSITIONS TO DISCOVERY REQUESTS

The Plaintiff respectfully submits the following responses to Defendant's objections:

1. Regarding organisational charts showing corporate relationships:
This request is neither unclear nor broad. It specifically seeks documents limited to a 4-month timeframe that show the legal relationship between two specific entities. These documents are directly relevant to the Defendant's assertion that data sharing between "subsidiaries of the same company" does not require consent. The corporate structure is a central element in determining whether separate legal entities were sharing personal data without proper disclosure, which is the core of our Privacy Act claims.

2. Regarding documentation of data sharing:
The "proprietary" objection has no basis in discovery rules. Rule 4.7 requires only that "material must be relevant to the case." How user data was shared between entities is directly relevant to our claims under Privacy Act Section 9(1). Furthermore, the court can implement protective orders if necessary to prevent public disclosure while allowing the material to be used in litigation. The Defendant has already AFFIRMED they collect and share such data; we merely seek documentation of how this was done.

3. Regarding internal communications mentioning "privacy policy":
Again, "proprietary" is not a valid objection under Rule 4.7. These communications are directly relevant to establishing whether the lack of a Privacy Policy was a deliberate choice or reckless disregard, which is essential for our punitive damages claim. The Defendant has already AFFIRMED that no privacy policy existed; we seek only to understand the intentional nature of this omission. Without this information, we cannot establish the degree of culpability necessary for appropriate damages.

4. Regarding drafts of privacy policies:
This request is highly relevant. If drafts existed prior to April 11, 2025, this would show the Defendant was aware of the need for a Privacy Policy while continuing to operate without one. This directly contradicts their defence characterising the omission as a mere "mistake left over from a boiler-plate Terms of Service." The existence of drafts would demonstrate knowledge and deliberate inaction.

5. Regarding documentation of executive awareness:
The Defendant mischaracterises our request. We do not seek to document thoughts, but rather tangible evidence such as messages, meeting minutes, or internal memos where executives discussed the missing Privacy Policy. The Defendant's own executive has already admitted they were "working on one" (P-007), clearly showing awareness. We merely seek documentation of when this awareness occurred, which is critical for establishing the duration of knowing non-compliance.

6. Regarding user statistics:
The number of users is directly relevant to determining the scope of the Privacy Act violations and appropriate punitive damages. Courts regularly consider the number of affected individuals when assessing damages for privacy violations. The Defendant already AFFIRMED these practices "affected all VMA users in a uniform manner" - we simply seek to quantify "all users" to properly assess the scale of the violations.

7. Regarding transaction volume:
The volume of sensitive financial data processed without proper privacy protections is directly relevant to establishing "outrageous conduct" under Section 5 of the Legal Damages Act, which is the legal threshold for punitive damages. A financial institution processing millions in transactions while knowingly operating without required privacy disclosures demonstrates a particularly egregious disregard for privacy obligations, well beyond mere oversight. The scale of sensitive financial data exposed to improper handling directly correlates to the potential harm and thus the "outrageous" nature of the violations, making this information essential for the Court to properly assess punitive damages.

The Plaintiff respectfully requests that the Court order the Defendant to produce all requested discovery materials, as each request is narrowly tailored to obtain information directly relevant to our claims under the Privacy Act and the determination of appropriate damages.

 

[Nim]

Objection

BREACH OF PROCEDURE

Rule 4.8 requires that Interrogatories are asked 72 hours prior to the end of Discovery, which these were not.

We ask they are struck.

EXTENSION OF DISCOVERY AND RESPONSE TO INTERROGATORIES OBJECTION

Pursuant to Rule 4.4 (Request for Extension of Discovery), the Plaintiff respectfully requests an extension of the discovery period and submits the following response to Defendant's objection regarding our interrogatories:

1. Logical Impossibility in Rule Application

Rule 4.8 contains two requirements that create a logical impossibility in the current timeframe:
a) Interrogatories may only be asked "while within discovery"
b) Interrogatories "must be made 72 hours prior to the end of discovery"

The Court ordered on April 25, 2025 at 11:55pm (UTC+1) that "discovery period to last no more than 72 hours." This creates a paradoxical situation where:
- We cannot submit interrogatories before discovery begins (violating the "while within discovery" requirement)
- We cannot submit them after discovery begins because any time within the 72-hour window would be less than 72 hours before discovery ends

This creates a situation where interrogatories become impossible to use in any 72-hour discovery period, effectively nullifying a key discovery tool provided by the rules.

2. Request for Extension

We respectfully request a 3-day extension of discovery pursuant to Rule 4.4 to resolve this contradiction and allow for the proper use of interrogatories as contemplated by the Court Rules. This extension would:
a) Allow our existing interrogatories to meet the 72-hour requirement
b) Preserve the intended purpose of Rule 4.8
c) Ensure both parties have access to this important discovery tool

3. Alternative Relief

Should the Court decline to extend discovery, we alternatively request the Court exercise its discretion under Rule 1.2 (Presiding Judge) to allow our interrogatories despite the timing issue, considering:
a) The inherent contradiction in the rules
b) The fact that we submitted interrogatories at the earliest possible time (within 14 hours of discovery beginning)
c) The critical relevance of the information sought to the undisputed Privacy Act violations

The Plaintiff submits that justice would be best served by either extending discovery or allowing the interrogatories to proceed despite the timing issue created by the inherent contradiction in Rule 4.8 when applied to a 72-hour discovery period.

 

[Dartanboy]

Your honour, I am a practising Barrister with Mezimori and co-counsel to this case.

PLAINTIFF'S RESPONSE TO DEFENDANT'S OBJECTIONS TO DISCOVERY REQUESTS

The Plaintiff respectfully submits the following responses to Defendant's objections:

1. Regarding organisational charts showing corporate relationships:
This request is neither unclear nor broad. It specifically seeks documents limited to a 4-month timeframe that show the legal relationship between two specific entities. These documents are directly relevant to the Defendant's assertion that data sharing between "subsidiaries of the same company" does not require consent. The corporate structure is a central element in determining whether separate legal entities were sharing personal data without proper disclosure, which is the core of our Privacy Act claims.

2. Regarding documentation of data sharing:
The "proprietary" objection has no basis in discovery rules. Rule 4.7 requires only that "material must be relevant to the case." How user data was shared between entities is directly relevant to our claims under Privacy Act Section 9(1). Furthermore, the court can implement protective orders if necessary to prevent public disclosure while allowing the material to be used in litigation. The Defendant has already AFFIRMED they collect and share such data; we merely seek documentation of how this was done.

3. Regarding internal communications mentioning "privacy policy":
Again, "proprietary" is not a valid objection under Rule 4.7. These communications are directly relevant to establishing whether the lack of a Privacy Policy was a deliberate choice or reckless disregard, which is essential for our punitive damages claim. The Defendant has already AFFIRMED that no privacy policy existed; we seek only to understand the intentional nature of this omission. Without this information, we cannot establish the degree of culpability necessary for appropriate damages.

4. Regarding drafts of privacy policies:
This request is highly relevant. If drafts existed prior to April 11, 2025, this would show the Defendant was aware of the need for a Privacy Policy while continuing to operate without one. This directly contradicts their defence characterising the omission as a mere "mistake left over from a boiler-plate Terms of Service." The existence of drafts would demonstrate knowledge and deliberate inaction.

5. Regarding documentation of executive awareness:
The Defendant mischaracterises our request. We do not seek to document thoughts, but rather tangible evidence such as messages, meeting minutes, or internal memos where executives discussed the missing Privacy Policy. The Defendant's own executive has already admitted they were "working on one" (P-007), clearly showing awareness. We merely seek documentation of when this awareness occurred, which is critical for establishing the duration of knowing non-compliance.

6. Regarding user statistics:
The number of users is directly relevant to determining the scope of the Privacy Act violations and appropriate punitive damages. Courts regularly consider the number of affected individuals when assessing damages for privacy violations. The Defendant already AFFIRMED these practices "affected all VMA users in a uniform manner" - we simply seek to quantify "all users" to properly assess the scale of the violations.

7. Regarding transaction volume:
The volume of sensitive financial data processed without proper privacy protections is directly relevant to establishing "outrageous conduct" under Section 5 of the Legal Damages Act, which is the legal threshold for punitive damages. A financial institution processing millions in transactions while knowingly operating without required privacy disclosures demonstrates a particularly egregious disregard for privacy obligations, well beyond mere oversight. The scale of sensitive financial data exposed to improper handling directly correlates to the potential harm and thus the "outrageous" nature of the violations, making this information essential for the Court to properly assess punitive damages.

The Plaintiff respectfully requests that the Court order the Defendant to produce all requested discovery materials, as each request is narrowly tailored to obtain information directly relevant to our claims under the Privacy Act and the determination of appropriate damages.

Objection

BREACH OF PROCEDURE

These were not Objections, they were oppositions made under Rule 4.7. No response is permitted.

If they had more to say, they should've included it in the original request.

 

[Dartanboy]

Your honor I have some Objections to make but I got an injury which is making it difficult to type could we have a forty eight hour extension to discovery while I go to the doctor and heal up

 

[ToadKing]

Motion

MOTION TO STRIKE

Naezaratheus is deported and cannot be a Plaintiff. We ask he be struck from the list as well.

Spoiler: Proof

View attachment 54645

RESPONSE TO MOTION TO STRIKE

The Plaintiff requests that the Court deny this Motion to Strike as Naezaratheus is no longer subject to deportation status.

Spoiler: Proof

 

[ColonelKai]

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
ORDER OF THE COURT

Case [2025] FCR 36
Between:
Privacy Matters, Class Action Group
v
Vanguard Securities, LLC

REGARDING MOTION FOR SUMMARY JUDGEMENT
The motion for summary judgement dated 25th of April is hereby denied. The court concurs that while facts may not be at dispute, there are still enough legal argument at dispute to necessitate a continued trial.

Spoiler: Attachment: Motion by Plaintiff

Motion​

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR SUMMARY JUDGEMENT

The Plaintiffs move for summary judgment based on the following undisputed material facts AFFIRMED by the Defendant in their Answer to Complaint:

UNDISPUTED MATERIAL FACTS:

1. Defendant required users to agree to a Privacy Policy upon login, stating "By logging in, you agree to our Terms of Service and Privacy Policy" (Answer 1)

2. No Privacy Policy existed for a period of at least four months (Answer 2)

3. A VMA executive admitted no Privacy Policy existed, stating "We are working on one" (Answer 2)

4. Defendant's Terms of Service falsely claimed there was a "Disclosures" section containing "how your personal information is handled by the firm" (Answer 3)

5. Defendant had direct access to users' Discover Bank account information, including account numbers and balances (Answer 4)

6. Users were not given choices regarding account types or data sharing options (Answer 5)

7. Defendant collected personal identifiable information (PII) including account numbers and balances (Answer 7)

8. These practices affected all VMA users in a uniform manner (Answer 9)

LEGAL VIOLATIONS ESTABLISHED:

1. Violation of Privacy Act Section 5(1)(a): Users were denied their right to "know why personal information is being collected, how it will be used and who it will be disclosed to"

2. Violation of Privacy Act Section 4(2): Users were denied "Access to how private information is collected and stored"

3. Violation of Privacy Act Section 9(1): Personal information was shared between legally separate entities without proper disclosure or consent

PRAYER FOR RELIEF:

Based on these undisputed material facts establishing Privacy Act violations as a matter of law, Plaintiffs request:

1. Summary judgment on liability
2. Punitive damages of $20,000 per Plaintiff
3. 30% case value in legal fees, as provided by Section 9 of the Legal Damages Act.

DATED: This 25th day of April 2025

Filed this 28th of April 2025.
@Vernicia @Dartanboy

---

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
ORDER OF THE COURT

Case [2025] FCR 36
Between:
Privacy Matters, Class Action Group
v
Vanguard Securities, LLC

REGARDING REQUESTS OF DISCOVERY
The court agrees with both sides on certain topics on this argument. The court concurs that the requests are valid for the documentation, and they are indeed relevant in showing character and intent which may help build plantiff's case. However, it must be noted that these are requests for existing documentation or simple evidence providing. The plaintiff cannot compel the defendant to create new documentation on information. This should be something that should be sought through interrogatives. In this interest;

1. The Request for Discovery numbered 5 is struck from validity, as it's specification of what documentation it seeks is vague and does not actually point to any actual pieces of document. This should have been an interrogative.
2. The remaining requests are hereby upheld by the court and the court compels the defendant to produce the evidence IF they have ready access to the information. The court would like to remind the defendant that any omission of readily available information requested will result in perjury charges and further ramifications.

The court additionally denies objection on the grounds of breach of procedure by the defendant as it saves us time if nobody has to ask for ability to respond to motions, objections and things that are similar to the mentioned.

Spoiler: Attachment: Requests for Discovery & Opposition

Pursuant to Rule 4.7 (Request for Discovery, Opposing Party Movement), the Plaintiff requests the Defendant to produce the following materials relevant to the case:

1. All organizational charts showing the corporate relationship between Vanguard Securities LLC and Discover Bank from January 2025 to April 11, 2025.

2. All documentation, policies, procedures, or technical diagrams showing how user financial data is shared between Vanguard Securities LLC and Discover Bank.

3. All internal communications (including but not limited to: messages, chat logs, meeting minutes) mentioning "privacy policy" from January 2025 to April 11, 2025.

4. Any drafts of privacy policies created or worked on prior to April 11, 2025.

5. Documentation of when VMA executives first became aware that no Privacy Policy existed while users were being required to agree to one.

6. Statistics showing total number of users who accessed VMA services between launch and April 11, 2025.

7. Documentation showing the total volume of financial transactions processed during the period without a Privacy Policy.

We oppose this because it is unclear and briad. Showing all "corporate relationship" would be an immensely over-encumbering task. Under Rule 4.7, we ask the Judge to deny this request.


We oppose this because such documents, if they exist, are proprietary information that shall not be made public. Under Rule 4.7, we ask the Judge to deny this request.



We oppose this because such conversations, if they exist, are proprietary information that shall not be made public. Under Rule 4.7, we ask the Judge to deny this request.



We oppose this because it is irrelevant. Privacy Policy drafts were never in effect and have no bearing on this case. Under Rule 4.7, we ask the Judge to deny this request.



We oppose this because it is impossible to show when someone "became aware" of something. This takes place in the mind, and it cannot be documented. Under Rule 4.7, we ask the Judge to deny this request.



We oppose this because it is irrelevant. The number of users is not relevant to this case. Under Rule 4.7, we ask the Judge to deny this request.



We oppose this because it is irrelevant. The volume of transactions processed is not relevant to this case. Under Rule 4.7, we ask the Judge to deny this request.

Filed this 28th of April 2025.
@Vernicia @Dartanboy

---

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
ORDER OF THE COURT

Case [2025] FCR 36
Between:
Privacy Matters, Class Action Group
v
Vanguard Securities, LLC

REGARDING INTERROGATIVES
The court concurs with the plaintiff. The following remedies are hereby ordered by the court;
1. All of the interrogatives, unless objected further, are valid.
2. The discovery is to be extended 72 hours starting the submission of this message.

Spoiler: Attachment: Interrogatives & Objection

Pursuant to Rule 4.8 (Interrogatories), the Plaintiff submits the following interrogatories which the Defendant must answer truthfully and to the best of their ability:

1. When did Vanguard Securities LLC first become aware that it was operating without a Privacy Policy while requiring users to agree to one at login?

2. What specific steps, if any, did Vanguard Securities LLC take to comply with Privacy Act requirements prior to April 11, 2025?

3. Why did Vanguard Securities LLC continue to display "By logging in, you agree to our Terms of Service and Privacy Policy" after becoming aware no Privacy Policy existed?

4. What decision-making process led to the creation of a Privacy Policy on April 11, 2025, and why wasn't this done at launch?

5. Does Vanguard Securities LLC maintain that implied consent is sufficient for sharing financial data between legally distinct entities, and if so, on what legal basis?

Objection

BREACH OF PROCEDURE

Rule 4.8 requires that Interrogatories are asked 72 hours prior to the end of Discovery, which these were not.

We ask they are struck.

Spoiler: Attachment: Response to Objection by Plaintiff

EXTENSION OF DISCOVERY AND RESPONSE TO INTERROGATORIES OBJECTION

Pursuant to Rule 4.4 (Request for Extension of Discovery), the Plaintiff respectfully requests an extension of the discovery period and submits the following response to Defendant's objection regarding our interrogatories:

1. Logical Impossibility in Rule Application

Rule 4.8 contains two requirements that create a logical impossibility in the current timeframe:
a) Interrogatories may only be asked "while within discovery"
b) Interrogatories "must be made 72 hours prior to the end of discovery"

The Court ordered on April 25, 2025 at 11:55pm (UTC+1) that "discovery period to last no more than 72 hours." This creates a paradoxical situation where:
- We cannot submit interrogatories before discovery begins (violating the "while within discovery" requirement)
- We cannot submit them after discovery begins because any time within the 72-hour window would be less than 72 hours before discovery ends

This creates a situation where interrogatories become impossible to use in any 72-hour discovery period, effectively nullifying a key discovery tool provided by the rules.

2. Request for Extension

We respectfully request a 3-day extension of discovery pursuant to Rule 4.4 to resolve this contradiction and allow for the proper use of interrogatories as contemplated by the Court Rules. This extension would:
a) Allow our existing interrogatories to meet the 72-hour requirement
b) Preserve the intended purpose of Rule 4.8
c) Ensure both parties have access to this important discovery tool

3. Alternative Relief

Should the Court decline to extend discovery, we alternatively request the Court exercise its discretion under Rule 1.2 (Presiding Judge) to allow our interrogatories despite the timing issue, considering:
a) The inherent contradiction in the rules
b) The fact that we submitted interrogatories at the earliest possible time (within 14 hours of discovery beginning)
c) The critical relevance of the information sought to the undisputed Privacy Act violations

The Plaintiff submits that justice would be best served by either extending discovery or allowing the interrogatories to proceed despite the timing issue created by the inherent contradiction in Rule 4.8 when applied to a 72-hour discovery period.

Filed this 28th of April 2025.
@Vernicia @Dartanboy

---

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
ORDER OF THE COURT

Case [2025] FCR 36
Between:
Privacy Matters, Class Action Group
v
Vanguard Securities, LLC

REGARDING MOTION TO STRIKE WITNESS
The motion is denied. The court concurs with the response by defense.

Spoiler: Attachment: Motion & Response

Motion

MOTION TO STRIKE

Naezaratheus is deported and cannot be a Plaintiff. We ask he be struck from the list as well.

Spoiler: Proof

View attachment 54645

RESPONSE TO MOTION TO STRIKE

The Plaintiff requests that the Court deny this Motion to Strike as Naezaratheus is no longer subject to deportation status.

Spoiler: Proof

Filed this 28th of April 2025.
@Vernicia @Dartanboy

 

[Dartanboy]

The motion is denied. The court concurs with the response by defense.

Motion

MOTION TO RECONSIDER

Even though he is no longer deported, he was at the time.

In [2025] SCR 2 (Lawsuit: Dismissed - UnityMaster v. lcn [2025] SCR 2), the Supreme Court established the following precedent:

Finally, at the time of filling this case, the plaintiff was indeed deported. Deported players have no rights in our nation and have no rights to dispute this in court.

This precedent is binding to the Federal Court and Naezaratheus must be removed from this case.

 

[Dartanboy]

2. What specific steps, if any, did Vanguard Securities LLC take to comply with Privacy Act requirements prior to April 11, 2025?

Objection

RELEVANCE

Whether Vanguard took steps to comply is irrelevant. What matters is whether or not they actually complied.

4. What decision-making process led to the creation of a Privacy Policy on April 11, 2025, and why wasn't this done at launch?

Objection

RELEVANCE

Any decision-making processes are irrelevant. What matters is whether or not Vanguard complied with the Privacy Act.

 

[Dartanboy]

Pursuant to Rule 4.8 (Interrogatories), the Defendant submits the following interrogatories which the Plaintiff must answer truthfully and to the best of their ability:

1. In what tangible and measurable way were the Plaintiffs damaged by the Defendant's alleged violations?

 

[ToadKing]

Motion

MOTION TO RECONSIDER

Even though he is no longer deported, he was at the time.

In [2025] SCR 2 (Lawsuit: Dismissed - UnityMaster v. lcn [2025] SCR 2), the Supreme Court established the following precedent:



This precedent is binding to the Federal Court and Naezaratheus must be removed from this case.

RESPONSE TO MOTION TO RECONSIDER

The Defendant's motion to reconsider should be denied for the following reasons:

1. The Plaintiff was not deported at the time this case was filed. UnityMaster v. lcn [2025] SCR 2 specifically addressed situations where the plaintiff "was indeed deported" "at the time of filing this case." That precedent is inapplicable here, as Naezaratheus had full citizenship rights when this litigation commenced.

2. Even if the Plaintiff experienced a temporary deportation during these proceedings, he has since been restored to full citizenship status with all associated rights and protections under the Constitution.

3. The Constitution in Part IV, Section 33 guarantees that "Every citizen is equal before and under the law and has the right to equal protection and equal benefit of the law" and that citizens have "the right to a speedy and fair trial".

4. The Defendant's position would create an untenable precedent whereby any citizen who experiences a temporary deportation during lengthy proceedings would be permanently barred from the proceedings, even after their citizenship is fully restored. This directly contradicts the equal protection clause of the Constitution.

The Plaintiff respectfully requests that this Court deny the Defendant's Motion to Reconsider.

 

[ToadKing]

Objection

RELEVANCE

Whether Vanguard took steps to comply is irrelevant. What matters is whether or not they actually complied.

Objection

RELEVANCE

Any decision-making processes are irrelevant. What matters is whether or not Vanguard complied with the Privacy Act.

RESPONSE TO OBJECTIONS

2. What specific steps, if any, did Vanguard Securities LLC take to comply with Privacy Act requirements prior to April 11, 2025?
This interrogatory is directly relevant to establishing whether Vanguard's violations were deliberate or merely negligent, which is central to the "outrageous conduct" assessment required for punitive damages under Section 5 of the Legal Damages Act. The steps taken (or not taken) speak directly to the "character of the defendant's act" which Section 5(3)(a) explicitly permits courts to consider when assessing punitive damages. Knowledge of compliance efforts is essential for determining the level of culpability and appropriate damages.

4. What decision-making process led to the creation of a Privacy Policy on April 11, 2025, and why wasn't this done at launch?
The decision-making process and timing of the Privacy Policy creation are directly relevant to establishing the duration of knowing non-compliance, a key factor in determining whether conduct was "outrageous" under Section 5 of the Legal Damages Act. This information reveals whether Vanguard created a policy only in response to litigation or had been working on compliance, directly impacting the assessment of punitive damages. The timing between awareness of obligation and actual compliance is central to establishing deliberate disregard versus simple oversight.

 

[ToadKing]

Pursuant to Rule 4.8 (Interrogatories), the Defendant submits the following interrogatories which the Plaintiff must answer truthfully and to the best of their ability:

1. In what tangible and measurable way were the Plaintiffs damaged by the Defendant's alleged violations?

1. In what tangible and measurable way were the Plaintiffs damaged by the Defendant's alleged violations?
The Plaintiffs did not suffer quantifiable financial losses as a result of the Defendant's violations. The tangible impact experienced was the deprivation of our statutory rights under the Privacy Act - specifically, our right to know how our sensitive financial information was being collected, used, and shared. This prevented us from making informed decisions about our personal data and created uncertainty regarding the handling of our private financial information. The violations also caused concerns about potential security implications of undisclosed data sharing between entities.

 

[Dartanboy]

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO DISMISS

The Defendant seeks dismissal of this case, and in support thereof, respectfully alleges:

Rule 5.12 - Lack of Personal Jurisdiction (Insufficient Standing)
As per the Plaintiff's response to interrogatories, "The Plaintiffs did not suffer quantifiable financial losses as a result of the Defendant's [alleged] violations."

Rule 2.1 Clearly states:

In order for a plaintiff to pursue a case, they must show the following to the court:

1. Suffered some injury caused by a clear second party; or is affected by an application of law.
2. The cause of injury was against the law.
3. Remedy is applicable under relevant law that can be granted by a favorable decision.

While the Plaintiff has alleged that the actions were against the law, they have failed to show any injury caused by the Defendant's actions. As such, they lack standing to pursue this case.

 

[ToadKing]

Motion

IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO DISMISS

The Defendant seeks dismissal of this case, and in support thereof, respectfully alleges:

Rule 5.12 - Lack of Personal Jurisdiction (Insufficient Standing)
As per the Plaintiff's response to interrogatories, "The Plaintiffs did not suffer quantifiable financial losses as a result of the Defendant's [alleged] violations."

Rule 2.1 Clearly states:


While the Plaintiff has alleged that the actions were against the law, they have failed to show any injury caused by the Defendant's actions. As such, they lack standing to pursue this case.

RESPONSE TO MOTION TO DISMISS

The Plaintiff respectfully opposes Defendant's Motion to Dismiss and submits that the motion fundamentally misinterprets the standing requirements of Rule 2.1:

1. Rule 2.1 explicitly states that a plaintiff must show they "Suffered some injury caused by a clear second party; OR is affected by an application of law" (emphasis added). This is disjunctive - either condition is sufficient. The Plaintiffs are clearly "affected by an application of law" (the Privacy Act), satisfying this requirement regardless of financial injury.

2. The Defendant erroneously equates "injury" exclusively with "financial loss." The Privacy Act specifically creates legal rights to privacy protections, and the deprivation of these rights constitutes a cognizable injury regardless of financial impact.

3. Rule 2.1 provides two separate paths for standing: either "suffered some injury" OR "is affected by an application of law." Our standing primarily is based on the second path - the Plaintiffs are directly affected by the Privacy Act, which governs how their personal information must be handled. The Defendant's motion ignores this alternative basis for standing that is explicitly written in the rule.

4. The Defendant has AFFIRMED multiple Privacy Act violations, including:
- No Privacy Policy existed despite requiring agreement
- False claims about a "Disclosures" section
- Collection of personal information without required disclosures

5. The Plaintiffs have satisfied all three requirements of Rule 2.1:
- First requirement: Plaintiffs are "affected by an application of law" (the Privacy Act)
- Second requirement: The Defendant's AFFIRMED violations were against the law
- Third requirement: Punitive damages under Legal Damages Act Section 5 provide an applicable remedy

The Defendant's motion attempts to rewrite the standing requirements by ignoring the disjunctive language of Rule 2.1 and conflating "injury" exclusively with "financial loss".

The Court should deny this motion and allow this case to proceed on its merits.

 

[ToadKing]

Pursuant to Rule 3.3 (Amendment to Complaint), the Plaintiff amends the Prayer for Relief section of the Complaint as follows:

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:

1. Punitive damages in the amount of $50,000 per Plaintiff for the Defendant's outrageous conduct in violation of the Privacy Act;
2. An order requiring Defendant to implement proper consent mechanisms for data sharing between subsidiaries;
3. Legal fees as provided by Section 9 of the Legal Damages Act.

EXPLANATION FOR AMENDMENT:

This amendment removes the request for compensatory damages and increases punitive damages to $50,000 per Plaintiff, based on the following factors authorised by Section 5(3)(a) of the Legal Damages Act:

1. Character of the Defendant's Act: The Defendant, a sophisticated financial institution, AFFIRMED that for approximately four months it:
- Required users to agree to a non-existent Privacy Policy
- Falsely claimed their documentation contained privacy disclosures
- Collected and shared sensitive financial data without proper disclosure
These actions demonstrate a deliberate or recklessly negligent approach to fundamental privacy obligations.

2. Need for Deterrence: Section 5(1)(a) explicitly states that punitive damages serve "to punish them for their outrageous conduct and to deter them and others like them from similar conduct in the future." A substantial award is necessary to deter similar violations by financial institutions handling sensitive data.

3. Nature of the Violation: The Privacy Act creates fundamental rights regarding personal data. Violations affecting financial information are particularly serious given the sensitive nature of such data and the trust placed in financial institutions.

4. Section 5(1)(a) explicitly states punitive damages are appropriate "where there does not need to be any actual loss to be compensated," confirming the legal basis for substantial punitive damages without compensatory damages.

The amount requested is proportionate to the seriousness of the violations, the need for deterrence, and the Defendant's status as a financial institution handling sensitive user data.