SEC v. GA Investors; and John Does Nos. 1-4, No. 1:23-cv-11050, District of Massachusetts (May 11, 2023) — Complaint

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

SECURITIES AND EXCHANGE COMMISSION,

Plaintiff,

v.

GA INVESTORS, and
JOHN DOES NOS. 1-4,

Defendants.

    Civil Action No.

JURY TRIAL DEMANDED

COMPLAINT
Plaintiff Securities and Exchange Commission (the “Commission”) alleges:
SUMMARY
1. This is an emergency enforcement action to stop GA Investors and John Does
Nos. 1-4 (collectively, “Defendants”), the unknown owners and operators of dozens of
fraudulent websites, including GA-Investors.org, from engaging in an ongoing fraudulent
scheme.  Defendants are soliciting investors by falsely impersonating legitimate companies
and/or falsely promising exorbitant returns—in some cases as high as 61.9% in 24 hours—
for investments in various securities offerings, including crypto asset mining pools.
2. In reality, this is a fraud.  Defendants have no connection to the legitimate
companies they are claiming to be, they have already misappropriated thousands of dollars
from investors, and they are actively perpetrating fraudulent securities offerings.  Further,
although GA-Investors.org is no longer accessible to the public, at least 26 of the
Defendants’ websites are currently active, including the newly published and similarly

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named GA-Investor.org (dropping the “s” in GA-Investors).  GA-Investor.org contains the
same false information and representations as GA-Investors.org.
3. By engaging in the conduct alleged, Defendants violated, and unless
restrained and enjoined, will continue to violate, Section 17(a) of the Securities Act of 1933
(the “Securities Act”) [15 U.S.C. § 77q(a)] and Section 10(b) of the Securities Exchange Act
of 1934 (the “Exchange Act’) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R.
§ 240.10b-5].
4. Because this fraud is ongoing and because of the danger that investor funds
will continue to be accumulated by the Defendants and will be dissipated, the Commission
seeks emergency preliminary relief, including: (a) an order prohibiting Defendants from
continuing to violate Section 17(a) of the Securities Act and Section 10(b) of the Exchange
Act and Rule 10b-5 thereunder; ( b) an order freezing the assets of Defendants held for their
direct or indirect benefit, and/or subject to their direct or indirect control; (c) an order
freezing all direct or indirect proceeds of the misconduct described in the Complaint; (  d) an
order prohibiting Defendants from soliciting, accepting or depositing any monies obtained
from investors pending the resolution of this action; (e) an order requiring Defendants to
repatriate assets held outside the United States; (f) an order requiring an expedited
accounting of the Defendants’ assets and liabilities; ( g) an order restraining Defendants from
destroying, concealing, or disposing of property or documents related to the conduct alleged
in this Complaint; (h) an order providing for alternative service of process; and (i) an order
requiring that Defendants’ fraudulent websites soliciting investments in securities offerings
be taken down forthwith.
5. The Commission also seeks: (a) entry of permanent injunctions against
Defendants, prohibiting them from further violations of Section 17(a) of the Securities Act

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and Section 10(b) of the Exchange Act and Rule 10b-5 thereunder; ( b) disgorgement of all
ill-gotten gains from the unlawful activity set forth in this Complaint, together with
prejudgment interest, pursuant to Sections 21(d)(3) and 21(d)(7) of the Exchange Act [15
U.S.C. §§ 78u(d)(3) and (d)(7)]; ( c) the imposition of civil monetary penalties pursuant to
Sections 20(d) of the Securities Act [ 15 U.S.C. § 78t(d)] and Section 21(d)(3) of the
Exchange Act [15 U.S.C. § 78u(d)(3)]; (  d) conduct-based injunctions enjoining Defendants
from directly or indirectly, including, but not limited to, through any entity owned or
controlled by Defendants, participating in the purchase, offer or sale of any security to
investors or potential investors, provided, however, that such injunction shall not prevent
Defendants from purchasing or selling securities listed on a national securities exchange for
their own personal accounts; and (e) such other relief as the Court may deem appropriate.
JURISDICTION AND VENUE
6. The Commission brings this action pursuant to the enforcement authority
conferred upon it by Section 20(b) of the Securities Act [15 U.S.C. § 77t(b)] and Section
21(d) of the Exchange Act [ 15 U.S.C. § 78u(d)].
7. This Court has jurisdiction over this action pursuant to Section 22(a) of the
Securities Act [15 U.S.C. § 77v(a)] and Sections 21(d), 21(e), and 27 of the Exchange Act
[15 U.S.C. §§ 78u(d), 78u(e) and 78aa].
8. Venue lies in this District pursuant to Section 22(a) of the Securities Act [15
U.S.C. § 77(a)] and Section 27 of the Exchange Act [15 U.S.C. § 78aa], because certain of
the acts, practices, transactions, and courses of business alleged in this Complaint occurred
within the District, including soliciting and receiving investments from at least one
Massachusetts resident.

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9. In connection with the conduct described in this Complaint, GA Investors and
John Does Nos. 1-4 have, directly or indirectly, made use of the means or instruments or
instrumentalities of transportation or communication in interstate commerce, or of the mails,
or the facilities of a national securities exchange.
10. Defendants’ conduct took place in connection with the purchase or sale, and
in the offer or sale, of securities.
DEFENDANTS
11. GA Investors (“GAI”) is the entity that offered the securities described on the
GA-Investors.org website and the GA-Investor.org website.  GAI is not an incorporated
entity in any jurisdiction and is not registered with the Commission.  As described further
below, GAI has impersonated and used the information of various legitimate companies,
including names, addresses, website content, and stock trading information.
12. John Does Nos. 1-4 (“DOES”) are unknown individuals and/or groups of
individuals responsible for and/or controlling GAI and GA-Investors.org,  as well as dozens
of other fraudulent websites offering securities.  DOES include the individuals responsible
for maintaining, organizing, and funding GA-Investors.org, as well as those persons
responsible for constructing and advertising the securities offered by GAI.  DOES
communicated online with investors through aliases, including the alias “Brian K. Stafford.”
FACTS
A. Defendants Offered Securities Through Dozens of Fraudulent Websites.

13. From at least March 2022 to the present, Defendants have offered investments
through dozens of fraudulent websites.  Some websites offer investments in traditional
securities such as stocks and bonds, while other websites capitalize on the rise of crypto
assets by offering investments in crypto asset mining pools.  Some of the websites also

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impersonate legitimate companies and/or promise exorbitant returns on investments, such as
61.9% in 24 hours.  Over time, some of the websites have been taken down, while others
remain publicly accessible on the Internet.  A list of Defendants’ known currently active
websites is attached as Appendix A to this Complaint.
14. Through the websites, related social media sites, and via smartphone
messaging applications, Defendants solicited investors from across the world, including
investors in the United States, who invested approximately $85,000 in GAI’s fraudulent
securities offerings on the now-defunct GA-Investors.org website.
15. GAI impersonated legitimate companies by misappropriating authentic
information for fraudulent use on the GA-Investors.org website.  Some of the genuine
information that GAI falsely claimed as its own includes:
a. That GAI’s “District Office” is located at 6025 Metcalf Lane, Overland
Park, Kansas 66202.  In fact, a registered broker-dealer with a similar
name—which has no affiliation with GAI or GA-Investors.org—is located
at that address.
b. That GAI’s “Corporate Headquarters” is located in the “GA Investors
Tower” at 301 E. Fourth St., Cincinnati, Ohio 45202.  In fact, an insurance
company with a similar name—which has no affiliation with GAI or GA-
Investors.org—is located at that address.
c. Stock trading data purportedly for GAI on both the London Stock
Exchange and Johannesburg Stock Exchange.  In fact, the stock trading
data on GA-Investors.org belongs to a publicly-traded company which has
no affiliation with GAI or GA-Investors.org.

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16. GAI solicited investments in “Unit Trusts and [exchange-traded funds].” The
GA-Investors.org website described the Unit Trusts as investments where “[y]our money is
combined with the money of other investors and our investment managers use the pool of
money to buy underlying investments, such as equities, bonds, cash and property” and
“‘units’ . . . are allocated to you according to the amount of money you invest.”
17. GAI described the “Unit Trusts” as consisting of six “investment types,”
which offered daily, guaranteed returns ranging from 2% to 4.5%, depending on the size of
the investment.  With respect to these investments in the Unit Trusts, GAI made numerous
false statements on the GA-Investors.org website and its affiliated social media accounts,
including:
a. “Profit is guaranteed.”
b. “Your profit starts accumulating daily, and you can withdraw at any time.”
c. “[Y]ou own the [GAI Trust] units until you decide to sell them.”
18. Each of the statements and representations in paragraph 17 concerning GAI’s
investments were false and misleading because Defendants halted investor withdrawals and
misappropriated invested assets.
19. To invest, GAI required individuals to create a private account on the GA-
Investors.org website.  These private account pages included, among other things, a digital
wallet address that was controlled by GAI.  Investors were then directed to purchase crypto
assets from a separate crypto asset trading platform and transfer those crypto assets to GAI
by sending them to the GAI wallet address listed on the private account page.  Once the
transfer was complete, investors were sent a confirmation email and could then view their
investment on the private account page on the GA-Investors.org website.

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20. GAI displayed to its investors on their private account pages accumulated
profits on investments, when no such profits existed.  Defendants, at times, permitted at least
some investors to make small withdrawals from their accounts after investment.  But when
investors sought to recoup larger portions of their investment, Defendants concocted excuses
for why the funds could not be withdrawn and then froze those accounts.
21. The investments that GAI offered for sale on GA-Investors.org are investment
contracts, a type of security under Section 2(a)(1) of the Securities Act and Section 3(a)(10)
of the Exchange Act.
B. Defendants Solicited Investors Online With False and Misleading Statements.

22. In addition to the numerous false and misleading representations contained on
the GA-Investors.org website, DOES made numerous false statements about GAI and the
securities offered by GAI in direct communications with investors and potential investors
using instant messaging platforms on various social media sites and smartphone applications.
23. In direct communications with investors and potential investors, DOES
identified themselves as an individual named “Brian K. Stafford,” representing that Stafford
was a “stakeholder” in GAI who had recently been hired as its Chief Operating Officer, and
claiming that he operated a nutrition business in Texas.
24. In reality, Stafford is an alias.  DOES used the Stafford figurehead, fictitious
biography, and photographs misappropriated from a real person’s social media sites to solicit
investors around the world, including at least one Massachusetts investor.  From
approximately October 2022 to January 2023, DOES used the Stafford persona to make
numerous false and misleading statements to the Massachusetts investor about GAI,
including the following:
a. “[Y]ou won’t lose money it works just like your bank.”  (Oct. 27, 2022).

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b. GAI is “a blockchain leading company and an Insurance Company
meaning that your account and investments are insured, it’s endorsed by
Elon musk [sic] and Peter Smith and Insured by the FDIC.”  (  Oct. 27,
2022).
c. To receive a profit, “you have to purchase the [crypto] coins and store
them in your wallet so what GA does is to help you invest them, by
purchasing more crypto mining equipments [sic] and machines to speed up
their mining . . . and you receive returns daily.”  (Nov. 3, 2022).
d. “[C]rypto mining” with GAI will “earn profits daily;” “with mining you
earn profits everyday;” and that after depositing money “to your GA
wallet . . . your account would automatically start generating daily ROIs
[returns on investment].”  (Oct. 26, 2022; Nov. 1, 2022; Nov. 4, 2022).
25. Each of the statements to the Massachusetts investor was false or misleading
because GAI did not act like an FDIC insured bank, and investor assets were not invested in
crypto mining or other projects.  Rather, the Massachusetts investor’s funds were
misappropriated by Defendants.
26. The Massachusetts investor agreed to invest approximately $2,400 in GAI on
or about November 4, 2022, expecting to receive a purported guaranteed daily 3% return,
based on GAI’s misrepresentations as communicated by “Stafford” and posted on the GA-
Investors.org website.  From approximately November 11, 2022 to November 23, 2022, the
Massachusetts investor invested approximately $ 47,500 more in GAI, believing that all
invested funds and purported profits could be withdrawn at any time.
27. From approximately November 30, 2022 to December 7, 2022, the
Massachusetts investor was able to withdraw approximately $15,000 from their GAI account.

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However, when the Massachusetts investor subsequently attempted to withdraw additional
money, GAI stated on December 19, 2022, that the account had been “suspended” and,
subsequently on December 25, 2022, GAI stated that the Massachusetts investor would have
to invest an additional $40,000 to withdraw any more money.
28. On January 21, 2023, GAI informed the Massachusetts investor that they were
“expected to make a $20,000 deposit to unfreeze” the account.
29. At least three other investors invested a total of approximately $35,000 in
GAI, with similar claims by DOES, acting as Stafford, of exorbitant daily returns.  These
other investors were not able to withdraw any funds from GAI or the GA-Investors.org
website.
C. Defendant DOES Own and/or Operate Dozens of Similar Fraudulent Websites
and Smartphone Applications.

30. From at least March 2022 to the present, DOES have operated dozens of
websites and smartphone applications through which they conducted similar fraudulent
securities offerings, much as they did on GA-Investors.org, often using the same or similar
templates and information.  Since April 19, 2023, the GA-Investors.org website is no longer
accessible, but many of DOES’ other websites and applications continue to offer similar
investments in securities such as stocks, bonds, and exchange-traded funds, as well as
investments in crypto asset mining, crypto asset ATMs, and other pooled investments.
DOES continue to solicit investors through false statements, impersonating legitimate
companies, and/or offering exorbitant returns on investment.  For example, a website located
at the URL GA-Investor.org (dropping the “s” in GA-Investors) is currently accessible to the
public and contains the same information and representations reflected in paragraphs 15-17
above.

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D. Defendants Acted With Scienter.
31. Defendants owned, controlled, and orchestrated the fraudulent GA-
Investors.org website and offerings as well as the dozens of other related websites and
smartphone applications, and therefore knew, or were reckless or negligent in not knowing,
that the stated companies or persons were not who they claimed to be, they had no reasonable
basis to advertise exorbitant returns, and there were no underlying investments in activities
such as crypto asset mining pools.
NEED FOR EMERGENCY RELIEF
32. This is an ongoing fraud.  Defendant DOES’ fraudulent websites identified in
Appendix A are currently accessible on the Internet, and Defendant DOES continue to use
these to offer investments to the public.  Potential investors continue to be able to place
money in those investments.  Further, although GA-Investors.org is  no longer accessible to
the public as of April 19, 2023, a website located at the URL GA-Investor.org is currently
accessible to the public.  The GA-Investor.org website contains the same information and
representations as the GA-Investors.org website reflected in paragraphs 15 to 17 above.
Emergency relief in the form of a temporary restraining order and, subsequently, preliminary
injunction are necessary to stop Defendants’ fraudulent solicitations and potential harm to the
investing public.
33. Defendants will likely dissipate assets belonging to investors by transferring
them outside the Court’s jurisdiction.

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34. The emergency relief requested is necessary in order to prevent further
violations of the federal securities laws and further harm to investors, including further
dissipation of investor assets.
35. The violations set forth in this Complaint involve fraud, deceit, manipulation,
or deliberate or reckless disregard of a regulatory requirement,  and such violations directly or
indirectly resulted in substantial losses or created a significant risk of substantial losses to
other persons.
FIRST CLAIM FOR RELIEF
Violations of Exchange Act Section 10(b) and Rule 10b-5 Thereunder
(All Defendants)

36.  Paragraphs 1 through 35 are re-alleged and incorporated by reference.
37.  By engaging in the conduct described above, Defendants, singly or in concert
with others, directly or indirectly, acting intentionally, knowingly or recklessly, by use of the
means or instrumentalities of interstate commerce or of the mails, in connection with the
purchase or sale of securities: (a) have employed, are employing, and are about to employ
devices, schemes or artifices to defraud; (b) have made, are making, and are about to make
untrue statements of material fact or have omitted, are omitting, and are about to omit 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; or (c) have engaged, are
engaging, and are about to engage in acts, practices or courses of business which operate as a
fraud or deceit upon certain persons.
38.  By engaging in the foregoing conduct, the Defendants, directly and indirectly,
violated, and unless enjoined, will again 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].

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SECOND CLAIM FOR RELIEF
Violations of Securities Act Section 17(a)
(All Defendants)

39.    Paragraphs 1 through 35 are re-alleged and incorporated by reference.
40.  By virtue of the foregoing, Defendants, singly or in concert with others, acting
intentionally, knowingly or recklessly, or negligently, in the offer or sale of securities, by use
of the means or instruments of
 transportation or communication in interstate commerce or by
use of the mails: (a) have employed, are employing, and are about to employ devices,
schemes or artifices to defraud; (b) have obtained, are obtaining, and are about to obtain
money or property by means of untrue statements of material fact or omissions 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; or (c) have engaged, are
engaging, and are about to engage in transactions, practices or courses of business which
operate as a fraud or deceit upon the purchasers of the securities.
41.  By virtue of the foregoing, Defendants, directly or indirectly, violated, and
unless enjoined, will again violate, Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)].
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that this Court:
A. Enter a temporary restraining order which:
1. Restrains GAI and John Does Nos. 1-4, and each of their officers,
agents, servants, employees, attorneys, and those persons in active concert or participation
with them who receive actual notice of the order by personal service or otherwise, including
facsimile transmission, electronic mail or overnight delivery service, from directly or
indirectly violating Section 17(a) of the Securities Act [l 5 U.S.C. § 77q(a)] and Section

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10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F .R.
§ 240.10b-5].
2. Requires GAI and John Does Nos. 1-4, and each of their officers,
agents, servants, employees, attorneys, and those persons in active concert or participation
with them who receive actual notice of the order by personal service or otherwise, including
facsimile transmission, electronic mail or overnight delivery service, to hold and retain all
funds and other assets held for the direct or indirect benefit, or under the direct or indirect
control, of GAI and John Does Nos. 1-4, to prevent any withdrawal, sale, payment, transfer,
dissipation, assignment, pledge, alienation, encumbrance, diminution in value or other
disposal of any such funds and other assets, including incurring charges or cash advances on
any credit card, and to freeze such funds and other assets pending further order of this Court,
and further require all banks, brokerage firms, other financial institutions, Internet payment
agents, and other persons and entities which receive actual notice of the order by personal
service or otherwise, including by facsimile transmission, electronic mail or overnight
delivery service, and which hold any funds or other assets for the direct or indirect benefit, or
under the direct or indirect control, of GAI and John Does Nos. 1-4, to hold and retain within
their control and prohibit the withdrawal, sale, payment, transfer, dissipation, assignment,
pledge, alienation, encumbrance, diminution in value or other disposal of any such funds and
other assets;
3. Requires that all persons who hold or possess funds or other assets in
the name, for the direct or indirect benefit, or under the direct or indirect control of the
Defendants (including assets in the name of GA Investors or John Does Nos. 1-4)  , hold and
retain such funds and other assets, prevent any withdrawal, sale, payment, transfer,
dissipation, assignment, pledge, alienation, encumbrance, diminution in value or other

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disposal of any or all such funds or other assets, and freeze such funds and other assets
pending further order of this Court;
4. Restrains GAI and John Does Nos. 1-4 and each of their officers,
agents, servants, employees and attorneys, and those persons in active concert or
participation with them who receive actual notice of the order by personal service or
otherwise, including facsimile transmission, electronic mail or overnight delivery service,
from soliciting, accepting, or depositing into any account in which any of them has a direct or
indirect beneficial interest or over which they exercise direct or indirect control, any funds or
other assets obtained in connection with solicitations from actual or prospective investors
pending the resolution of this action;
5. Requires that GAI and John Does Nos. 1-4, and each of their officers,
agents, servants, employees and attorneys, and those persons in active concert or
participation with them who receive actual notice of this Order by personal service or
otherwise, including facsimile transmissions, electronic mail or overnight delivery service,
and each of them, shall, within five (5) days of receiving actual notice of this Order, take
such steps as are necessary to repatriate and deposit into the registry of the Court in an
interest bearing account, any and all funds or assets that presently may be located outside of
the United States that were obtained directly or indirectly from investors;
6. Requires GAI and John Does Nos. 1-4 to submit in writing and serve
upon counsel for the Commission, within five ( 5) business days following service of the
order, a written accounting identifying:
a.  all transfers or payments of funds to them or any other entity
controlled by them from investors in connection with the misconduct
described in the Complaint (the identification shall include the amount of each

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such transfer or payment, the date of the transfer or payment, and the name,
address, account number and financial institution or Internet payment agent of
the party making and the party receiving the transfer or payment);
b.  in detail, the precise disposition of each transfer or payment identified
in response to paragraph 6.a above and all assets derived therefrom, including
but not limited to:
• the nature and results of any investment in which the funds were
used;
• any subsequent transfer or payment of the funds (the
identification shall include the amount of each such transfer or
payment, the date of the transfer or payment, the name, address,
account number and financial institution of the party making and
receiving the transfer or payment, and the reason for the transfer
or payment); and
• any fees or expenses charged and a detailed statement of the
nature and purpose of such fees and expenses.
c.   by name and address, all persons, entities and accounts currently
holding funds or assets derived from the transfers or payments described in
paragraph 6.a above and the reason each received the funds or assets (the
identification shall include the amount each received, the date received, the
reason received, the institution and account number or location in which the
funds or other assets are held and the name, address, account number and
financial institution or Internet payment agent of the person or entity who
provided each with the funds or other assets);

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d.  assets of every type and description that currently, or at the time of
acquisition, has or had a value of at least one thousand dollars ($1,000)
presently owned by or held for the direct or indirect benefit, or subject to the
direct or indirect control, of Defendants, whether in the United States or
elsewhere; and
e.  all accounts held at any bank, brokerage or other financial institution
or Internet payment agent in the United States or elsewhere in the name, for
the direct or indirect benefit, or under the direct or indirect control, of
Defendants, or in which Defendants have or had any direct or indirect
beneficial interest, at any time from January 1, 2022, to the present.
7. Restrains GAI and John Does Nos. 1-4 and each of their officers,
agents, servants, employees and attorneys and those persons in active concert or participation
with them who receive actual notice of the order by personal service or otherwise, including
by facsimile transmission, electronic mail or overnight delivery service, from destroying,
mutilating, concealing, altering, or disposing of any items, including but not limited to any
books, records, documents, correspondence, contracts, agreements, assignments, obligations,
tape recordings, computer media or other property relating to GAI and John Does Nos. 1-4 or
any of their securities, financial, or other business dealings;
8. Provides that, pursuant to Rule 5 of the Federal Rules of Civil
Procedure, service of all pleadings and other papers to be served in this action, including the
Summons and Complaint, may be made by email, overnight delivery service, personally by
any employee of the Commission who is not counsel of records in this matter, or any other
person, or in any other manner authorized by Rule 5 of the Federal Rules of Civil Procedure,
or by publication;

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9. Requires GAI and John Does Nos. 1-4 to serve the statements and
accountings required by the order and all other filings in this action on counsel for the
Commission by email, messenger, overnight delivery service, or by facsimile to David H.
London, U.S. Securities and Exchange Commission, 33 Arch Street, 24th Floor, Boston,
Massachusetts 02110, [email protected], facsimile number (617) 573-4590; and
10. Requires that all websites associated with the Defendants that are
making material misrepresentations relating to a securities offering, as identified in Appendix
A, be taken down forthwith.
B. Enter a preliminary injunction extending the terms of the temporary
restraining order described above;
C. Enter a permanent injunction which:
1. Restrains GAI and John Does Nos. 1-4 and each of their officers,
agents, servants, employees, attorneys, and those persons in active concert or participation
with them who receive actual notice of the order or injunction by personal service or
otherwise, from directly or indirectly engaging in the conduct described above, or in conduct
of similar purport and effect, in violation of:
a. Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)], and
b. 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];
2. Requires GAI and John Does Nos. 1-4 to disgorge their ill-gotten
gains, including prejudgment interest, pursuant to Sections 21(d)(3) and 21(d)(7) of the
Exchange Act [15 U.S.C. §§ 78u(d)(3) and (d)(7)];

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3. Order GAI and John Does Nos. 1-4 to pay appropriate civil monetary
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)];
D. Enjoins GAI and John Does Nos. 1-4 from directly or indirectly, including,
but not limited to, through any entity owned or controlled by GAI and/or John Does Nos. 1-
4, participating in the purchase, offer or sale of any security to investors or potential
investors, provided, however, that such injunction shall not prevent GAI and John Does Nos.
1-4 from purchasing or selling securities listed on a national securities exchange for their
own personal accounts
E. Retain jurisdiction over this action to implement and carry out the terms of all
orders and decrees that may be entered; and
F. Award such other and further relief as the Court deems just and proper.
JURY DEMAND
 The Commission demands a jury in this matter for all claims so triable.

Dated:  May 11, 2023
Respectfully submitted,

SECURITIES AND EXCHANGE COMMISSION

By its attorneys,

________________________________
David H. London (BBO# 638289)
Kerry Dakin (BBO# 640826)
Russell A. Mawn, Jr. (BBO# 712095)
Boston Regional Office
33 Arch Street, 24th Floor
Boston, MA 02110
(617) 573-8997 (London)
[email protected]

SEC v. GA Investors and John Does Nos. 1‐4
Appendix A
Website
Connection to GAISecurity OfferedNature of Fraud
abotsmartcontract.com
Same domain registrar account 
as ga‐investors.orgStocks; bondsDaily profits of 5‐20%
affinittycapitals.com
Same domain registrar account 
as ga‐investors.orgStocks; ETFsDaily profits of 5‐12%
bluechip‐brokers.com
Same domain registrar account 
as ga‐investors.orgStocks; ETFs1‐7‐day profits of 4‐90%
brix‐finances.com
Same domain registrar account 
as ga‐investors.orgStocksDaily profits of 0.5‐5%
commerscapital.com
Same domain registrar account 
as ga‐investors.orgStocks; unit trusts
Impersonating legitimate 
company
elsavierfinance.com
Same domain registrar account 
as ga‐investors.orgStocks; ETFsDaily profits of 5‐14%
enkryptfinance.com
Sent to Investor A by Brian 
Stafford
Investment contracts; 
stocks; ETFs; optionsMonthly profits of 13.5‐25%
fortuneminters.com
Same domain registrar account 
as
 ga‐investors.orgStocksDaily profits of 2.9‐10%
g7capital.org
Same domain registrar account 
as enkryptfinance.comStocks; options
Impersonating legitimate 
company
ga‐investor.org
Copy of ga‐investors.org 
launched after ga‐investors.org 
was removedInvestment contracts
Impersonating legitimate 
companies
galpcoin‐invests.com
Same domain registrar account 
as ga‐investors.orgStocks; options
Claimed affiliation with 
letigimate company
gloprimeinvest.com
Same domain registrar account 
as ga‐investors.orgStocks3
‐7‐day profits of 2‐10%
goldassetsmgtlimited.com
Same domain registrar account 
as ga‐investors.orgStocksDaily profits of 2‐3%
hemeraint.com
Same domain registrar account 
as ga‐investors.orgStocksDaily profits of 1‐5%
impacttrading.org
Same domain registrar account 
as ga‐investors.orgStocksDaily profits of 18.2‐43.2%
lerwick‐financials.com
Same domain registrar account 
as ga‐investors.orgInvestment contractsDaily profits of 
10‐30%
magnarinvestment.com
Same domain registrar account 
as ga‐investors.orgInvestment contracts2‐7‐day profits of 12‐50%
mettro‐finance.com
Same domain registrar account 
as ga‐investors.orgInvestment contracts2‐7‐day profits of 4.9‐24.9%
oceanviewinvestment.com
Same domain registrar account 
as ga‐investors.orgInvestment contractsDaily profits of 1.9‐3%
prime‐stake.com
Same domain registrar account 
as ga‐investors.orgInvestment
 contracts1‐7‐day profits of 5‐25%
ranfurtinvest.com
Same domain registrar account 
as ga‐investors.orgInvestment contracts2‐10‐day profits of 2‐10%
tab‐finances.com
Same domain registrar account 
as ga‐investors.orgInvestment contractsDaily profits of 3‐5%
timestatictrading.com
Same domain registrar account 
as ga‐investors.orgStocks; bondsDaily profits of 20.8‐49.8%
tstradings.org
Same domain registrar account 
as ga‐investors.orgInvestment contractsDaily profits of 1.5‐5.5%
uptown‐finance.com
Same domain registrar account 
as ga‐investors.orgInvestment contractsDaily profits of 16.9‐61.9%
westrockfinances.com
Same domain registrar account 
as ga‐investors.orgInvestment contracts3‐10‐day profits of 2.1‐5.1%

UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 

 
 
 
SECURITIES AND EXCHANGE COMMISSION, 
 

Plaintiff, 
 

v. 
 
 
GA INVESTORS, and 
JOHN DOES NOS. 1-4, 
 

Defendants. 
 

 
 

    Civil Action No.  
 

 
JURY TRIAL DEMANDED 

 

COMPLAINT 

Plaintiff Securities and Exchange Commission (the “Commission”) alleges: 

SUMMARY 

1. This is an emergency enforcement action to stop GA Investors and John Does 

Nos. 1-4 (collectively, “Defendants”), the unknown owners and operators of dozens of 

fraudulent websites, including GA-Investors.org, from engaging in an ongoing fraudulent 

scheme.  Defendants are soliciting investors by falsely impersonating legitimate companies 

and/or falsely promising exorbitant returns—in some cases as high as 61.9% in 24 hours—

for investments in various securities offerings, including crypto asset mining pools.   

2. In reality, this is a fraud.  Defendants have no connection to the legitimate 

companies they are claiming to be, they have already misappropriated thousands of dollars 

from investors, and they are actively perpetrating fraudulent securities offerings.  Further, 

although GA-Investors.org is no longer accessible to the public, at least 26 of the 

Defendants’ websites are currently active, including the newly published and similarly 

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2 
 

named GA-Investor.org (dropping the “s” in GA-Investors).  GA-Investor.org contains the 

same false information and representations as GA-Investors.org. 

3. By engaging in the conduct alleged, Defendants violated, and unless 

restrained and enjoined, will continue to violate, Section 17(a) of the Securities Act of 1933 

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

of 1934 (the “Exchange Act’) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. 

§ 240.10b-5]. 

4. Because this fraud is ongoing and because of the danger that investor funds 

will continue to be accumulated by the Defendants and will be dissipated, the Commission 

seeks emergency preliminary relief, including: (a) an order prohibiting Defendants from 

continuing to violate Section 17(a) of the Securities Act and Section 10(b) of the Exchange 

Act and Rule 10b-5 thereunder; (b) an order freezing the assets of Defendants held for their 

direct or indirect benefit, and/or subject to their direct or indirect control; (c) an order 

freezing all direct or indirect proceeds of the misconduct described in the Complaint; (d) an 

order prohibiting Defendants from soliciting, accepting or depositing any monies obtained 

from investors pending the resolution of this action; (e) an order requiring Defendants to 

repatriate assets held outside the United States; (f) an order requiring an expedited 

accounting of the Defendants’ assets and liabilities; (g) an order restraining Defendants from 

destroying, concealing, or disposing of property or documents related to the conduct alleged 

in this Complaint; (h) an order providing for alternative service of process; and (i) an order 

requiring that Defendants’ fraudulent websites soliciting investments in securities offerings 

be taken down forthwith. 

5. The Commission also seeks: (a) entry of permanent injunctions against 

Defendants, prohibiting them from further violations of Section 17(a) of the Securities Act 

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3 
 

and Section 10(b) of the Exchange Act and Rule 10b-5 thereunder; (b) disgorgement of all 

ill-gotten gains from the unlawful activity set forth in this Complaint, together with 

prejudgment interest, pursuant to Sections 21(d)(3) and 21(d)(7) of the Exchange Act [15 

U.S.C. §§ 78u(d)(3) and (d)(7)]; (c) the imposition of civil monetary penalties pursuant to 

Sections 20(d) of the Securities Act [15 U.S.C. § 78t(d)] and Section 21(d)(3) of the 

Exchange Act [15 U.S.C. § 78u(d)(3)]; (d) conduct-based injunctions enjoining Defendants 

from directly or indirectly, including, but not limited to, through any entity owned or 

controlled by Defendants, participating in the purchase, offer or sale of any security to 

investors or potential investors, provided, however, that such injunction shall not prevent 

Defendants from purchasing or selling securities listed on a national securities exchange for 

their own personal accounts; and (e) such other relief as the Court may deem appropriate. 

JURISDICTION AND VENUE 

6. The Commission brings this action pursuant to the enforcement authority 

conferred upon it by Section 20(b) of the Securities Act [15 U.S.C. § 77t(b)] and Section 

21(d) of the Exchange Act [15 U.S.C. § 78u(d)].   

7. This Court has jurisdiction over this action pursuant to Section 22(a) of the 

Securities Act [15 U.S.C. § 77v(a)] and Sections 21(d), 21(e), and 27 of the Exchange Act 

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

8. Venue lies in this District pursuant to Section 22(a) of the Securities Act [15 

U.S.C. § 77(a)] and Section 27 of the Exchange Act [15 U.S.C. § 78aa], because certain of 

the acts, practices, transactions, and courses of business alleged in this Complaint occurred 

within the District, including soliciting and receiving investments from at least one 

Massachusetts resident. 

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4 
 

9. In connection with the conduct described in this Complaint, GA Investors and 

John Does Nos. 1-4 have, directly or indirectly, made use of the means or instruments or 

instrumentalities of transportation or communication in interstate commerce, or of the mails, 

or the facilities of a national securities exchange.   

10. Defendants’ conduct took place in connection with the purchase or sale, and 

in the offer or sale, of securities. 

DEFENDANTS 

11. GA Investors (“GAI”) is the entity that offered the securities described on the 

GA-Investors.org website and the GA-Investor.org website.  GAI is not an incorporated 

entity in any jurisdiction and is not registered with the Commission.  As described further 

below, GAI has impersonated and used the information of various legitimate companies, 

including names, addresses, website content, and stock trading information.    

12. John Does Nos. 1-4 (“DOES”) are unknown individuals and/or groups of 

individuals responsible for and/or controlling GAI and GA-Investors.org, as well as dozens 

of other fraudulent websites offering securities.  DOES include the individuals responsible 

for maintaining, organizing, and funding GA-Investors.org, as well as those persons 

responsible for constructing and advertising the securities offered by GAI.  DOES 

communicated online with investors through aliases, including the alias “Brian K. Stafford.” 

FACTS 

A. Defendants Offered Securities Through Dozens of Fraudulent Websites. 
 
13. From at least March 2022 to the present, Defendants have offered investments 

through dozens of fraudulent websites.  Some websites offer investments in traditional 

securities such as stocks and bonds, while other websites capitalize on the rise of crypto 

assets by offering investments in crypto asset mining pools.  Some of the websites also 

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5 
 

impersonate legitimate companies and/or promise exorbitant returns on investments, such as 

61.9% in 24 hours.  Over time, some of the websites have been taken down, while others 

remain publicly accessible on the Internet.  A list of Defendants’ known currently active 

websites is attached as Appendix A to this Complaint. 

14. Through the websites, related social media sites, and via smartphone 

messaging applications, Defendants solicited investors from across the world, including 

investors in the United States, who invested approximately $85,000 in GAI’s fraudulent 

securities offerings on the now-defunct GA-Investors.org website.  

15. GAI impersonated legitimate companies by misappropriating authentic 

information for fraudulent use on the GA-Investors.org website.  Some of the genuine 

information that GAI falsely claimed as its own includes: 

a. That GAI’s “District Office” is located at 6025 Metcalf Lane, Overland 

Park, Kansas 66202.  In fact, a registered broker-dealer with a similar 

name—which has no affiliation with GAI or GA-Investors.org—is located 

at that address.   

b. That GAI’s “Corporate Headquarters” is located in the “GA Investors 

Tower” at 301 E. Fourth St., Cincinnati, Ohio 45202.  In fact, an insurance 

company with a similar name—which has no affiliation with GAI or GA-

Investors.org—is located at that address. 

c. Stock trading data purportedly for GAI on both the London Stock 

Exchange and Johannesburg Stock Exchange.  In fact, the stock trading 

data on GA-Investors.org belongs to a publicly-traded company which has 

no affiliation with GAI or GA-Investors.org.   

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6 
 

16. GAI solicited investments in “Unit Trusts and [exchange-traded funds].” The 

GA-Investors.org website described the Unit Trusts as investments where “[y]our money is 

combined with the money of other investors and our investment managers use the pool of 

money to buy underlying investments, such as equities, bonds, cash and property” and 

“‘units’ . . . are allocated to you according to the amount of money you invest.”   

17. GAI described the “Unit Trusts” as consisting of six “investment types,” 

which offered daily, guaranteed returns ranging from 2% to 4.5%, depending on the size of 

the investment.  With respect to these investments in the Unit Trusts, GAI made numerous 

false statements on the GA-Investors.org website and its affiliated social media accounts, 

including: 

a. “Profit is guaranteed.” 

b. “Your profit starts accumulating daily, and you can withdraw at any time.”   

c. “[Y]ou own the [GAI Trust] units until you decide to sell them.” 

18. Each of the statements and representations in paragraph 17 concerning GAI’s 

investments were false and misleading because Defendants halted investor withdrawals and 

misappropriated invested assets.  

19. To invest, GAI required individuals to create a private account on the GA-

Investors.org website.  These private account pages included, among other things, a digital 

wallet address that was controlled by GAI.  Investors were then directed to purchase crypto 

assets from a separate crypto asset trading platform and transfer those crypto assets to GAI 

by sending them to the GAI wallet address listed on the private account page.  Once the 

transfer was complete, investors were sent a confirmation email and could then view their 

investment on the private account page on the GA-Investors.org website. 

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7 
 

20. GAI displayed to its investors on their private account pages accumulated 

profits on investments, when no such profits existed.  Defendants, at times, permitted at least 

some investors to make small withdrawals from their accounts after investment.  But when 

investors sought to recoup larger portions of their investment, Defendants concocted excuses 

for why the funds could not be withdrawn and then froze those accounts.    

21. The investments that GAI offered for sale on GA-Investors.org are investment 

contracts, a type of security under Section 2(a)(1) of the Securities Act and Section 3(a)(10) 

of the Exchange Act. 

B. Defendants Solicited Investors Online With False and Misleading Statements. 
 
22. In addition to the numerous false and misleading representations contained on 

the GA-Investors.org website, DOES made numerous false statements about GAI and the 

securities offered by GAI in direct communications with investors and potential investors 

using instant messaging platforms on various social media sites and smartphone applications.   

23. In direct communications with investors and potential investors, DOES 

identified themselves as an individual named “Brian K. Stafford,” representing that Stafford 

was a “stakeholder” in GAI who had recently been hired as its Chief Operating Officer, and 

claiming that he operated a nutrition business in Texas.   

24. In reality, Stafford is an alias.  DOES used the Stafford figurehead, fictitious 

biography, and photographs misappropriated from a real person’s social media sites to solicit 

investors around the world, including at least one Massachusetts investor.  From 

approximately October 2022 to January 2023, DOES used the Stafford persona to make 

numerous false and misleading statements to the Massachusetts investor about GAI, 

including the following: 

a. “[Y]ou won’t lose money it works just like your bank.”  (Oct. 27, 2022). 

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8 
 

b. GAI is “a blockchain leading company and an Insurance Company 

meaning that your account and investments are insured, it’s endorsed by 

Elon musk [sic] and Peter Smith and Insured by the FDIC.”  (Oct. 27, 

2022). 

c. To receive a profit, “you have to purchase the [crypto] coins and store 

them in your wallet so what GA does is to help you invest them, by 

purchasing more crypto mining equipments [sic] and machines to speed up 

their mining . . . and you receive returns daily.”  (Nov. 3, 2022). 

d. “[C]rypto mining” with GAI will “earn profits daily;” “with mining you 

earn profits everyday;” and that after depositing money “to your GA 

wallet . . . your account would automatically start generating daily ROIs 

[returns on investment].”  (Oct. 26, 2022; Nov. 1, 2022; Nov. 4, 2022). 

25. Each of the statements to the Massachusetts investor was false or misleading 

because GAI did not act like an FDIC insured bank, and investor assets were not invested in 

crypto mining or other projects.  Rather, the Massachusetts investor’s funds were 

misappropriated by Defendants.   

26. The Massachusetts investor agreed to invest approximately $2,400 in GAI on 

or about November 4, 2022, expecting to receive a purported guaranteed daily 3% return, 

based on GAI’s misrepresentations as communicated by “Stafford” and posted on the GA-

Investors.org website.  From approximately November 11, 2022 to November 23, 2022, the 

Massachusetts investor invested approximately $47,500 more in GAI, believing that all 

invested funds and purported profits could be withdrawn at any time.   

27. From approximately November 30, 2022 to December 7, 2022, the 

Massachusetts investor was able to withdraw approximately $15,000 from their GAI account.  

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9 
 

However, when the Massachusetts investor subsequently attempted to withdraw additional 

money, GAI stated on December 19, 2022, that the account had been “suspended” and, 

subsequently on December 25, 2022, GAI stated that the Massachusetts investor would have 

to invest an additional $40,000 to withdraw any more money. 

28. On January 21, 2023, GAI informed the Massachusetts investor that they were 

“expected to make a $20,000 deposit to unfreeze” the account. 

29. At least three other investors invested a total of approximately $35,000 in 

GAI, with similar claims by DOES, acting as Stafford, of exorbitant daily returns.  These 

other investors were not able to withdraw any funds from GAI or the GA-Investors.org 

website.  

C. Defendant DOES Own and/or Operate Dozens of Similar Fraudulent Websites 
and Smartphone Applications. 
 
30. From at least March 2022 to the present, DOES have operated dozens of 

websites and smartphone applications through which they conducted similar fraudulent 

securities offerings, much as they did on GA-Investors.org, often using the same or similar 

templates and information.  Since April 19, 2023, the GA-Investors.org website is no longer 

accessible, but many of DOES’ other websites and applications continue to offer similar 

investments in securities such as stocks, bonds, and exchange-traded funds, as well as 

investments in crypto asset mining, crypto asset ATMs, and other pooled investments.  

DOES continue to solicit investors through false statements, impersonating legitimate 

companies, and/or offering exorbitant returns on investment.  For example, a website located 

at the URL GA-Investor.org (dropping the “s” in GA-Investors) is currently accessible to the 

public and contains the same information and representations reflected in paragraphs 15-17 

above. 

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10 
 

 

 

D. Defendants Acted With Scienter. 

31. Defendants owned, controlled, and orchestrated the fraudulent GA-

Investors.org website and offerings as well as the dozens of other related websites and 

smartphone applications, and therefore knew, or were reckless or negligent in not knowing, 

that the stated companies or persons were not who they claimed to be, they had no reasonable 

basis to advertise exorbitant returns, and there were no underlying investments in activities 

such as crypto asset mining pools. 

NEED FOR EMERGENCY RELIEF 

32. This is an ongoing fraud.  Defendant DOES’ fraudulent websites identified in 

Appendix A are currently accessible on the Internet, and Defendant DOES continue to use 

these to offer investments to the public.  Potential investors continue to be able to place 

money in those investments.  Further, although GA-Investors.org is no longer accessible to 

the public as of April 19, 2023, a website located at the URL GA-Investor.org is currently 

accessible to the public.  The GA-Investor.org website contains the same information and 

representations as the GA-Investors.org website reflected in paragraphs 15 to 17 above.   

Emergency relief in the form of a temporary restraining order and, subsequently, preliminary 

injunction are necessary to stop Defendants’ fraudulent solicitations and potential harm to the 

investing public. 

33. Defendants will likely dissipate assets belonging to investors by transferring 

them outside the Court’s jurisdiction.  

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11 
 

34. The emergency relief requested is necessary in order to prevent further 

violations of the federal securities laws and further harm to investors, including further 

dissipation of investor assets.  

35. The violations set forth in this Complaint involve fraud, deceit, manipulation, 

or deliberate or reckless disregard of a regulatory requirement, and such violations directly or 

indirectly resulted in substantial losses or created a significant risk of substantial losses to 

other persons. 

FIRST CLAIM FOR RELIEF 

Violations of Exchange Act Section 10(b) and Rule 10b-5 Thereunder  
(All Defendants) 

 
36.  Paragraphs 1 through 35 are re-alleged and incorporated by reference. 

37.  By engaging in the conduct described above, Defendants, singly or in concert 

with others, directly or indirectly, acting intentionally, knowingly or recklessly, by use of the 

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

purchase or sale of securities: (a) have employed, are employing, and are about to employ 

devices, schemes or artifices to defraud; (b) have made, are making, and are about to make 

untrue statements of material fact or have omitted, are omitting, and are about to omit 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; or (c) have engaged, are 

engaging, and are about to engage in acts, practices or courses of business which operate as a 

fraud or deceit upon certain persons. 

38.  By engaging in the foregoing conduct, the Defendants, directly and indirectly, 

violated, and unless enjoined, will again 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]. 

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12 
 

SECOND CLAIM FOR RELIEF 

Violations of Securities Act Section 17(a)  
(All Defendants) 

 
39.    Paragraphs 1 through 35 are re-alleged and incorporated by reference. 

40.  By virtue of the foregoing, Defendants, singly or in concert with others, acting 

intentionally, knowingly or recklessly, or negligently, in the offer or sale of securities, by use 

of the means or instruments of transportation or communication in interstate commerce or by 

use of the mails: (a) have employed, are employing, and are about to employ devices, 

schemes or artifices to defraud; (b) have obtained, are obtaining, and are about to obtain 

money or property by means of untrue statements of material fact or omissions 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; or (c) have engaged, are 

engaging, and are about to engage in transactions, practices or courses of business which 

operate as a fraud or deceit upon the purchasers of the securities. 

41.  By virtue of the foregoing, Defendants, directly or indirectly, violated, and 

unless enjoined, will again violate, Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]. 

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that this Court:  

A. Enter a temporary restraining order which:  

1. Restrains GAI and John Does Nos. 1-4, and each of their officers, 

agents, servants, employees, attorneys, and those persons in active concert or participation 

with them who receive actual notice of the order by personal service or otherwise, including 

facsimile transmission, electronic mail or overnight delivery service, from directly or 

indirectly violating Section 17(a) of the Securities Act [l 5 U.S.C. § 77q(a)] and Section 

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13 
 

10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F .R. 

§ 240.10b-5]. 

2. Requires GAI and John Does Nos. 1-4, and each of their officers, 

agents, servants, employees, attorneys, and those persons in active concert or participation 

with them who receive actual notice of the order by personal service or otherwise, including 

facsimile transmission, electronic mail or overnight delivery service, to hold and retain all 

funds and other assets held for the direct or indirect benefit, or under the direct or indirect 

control, of GAI and John Does Nos. 1-4, to prevent any withdrawal, sale, payment, transfer, 

dissipation, assignment, pledge, alienation, encumbrance, diminution in value or other 

disposal of any such funds and other assets, including incurring charges or cash advances on 

any credit card, and to freeze such funds and other assets pending further order of this Court, 

and further require all banks, brokerage firms, other financial institutions, Internet payment 

agents, and other persons and entities which receive actual notice of the order by personal 

service or otherwise, including by facsimile transmission, electronic mail or overnight 

delivery service, and which hold any funds or other assets for the direct or indirect benefit, or 

under the direct or indirect control, of GAI and John Does Nos. 1-4, to hold and retain within 

their control and prohibit the withdrawal, sale, payment, transfer, dissipation, assignment, 

pledge, alienation, encumbrance, diminution in value or other disposal of any such funds and 

other assets;  

3. Requires that all persons who hold or possess funds or other assets in 

the name, for the direct or indirect benefit, or under the direct or indirect control of the 

Defendants (including assets in the name of GA Investors or John Does Nos. 1-4), hold and 

retain such funds and other assets, prevent any withdrawal, sale, payment, transfer, 

dissipation, assignment, pledge, alienation, encumbrance, diminution in value or other 

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14 
 

disposal of any or all such funds or other assets, and freeze such funds and other assets 

pending further order of this Court;  

4. Restrains GAI and John Does Nos. 1-4 and each of their officers, 

agents, servants, employees and attorneys, and those persons in active concert or 

participation with them who receive actual notice of the order by personal service or 

otherwise, including facsimile transmission, electronic mail or overnight delivery service, 

from soliciting, accepting, or depositing into any account in which any of them has a direct or 

indirect beneficial interest or over which they exercise direct or indirect control, any funds or 

other assets obtained in connection with solicitations from actual or prospective investors 

pending the resolution of this action; 

5. Requires that GAI and John Does Nos. 1-4, and each of their officers, 

agents, servants, employees and attorneys, and those persons in active concert or 

participation with them who receive actual notice of this Order by personal service or 

otherwise, including facsimile transmissions, electronic mail or overnight delivery service, 

and each of them, shall, within five (5) days of receiving actual notice of this Order, take 

such steps as are necessary to repatriate and deposit into the registry of the Court in an 

interest bearing account, any and all funds or assets that presently may be located outside of 

the United States that were obtained directly or indirectly from investors; 

6. Requires GAI and John Does Nos. 1-4 to submit in writing and serve 

upon counsel for the Commission, within five (5) business days following service of the 

order, a written accounting identifying:  

a.  all transfers or payments of funds to them or any other entity 

controlled by them from investors in connection with the misconduct 

described in the Complaint (the identification shall include the amount of each 

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15 
 

such transfer or payment, the date of the transfer or payment, and the name, 

address, account number and financial institution or Internet payment agent of 

the party making and the party receiving the transfer or payment); 

b.  in detail, the precise disposition of each transfer or payment identified 

in response to paragraph 6.a above and all assets derived therefrom, including 

but not limited to: 

• the nature and results of any investment in which the funds were 

used; 

• any subsequent transfer or payment of the funds (the 

identification shall include the amount of each such transfer or 

payment, the date of the transfer or payment, the name, address, 

account number and financial institution of the party making and 

receiving the transfer or payment, and the reason for the transfer 

or payment); and 

• any fees or expenses charged and a detailed statement of the 

nature and purpose of such fees and expenses. 

c.   by name and address, all persons, entities and accounts currently 

holding funds or assets derived from the transfers or payments described in 

paragraph 6.a above and the reason each received the funds or assets (the 

identification shall include the amount each received, the date received, the 

reason received, the institution and account number or location in which the 

funds or other assets are held and the name, address, account number and 

financial institution or Internet payment agent of the person or entity who 

provided each with the funds or other assets); 

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16 
 

d.  assets of every type and description that currently, or at the time of 

acquisition, has or had a value of at least one thousand dollars ($1,000) 

presently owned by or held for the direct or indirect benefit, or subject to the 

direct or indirect control, of Defendants, whether in the United States or 

elsewhere; and 

e.  all accounts held at any bank, brokerage or other financial institution 

or Internet payment agent in the United States or elsewhere in the name, for 

the direct or indirect benefit, or under the direct or indirect control, of 

Defendants, or in which Defendants have or had any direct or indirect 

beneficial interest, at any time from January 1, 2022, to the present. 

7. Restrains GAI and John Does Nos. 1-4 and each of their officers, 

agents, servants, employees and attorneys and those persons in active concert or participation 

with them who receive actual notice of the order by personal service or otherwise, including 

by facsimile transmission, electronic mail or overnight delivery service, from destroying, 

mutilating, concealing, altering, or disposing of any items, including but not limited to any 

books, records, documents, correspondence, contracts, agreements, assignments, obligations, 

tape recordings, computer media or other property relating to GAI and John Does Nos. 1-4 or 

any of their securities, financial, or other business dealings; 

8. Provides that, pursuant to Rule 5 of the Federal Rules of Civil 

Procedure, service of all pleadings and other papers to be served in this action, including the 

Summons and Complaint, may be made by email, overnight delivery service, personally by 

any employee of the Commission who is not counsel of records in this matter, or any other 

person, or in any other manner authorized by Rule 5 of the Federal Rules of Civil Procedure, 

or by publication; 

Case 1:23-cv-11050   Document 1   Filed 05/11/23   Page 16 of 19



17 
 

9. Requires GAI and John Does Nos. 1-4 to serve the statements and 

accountings required by the order and all other filings in this action on counsel for the 

Commission by email, messenger, overnight delivery service, or by facsimile to David H. 

London, U.S. Securities and Exchange Commission, 33 Arch Street, 24th Floor, Boston, 

Massachusetts 02110, [email protected], facsimile number (617) 573-4590; and 

10. Requires that all websites associated with the Defendants that are 

making material misrepresentations relating to a securities offering, as identified in Appendix 

A, be taken down forthwith.   

B. Enter a preliminary injunction extending the terms of the temporary 

restraining order described above;  

C. Enter a permanent injunction which:  

1. Restrains GAI and John Does Nos. 1-4 and each of their officers, 

agents, servants, employees, attorneys, and those persons in active concert or participation 

with them who receive actual notice of the order or injunction by personal service or 

otherwise, from directly or indirectly engaging in the conduct described above, or in conduct 

of similar purport and effect, in violation of:  

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

b. 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];  

2. Requires GAI and John Does Nos. 1-4 to disgorge their ill-gotten 

gains, including prejudgment interest, pursuant to Sections 21(d)(3) and 21(d)(7) of the 

Exchange Act [15 U.S.C. §§ 78u(d)(3) and (d)(7)];  

Case 1:23-cv-11050   Document 1   Filed 05/11/23   Page 17 of 19



18 
 

3. Order GAI and John Does Nos. 1-4 to pay appropriate civil monetary 

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)];  

D. Enjoins GAI and John Does Nos. 1-4 from directly or indirectly, including, 

but not limited to, through any entity owned or controlled by GAI and/or John Does Nos. 1-

4, participating in the purchase, offer or sale of any security to investors or potential 

investors, provided, however, that such injunction shall not prevent GAI and John Does Nos. 

1-4 from purchasing or selling securities listed on a national securities exchange for their 

own personal accounts 

E. Retain jurisdiction over this action to implement and carry out the terms of all 

orders and decrees that may be entered; and  

F. Award such other and further relief as the Court deems just and proper.  

JURY DEMAND 

 The Commission demands a jury in this matter for all claims so triable. 

 
Dated:  May 11, 2023 

Respectfully submitted, 
 
SECURITIES AND EXCHANGE COMMISSION 
 
By its attorneys, 

 

 
________________________________ 
David H. London (BBO# 638289) 
Kerry Dakin (BBO# 640826) 
Russell A. Mawn, Jr. (BBO# 712095) 
Boston Regional Office 
33 Arch Street, 24th Floor 
Boston, MA 02110 
(617) 573-8997 (London) 
[email protected] 

Case 1:23-cv-11050   Document 1   Filed 05/11/23   Page 18 of 19



SEC v. GA Investors and John Does Nos. 1‐4

Appendix A

Website Connection to GAI Security Offered Nature of Fraud

abotsmartcontract.com

Same domain registrar account 

as ga‐investors.org Stocks; bonds Daily profits of 5‐20%

affinittycapitals.com

Same domain registrar account 

as ga‐investors.org Stocks; ETFs Daily profits of 5‐12%

bluechip‐brokers.com

Same domain registrar account 

as ga‐investors.org Stocks; ETFs 1‐7‐day profits of 4‐90%

brix‐finances.com

Same domain registrar account 

as ga‐investors.org Stocks Daily profits of 0.5‐5%

commerscapital.com

Same domain registrar account 

as ga‐investors.org Stocks; unit trusts

Impersonating legitimate 

company

elsavierfinance.com

Same domain registrar account 

as ga‐investors.org Stocks; ETFs Daily profits of 5‐14%

enkryptfinance.com

Sent to Investor A by Brian 

Stafford

Investment contracts; 

stocks; ETFs; options Monthly profits of 13.5‐25%

fortuneminters.com

Same domain registrar account 

as ga‐investors.org Stocks Daily profits of 2.9‐10%

g7capital.org

Same domain registrar account 

as enkryptfinance.com Stocks; options

Impersonating legitimate 

company

ga‐investor.org

Copy of ga‐investors.org 

launched after ga‐investors.org 

was removed Investment contracts

Impersonating legitimate 

companies

galpcoin‐invests.com

Same domain registrar account 

as ga‐investors.org Stocks; options

Claimed affiliation with 

letigimate company

gloprimeinvest.com

Same domain registrar account 

as ga‐investors.org Stocks 3‐7‐day profits of 2‐10%

goldassetsmgtlimited.com

Same domain registrar account 

as ga‐investors.org Stocks Daily profits of 2‐3%

hemeraint.com

Same domain registrar account 

as ga‐investors.org Stocks Daily profits of 1‐5%

impacttrading.org

Same domain registrar account 

as ga‐investors.org Stocks Daily profits of 18.2‐43.2%

lerwick‐financials.com

Same domain registrar account 

as ga‐investors.org Investment contracts Daily profits of 10‐30%

magnarinvestment.com

Same domain registrar account 

as ga‐investors.org Investment contracts 2‐7‐day profits of 12‐50%

mettro‐finance.com

Same domain registrar account 

as ga‐investors.org Investment contracts 2‐7‐day profits of 4.9‐24.9%

oceanviewinvestment.com

Same domain registrar account 

as ga‐investors.org Investment contracts Daily profits of 1.9‐3%

prime‐stake.com

Same domain registrar account 

as ga‐investors.org Investment contracts 1‐7‐day profits of 5‐25%

ranfurtinvest.com

Same domain registrar account 

as ga‐investors.org Investment contracts 2‐10‐day profits of 2‐10%

tab‐finances.com

Same domain registrar account 

as ga‐investors.org Investment contracts Daily profits of 3‐5%

timestatictrading.com

Same domain registrar account 

as ga‐investors.org Stocks; bonds Daily profits of 20.8‐49.8%

tstradings.org

Same domain registrar account 

as ga‐investors.org Investment contracts Daily profits of 1.5‐5.5%

uptown‐finance.com

Same domain registrar account 

as ga‐investors.org Investment contracts Daily profits of 16.9‐61.9%

westrockfinances.com

Same domain registrar account 

as ga‐investors.org Investment contracts 3‐10‐day profits of 2.1‐5.1%

Case 1:23-cv-11050   Document 1   Filed 05/11/23   Page 19 of 19