SEC v. COINW6; d/b/a CoinW6.com; 6hsh.com; dmd567.com; bybit.cc; and cglobalw.com, No. 2:24-cv-07924, Central District of California (Sept. 17, 2024) — Complaint

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

1
MATTHEW B. REISIG (NY Bar No. 4898094)
Email: [email protected]
100 F Street, N.E.
Washington, DC 20549
Telephone: (202) 551-6429
Facsimile: (202) 772-9282
DANIEL O. BLAU
(Cal Bar. No. 305008)
Email: [email protected]
444 S. Flower Street, Suite 900
Los Angeles, California 90071
Telephone: (323) 965-3306
Facsimile: (213) 443-1904
Attorneys for Plaintiff
Securities and Exchange Commission
IN THE UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
SECURITIES AND EXCHANGE
COMMISSION,
PLAINTIFF,
v.
COINW6,
d/b/a CoinW6.com, 6hsh.com,
dmd567.com, bybit.cc, and
cglobalw.com,
DEFENDANT.
Case No.:
COMPLAINT
DEMAND FOR
JURY TRIAL
Plaintiff, Securities and Exchange Commission (the “Commission”) alleges as
follows:
2:24-cv-07924

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2
JURISDICTION AND VENUE
1.The Commission brings this action pursuant to Sections 20(b), 20(d), and
22(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77t(b), 77t(d), and
77v(a)], and Sections 21(d), 21(e), and 27 of the Securities Exchange Act of 1934
(“Exchange Act”) [15 U.S.C. §§ 78u(d), 78u(e), and 78aa].
2.This Court has jurisdiction over this action pursuant to Sections 20(b),
20(d)(1), and 22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d)(1), and 77v(a)] and
Sections 21(d), 21(e), and 27 of the Exchange Act [15 U.S.C. §§ 78u(d), 78(e), and
78aa].
3.Defendant, directly or indirectly, made use of the means and
instrumentalities of interstate commerce or the mails in connection with the acts,
transactions, practices, and courses of business alleged in this Complaint.
4.Venue for this action is proper in the Central District of California under
Section 22(a) of the Securities Act [15 U.S.C. § 77v(a)] and under Section 27 of the
Exchange Act [15 U.S.C. § 78aa]. Certain of the acts, practices, transactions, and
courses of business that form the basis for the violations alleged in this Complaint
occurred within the Central District of California. Several investors were residents of
this District at all relevant times, the Defendant sent text messages and communications
which included material misrepresentations into this District to the investors, and the
Defendant offered its crypto asset products as securities to persons residing in this
District including investors.
SUMMARY OF ALLEGATIONS
5.This case concerns a romance investment scam perpetrated by a web of
individuals and entities through a fake online crypto asset platform operating under the
names coinW6.com, 6hsh.com, dmd567.com, bybit.cc, and cglobalw.com (collectively
“CoinW6” or the “Defendant”) that defrauded U.S. investors by contacting them through
social media platforms, gaining their trust, and then manipulating them into transferring
their crypto assets and funds before effectively disappearing.

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

3

6. From at least July 2022 through at least December 2023, individuals who
were either controlled by CoinW6 or who controlled CoinW6 themselves (“Scheme
Participants”) engaged in this coordinated scheme to defraud at least 11 investors out of
more than approximately $2.2 million.
7. The Scheme Participants contacted prospective investors through social
media platforms, such as LinkedIn and Instagram, and then pursued romantic
relationships with them over the messaging platform, WhatsApp. After developing
online romantic relationships with prospective investors, the Scheme Participants
introduced the investors to so-called “cryptocurrency,” claiming that they had earned
hundreds of thousands of dollars through crypto asset products that CoinW6 offered and
sold on its websites through an online crypto trading platform (“CoinW6 Platform”). The
CoinW6 Platform promised two to three percent passive returns per day from crypto
asset staking, mining, or yield farming products that the Defendant purportedly operated.
In fact, the CoinW6 Platform and its products were entirely fictitious.
8. The Scheme Participants instructed investors on how to purchase crypto
assets, such as Tether (USDT) and Ethereum (ETH), and invest those assets on the
CoinW6 Platform. After investing, the Defendant misrepresented to investors that they
were earning massive daily returns while, in reality, the Defendant had already
misappropriated their crypto assets. After a few months of operating the fraud on a
website, and as investors tried to withdraw funds from their accounts, the Defendant
removed content from the website and continued the fraud under a new web domain.
9. The Defendant’s purported crypto asset staking, mining, and yield farming
products were investment contracts and thus securities offered and sold in unregistered
transactions in violation of Sections 5(a) and 5(c) of the Securities Act [15 U.S.C. §§
77e(a) and 77e(c)].
10. By directly or indirectly making materially false statements to investors to
offer and sell investment contracts to investors, and/or engaging in deceptive acts in
connection with the offer, purchase, and sale of these investment contracts, the

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

4

Defendant violated the antifraud provisions of Section 17(a) of the Securities Act [15
U.S.C. §77q(a)] and Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and
Exchange Act Rule 10b-5(a)-(c) [17 C.F.R. § 240.10b-5].
11. In this action, the Commission seeks permanent injunctions prohibiting the
Defendant from violating the securities laws by engaging in the kind of conduct alleged
herein, as well as permanently enjoining the Defendant from directly or indirectly
participating in the issuance, purchase, offer or sale of any security. The Commission
also seeks an order requiring the Defendant to remove all pages of its websites and in its
place post a copy of the Commission’s Complaint, disgorge its ill-gotten gains plus
prejudgment interest, and impose a civil penalty.
DEFENDANT
12. CoinW6 is an unincorporated business with no known address and no
known officers or directors. Individuals in the United Arab Emirates registered the
CoinW6.com web domain on November 11, 2022, through a web domain registrar
located in Singapore. CoinW6 referred to itself as CoinW on its platform, which is the
name of an unrelated, actual crypto asset exchange based in Singapore.
13. As described further herein, CoinW6 did business and operated through a
number of predecessor and successor websites, including 6hsh.com, dmd567.com,
bybit.cc, and cglobalw.com. Individuals registered 6hsh.com on June 10, 2022, with a
web domain registrar located in the People’s Republic of China. Individuals registered
dmd567.com and bybit.cc with the same web domain registrar as CoinW6.com in
Singapore on November 23, 2022, and January 30, 2023, respectively. Individuals in the
People’s Republic of China registered cglobalw.com on June 9, 2023, with a web
domain registrar located in the United States. Regardless of web domain or address, all
iterations of CoinW6’s Platform were nearly identical in appearance and offered similar
purported crypto asset products. As described further herein, regardless of the web
domain name or address, CoinW6 Scheme Participants contacted investors through
similar means and operated in a similar fashion. Upon information and belief,

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

5

CoinW6.com, 6hsh.com, dmd567.com, bybit.cc, and cglobalw.com were controlled by
and part of a single enterprise.
FACTS
I. COINW6’s SCHEME TO DEFRAUD
14. From at least July 2022 through at least December 2023, CoinW6, by and
through the Scheme Participants, perpetrated a coordinated scheme to defraud at least 11
investors out of more than approximately $2.2 million.
A. CoinW6 Scheme Participants Develop Romantic Relationships with
Potential Investors
15. CoinW6’s fraudulent scheme began with Scheme Participants purporting to
be young, attractive professionals contacting prospective investors across the United
States through social media platforms such as LinkedIn and Instagram. Often Scheme
Participants would claim to have mistakenly stumbled upon a prospective investor’s
social media profile.
16. For example, as shown in the screenshots below, on September 8, 2022, a
Scheme Participant using the pseudonym “Margaret,” contacted a prospective investor
residing in California on Instagram claiming to have “accidentally brushed” a post from
the prospective investor and then sought to move the conversation to WhatsApp.

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

6

17. Upon establishing initial rapport, the Scheme Participants then pursued
romantic relationships with prospective investors over the messaging platform,
WhatsApp. The Scheme Participants created and used fictional online personas,
purporting to be managers of businesses like salons in New York or Los Angeles. As
shown below, the Scheme Participants depicted themselves as young, beautiful, and rich
on social media and in photos sent to investors. The Scheme Participants often told
investors that they were frustrated with dating and disappointed with their prior
relationships.
1

18. For example, a Scheme Participant using the pseudonym “Viviana,”
contacted a prospective investor residing in California, “Investor A,” in early September
2022 and told him, over WhatsApp, that she had moved to New York City from
Australia after a divorce and the death of her only child. Viviana also told Investor A
that she owned and managed a salon with 25 employees in the city.

1
 The SEC has anonymized or obscured certain names, identifying information, or
images to protect the identities of alleged victims of this fraud as well as unaffiliated
individuals whose names, images, or likenesses may have been misappropriated by the
Defendant or Scheme Participants to perpetrate the scheme.

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

7

19. In another instance in or around September 2022, a Scheme Participant
using the alias “Arlene,” contacted a prospective investor residing in Missouri, “Investor
B,” over LinkedIn purporting to run a business in New York City after moving there
from China.
20. After establishing initial faux rapport with investors over social media,
Scheme Participants sought to develop online romantic relationships with prospective
investors using WhatsApp. The Scheme Participants would discuss travel, hobbies, prior
relationships, and share photographs. Often after a month of conversations, with very
little mention of “cryptocurrency,” a romantic relationship developed in which the
investor had formed trust in the Scheme Participant, believing their story to be true and
their romantic interest in them to be genuine.
B. Scheme Participants Induce Investors to Purchase Crypto Assets
21. After Scheme Participants had fostered romantic relationships with
prospective investors, they introduced investors to so-called “cryptocurrency,” and
recommended investment into crypto staking, mining, and yield farming products that
the Defendant offered on the CoinW6 Platform. These products, as further described
below, offered different daily returns on invested funds for different periods of time,
such as 3, 7, 15, or 30 days. To invest in CoinW6’s products, the Scheme Participants
directed investors to use U.S. dollars to purchase crypto assets such as Tether (USDT),
which is a crypto asset purportedly pegged to the U.S. dollar, or Ethereum (ETH), on
U.S.-based crypto platforms. From there, they showed investors, using screenshots over
WhatsApp, how to open self-custodial crypto wallets, and then move their USDT or
ETH crypto assets to those self-custodial wallets. The Scheme Participants then showed
the investors how to open an account on the purported CoinW6 Platform and how to

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

8

deposit their USDT or ETH crypto assets into those accounts. After the investors’
accounts on the CoinW6 Platform were purportedly credited with crypto assets, the
Scheme Participants walked the investors through investing in CoinW6’s purported
crypto asset staking, mining, and yield farming products. The investors selected the
product almost always based on the Scheme Participants’ recommendation.
22. In the case of Investor A, for example, on October 10, 2022, after having
developed a romantic relationship over a month, Viviana recommended investing in
crypto assets and introduced Investor A to CoinW6 and its crypto asset products.
23. Specifically, Viviana directed Investor A to 6.hsh.com where Investor A
was presented with what appeared to be an authentic interface which purported to offer
trading in dozens of crypto assets, and which mimicked the features and functionality of
a legitimate trading platform as reflected in the below screenshots Viviana sent to
Investor A over WhatsApp. Viviana then walked Investor A through setting up an
account with CoinW6 on the 6hsh.com interface. The screenshots were of the 6hsh.com
web domain and its successor web domain, coinw6.com, which were nearly identical.

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

9

24. In reality, the Commission’s investigation revealed no evidence that a bona
fide crypto asset trading platform existed and no evidence that any transactions were
executed on the CoinW6 Platform.
25. With Viviana’s guidance, Investor A started investing, first purchasing
$1,000 worth of USDT on a U.S.-based crypto asset platform and transferring those
assets to a self-custodial crypto wallet Viviana showed Investor A how to create. Sharing
screenshots of the wallet and the account Investor A set up on the CoinW6 Platform with
Viviana’s assistance, Viviana walked the investor through transferring the crypto assets
to a crypto address CoinW6 represented as tied to Investor A’s CoinW6 account for the
purpose of investing in the Defendant’s crypto asset products. On or about October 27,
2022, Viviana recommended and again through the use of screenshots, showed Investor
A how to purchase CoinW6’s 3-day crypto asset staking product using the 1,000 USDT.
26. Similarly for Investor B, Arlene directed him to open an account on the
CoinW6 Platform and, in addition to investing in CoinW6’s crypto asset staking and
mining products, she directed trades in crypto asset pairs on the platform to generate
thousands of dollars in returns. Arlene, using screenshots sent over WhatsApp, showed
Investor B how to deposit crypto assets, trade crypto asset pairs, and how to purchase
CoinW6’s products. On December 12, 2022, Investor B invested $5,000 in a purported
crypto asset mining product that Arlene had recommended and that was advertised on

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

10

the CoinW6 Platform.
C. Scheme Participants Pressure Investors to Increase Their Investment
On the CoinW6 Platform
27. As the romantic relationships continued and Investors were led to believe
their investments were generating significant returns by the CoinW6 Platform which
reflected purported profits at several multiples of the principal invested, the Scheme
Participants then urged investors to find more money to invest – even recommending
that investors withdraw funds from retirement accounts or borrow money from friends
and family to generate larger returns on CoinW6. Several of the Scheme Participants
also led investors to believe they had deposited funds into the investors’ CoinW6
accounts to qualify for promotions, pay fees, or to co-invest.
28. For example, on or about November 1, 2022, Viviana told Investor A that
CoinW6’s staking program generates daily returns of 2.2 to 2.6 percent, which she
claimed had amounted to income of $150 in just 3 days on Investor A’s initial
investment of $1,000. Viviana then assisted Investor A in using the principal and
purported proceeds to invest in CoinW6’s 7-day crypto asset mining product. From
November 1 through November 6, Viviana consistently asked Investor A to deposit
more crypto assets to invest into CoinW6’s products, recommending a balance of at least
$50,000.
29. After seeing what appeared to be generous returns reflected on the CoinW6
Platform on the 7-day investment in the crypto asset mining pool, Investor A agreed to
deposit more funds with the assistance of Viviana, bringing his total principal –
excluding any returns – to about 9,500 USDT. On or about November 11, 2022, Viviana
recommended that Investor A invest in CoinW6’s 30-day crypto asset mining product,
which offered daily returns of 3.2 to 3.6 percent, and told the investor that an investment
of $100,000 would result in profits of $3,540 per day. On or about November 29, 2022,
Viviana and the CoinW6 Platform represented to Investor A that he had made a return of
approximately 6,238 USDT on his principal of 9,500 USDT in a month.

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

11

30.  Scheme Participants further lured investors into investing more funds with
the promise of even greater returns through promotional investment opportunities.
Beginning on or about November 13, 2022, for example, Viviana informed Investor A
that CoinW6 was offering an event reward “due to the arrival of Christmas.”
Specifically, Viviana claimed that if Investor A invested $41,00 more with CoinW6 to
bring his balance to $50,000, he would be entitled to a “bonus” of over $18,000,
equivalent to a 37 percent return. Over the course of following weeks, Viviana
repeatedly pressured Investor A to bring his total investment up to $50,000.
31. When Investor A expressed hesitation in investing more funds, Viviana
appealed to their relationship stating, “I just want you to progress with me and increase
your money in the hope that you can follow in my footsteps and make me feel like
someone I care about is doing what I love with me.” Viviana also raised that she had
recommended that Investor A increase his principal on three different occasions, and that
his failure to do so suggested that he did not care about her, stating “[Y]ou don’t respect
my suggestions and take my advice. It shows that you don’t want to progress with me.”
After extensive romantic conversations over several days to resolve Viviana’s accusation
that Investor A did not care about her, he committed to raising his investment principal
at CoinW6 to $50,000 on or about December 12, 2022.
32. Scheme Participants also attempted to build trust with investors by claiming
to deposit funds on their behalf in order to meet the balance requirements for
promotions. For example, on or about December 16, 2022, a WhatsApp message
purportedly from CoinW6 “Customer Service” informed Investor A that he needed an
additional $2,059 fee to qualify for the $50,000 promotion to collect $17,777 in rewards.
Viviana offered to pay the fee into Investor A’s account and asked for a screenshot of his
purported address at CoinW6.
33. Despite telling Investor A that she had transferred crypto assets worth
$2,300 to Investor A, in reality, no such assets were transferred – the Ethereum
blockchain showed no deposits into the investor’s account in the hour before or after she

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

12

claimed to have sent the crypto assets.
2
 Despite not having sent the crypto assets, the
CoinW6 Platform falsely reflected a 2,300 USDT credit in Investor A’s account.
Investor A promised to pay Viviana back, which she said he could do by treating her to a
delicious dinner and a bouquet of roses, a common technique used in romance
investment scams to create the vision of a future together.
34. On or about December 17, 2022, the Defendant represented on the CoinW6
Platform to Investor A that he had qualified for the bonus and that his account balance
now represented 118,021 USDT. As Investor A had not deposited more than 50,000
USDT, his account on the CoinW6 Platform now reflected a purported a return of more
than 100 percent.
35.  On or about December 22, 2022, Viviana also told Investor A that she had
sent 200,000 USDT to the address purportedly tied to the investor’s account at CoinW6
to co-invest with him. The Ethereum blockchain reflects no such transfer.
36. This tactic, in which the Scheme Participants told investors that they had
deposited crypto assets into the investor’s account to co-invest or pay fees, was used
with other investors. Once again, the Ethereum blockchain reflects that these co-
investments or payments never occurred.
37. Based on Viviana’s statements and information displayed on the CoinW6
Platform, Investor A would ultimately deposit crypto assets worth approximately

2
 The term “blockchain” typically refers to a distributed digital ledger that is used to
record transactions across many computers, secured by cryptographic techniques so that
the record cannot be altered retroactively without the alteration of all subsequent blocks
and the consensus of the network.

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

13

$495,600 with the Defendant during the Relevant Period, of which at least $97,000 was
deposited to invest in CoinW6’s crypto asset products. Investor A pulled some of these
invested funds from his retirement account. By February 1, 2023, his account on the
CoinW6 Platform reflected a balance of approximately 925,662 USDT as shown in the
screenshot below. The account balance reflects profits of 626,362 USDT – after
deducting the funds credited to the account from transfers Viviana failed to send
(203,200 USDT) as outlined in paragraphs 33 and 35. These profits represented
purported profits of 6.5 times Investor’s A principal of $97,000 over approximately four
months.
38. Investor B was induced to invest further into CoinW6 by Scheme
Participants using similar deceptive acts. On or about December 9, 2022, Arlene told
Investor B that without depositing $8,000 to his account that day, he would miss out on
$40,000 of profits from CoinW6’s products and recommended a balance of at least
$50,000 for an upcoming trade on December 15, 2022.
39. During December 2022, Arlene also applied romantic pressure to have
Investor B deposit an additional $50,000. Arlene explained that he could make a million
dollars in profits. Initially, Investor B deposited $5,000 on December 12, 2022, which as
stated previously, Arlene directed him to invest in CoinW6’s crypto asset mining
product.
40. While pressuring Investor B to invest further, Arlene also talked about
building a house and starting a life together soon with Investor B.

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

14

41. In total during the Relevant Period, Investor B had deposited nearly
$131,000 worth of USDT into his account on the CoinW6 Platform, which included
some funds he had borrowed from family, investing all of it through at least January 15,
2023. His purported returns as reflected on the CoinW6 Platform collectively reached a
balance of approximately one million USDT or about 6.6 times his invested principal
over approximately just four months.
D. While Scheme Participants Lulled Investors to Invest on the CoinW6
Platform, CoinW6 Was Misappropriating Their Funds
42. As described above, Scheme Participants directed Investors to transfer their
crypto assets to addresses purportedly connected to the CoinW6 Platform. Unbeknownst
to investors, within hours after they transferred their crypto assets to this address, the
Defendant transferred the crypto assets to an offshore crypto asset “tumbler”. A crypto
asset tumbler or “mixer platform” is a service that mixes potentially identifiable or
“tainted” crypto assets with other crypto assets, so as to obscure the trail between the
asset’s original source and its destination. This is usually done by pooling together
crypto assets from multiple inputs for a large and random period of time, and then
spitting them back out to destination addresses. Since the purpose of using a tumbler is
to create anonymity, persons often use tumblers to launder crypto assets that have been
misappropriated.
43. After the Defendant transferred investors’ crypto assets to the tumbler, it
misappropriated these assets for its own benefit because investors were not able to make

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

15

withdrawals on their accounts with the CoinW6 Platform and lost all the crypto assets
they had invested.
44. As described above, although the crypto assets were obscured and diverted
to other crypto wallet addresses, the Defendant, through displays on the CoinW6
Platform, misrepresented to investors that their funds were safely custodied in the
investors’ accounts with the Defendant. The accounts for the investors, which investors
could access online as instructed by the Scheme Participants, falsely reflected the
amount of crypto assets the investors believed they had deposited. For example, Investor
A transferred 29,230 in USDT to his account with the CoinW6 Platform on or about
December 6, 2022. Although the Defendant had diverted the crypto assets, the CoinW6
Platform reflected a balance of 39,341 USDT, which included a prior balance of
approximately 9,835 USDT that had also been diverted to a tumbler. The screenshots
below show the prior balance, the Defendant recording the deposit transaction, and the
investor’s balance after the deposit.
45. The Defendant and the Scheme Participants misrepresented to the investors
that the investors had, according to their account balances on the Defendant’s websites,
made hundreds of thousands of dollars from the additional investments. For example, the

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

16

Defendant misrepresented that Investor A and Investor B had earned approximately
619,000 USDT and 869,000 USDT, respectively, through the platform’s products in less
than six months on principal of approximately $97,000 and $131,000, respectively. The
Defendant, however, never retained the crypto assets in an account for the investor’s
benefit and the purported investment returns reflected on the CoinW6 Platform were
fake. For instance, in one screenshot of Investor A’s account on December 22, 2022, the
Defendant represented that his account had a balance of 135,798 USDT and that he had
earned cumulative income of 30,226 in USDT, or approximately 22.3 percent, through
its staking product with all of the income but for 2,277 in USDT being earned over the
prior 35 days.
E. CoinW6 Blocks Investors From Withdrawing Their Funds With False
Claims of Money Laundering Asset Freezes, Taxes, and Fees
46. Eventually, investors stopped investing additional funds – often because
they did not have any more funds to invest – or tried to withdraw the funds reflected in
their accounts on the CoinW6 Platform, and as described below, were unable to do so. In
response, the Defendant’s “Customer Service” would routinely contact investors through
WhatsApp claiming that their crypto assets were frozen because the U.S. Department of
Treasury’s Financial Crimes Enforcement Network (“FinCEN”) had detected money
laundering, they owed taxes on the assets in their account, or they owed fees to crypto
asset miners.
47. To withdraw the funds, Customer Service told investors that they needed to
deposit additional crypto assets to be held in escrow pending the outcome of FinCEN’s
investigation or to pay the applicable taxes or fees. If the crypto assets were not
deposited, Customer Service claimed that CoinW6 would assess penalties of one percent
of the investor’s account value per day. These statements were all false. The false
statements pressured investors to deposit additional crypto assets, and continued to
intimidate investors from withdrawing their principal and the returns they had
supposedly earned from the Defendant’s investment products.

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

17

48. For example, after Investor A had exhausted the amount of funds he had
available to invest a month prior, Customer Service told him on or about January 26,
2023, as shown below, that he owed $187,000 of taxes on profits made using the
Defendant’s products. At this time, the Defendant represented that the investor’s account
balance was approximately 816,000 USDT, as shown above, which resulted in profits of
5.3 times the investor’s principal over a 3-month period – October 2022 to January 2023.
Viviana explained and walked Investor A through making the necessary payment, which
Investor A transferred to an address Customer Service sent him over WhatsApp.
49. The Scheme Participants reassured the investors that they had deposited
additional crypto assets in the past to successfully withdraw their earnings on the
CoinW6 Platform or pressured the investor by putting them under duress to make the
additional payments. The Scheme Participants, in several instances, told investors that
they could not be together without withdrawing the crypto assets earned from investing
in CoinW6’s products. The Scheme Participants also cited to promises from the
investors to gift money for the Scheme Participants’ fake businesses that were
supposedly in dire financial condition, or even tried to blackmail the investors. A few
investors paid additional funds but were unable to withdraw any funds.

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

18

50. For example, prior to paying the purported taxes of $187,000, Viviana told
Investor A that he would be able to withdraw all his funds after the tax payment, which
would also enable him to repay her the 202,300 USDT she claimed to have sent him to
co-invest and qualify him for a CoinW6 promotion.
51. Arlene – like Viviana – also reassured Investor B by giving assurances that
a miner’s fee was legitimate and her fault for not warning him to not have reinvested all
the ETH in CoinW6’s products, thereby rendering those crypto assets unavailable to pay
the miner’s fee until the product’s duration ended (i.e. 3, 7, 15, or 30 days depending on
the product): “I forgot to remind you! Honey, it’s all my fault. . . . I should have
reminded you earlier to leave some ETH in your wallet as a miner’s fee instead of
putting them all in coinw.” Arlene continued representing that the transaction to pay the
miner’s fee was safe, and continued to discuss their future together.
52. After paying the purported taxes to the Defendant as described in paragraph
48, Investor A attempted to withdraw his funds on or about January 31, 2023. On or
about February 2, 2023, the Defendant rejected the withdrawal and sent a notice
purportedly from FinCEN to Investor A, as depicted below, which informed him that his
account had been suspended because of suspected money laundering. According to the

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

19

notice, to un-suspend the account, Investor A would need to transfer approximately
256,000 USDT as a security deposit.
53. Investor A initially believed that the notice was legitimate and caused by
Viviana’s deposits of 202,300 USDT. Viviana knew she never transferred any actual
crypto assets to Investor A’s account and hence knew that the reflected amounts in the
investor’s account at CoinW6 were fictitious. Viviana, therefore, made these fake
transfers and communicated them to the Defendant to assist in creating a pretext for
denying Investor A’s attempt to withdraw funds and devise another means through
which she could try to pressure the investor into transferring more crypto assets to the
Defendant to be misappropriated.
54. To add additional pressure for Investor A to pay the security deposit,
Viviana represented that she never had any issues ultimately withdrawing her funds from
CoinW6 and that the FinCEN inquiry was indeed serious and legitimate. She said to
Investor A, “Don’t worry, what we do is safe and formal. I have invested longer than
you, and I have never encountered problems like yours in withdrawing money before.”
Viviana had also told Investor A that she had a very rich uncle who specialized in crypto
assets, and that she had learned from him. Several other investors described the Scheme
Participants also telling them that they had such uncles too. Viviana told Investor A that
her purported uncle recommended paying the security deposit, saying “Uncle just told
me that money laundering accidents in financial investment are very serious now. . . .
Uncle recommends that you complete the verification process, otherwise your account
will be frozen, which will also affect your investment credit.”
55. Because Investor A was unconvinced that additional funds would enable
him to withdrawal his funds from CoinW6, Viviana started to tell him that it was urgent
that she get her 203,200 USDT back as soon as possible because her salon needed the
funds to pay her suppliers.
56. After Investor A refused to send additional funds, Viviana resorted to
blackmail, as shown in the WhatsApp messages at the top of the next page.

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

20

57. Similarly for Investor B, after paying the mining fee as described in
paragraph 51, CoinW6 informed him on December 30, 2022, that he also owed a further
$16,000 as a handling fee on his withdrawal. Arlene did not resort to blackmail, but like
Viviana, she continued to discuss a future together with Investor B, led him to believe
that she was in financial trouble and in need of money from the withdraw as she had co-
invested with him, and told him to prove that he loved her: “If you really love me, I
think you should find a way to get the money out. If you can’t don’t say you love me.”
F. The Defendant Continued The Fraud Through Successor Websites
58. After a few months of operating the fraud on a website and as investors
started to try to withdraw funds from their accounts and online blogs would flag the web
domain as a scam, the Defendant would take down the content from the website and
restart the fraud under a new web domain. For investors who had yet to complain or

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

21

attempt to withdraw funds, the Defendant would send them a notice that its products,
like its crypto asset mining pool, were undergoing maintenance upgrades. As a part of
this process, the Defendant would share the new web domain and instruct the investor to
use it to gain access to the investor’s account and continuing investing with CoinW6.
59. For example, Viviana initially directed Investor A to the CoinW6 Platform
in October 2022 through the web domain 6hsh.com. Later in December 2022, Viviana
began directing Investor A to access the CoinW6 Platform through the web domain
coinw6.com.
60. Likewise, an investor residing in Minnesota (“Investor C”) contacted
Customer Service through WhatsApp in November 2022 concerning a lack of account
access. Customer Service told Investor C that the mining pool was undergoing a
maintenance upgrade. On or about November 23, 2028, Customer Service informed
Investor C that his account and the platform’s crypto asset mining product could now be
accessed through coinw6.com. Investor C’s account had initially been at 6hsh.com.
61. The web domains coinw6.com, dmd567.com, and bybit.cc were all
registered by persons with the same email address. Persons used the email address
[email protected] to register the web domains dmd567.com and bybit.cc.
Although persons used the email peteraops@gmail to register coinw6.com, the recovery
email listed for that account was [email protected] which, in turn, had a recovery
email of [email protected] – the same address used to register dmd567.com and
bybit.cc.
II. COINW6’s PURPORTED INVESTMENT PRODUCTS WERE
 FICTITIOUS
62. CoinW6’s crypto asset staking product, as presented on the website, offered
investors daily income of two to three percent. Crypto asset staking is a process whereby
one “stakes” (or locks) the “native” token of a particular blockchain in order to earn the
opportunity to participate on the “validation” mechanism, typically for “proof of stake”
blockchains in exchange for earning rewards. The Defendant – not the investor – chose

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

22

what crypto assets to stake and transferred the purported income from its crypto asset
staking product to the investor. The investors’ sole involvement in the investment was
selecting how long the investors wanted their crypto assets invested in CoinW6’s
purported crypto asset staking product.
63. The Defendant, through its websites and the Scheme Participants,
misrepresented to investors that CoinW6’s crypto asset staking product existed and was
providing returns to investors of two to three percent per day. For example, as described
in paragraph 28, the Defendant and Viviana had represented to Investor A that he had
earned $150 on an investment of 1,000 USDT into CoinW6’s 3-day crypto asset staking
product. When Investor A made his election to invest in the product, the address
purportedly tied to the CoinW6 Platform did nothing; instead, his deposited funds were
diverted hours later to a tumbler. Neither Investor A’s principal nor supposed investment
gains were returned to Investor A.
64. CoinW6’s crypto asset mining product, as presented on the website, offered
investors daily income of two to three percent. In crypto asset mining pools, investors
invest in a collection of crypto asset miners who combine their computational resources
over a network to increase their chances to mine blocks and earn crypto asset rewards
from proof of work blockchains. The Defendant – not the investor – chose which
purported crypto asset mining pools to invest in and transferred the purported income to
the investor. The investors’ sole involvement in the investments was selecting how long
the investors wanted their crypto assets invested in CoinW6’s crypto asset mining
product.
65. The Defendant, through its websites and the Scheme Participants,
misrepresented to investors that CoinW6’s crypto asset mining product existed and was
providing returns to investors of two to three percent per day. For example, as outlined
in paragraph 29, the Defendant and Viviana had represented to Investor A that he had
earned $6,238 on an investment of 9,500 USDT into CoinW6’s crypto asset mining
product in a month. Again, when Investor A made his election to invest in the product,

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

23

the address purportedly tied to the CoinW6 Platform did nothing; instead, his deposited
funds were diverted hours later to a tumbler.
66. CoinW6’s crypto asset yield farming product, as presented on the website,
offered investors daily income of two to three percent. In crypto asset yield farming,
investors lock their crypto assets in smart contracts called liquidity pools on so-called
decentralized crypto asset trading platforms to provide liquidity for various token pairs
that trade in that liquidity pool. Investors who lock their crypto assets into liquidity pools
can earn portions of fees charged or other rewards the platforms. The Defendant – not
the investor – chose which liquidity pools to invest and transferred the purported income
to the investor. The investors’ sole involvement in the investment was selecting how
long they wanted their crypto assets invested in CoinW6’s crypto asset yield farming
product.
67. The Defendant, through its websites and the Scheme Participants,
misrepresented to investors that CoinW6’s crypto asset yield farming product existed
and was providing returns to investors of two to three percent per day. There is no
evidence that CoinW6 maintained or invested in any actual liquidity pools.
68. Reasonable investors would have considered it material to their decision to
invest in the Defendant’s crypto asset staking, mining, and yield farming products that
the products did not exist and hence were not generating any income for investors.
69. The Scheme Participants misrepresented to investors that they had earned
hundreds of thousands of dollars in profits from the Defendant’s products. The Scheme
Participants also misrepresented to investors that they were co-investing in the
Defendant’s products. For example, on December 6, 2022, after Investor A had
deposited and invested 50,000 USDT – but prior to depositing and investing at least an
additional 100,000 USDT – Viviana represented that she had invested $350,000 with the
Defendant, earned $250,000, and planned to invest an additional $550,000. She also later
represented that she had earned $1 million in rewards through CoinW6 promotions.
70. Reasonable investors would have considered it material to their decision to

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

24

invest in the Defendant’s products that the Scheme Participants – acting with, for, or
controlling the Defendant – had not earned hundreds of thousands of dollars in profits
and were not co-investing in the Defendant’s products.
71. The Defendant misrepresented to investors on its websites that its platform
was affiliated with CoinW and/or Coinbase, which are existing crypto asset trading
platforms. The Defendant displayed on its websites a Whitepaper of Coinbase, holding it
out to be Defendant’s Whitepaper. A Whitepaper is a document that explains a crypto
project’s objectives, potential, and technical and economic factors. Reasonable investors
would have considered it material to their decision to invest in the Defendant’s products
that the Defendant was not affiliated with CoinW or Coinbase and that the Whitepaper
displayed on Defendant’s websites was, in fact, not Defendant’s Whitepaper, but the
Whitepaper of Coinbase.
III.  COINW6’S PURPORTED INVESTMENT PRODUCTS WERE OFFERED
 AND SOLD AS SECURITIES
72. As described above, including, but not limited to, in paragraphs 25, 26, 29,
37, and 41, investors invested money in the form of crypto assets – usually USDT – in
the Defendant’s non-existent crypto asset products on the CoinW6 Platform, which
included crypto asset staking, crypto asset mining, and crypto asset yield farming.
73. As described above, including, but not limited to, in paragraph 69, investors
were investing in a common enterprise by co-investing or pooling their crypto assets
with other persons in the Defendant’s crypto asset products. The investors, including
Investor A and Investor B, had each invested in the Defendant’s crypto asset mining
product. When making a deposit with CoinW6, in many instances the Defendant
directed investors to transfer their assets to the same crypto address, thereby comingling
and pooling crypto assets. Viviana and Arlene also claimed to have contributed funds to
co-invest with these investors and had told them that they already had made hundreds of
thousands of dollars investing with the Defendant. CoinW6 published rates of return for
each of its crypto asset products on the CoinW6 Platform. Investors potential purported

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

25

profits or loss rose or fell together in proportion to their investment depending on the
profitability of CoinW6’s purported crypto asset products. Moreover, investors’ potential
for profits depended entirely on CoinW6’s ability to operate and maintain the CoinW6
Platform as well manage its purported crypto asset products.
74. As described above, including, but not limited to, in paragraphs 62-67,
investors in the Defendant’s crypto asset-products had an expectation of profits derived
from the efforts of the Defendant. The Defendant’s crypto asset products offered
investors daily, passive income of two to three percent, which was reflected for each
product on the CoinW6 Platform prior to investment, as shown in the images at the top
of the next page. The Defendant – not the investor – chose which crypto assets to stake,
into which crypto mining pool to invest, or into which liquidity pool to invest (yield
farming), and transferred the purported income to the investor from these products. The
investor’s sole decision was for how long they wanted their crypto assets invested in
CoinW6’s products. As a result, investors potential for returns were dependent
CoinW6’s ability to make their crypto asset products profitable.
IV.  COINW6 ACTED WITH SCIENTER
75. As described above, including but not limited to, in paragraphs 44, 63, and

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

26

65, the Defendant had transferred the investors’ crypto assets to a tumbler and
misappropriated the funds as investors were unable to withdraw their investments and
lost all their crypto assets. Yet, as described in paragraphs 28, 29, 37, 41, 44, and 45, the
Defendant represented to investors that crypto assets were in an account for each
investor’s benefit and were being invested in CoinW6’s crypto asset products. The
Defendant, however, had misappropriated the investors’ crypto assets prior to the
investors selecting which product to invest. As a result, the Defendant knew or was
reckless in not knowing that its representations concerning the investors’ account
balances and profits reflected in their accounts on the CoinW6 Platform were fictitious
and untrue.
76. As described above, including but not limited to, in paragraphs 48, 51, and
52, the Defendant, acting through the guise of Customer Service, represented to
investors that FinCEN had frozen account balances, that taxes were due on their
accounts, or that investors owed miner fees. As FinCEN does not have authority to
freeze assets or block funds transfers – which it states clearly in an alert on its website at
fincen.gov – the Defendant knew or was reckless in not knowing that its representations
concerning FinCEN were false. Similarly, since the Defendant could not make tax
payments because it did not collect tax identification numbers of the investors, and since
the Defendant had not used investor’s funds to invest in any crypto asset mining pools,
the Defendant knew or was reckless in not knowing that it representations about taxes or
miner fees being owed were false.
77. As described above, including but not limited to, in paragraphs 33 and 35,
the Scheme Participants told investors that they had transferred crypto assets into the
investors’ accounts to co-invest or pay fees. A review of the Ethereum blockchain for the
purported crypto addresses of the investors on the CoinW6 Platform shows that the
Scheme Participants like Viviana never made these transfers. Despite the transfers not
occurring, the Defendant credited the investors’ accounts for these transfers,
misrepresenting to investors that the deposits had been made. As the transfers had not

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

27

occurred, the Defendant had to have been aware of the Scheme Participants’
conversations with the investors so the CoinW6 Platform would reflect a deposit in the
proper amount. As such, the Defendant knew or was reckless in not knowing that the
Scheme Participants were making misrepresentations to the investors about having
deposited crypto assets into their accounts with the CoinW6 Platform and knew or was
reckless in not knowing that those deposits never occurred.
FIRST CAUSE OF ACTION
Violation of Sections 5(a) and 5(c) of the Securities Act
[15 U.S.C. §§ 77e(a), 77e(c)]
78. The Commission realleges and incorporates by reference the allegations
contained in Paragraphs 1-11, 21-41, and 58-74, above.
79. Section 5(a) of the Securities Act provides that unless a registration
statement is in effect as to a security, it shall be unlawful any person, directly or directly,
(1) to make use of any means or instruments of transportation or communication
in interstate commerce or of the mails to sell such security through the use or medium of
any prospectus or otherwise; or (2) to carry or cause to be carried through the mails or
in interstate commerce, by any means or instruments of transportation, any
such security for the purpose of sale or for delivery after sale.
80. Section 5(c) of the Securities Act provides that it shall be unlawful for any
person, directly or indirectly, to make use of any means or instruments of transportation
or communication in interstate commerce or of the mails to offer to sell or offer to buy
through the use or medium of any prospectus or otherwise any security, unless a
registration statement has been filed as to such security, or while the registration
statement is the subject of a refusal order or stop order or (prior to the effective date of
the registration statement) any public proceeding or examination under section 77h of
this title.
81. No registration statement had been filed or was in effect for any of the
securities offered and sold by the Defendant and no exemption applied.

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

28

82. The Defendant, by engaging in the conduct described above, directly or
indirectly, made use of means or instruments of transportation or communication in
interstate commerce or of the mails to offer to sell or to sell such securities.
83. By reason of the foregoing, the Defendant violated, and unless enjoined will
again violate, Sections 5(a) and (c) of the Securities Act [15 U.S.C. §§ 77e(a) and (c)].
SECOND CAUSE OF ACTION
Violation of Section 17(a) of the Securities Act
[15 U.S.C. §§ 77q(a)]
84. The Commission realleges and incorporates by reference the allegations
contained in Paragraphs 1 through 77, above.
85. By engaging in the conduct described above, the Defendant, in the offer or
sale of securities, and by the use of the means or instruments of transportation or
communication in interstate commerce or by use of the mails, directly or indirectly: (a)
employed devices, schemes, or artifices to defraud; (b) obtained money or property by
means of untrue statements of material facts of by omitting to state a material fact
necessary to make the statements made, in light of the circumstances under which they
were made, not misleading; and (c) engaged in transactions, practices, or courses of
business which operated or would operate as a fraud or deceit upon the buyer.
86. By reason of the foregoing, The Defendant, directly or indirectly violated,
and unless enjoined will continue to violate, Section 17(a) of the Securities Act [15
U.S.C. § 77q(a)].
THIRD CAUSE OF ACTION
Violation of Section 10(b) of the Securities Exchange Act [15 U.S.C. § 78j(b)]
and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]
87. The Commission realleges and incorporates by reference the allegations
contained in Paragraphs 1 through 77, above.
88. The Defendant, by engaging in the conduct described above, directly or
indirectly, by the use of means or instrumentalities of interstate commerce or use of the

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

29

mails, in connection with the purchase or sale of securities, with scienter, (a) employed
devices, schemes, or artifices to defraud; (b) made untrue statements of a material fact or
omitted to state a material fact necessary in order to make the statements made, in the
light of the circumstances under which they were made, not misleading; and (c) engaged
in acts, practices, or courses of business that operated or would operate as a fraud and
deceit upon other persons.
89. By reason of the foregoing, the Defendant violated, and unless restrained
and enjoined will continue to violate, Section 10(b) of the Exchange Act [15 U.S.C.
§78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that the Court enter a Final
Judgment:
I.
Finding that the Defendant committed the violations of the federal securities laws
as alleged in this Complaint;
II.
In forms consistent with Rule 65(d) of the Federal Rules of Civil Procedure,
permanently enjoining Defendant and its officers, agents, servants, employees, and
attorneys, and those persons in active concert or participation with any of them, who
receive actual notice of the judgment by personal service or otherwise, and each of them,
from:
a. violating Sections 5(a) and 5(c) of the Securities Act [15 U.S.C. §§ 77e(a),
77e(c)];
b. violating Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]; and
c. violating Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)], and Rule
10b-5 thereunder [17 C.F.R. § 240.10b-5].

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

30

III.
In forms consistent with Rule 65(d) of the Federal Rules of Civil Procedure,
enjoining the Defendant from directly or indirectly participating in the issuance,
purchase, offer, or sale of any security, including, but not limited to, through any entity,
affiliate or person owned or controlled by CoinW6 or acting for or with CoinW6.
IV.
Issue an order requiring the Defendant to remove all pages of its websites and in
its place post a copy of the Commission’s Complaint.
V.
Ordering the Defendant to disgorge all ill-gotten gains obtained as a result of the
acts or courses of conduct alleged in this Complaint, together with prejudgment interest
thereon, pursuant to Section 21(d)(3), (d)(5) and 21(d)(7) of the Exchange Act [15
U.S.C. §§ 78u(d)(3), 78u(d)(5) and 78u(d)(7)].
VI.
Ordering the Defendant to pay civil penalties pursuant to Section 20(d) of the
Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C.
§ 78u(d)(3)].
VII.
Retaining jurisdiction of this action in accordance with the principles of equity
and the Federal Rules of Civil Procedure in order to implement and carry out the terms
of all orders and decrees that may be entered, or to entertain any suitable application or
motion for additional relief within the jurisdiction of this Court.
VIII.
Granting such other and further relief as this Court may determine to be just and
necessary.

1
 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

31

DEMAND FOR JURY TRIAL
Pursuant to Federal Rule of Civil Procedure 38, the Commission demands trial by
jury.
Dated: September 17, 2024   /s/ Daniel O. Blau

Daniel O. Blau
Matthew B. Reisig
Attorneys for Plaintiff
Securities and Exchange
 Commission

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

1 

MATTHEW B. REISIG (NY Bar No. 4898094) 

Email: [email protected]  

100 F Street, N.E. 

Washington, DC 20549 

Telephone: (202) 551-6429 

Facsimile: (202) 772-9282 

DANIEL O. BLAU 

(Cal Bar. No. 305008) 

Email: [email protected] 

444 S. Flower Street, Suite 900 

Los Angeles, California 90071 

Telephone: (323) 965-3306 

Facsimile: (213) 443-1904 

Attorneys for Plaintiff 

Securities and Exchange Commission 

IN THE UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

SECURITIES AND EXCHANGE 

COMMISSION, 

PLAINTIFF, 

v. 

COINW6, 

d/b/a CoinW6.com, 6hsh.com, 

dmd567.com, bybit.cc, and 

cglobalw.com, 

DEFENDANT. 

Case No.: 

COMPLAINT 

DEMAND FOR 

JURY TRIAL 

Plaintiff, Securities and Exchange Commission (the “Commission”) alleges as 

follows: 

2:24-cv-07924

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 1 of 31   Page ID #:1



1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

2 

JURISDICTION AND VENUE 

1. The Commission brings this action pursuant to Sections 20(b), 20(d), and

22(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77t(b), 77t(d), and 

77v(a)], and Sections 21(d), 21(e), and 27 of the Securities Exchange Act of 1934 

(“Exchange Act”) [15 U.S.C. §§ 78u(d), 78u(e), and 78aa]. 

2. This Court has jurisdiction over this action pursuant to Sections 20(b),

20(d)(1), and 22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d)(1), and 77v(a)] and 

Sections 21(d), 21(e), and 27 of the Exchange Act [15 U.S.C. §§ 78u(d), 78(e), and 

78aa].  

3. Defendant, directly or indirectly, made use of the means and

instrumentalities of interstate commerce or the mails in connection with the acts, 

transactions, practices, and courses of business alleged in this Complaint. 

4. Venue for this action is proper in the Central District of California under

Section 22(a) of the Securities Act [15 U.S.C. § 77v(a)] and under Section 27 of the 

Exchange Act [15 U.S.C. § 78aa]. Certain of the acts, practices, transactions, and 

courses of business that form the basis for the violations alleged in this Complaint 

occurred within the Central District of California. Several investors were residents of 

this District at all relevant times, the Defendant sent text messages and communications 

which included material misrepresentations into this District to the investors, and the 

Defendant offered its crypto asset products as securities to persons residing in this 

District including investors.  

SUMMARY OF ALLEGATIONS 

5. This case concerns a romance investment scam perpetrated by a web of

individuals and entities through a fake online crypto asset platform operating under the 

names coinW6.com, 6hsh.com, dmd567.com, bybit.cc, and cglobalw.com (collectively 

“CoinW6” or the “Defendant”) that defrauded U.S. investors by contacting them through 

social media platforms, gaining their trust, and then manipulating them into transferring 

their crypto assets and funds before effectively disappearing. 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 2 of 31   Page ID #:2



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

3 

 

6. From at least July 2022 through at least December 2023, individuals who 

were either controlled by CoinW6 or who controlled CoinW6 themselves (“Scheme 

Participants”) engaged in this coordinated scheme to defraud at least 11 investors out of 

more than approximately $2.2 million. 

7. The Scheme Participants contacted prospective investors through social 

media platforms, such as LinkedIn and Instagram, and then pursued romantic 

relationships with them over the messaging platform, WhatsApp. After developing 

online romantic relationships with prospective investors, the Scheme Participants 

introduced the investors to so-called “cryptocurrency,” claiming that they had earned 

hundreds of thousands of dollars through crypto asset products that CoinW6 offered and 

sold on its websites through an online crypto trading platform (“CoinW6 Platform”). The 

CoinW6 Platform promised two to three percent passive returns per day from crypto 

asset staking, mining, or yield farming products that the Defendant purportedly operated. 

In fact, the CoinW6 Platform and its products were entirely fictitious. 

8. The Scheme Participants instructed investors on how to purchase crypto 

assets, such as Tether (USDT) and Ethereum (ETH), and invest those assets on the 

CoinW6 Platform. After investing, the Defendant misrepresented to investors that they 

were earning massive daily returns while, in reality, the Defendant had already 

misappropriated their crypto assets. After a few months of operating the fraud on a 

website, and as investors tried to withdraw funds from their accounts, the Defendant 

removed content from the website and continued the fraud under a new web domain. 

9. The Defendant’s purported crypto asset staking, mining, and yield farming 

products were investment contracts and thus securities offered and sold in unregistered 

transactions in violation of Sections 5(a) and 5(c) of the Securities Act [15 U.S.C. §§ 

77e(a) and 77e(c)].  

10. By directly or indirectly making materially false statements to investors to 

offer and sell investment contracts to investors, and/or engaging in deceptive acts in 

connection with the offer, purchase, and sale of these investment contracts, the 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 3 of 31   Page ID #:3



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

4 

 

Defendant violated the antifraud provisions of Section 17(a) of the Securities Act [15 

U.S.C. §77q(a)] and Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and 

Exchange Act Rule 10b-5(a)-(c) [17 C.F.R. § 240.10b-5]. 

11. In this action, the Commission seeks permanent injunctions prohibiting the 

Defendant from violating the securities laws by engaging in the kind of conduct alleged 

herein, as well as permanently enjoining the Defendant from directly or indirectly 

participating in the issuance, purchase, offer or sale of any security. The Commission 

also seeks an order requiring the Defendant to remove all pages of its websites and in its 

place post a copy of the Commission’s Complaint, disgorge its ill-gotten gains plus 

prejudgment interest, and impose a civil penalty. 

DEFENDANT 

12. CoinW6 is an unincorporated business with no known address and no 

known officers or directors. Individuals in the United Arab Emirates registered the 

CoinW6.com web domain on November 11, 2022, through a web domain registrar 

located in Singapore. CoinW6 referred to itself as CoinW on its platform, which is the 

name of an unrelated, actual crypto asset exchange based in Singapore.  

13. As described further herein, CoinW6 did business and operated through a 

number of predecessor and successor websites, including 6hsh.com, dmd567.com, 

bybit.cc, and cglobalw.com. Individuals registered 6hsh.com on June 10, 2022, with a 

web domain registrar located in the People’s Republic of China. Individuals registered 

dmd567.com and bybit.cc with the same web domain registrar as CoinW6.com in 

Singapore on November 23, 2022, and January 30, 2023, respectively. Individuals in the 

People’s Republic of China registered cglobalw.com on June 9, 2023, with a web 

domain registrar located in the United States. Regardless of web domain or address, all 

iterations of CoinW6’s Platform were nearly identical in appearance and offered similar 

purported crypto asset products. As described further herein, regardless of the web 

domain name or address, CoinW6 Scheme Participants contacted investors through 

similar means and operated in a similar fashion. Upon information and belief, 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 4 of 31   Page ID #:4



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

5 

 

CoinW6.com, 6hsh.com, dmd567.com, bybit.cc, and cglobalw.com were controlled by 

and part of a single enterprise.  

FACTS 

I. COINW6’s SCHEME TO DEFRAUD 

14. From at least July 2022 through at least December 2023, CoinW6, by and 

through the Scheme Participants, perpetrated a coordinated scheme to defraud at least 11 

investors out of more than approximately $2.2 million. 

A. CoinW6 Scheme Participants Develop Romantic Relationships with 

Potential Investors  

15. CoinW6’s fraudulent scheme began with Scheme Participants purporting to 

be young, attractive professionals contacting prospective investors across the United 

States through social media platforms such as LinkedIn and Instagram. Often Scheme 

Participants would claim to have mistakenly stumbled upon a prospective investor’s 

social media profile.  

16. For example, as shown in the screenshots below, on September 8, 2022, a 

Scheme Participant using the pseudonym “Margaret,” contacted a prospective investor 

residing in California on Instagram claiming to have “accidentally brushed” a post from 

the prospective investor and then sought to move the conversation to WhatsApp. 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 5 of 31   Page ID #:5



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

6 

 

17. Upon establishing initial rapport, the Scheme Participants then pursued 

romantic relationships with prospective investors over the messaging platform, 

WhatsApp. The Scheme Participants created and used fictional online personas, 

purporting to be managers of businesses like salons in New York or Los Angeles. As 

shown below, the Scheme Participants depicted themselves as young, beautiful, and rich 

on social media and in photos sent to investors. The Scheme Participants often told 

investors that they were frustrated with dating and disappointed with their prior 

relationships.1 

18. For example, a Scheme Participant using the pseudonym “Viviana,” 

contacted a prospective investor residing in California, “Investor A,” in early September 

2022 and told him, over WhatsApp, that she had moved to New York City from 

Australia after a divorce and the death of her only child. Viviana also told Investor A 

that she owned and managed a salon with 25 employees in the city.  

 
1 The SEC has anonymized or obscured certain names, identifying information, or 

images to protect the identities of alleged victims of this fraud as well as unaffiliated 

individuals whose names, images, or likenesses may have been misappropriated by the 

Defendant or Scheme Participants to perpetrate the scheme. 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 6 of 31   Page ID #:6



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

7 

 

19. In another instance in or around September 2022, a Scheme Participant 

using the alias “Arlene,” contacted a prospective investor residing in Missouri, “Investor 

B,” over LinkedIn purporting to run a business in New York City after moving there 

from China. 

20. After establishing initial faux rapport with investors over social media, 

Scheme Participants sought to develop online romantic relationships with prospective 

investors using WhatsApp. The Scheme Participants would discuss travel, hobbies, prior 

relationships, and share photographs. Often after a month of conversations, with very 

little mention of “cryptocurrency,” a romantic relationship developed in which the 

investor had formed trust in the Scheme Participant, believing their story to be true and 

their romantic interest in them to be genuine. 

B. Scheme Participants Induce Investors to Purchase Crypto Assets  

21. After Scheme Participants had fostered romantic relationships with 

prospective investors, they introduced investors to so-called “cryptocurrency,” and 

recommended investment into crypto staking, mining, and yield farming products that 

the Defendant offered on the CoinW6 Platform. These products, as further described 

below, offered different daily returns on invested funds for different periods of time, 

such as 3, 7, 15, or 30 days. To invest in CoinW6’s products, the Scheme Participants 

directed investors to use U.S. dollars to purchase crypto assets such as Tether (USDT), 

which is a crypto asset purportedly pegged to the U.S. dollar, or Ethereum (ETH), on 

U.S.-based crypto platforms. From there, they showed investors, using screenshots over 

WhatsApp, how to open self-custodial crypto wallets, and then move their USDT or 

ETH crypto assets to those self-custodial wallets. The Scheme Participants then showed 

the investors how to open an account on the purported CoinW6 Platform and how to 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 7 of 31   Page ID #:7



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

8 

 

deposit their USDT or ETH crypto assets into those accounts. After the investors’ 

accounts on the CoinW6 Platform were purportedly credited with crypto assets, the 

Scheme Participants walked the investors through investing in CoinW6’s purported 

crypto asset staking, mining, and yield farming products. The investors selected the 

product almost always based on the Scheme Participants’ recommendation. 

22. In the case of Investor A, for example, on October 10, 2022, after having 

developed a romantic relationship over a month, Viviana recommended investing in 

crypto assets and introduced Investor A to CoinW6 and its crypto asset products.  

23. Specifically, Viviana directed Investor A to 6.hsh.com where Investor A 

was presented with what appeared to be an authentic interface which purported to offer 

trading in dozens of crypto assets, and which mimicked the features and functionality of 

a legitimate trading platform as reflected in the below screenshots Viviana sent to 

Investor A over WhatsApp. Viviana then walked Investor A through setting up an 

account with CoinW6 on the 6hsh.com interface. The screenshots were of the 6hsh.com 

web domain and its successor web domain, coinw6.com, which were nearly identical. 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 8 of 31   Page ID #:8



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

9 

 

24. In reality, the Commission’s investigation revealed no evidence that a bona 

fide crypto asset trading platform existed and no evidence that any transactions were 

executed on the CoinW6 Platform. 

25. With Viviana’s guidance, Investor A started investing, first purchasing 

$1,000 worth of USDT on a U.S.-based crypto asset platform and transferring those 

assets to a self-custodial crypto wallet Viviana showed Investor A how to create. Sharing 

screenshots of the wallet and the account Investor A set up on the CoinW6 Platform with 

Viviana’s assistance, Viviana walked the investor through transferring the crypto assets 

to a crypto address CoinW6 represented as tied to Investor A’s CoinW6 account for the 

purpose of investing in the Defendant’s crypto asset products. On or about October 27, 

2022, Viviana recommended and again through the use of screenshots, showed Investor 

A how to purchase CoinW6’s 3-day crypto asset staking product using the 1,000 USDT. 

26. Similarly for Investor B, Arlene directed him to open an account on the 

CoinW6 Platform and, in addition to investing in CoinW6’s crypto asset staking and 

mining products, she directed trades in crypto asset pairs on the platform to generate 

thousands of dollars in returns. Arlene, using screenshots sent over WhatsApp, showed 

Investor B how to deposit crypto assets, trade crypto asset pairs, and how to purchase 

CoinW6’s products. On December 12, 2022, Investor B invested $5,000 in a purported 

crypto asset mining product that Arlene had recommended and that was advertised on 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 9 of 31   Page ID #:9



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

10 

 

the CoinW6 Platform.  

C. Scheme Participants Pressure Investors to Increase Their Investment 

On the CoinW6 Platform 

27. As the romantic relationships continued and Investors were led to believe 

their investments were generating significant returns by the CoinW6 Platform which 

reflected purported profits at several multiples of the principal invested, the Scheme 

Participants then urged investors to find more money to invest – even recommending 

that investors withdraw funds from retirement accounts or borrow money from friends 

and family to generate larger returns on CoinW6. Several of the Scheme Participants 

also led investors to believe they had deposited funds into the investors’ CoinW6 

accounts to qualify for promotions, pay fees, or to co-invest.  

28. For example, on or about November 1, 2022, Viviana told Investor A that 

CoinW6’s staking program generates daily returns of 2.2 to 2.6 percent, which she 

claimed had amounted to income of $150 in just 3 days on Investor A’s initial 

investment of $1,000. Viviana then assisted Investor A in using the principal and 

purported proceeds to invest in CoinW6’s 7-day crypto asset mining product. From 

November 1 through November 6, Viviana consistently asked Investor A to deposit 

more crypto assets to invest into CoinW6’s products, recommending a balance of at least 

$50,000. 

29. After seeing what appeared to be generous returns reflected on the CoinW6 

Platform on the 7-day investment in the crypto asset mining pool, Investor A agreed to 

deposit more funds with the assistance of Viviana, bringing his total principal – 

excluding any returns – to about 9,500 USDT. On or about November 11, 2022, Viviana 

recommended that Investor A invest in CoinW6’s 30-day crypto asset mining product, 

which offered daily returns of 3.2 to 3.6 percent, and told the investor that an investment 

of $100,000 would result in profits of $3,540 per day. On or about November 29, 2022, 

Viviana and the CoinW6 Platform represented to Investor A that he had made a return of 

approximately 6,238 USDT on his principal of 9,500 USDT in a month. 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 10 of 31   Page ID #:10



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

11 

 

30.  Scheme Participants further lured investors into investing more funds with 

the promise of even greater returns through promotional investment opportunities. 

Beginning on or about November 13, 2022, for example, Viviana informed Investor A 

that CoinW6 was offering an event reward “due to the arrival of Christmas.” 

Specifically, Viviana claimed that if Investor A invested $41,00 more with CoinW6 to 

bring his balance to $50,000, he would be entitled to a “bonus” of over $18,000, 

equivalent to a 37 percent return. Over the course of following weeks, Viviana 

repeatedly pressured Investor A to bring his total investment up to $50,000.  

31. When Investor A expressed hesitation in investing more funds, Viviana 

appealed to their relationship stating, “I just want you to progress with me and increase 

your money in the hope that you can follow in my footsteps and make me feel like 

someone I care about is doing what I love with me.” Viviana also raised that she had 

recommended that Investor A increase his principal on three different occasions, and that 

his failure to do so suggested that he did not care about her, stating “[Y]ou don’t respect 

my suggestions and take my advice. It shows that you don’t want to progress with me.” 

After extensive romantic conversations over several days to resolve Viviana’s accusation 

that Investor A did not care about her, he committed to raising his investment principal 

at CoinW6 to $50,000 on or about December 12, 2022. 

32. Scheme Participants also attempted to build trust with investors by claiming 

to deposit funds on their behalf in order to meet the balance requirements for 

promotions. For example, on or about December 16, 2022, a WhatsApp message 

purportedly from CoinW6 “Customer Service” informed Investor A that he needed an 

additional $2,059 fee to qualify for the $50,000 promotion to collect $17,777 in rewards. 

Viviana offered to pay the fee into Investor A’s account and asked for a screenshot of his 

purported address at CoinW6. 

33. Despite telling Investor A that she had transferred crypto assets worth 

$2,300 to Investor A, in reality, no such assets were transferred – the Ethereum 

blockchain showed no deposits into the investor’s account in the hour before or after she 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 11 of 31   Page ID #:11



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

12 

 

claimed to have sent the crypto assets.2 Despite not having sent the crypto assets, the 

CoinW6 Platform falsely reflected a 2,300 USDT credit in Investor A’s account. 

Investor A promised to pay Viviana back, which she said he could do by treating her to a 

delicious dinner and a bouquet of roses, a common technique used in romance 

investment scams to create the vision of a future together. 

34. On or about December 17, 2022, the Defendant represented on the CoinW6 

Platform to Investor A that he had qualified for the bonus and that his account balance 

now represented 118,021 USDT. As Investor A had not deposited more than 50,000 

USDT, his account on the CoinW6 Platform now reflected a purported a return of more 

than 100 percent. 

35.  On or about December 22, 2022, Viviana also told Investor A that she had 

sent 200,000 USDT to the address purportedly tied to the investor’s account at CoinW6 

to co-invest with him. The Ethereum blockchain reflects no such transfer.  

36. This tactic, in which the Scheme Participants told investors that they had 

deposited crypto assets into the investor’s account to co-invest or pay fees, was used 

with other investors. Once again, the Ethereum blockchain reflects that these co-

investments or payments never occurred. 

37. Based on Viviana’s statements and information displayed on the CoinW6 

Platform, Investor A would ultimately deposit crypto assets worth approximately 

 
2 The term “blockchain” typically refers to a distributed digital ledger that is used to 

record transactions across many computers, secured by cryptographic techniques so that 

the record cannot be altered retroactively without the alteration of all subsequent blocks 

and the consensus of the network. 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 12 of 31   Page ID #:12



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

13 

 

$495,600 with the Defendant during the Relevant Period, of which at least $97,000 was 

deposited to invest in CoinW6’s crypto asset products. Investor A pulled some of these 

invested funds from his retirement account. By February 1, 2023, his account on the 

CoinW6 Platform reflected a balance of approximately 925,662 USDT as shown in the 

screenshot below. The account balance reflects profits of 626,362 USDT – after 

deducting the funds credited to the account from transfers Viviana failed to send 

(203,200 USDT) as outlined in paragraphs 33 and 35. These profits represented 

purported profits of 6.5 times Investor’s A principal of $97,000 over approximately four 

months. 

38. Investor B was induced to invest further into CoinW6 by Scheme 

Participants using similar deceptive acts. On or about December 9, 2022, Arlene told 

Investor B that without depositing $8,000 to his account that day, he would miss out on 

$40,000 of profits from CoinW6’s products and recommended a balance of at least 

$50,000 for an upcoming trade on December 15, 2022. 

39. During December 2022, Arlene also applied romantic pressure to have 

Investor B deposit an additional $50,000. Arlene explained that he could make a million 

dollars in profits. Initially, Investor B deposited $5,000 on December 12, 2022, which as 

stated previously, Arlene directed him to invest in CoinW6’s crypto asset mining 

product. 

40. While pressuring Investor B to invest further, Arlene also talked about 

building a house and starting a life together soon with Investor B. 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 13 of 31   Page ID #:13



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

14 

 

41. In total during the Relevant Period, Investor B had deposited nearly 

$131,000 worth of USDT into his account on the CoinW6 Platform, which included 

some funds he had borrowed from family, investing all of it through at least January 15, 

2023. His purported returns as reflected on the CoinW6 Platform collectively reached a 

balance of approximately one million USDT or about 6.6 times his invested principal 

over approximately just four months. 

D. While Scheme Participants Lulled Investors to Invest on the CoinW6 

Platform, CoinW6 Was Misappropriating Their Funds  

42. As described above, Scheme Participants directed Investors to transfer their 

crypto assets to addresses purportedly connected to the CoinW6 Platform. Unbeknownst 

to investors, within hours after they transferred their crypto assets to this address, the 

Defendant transferred the crypto assets to an offshore crypto asset “tumbler”. A crypto 

asset tumbler or “mixer platform” is a service that mixes potentially identifiable or 

“tainted” crypto assets with other crypto assets, so as to obscure the trail between the 

asset’s original source and its destination. This is usually done by pooling together 

crypto assets from multiple inputs for a large and random period of time, and then 

spitting them back out to destination addresses. Since the purpose of using a tumbler is 

to create anonymity, persons often use tumblers to launder crypto assets that have been 

misappropriated. 

43. After the Defendant transferred investors’ crypto assets to the tumbler, it 

misappropriated these assets for its own benefit because investors were not able to make 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 14 of 31   Page ID #:14



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

15 

 

withdrawals on their accounts with the CoinW6 Platform and lost all the crypto assets 

they had invested. 

44. As described above, although the crypto assets were obscured and diverted 

to other crypto wallet addresses, the Defendant, through displays on the CoinW6 

Platform, misrepresented to investors that their funds were safely custodied in the 

investors’ accounts with the Defendant. The accounts for the investors, which investors 

could access online as instructed by the Scheme Participants, falsely reflected the 

amount of crypto assets the investors believed they had deposited. For example, Investor 

A transferred 29,230 in USDT to his account with the CoinW6 Platform on or about 

December 6, 2022. Although the Defendant had diverted the crypto assets, the CoinW6 

Platform reflected a balance of 39,341 USDT, which included a prior balance of 

approximately 9,835 USDT that had also been diverted to a tumbler. The screenshots 

below show the prior balance, the Defendant recording the deposit transaction, and the 

investor’s balance after the deposit.   

45. The Defendant and the Scheme Participants misrepresented to the investors 

that the investors had, according to their account balances on the Defendant’s websites, 

made hundreds of thousands of dollars from the additional investments. For example, the 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 15 of 31   Page ID #:15



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

16 

 

Defendant misrepresented that Investor A and Investor B had earned approximately 

619,000 USDT and 869,000 USDT, respectively, through the platform’s products in less 

than six months on principal of approximately $97,000 and $131,000, respectively. The 

Defendant, however, never retained the crypto assets in an account for the investor’s 

benefit and the purported investment returns reflected on the CoinW6 Platform were 

fake. For instance, in one screenshot of Investor A’s account on December 22, 2022, the 

Defendant represented that his account had a balance of 135,798 USDT and that he had 

earned cumulative income of 30,226 in USDT, or approximately 22.3 percent, through 

its staking product with all of the income but for 2,277 in USDT being earned over the 

prior 35 days. 

E. CoinW6 Blocks Investors From Withdrawing Their Funds With False 

Claims of Money Laundering Asset Freezes, Taxes, and Fees 

46. Eventually, investors stopped investing additional funds – often because 

they did not have any more funds to invest – or tried to withdraw the funds reflected in 

their accounts on the CoinW6 Platform, and as described below, were unable to do so. In 

response, the Defendant’s “Customer Service” would routinely contact investors through 

WhatsApp claiming that their crypto assets were frozen because the U.S. Department of 

Treasury’s Financial Crimes Enforcement Network (“FinCEN”) had detected money 

laundering, they owed taxes on the assets in their account, or they owed fees to crypto 

asset miners.  

47. To withdraw the funds, Customer Service told investors that they needed to 

deposit additional crypto assets to be held in escrow pending the outcome of FinCEN’s 

investigation or to pay the applicable taxes or fees. If the crypto assets were not 

deposited, Customer Service claimed that CoinW6 would assess penalties of one percent 

of the investor’s account value per day. These statements were all false. The false 

statements pressured investors to deposit additional crypto assets, and continued to 

intimidate investors from withdrawing their principal and the returns they had 

supposedly earned from the Defendant’s investment products. 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 16 of 31   Page ID #:16



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

17 

 

48. For example, after Investor A had exhausted the amount of funds he had 

available to invest a month prior, Customer Service told him on or about January 26, 

2023, as shown below, that he owed $187,000 of taxes on profits made using the 

Defendant’s products. At this time, the Defendant represented that the investor’s account 

balance was approximately 816,000 USDT, as shown above, which resulted in profits of 

5.3 times the investor’s principal over a 3-month period – October 2022 to January 2023. 

Viviana explained and walked Investor A through making the necessary payment, which 

Investor A transferred to an address Customer Service sent him over WhatsApp. 

49. The Scheme Participants reassured the investors that they had deposited 

additional crypto assets in the past to successfully withdraw their earnings on the 

CoinW6 Platform or pressured the investor by putting them under duress to make the 

additional payments. The Scheme Participants, in several instances, told investors that 

they could not be together without withdrawing the crypto assets earned from investing 

in CoinW6’s products. The Scheme Participants also cited to promises from the 

investors to gift money for the Scheme Participants’ fake businesses that were 

supposedly in dire financial condition, or even tried to blackmail the investors. A few 

investors paid additional funds but were unable to withdraw any funds. 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 17 of 31   Page ID #:17



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

18 

 

50. For example, prior to paying the purported taxes of $187,000, Viviana told 

Investor A that he would be able to withdraw all his funds after the tax payment, which 

would also enable him to repay her the 202,300 USDT she claimed to have sent him to 

co-invest and qualify him for a CoinW6 promotion. 

51. Arlene – like Viviana – also reassured Investor B by giving assurances that 

a miner’s fee was legitimate and her fault for not warning him to not have reinvested all 

the ETH in CoinW6’s products, thereby rendering those crypto assets unavailable to pay 

the miner’s fee until the product’s duration ended (i.e. 3, 7, 15, or 30 days depending on 

the product): “I forgot to remind you! Honey, it’s all my fault. . . . I should have 

reminded you earlier to leave some ETH in your wallet as a miner’s fee instead of 

putting them all in coinw.” Arlene continued representing that the transaction to pay the 

miner’s fee was safe, and continued to discuss their future together. 

52. After paying the purported taxes to the Defendant as described in paragraph 

48, Investor A attempted to withdraw his funds on or about January 31, 2023. On or 

about February 2, 2023, the Defendant rejected the withdrawal and sent a notice 

purportedly from FinCEN to Investor A, as depicted below, which informed him that his 

account had been suspended because of suspected money laundering. According to the 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 18 of 31   Page ID #:18



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

19 

 

notice, to un-suspend the account, Investor A would need to transfer approximately 

256,000 USDT as a security deposit. 

53. Investor A initially believed that the notice was legitimate and caused by 

Viviana’s deposits of 202,300 USDT. Viviana knew she never transferred any actual 

crypto assets to Investor A’s account and hence knew that the reflected amounts in the 

investor’s account at CoinW6 were fictitious. Viviana, therefore, made these fake 

transfers and communicated them to the Defendant to assist in creating a pretext for 

denying Investor A’s attempt to withdraw funds and devise another means through 

which she could try to pressure the investor into transferring more crypto assets to the 

Defendant to be misappropriated. 

54. To add additional pressure for Investor A to pay the security deposit, 

Viviana represented that she never had any issues ultimately withdrawing her funds from 

CoinW6 and that the FinCEN inquiry was indeed serious and legitimate. She said to 

Investor A, “Don’t worry, what we do is safe and formal. I have invested longer than 

you, and I have never encountered problems like yours in withdrawing money before.” 

Viviana had also told Investor A that she had a very rich uncle who specialized in crypto 

assets, and that she had learned from him. Several other investors described the Scheme 

Participants also telling them that they had such uncles too. Viviana told Investor A that 

her purported uncle recommended paying the security deposit, saying “Uncle just told 

me that money laundering accidents in financial investment are very serious now. . . . 

Uncle recommends that you complete the verification process, otherwise your account 

will be frozen, which will also affect your investment credit.” 

55. Because Investor A was unconvinced that additional funds would enable 

him to withdrawal his funds from CoinW6, Viviana started to tell him that it was urgent 

that she get her 203,200 USDT back as soon as possible because her salon needed the 

funds to pay her suppliers. 

56. After Investor A refused to send additional funds, Viviana resorted to 

blackmail, as shown in the WhatsApp messages at the top of the next page. 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 19 of 31   Page ID #:19



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

20 

 

57. Similarly for Investor B, after paying the mining fee as described in 

paragraph 51, CoinW6 informed him on December 30, 2022, that he also owed a further 

$16,000 as a handling fee on his withdrawal. Arlene did not resort to blackmail, but like 

Viviana, she continued to discuss a future together with Investor B, led him to believe 

that she was in financial trouble and in need of money from the withdraw as she had co-

invested with him, and told him to prove that he loved her: “If you really love me, I 

think you should find a way to get the money out. If you can’t don’t say you love me.” 

F. The Defendant Continued The Fraud Through Successor Websites 

58. After a few months of operating the fraud on a website and as investors 

started to try to withdraw funds from their accounts and online blogs would flag the web 

domain as a scam, the Defendant would take down the content from the website and 

restart the fraud under a new web domain. For investors who had yet to complain or 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 20 of 31   Page ID #:20



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

21 

 

attempt to withdraw funds, the Defendant would send them a notice that its products, 

like its crypto asset mining pool, were undergoing maintenance upgrades. As a part of 

this process, the Defendant would share the new web domain and instruct the investor to 

use it to gain access to the investor’s account and continuing investing with CoinW6. 

59. For example, Viviana initially directed Investor A to the CoinW6 Platform 

in October 2022 through the web domain 6hsh.com. Later in December 2022, Viviana 

began directing Investor A to access the CoinW6 Platform through the web domain 

coinw6.com. 

60. Likewise, an investor residing in Minnesota (“Investor C”) contacted 

Customer Service through WhatsApp in November 2022 concerning a lack of account 

access. Customer Service told Investor C that the mining pool was undergoing a 

maintenance upgrade. On or about November 23, 2028, Customer Service informed 

Investor C that his account and the platform’s crypto asset mining product could now be 

accessed through coinw6.com. Investor C’s account had initially been at 6hsh.com. 

61. The web domains coinw6.com, dmd567.com, and bybit.cc were all 

registered by persons with the same email address. Persons used the email address 

[email protected] to register the web domains dmd567.com and bybit.cc. 

Although persons used the email peteraops@gmail to register coinw6.com, the recovery 

email listed for that account was [email protected] which, in turn, had a recovery 

email of [email protected] – the same address used to register dmd567.com and 

bybit.cc. 

II. COINW6’s PURPORTED INVESTMENT PRODUCTS WERE 

 FICTITIOUS 

62. CoinW6’s crypto asset staking product, as presented on the website, offered 

investors daily income of two to three percent. Crypto asset staking is a process whereby 

one “stakes” (or locks) the “native” token of a particular blockchain in order to earn the 

opportunity to participate on the “validation” mechanism, typically for “proof of stake” 

blockchains in exchange for earning rewards. The Defendant – not the investor – chose 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 21 of 31   Page ID #:21



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

22 

 

what crypto assets to stake and transferred the purported income from its crypto asset 

staking product to the investor. The investors’ sole involvement in the investment was 

selecting how long the investors wanted their crypto assets invested in CoinW6’s 

purported crypto asset staking product.  

63. The Defendant, through its websites and the Scheme Participants, 

misrepresented to investors that CoinW6’s crypto asset staking product existed and was 

providing returns to investors of two to three percent per day. For example, as described 

in paragraph 28, the Defendant and Viviana had represented to Investor A that he had 

earned $150 on an investment of 1,000 USDT into CoinW6’s 3-day crypto asset staking 

product. When Investor A made his election to invest in the product, the address 

purportedly tied to the CoinW6 Platform did nothing; instead, his deposited funds were 

diverted hours later to a tumbler. Neither Investor A’s principal nor supposed investment 

gains were returned to Investor A.  

64. CoinW6’s crypto asset mining product, as presented on the website, offered 

investors daily income of two to three percent. In crypto asset mining pools, investors 

invest in a collection of crypto asset miners who combine their computational resources 

over a network to increase their chances to mine blocks and earn crypto asset rewards 

from proof of work blockchains. The Defendant – not the investor – chose which 

purported crypto asset mining pools to invest in and transferred the purported income to 

the investor. The investors’ sole involvement in the investments was selecting how long 

the investors wanted their crypto assets invested in CoinW6’s crypto asset mining 

product. 

65. The Defendant, through its websites and the Scheme Participants, 

misrepresented to investors that CoinW6’s crypto asset mining product existed and was 

providing returns to investors of two to three percent per day. For example, as outlined 

in paragraph 29, the Defendant and Viviana had represented to Investor A that he had 

earned $6,238 on an investment of 9,500 USDT into CoinW6’s crypto asset mining 

product in a month. Again, when Investor A made his election to invest in the product, 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 22 of 31   Page ID #:22



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

23 

 

the address purportedly tied to the CoinW6 Platform did nothing; instead, his deposited 

funds were diverted hours later to a tumbler. 

66. CoinW6’s crypto asset yield farming product, as presented on the website, 

offered investors daily income of two to three percent. In crypto asset yield farming, 

investors lock their crypto assets in smart contracts called liquidity pools on so-called 

decentralized crypto asset trading platforms to provide liquidity for various token pairs 

that trade in that liquidity pool. Investors who lock their crypto assets into liquidity pools 

can earn portions of fees charged or other rewards the platforms. The Defendant – not 

the investor – chose which liquidity pools to invest and transferred the purported income 

to the investor. The investors’ sole involvement in the investment was selecting how 

long they wanted their crypto assets invested in CoinW6’s crypto asset yield farming 

product. 

67. The Defendant, through its websites and the Scheme Participants, 

misrepresented to investors that CoinW6’s crypto asset yield farming product existed 

and was providing returns to investors of two to three percent per day. There is no 

evidence that CoinW6 maintained or invested in any actual liquidity pools. 

68. Reasonable investors would have considered it material to their decision to 

invest in the Defendant’s crypto asset staking, mining, and yield farming products that 

the products did not exist and hence were not generating any income for investors. 

69. The Scheme Participants misrepresented to investors that they had earned 

hundreds of thousands of dollars in profits from the Defendant’s products. The Scheme 

Participants also misrepresented to investors that they were co-investing in the 

Defendant’s products. For example, on December 6, 2022, after Investor A had 

deposited and invested 50,000 USDT – but prior to depositing and investing at least an 

additional 100,000 USDT – Viviana represented that she had invested $350,000 with the 

Defendant, earned $250,000, and planned to invest an additional $550,000. She also later 

represented that she had earned $1 million in rewards through CoinW6 promotions. 

70. Reasonable investors would have considered it material to their decision to 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 23 of 31   Page ID #:23



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

24 

 

invest in the Defendant’s products that the Scheme Participants – acting with, for, or 

controlling the Defendant – had not earned hundreds of thousands of dollars in profits 

and were not co-investing in the Defendant’s products. 

71. The Defendant misrepresented to investors on its websites that its platform 

was affiliated with CoinW and/or Coinbase, which are existing crypto asset trading 

platforms. The Defendant displayed on its websites a Whitepaper of Coinbase, holding it 

out to be Defendant’s Whitepaper. A Whitepaper is a document that explains a crypto 

project’s objectives, potential, and technical and economic factors. Reasonable investors 

would have considered it material to their decision to invest in the Defendant’s products 

that the Defendant was not affiliated with CoinW or Coinbase and that the Whitepaper 

displayed on Defendant’s websites was, in fact, not Defendant’s Whitepaper, but the 

Whitepaper of Coinbase. 

III.  COINW6’S PURPORTED INVESTMENT PRODUCTS WERE OFFERED 

 AND SOLD AS SECURITIES 

72. As described above, including, but not limited to, in paragraphs 25, 26, 29, 

37, and 41, investors invested money in the form of crypto assets – usually USDT – in 

the Defendant’s non-existent crypto asset products on the CoinW6 Platform, which 

included crypto asset staking, crypto asset mining, and crypto asset yield farming. 

73. As described above, including, but not limited to, in paragraph 69, investors 

were investing in a common enterprise by co-investing or pooling their crypto assets 

with other persons in the Defendant’s crypto asset products. The investors, including 

Investor A and Investor B, had each invested in the Defendant’s crypto asset mining 

product. When making a deposit with CoinW6, in many instances the Defendant 

directed investors to transfer their assets to the same crypto address, thereby comingling 

and pooling crypto assets. Viviana and Arlene also claimed to have contributed funds to 

co-invest with these investors and had told them that they already had made hundreds of 

thousands of dollars investing with the Defendant. CoinW6 published rates of return for 

each of its crypto asset products on the CoinW6 Platform. Investors potential purported 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 24 of 31   Page ID #:24



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

25 

 

profits or loss rose or fell together in proportion to their investment depending on the 

profitability of CoinW6’s purported crypto asset products. Moreover, investors’ potential 

for profits depended entirely on CoinW6’s ability to operate and maintain the CoinW6 

Platform as well manage its purported crypto asset products. 

74. As described above, including, but not limited to, in paragraphs 62-67, 

investors in the Defendant’s crypto asset-products had an expectation of profits derived 

from the efforts of the Defendant. The Defendant’s crypto asset products offered 

investors daily, passive income of two to three percent, which was reflected for each 

product on the CoinW6 Platform prior to investment, as shown in the images at the top 

of the next page. The Defendant – not the investor – chose which crypto assets to stake, 

into which crypto mining pool to invest, or into which liquidity pool to invest (yield 

farming), and transferred the purported income to the investor from these products. The 

investor’s sole decision was for how long they wanted their crypto assets invested in 

CoinW6’s products. As a result, investors potential for returns were dependent 

CoinW6’s ability to make their crypto asset products profitable.  

IV.  COINW6 ACTED WITH SCIENTER 

75. As described above, including but not limited to, in paragraphs 44, 63, and 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 25 of 31   Page ID #:25



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

26 

 

65, the Defendant had transferred the investors’ crypto assets to a tumbler and 

misappropriated the funds as investors were unable to withdraw their investments and 

lost all their crypto assets. Yet, as described in paragraphs 28, 29, 37, 41, 44, and 45, the 

Defendant represented to investors that crypto assets were in an account for each 

investor’s benefit and were being invested in CoinW6’s crypto asset products. The 

Defendant, however, had misappropriated the investors’ crypto assets prior to the 

investors selecting which product to invest. As a result, the Defendant knew or was 

reckless in not knowing that its representations concerning the investors’ account 

balances and profits reflected in their accounts on the CoinW6 Platform were fictitious 

and untrue.  

76. As described above, including but not limited to, in paragraphs 48, 51, and 

52, the Defendant, acting through the guise of Customer Service, represented to 

investors that FinCEN had frozen account balances, that taxes were due on their 

accounts, or that investors owed miner fees. As FinCEN does not have authority to 

freeze assets or block funds transfers – which it states clearly in an alert on its website at 

fincen.gov – the Defendant knew or was reckless in not knowing that its representations 

concerning FinCEN were false. Similarly, since the Defendant could not make tax 

payments because it did not collect tax identification numbers of the investors, and since 

the Defendant had not used investor’s funds to invest in any crypto asset mining pools, 

the Defendant knew or was reckless in not knowing that it representations about taxes or 

miner fees being owed were false. 

77. As described above, including but not limited to, in paragraphs 33 and 35, 

the Scheme Participants told investors that they had transferred crypto assets into the 

investors’ accounts to co-invest or pay fees. A review of the Ethereum blockchain for the 

purported crypto addresses of the investors on the CoinW6 Platform shows that the 

Scheme Participants like Viviana never made these transfers. Despite the transfers not 

occurring, the Defendant credited the investors’ accounts for these transfers, 

misrepresenting to investors that the deposits had been made. As the transfers had not 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 26 of 31   Page ID #:26



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

27 

 

occurred, the Defendant had to have been aware of the Scheme Participants’ 

conversations with the investors so the CoinW6 Platform would reflect a deposit in the 

proper amount. As such, the Defendant knew or was reckless in not knowing that the 

Scheme Participants were making misrepresentations to the investors about having 

deposited crypto assets into their accounts with the CoinW6 Platform and knew or was 

reckless in not knowing that those deposits never occurred. 

FIRST CAUSE OF ACTION 

Violation of Sections 5(a) and 5(c) of the Securities Act  

[15 U.S.C. §§ 77e(a), 77e(c)]  

78. The Commission realleges and incorporates by reference the allegations 

contained in Paragraphs 1-11, 21-41, and 58-74, above. 

79. Section 5(a) of the Securities Act provides that unless a registration 

statement is in effect as to a security, it shall be unlawful any person, directly or directly, 

(1) to make use of any means or instruments of transportation or communication 

in interstate commerce or of the mails to sell such security through the use or medium of 

any prospectus or otherwise; or (2) to carry or cause to be carried through the mails or 

in interstate commerce, by any means or instruments of transportation, any 

such security for the purpose of sale or for delivery after sale. 

80. Section 5(c) of the Securities Act provides that it shall be unlawful for any 

person, directly or indirectly, to make use of any means or instruments of transportation 

or communication in interstate commerce or of the mails to offer to sell or offer to buy 

through the use or medium of any prospectus or otherwise any security, unless a 

registration statement has been filed as to such security, or while the registration 

statement is the subject of a refusal order or stop order or (prior to the effective date of 

the registration statement) any public proceeding or examination under section 77h of 

this title. 

81. No registration statement had been filed or was in effect for any of the 

securities offered and sold by the Defendant and no exemption applied. 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 27 of 31   Page ID #:27



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

28 

 

82. The Defendant, by engaging in the conduct described above, directly or 

indirectly, made use of means or instruments of transportation or communication in 

interstate commerce or of the mails to offer to sell or to sell such securities. 

83. By reason of the foregoing, the Defendant violated, and unless enjoined will 

again violate, Sections 5(a) and (c) of the Securities Act [15 U.S.C. §§ 77e(a) and (c)]. 

SECOND CAUSE OF ACTION 

Violation of Section 17(a) of the Securities Act  

[15 U.S.C. §§ 77q(a)] 

84. The Commission realleges and incorporates by reference the allegations 

contained in Paragraphs 1 through 77, above. 

85. By engaging in the conduct described above, the Defendant, in the offer or 

sale of securities, and by the use of the means or instruments of transportation or 

communication in interstate commerce or by use of the mails, directly or indirectly: (a) 

employed devices, schemes, or artifices to defraud; (b) obtained money or property by 

means of untrue statements of material facts of by omitting to state a material fact 

necessary to make the statements made, in light of the circumstances under which they 

were made, not misleading; and (c) engaged in transactions, practices, or courses of 

business which operated or would operate as a fraud or deceit upon the buyer. 

86. By reason of the foregoing, The Defendant, directly or indirectly violated, 

and unless enjoined will continue to violate, Section 17(a) of the Securities Act [15 

U.S.C. § 77q(a)].  

THIRD CAUSE OF ACTION 

Violation of Section 10(b) of the Securities Exchange Act [15 U.S.C. § 78j(b)]  

and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5] 

87. The Commission realleges and incorporates by reference the allegations 

contained in Paragraphs 1 through 77, above. 

88. The Defendant, by engaging in the conduct described above, directly or 

indirectly, by the use of means or instrumentalities of interstate commerce or use of the 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 28 of 31   Page ID #:28



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

29 

 

mails, in connection with the purchase or sale of securities, with scienter, (a) employed 

devices, schemes, or artifices to defraud; (b) made untrue statements of a material fact or 

omitted to state a material fact necessary in order to make the statements made, in the 

light of the circumstances under which they were made, not misleading; and (c) engaged 

in acts, practices, or courses of business that operated or would operate as a fraud and 

deceit upon other persons. 

89. By reason of the foregoing, the Defendant violated, and unless restrained 

and enjoined will continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. 

§78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]. 

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that the Court enter a Final 

Judgment:  

I. 

Finding that the Defendant committed the violations of the federal securities laws 

as alleged in this Complaint; 

II. 

In forms consistent with Rule 65(d) of the Federal Rules of Civil Procedure, 

permanently enjoining Defendant and its officers, agents, servants, employees, and 

attorneys, and those persons in active concert or participation with any of them, who 

receive actual notice of the judgment by personal service or otherwise, and each of them, 

from: 

a. violating Sections 5(a) and 5(c) of the Securities Act [15 U.S.C. §§ 77e(a), 

77e(c)]; 

b. violating Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]; and 

c. violating Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)], and Rule 

10b-5 thereunder [17 C.F.R. § 240.10b-5]. 

 

 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 29 of 31   Page ID #:29



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

30 

 

III. 

In forms consistent with Rule 65(d) of the Federal Rules of Civil Procedure, 

enjoining the Defendant from directly or indirectly participating in the issuance, 

purchase, offer, or sale of any security, including, but not limited to, through any entity, 

affiliate or person owned or controlled by CoinW6 or acting for or with CoinW6. 

IV. 

Issue an order requiring the Defendant to remove all pages of its websites and in 

its place post a copy of the Commission’s Complaint. 

V. 

Ordering the Defendant to disgorge all ill-gotten gains obtained as a result of the 

acts or courses of conduct alleged in this Complaint, together with prejudgment interest 

thereon, pursuant to Section 21(d)(3), (d)(5) and 21(d)(7) of the Exchange Act [15 

U.S.C. §§ 78u(d)(3), 78u(d)(5) and 78u(d)(7)]. 

VI. 

Ordering the Defendant to pay civil penalties pursuant to Section 20(d) of the 

Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C. 

§ 78u(d)(3)]. 

VII. 

Retaining jurisdiction of this action in accordance with the principles of equity 

and the Federal Rules of Civil Procedure in order to implement and carry out the terms 

of all orders and decrees that may be entered, or to entertain any suitable application or 

motion for additional relief within the jurisdiction of this Court. 

VIII.  

Granting such other and further relief as this Court may determine to be just and 

necessary. 

 

 

 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 30 of 31   Page ID #:30



 

1 

 2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

  

 

31 

 

DEMAND FOR JURY TRIAL 

Pursuant to Federal Rule of Civil Procedure 38, the Commission demands trial by 

jury. 

Dated: September 17, 2024   /s/ Daniel O. Blau   

 Daniel O. Blau 

Matthew B. Reisig 

Attorneys for Plaintiff 

Securities and Exchange 

 Commission 

 

Case 2:24-cv-07924     Document 1     Filed 09/17/24     Page 31 of 31   Page ID #:31