SEC v. Trends Investments Inc.; Brandon Rossetti; Clinton Greyling; Leslie Greyling; Roger Bendelac; and Thomas Capellini, No. 1:22-cv-10889, District of Massachusetts (June 9, 2022) — Complaint

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

SECURITIES AND EXCHANGE
COMMISSION,
    Plaintiff,
            v.

TRENDS INVESTMENTS INC.,
BRANDON ROSSETTI, CLINTON
GREYLING, LESLIE GREYLING,
ROGER BENDELAC, and THOMAS
CAPELLINI
                                                Defendants.

Civil Action No. 22-CV-____
(___)

JURY TRIAL DEMANDED

COMPLAINT
 Plaintiff, Securities and Exchange Commission (the “Commission”), alleges the
following against the defendants Trends Investments Inc. (“Trends”), Brandon Rossetti
(“Rossetti”), Clinton Greyling, Leslie Greyling, Roger Bendelac (“Bendelac”), and Thomas
Capellini (“Capellini”):
SUMMARY
1. This is a securities fraud enforcement action.  Defendants Trends, a company
which was in the business of selling stock to investors, and Trends’ personnel Brandon Rossetti,
Clinton Greyling, and Leslie Greyling, engaged in a scheme to defraud investors in private
offerings of shares in publicly traded companies.  The scheme started in early 2017 when Trends
offered and sold shares of stock in Alterola Biotech Inc. (“Alterola”) to investors.  Alterola was a
publicly traded company with no reported revenue that was purportedly developing medicinal
chewing gum.  Rossetti and the Greylings misled investors to believe that Trends owned the

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shares of Alterola they were offering to sell to investors.  In reality, Trends owned zero shares of
Alterola.
2. Trends planned to obtain enough money from investors to purchase all of
Alterola’s common stock from a seller of public shell companies—companies that lack
meaningful assets or business operations.  However, although Trends obtained money from
investors, it did not acquire the Alterola shell at the time, and the scheme evolved over several
years as the Greylings and Rossetti scrambled to keep investor funds, obtain a different shell
company, solicit further investments, placate investor concerns, and avoid detection.  Among
other things, the scheme involved manipulative trading in the securities of one of the companies
the Greylings and Rossetti were trying to sell to investors.
3. Rossetti preyed on investors, some of whom are senior citizens, representing
himself as their “broker” or “wealth manager,” while he and the Greylings misled them with a
series of misrepresentations in connection with their investments in Alterola and a second
publicly traded company named Token Communities Ltd. (“Token”).  Rossetti was not
registered with the Commission as a broker or dealer, nor was he associated with a broker or
dealer registered with the Commission.
4. Bendelac was a director of Trends from August 2017 to October 2019 and
participated in the scheme.  Bendelac was a partner of the Greylings in the plan to acquire a shell
company using money that was obtained by Trends from investors.  Bendelac, through an entity
he controlled, acquired a block of shares in Token which was paid for by Trends using money
that Trends received from investors.  During the time period that Trends was offering and selling
shares of Token to investors in private offerings, Bendelac worked with Clinton Greyling to
coordinate trading in Token stock on the public securities markets.  Bendelac used multiple

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brokerage accounts, including Capellini’s (Bendelac’s brother-in-law), to place trades in Token’s
stock in order to create the false appearance of active trading in Token’s stock and to inflate the
stock price.  Bendelac placed these manipulative trades in order to induce the purchase of Token
stock (1) by private investors to whom Trends was offering stock; and (2) by other investors in
the public marketplace.  In total, Bendelac received approximately $97,000 from the sale of
Token stock in the public marketplace.
5. Capellini provided substantial assistance to the scheme and to Bendelac by giving
Bendelac access to his brokerage account and funding the brokerage account, enabling Bendelac
to purchase Token stock through Capellini’s account while Bendelac was selling Token stock
through the brokerage account of an entity controlled by Bendelac.
6. As a result of the scheme, from 2017 to at least 2020 (the “Relevant Period”), the
defendants defrauded more than 30 investors out of approximately $2.3 million.
7. By engaging in the conduct alleged herein, Trends, Rossetti, Clinton Greyling,
and Leslie Greyling violated Section 17(a) of the Securities Act of 1933 (“Securities Act”)
[15 U.S.C. § 77q(a)] and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”)
[15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 340.10b-5].
8. By engaging in the conduct alleged herein, Rossetti also violated Section 15(a)(1)
of the Exchange Act [15 U.S.C. § 78o(a)(1)].
9. By engaging in the conduct alleged herein, Bendelac violated Sections 17(a)(1)
and (3) of the Securities Act [15 U.S.C. § 77q(a)(1) and (3)], Section 9(a)(2) of the Exchange
Act [15 U.S.C. § 78i(a)(2)], and Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and
Rules 10b-5(a) and (c) thereunder [17 C.F.R. § 340.10b-5(a) and (c)], and aided and abetted
Trends’, Clinton Greyling’s, Leslie Greyling’s, and Rossetti’s violations of Sections 17(a)(1) and

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(3) of the Securities Act and Section 10(b) of the Exchange Act and Rules 10b-5(a) and (c)
thereunder.
10. By engaging in the conduct alleged herein, Capellini aided and abetted Bendelac’s
violations of Sections 17(a)(1) and (3) of the Securities Act and Sections 9(a)(2) and 10(b) of the
Exchange Act and Rules 10b-5(a) and (c) thereunder.
11. The Commission seeks permanent injunctions against the defendants,
disgorgement of the defendants’ ill-gotten gains from the unlawful conduct set forth in this
Complaint, together with prejudgment interest pursuant to Section 21(d)(7) of the Exchange Act
[15 U.S.C. §78u(d)(7)], 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)], an order barring the
defendants from participating in any offering of a penny stock, pursuant to Section 20(g) of the
Securities Act [15 U.S.C. § 77t(g)] and/or 21(d) of the Exchange Act [15 U.S.C. § 78u(d)], and
such other relief as the Court may deem appropriate.
JURISDICTION AND VENUE
12. 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].
13. Venue lies in this Court pursuant to Section 22(a) of the Securities Act [15 U.S.C.
§ 77v(a)] and Section 27 of the Exchange Act [15 U.S.C. § 78aa].  Certain of the acts, practices,
transactions and courses of business alleged in this Complaint occurred within the District of
Massachusetts, and were effected, directly or indirectly, by making use of means or
instrumentalities of transportation or communication in interstate commerce, or the mails.  For
example, during the Relevant Period, Trends solicited and received investments from two

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Massachusetts investors, and Rossetti resided in Massachusetts at various points when he offered
and sold stock on behalf of Trends.
DEFENDANTS
14. Trends Investments Inc. (“Trends”) is a Delaware corporation with a principal
place of business in Florida.  During the Relevant Period, Trends purported to be in the business
of selling securities to investors.  Trends was not registered with the Commission as a broker-
dealer or in any other capacity.
15. Clinton Greyling, age 47, is a resident of Florida and the President of Trends.
16. Leslie Greyling, age 70, is a South African citizen, a resident of the United
Kingdom and the father of Clinton Greyling.  Leslie Greyling was deported from the United
States after he pled guilty to securities fraud in 1997. U.S. v. Greyling, et al., No. 6:96-CR-00035
(M.D. Fla. 1996).  Although only Clinton Greyling had any formal title with Trends, Leslie
Greyling exercised authority over Trends through Clinton Greyling and Rossetti, primarily
behind the scenes from the United Kingdom.
17. Brandon Rossetti, age 41, was a resident of Florida, Maine, and Massachusetts at
various points during the Relevant Period.
18. Roger Bendelac, age 65, is a resident of New York.  Between approximately 1980
and 2006, Bendelac was employed in the securities industry by a series of broker-dealers,
including for a period as the Chief Executive Officer of a registered broker-dealer.  Bendelac was
a director of Trends from August 2017 to October 2019.
19. Thomas Capellini, age 59, is a resident of New York.  Between approximately
1994 and 2013, Capellini was employed in the securities industry, including for four years as a
Compliance Manager at a registered investment adviser.  On September 30, 2020, Capellini

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appeared before officers of the Commission to provide sworn testimony and asserted his Fifth
Amendment privilege against self-incrimination in response to all questions regarding Bendelac
and Bendelac’s use of Capellini’s brokerage accounts to conduct coordinated trading in securities
including Token.
RELATED ENTITIES
20. Alterola Biotech Inc. (“Alterola”) is a Nevada corporation with a purported
principal place of business in the United Kingdom.  It was incorporated in July 2008 under the
name Jedediah Resources Corp.  In July 2010, the company changed its name to Alterola
Biotech Inc.  The company’s description of its business in periodic reports voluntarily filed with
the Commission has evolved from mineral exploration, to medicinal chewing gum, to a drug for
ethanol based intoxication, back to medicinal chewing gum, to the cannabis industry generally,
and finally to therapeutic cannabinoids.  The company’s shares are quoted on OTC Link
operated by OTC Markets Group, Inc.  Prior to December 2019, the company traded under the
symbol ALTA.  In December 2019, the company changed its trading symbol from ALTA to
ABTI.  During the Relevant Period, the stock of Alterola was a “penny stock” as set forth in
Section 3(a)(51) of the Exchange Act and Rule 3a51-1 thereunder.
21. Token Communities Ltd., (“Token”) is a Delaware corporation with a purported
principal place of business in Florida.  It was incorporated in March 2014 under the name Pacific
Media Group Enterprises, Inc., and purported to be in the mobile applications business.  In April
2017, it changed its name to Extract Pharmaceuticals Inc. and purported to enter the medicinal
chewing gum business.  In January 2018, it changed its name to Token Communities Ltd. in
advance of a reverse merger with a private company, Token Communities PLC, which was
completed in May 2018.  Thereafter, the company purported to enter the blockchain technology

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sector.  Beginning in September 2016, Token had a class of securities registered with the
Commission under Exchange Act Section 12(g), and its shares were quoted on OTC Link
operated by OTC Markets Group, Inc.  On October 14, 2020, pursuant to Section 12(j) of the
Exchange Act, the Commission revoked Token’s securities registration, effective October 15,
2020, after Token failed to file any periodic reports with the Commission since the period ended
June 30, 2018.
BACKGROUND
22.  “Restricted stock” is stock of a publicly traded company (also known as an
“issuer”) that is acquired from an issuer, or an affiliate of the issuer, in a private transaction that
is not registered with the Commission.  Stock held by an issuer or affiliate of an issuer is
restricted stock.  Absent an exemption under the federal securities laws and rules, restricted stock
cannot legally be offered or sold to the public unless a securities registration statement has been
filed with the Commission (for an offer) or is in effect (for a sale).  A registration statement
contains important information about an issuer’s business operations, financial condition, results
of operation, risk factors, and management.  It also should disclose any person or group who is
the beneficial owner of more than 5% of the company’s securities.
23. An “affiliate” of an issuer is a person or entity that, directly or indirectly through
one or more intermediaries, controls, is controlled by, or is under common control with, such
issuer (i.e. a control person).  “Control” means the power to direct management and policies of
the company in question.  Typically, affiliates include officers, directors and controlling
shareholders, but any person who is “under common control” with an issuer may also be an
affiliate.  Absent registration, affiliates are only permitted to sell a small percentage of their stock
according to SEC Rule 144 [17 C.F.R. 230.144].

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24. “Unrestricted stock” is stock that may legally be offered and sold in the public
marketplace by a non-affiliate, without registration or restriction, ordinarily having previously
been subject to a registration statement filed with the Commission.  The term “float” refers to an
issuer’s purportedly unrestricted stock that is available for trading.  The purportedly unrestricted
shares are also sometimes referred to as “free-trading” shares.
25. A “transfer agent” is a company which, among other things, issues and cancels
certificates of a company’s stock to reflect changes in ownership.  Many companies that have
publicly traded securities use transfer agents to keep track of the individuals and entities that own
their stocks.  Share certificates for restricted stock typically bear a “restrictive” legend stating
that it may not be resold in the public marketplace unless the sale is exempt from the
Commission’s registration requirements.  Transfer agents commonly remove restrictive legends
from stock after receiving a legal opinion letter from an attorney attesting, among other things,
that the owner of the stock is not an “affiliate” of the public company.
26. DTC eligibility means that a public company’s securities may be deposited
through the Depository Trust Company (DTC), a depository which holds securities and allows
for securities to be traded electronically.  Most large U.S. broker-dealers and banks are DTC
participants, meaning that they deposit and hold securities at DTC.  DTC eligibility is a
prerequisite to book-entry transfer of securities, which facilitates the exchange of shares by
broker-dealers in the secondary market.  DTC eligibility enables the deposit of securities in a
brokerage account so that they may be sold in the secondary market in bulk.
27. The Over-The-Counter Securities Market (“OTC Markets”) is an inter-dealer
quotation and reporting service based in New York through which certain stocks are available for
trading and are publicly purchased and sold through brokered orders.

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28. A “shell company” is a legal entity that lacks meaningful assets or business
operations.  In a scheme to profit from such companies without actually commencing business
operations, individuals sometimes file materially false registration statements and other filings to
make company shares appear to be eligible for public trading and quotation.  As a matter of law,
acquisition of “free trading” shares by an affiliate means that those free trading shares become
restricted shares.  However, when such transactions are designed to allow the buyer to disguise
its affiliate status, the buyer may have the opportunity to control both the company and its
purportedly “free trading” shares, effectively enabling company insiders to profit by illegally
dumping shares they control.  Accordingly, such “clean” shells, as they are called, are often
bought or sold for substantial sums by individuals who seek to skirt the registration requirements
of the securities laws.
TRENDS’ ALTEROLA INVESTMENT SCHEME
29. In or around February 2017, the shell company Alterola was for sale for
approximately $300,000.  The seller of Alterola offered potential buyers the opportunity to
control all or substantially all of the shares of Alterola, including the purportedly “free trading”
shares of Alterola that were purportedly held by independent investors.
30. Leslie Greyling identified Alterola as a company for Trends to acquire, but
Trends lacked the funds to purchase the Alterola shell on its own.  To get the money to buy the
Alterola shell, the Greylings asked Rossetti to solicit investors to buy shares of Alterola from
Trends, knowing that Trends did not own any such shares.
31. Clinton Greyling created a document to memorialize the scheme and shared that
document with Rossetti.  Trends needed to raise $500,000 to purchase Alterola at a cost of
$300,000, with Rossetti to receive 40% of the funds raised, $200,000.  Instead of raising money

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to buy the Alterola shell transparently, the Greylings and Rossetti schemed to sell shares of
Alterola to investors in private transactions by falsely claiming in stock purchase agreements that
Trends already owned Alterola shares and could deliver them “simultaneously” with the
investors’ payments.
32. Much of the information sent to investors by Rossetti was created or compiled by
Leslie Greyling, and both Clinton Greyling and Rossetti regularly provided updates to Leslie
Greyling about their dealings with investors and potential investors.
33. The success of the scheme depended, in part, on maintaining the trust of Trends’
existing investors and persuading them that Trends was managing their money profitably.
Accordingly, the Greylings and Rossetti acted to create the false appearance that investors’ prior
securities purchases from Trends were good investments so that investors would be more likely
to buy more securities from Trends, or at least not complain to or about Trends.
34. The securities trading conducted by Roger Bendelac played an important role in
this aspect of the scheme.  Bendelac was an experienced professional in the securities industry
and used his skills in furtherance of the scheme.  Bendelac utilized a brokerage account at
Broker-Dealer A, where he had a personal connection to an employee, to deposit and trade
various securities in coordination with Clinton Greyling.  Bendelac’s connection at Broker-
Dealer A was responsible for supervising Bendelac’s account, which was in the name of
Aleutian Equity Holdings LLC (“Aleutian”), an entity Bendelac controlled.  As Bendelac
described to Clinton Greyling in an email, he had “zero scrutiny” on the deposit of share
certificates.  Bendelac also had access to brokerage accounts held by (1) a relative and (2) his
brother-in-law, Thomas Capellini, which Bendelac used to place trades.

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35. Some of the investors whom the defendants viewed as prospective purchasers of
Alterola stock had made previous purchases from Trends of stock in an issuer named Millennium
Energy Corp. (“Millennium”).  Millennium stock was not actively trading—there were zero
reported market trades in Millennium between December 14, 2016 and February 1, 2017.  On
February 3, 2017, the only reported trades for Millennium were orders less than two minutes
apart for 100 shares of Millennium at $4.50 per share ($0.50 per share higher than the reported
closing price on February 2, 2017, a day with zero trading).  This trade was orchestrated by
Bendelac, who placed matching buy and sell orders by logging into Capellini’s account and into
Bendelac’s relative’s account from an Internet Protocol address (an identifying number
associated with a particular account with an internet service provider) registered to Bendelac:
 
 Capellini Sell Order Relative’s Buy Order Execution
Time Qty Price Time Qty Price Time Qty Price
02:17:19         (100)      $4.50      02:19:15         100      $4.50      02:20:58         100      $4.50
 
36. The matching buy and sell orders placed by Bendelac manipulated Millennium’s
reported stock price and created the false appearance of a bona fide market trade.  Following this
trade, there were no trades in Millennium until April 3, 2017.  As a result, the reported market
price of Millennium remained at $4.50 per share during that time period.
   
37. Trends used the manipulated Millennium price in pitching the Alterola investment
to investors.  For example, on February 21, 2017, Rossetti forwarded to an investor to whom he
was pitching an Alterola investment a “portfolio report” sent by Leslie Greyling, which
summarized that investor’s existing investments through Trends.  Those prior investments
included 475,000 shares of Millennium, purchased for $0.63 per share and 100,000 shares of
Millennium purchased for $0.50 per share.  The February 2017 “portfolio report” valued all of
that investor’s Millennium shares at $4.50 per share, with a total value of $2,475,000.  Rossetti’s

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email also contained a draft stock purchase agreement for the sale to that investor of 200,000
“FREE TRADING” shares of Alterola, purportedly owned by Trends, for $200,000, with the
shares to be transferred “[s]imultaneously with the transfer of the [p]ayment.” Although this
investor did not buy the Alterola shares as Rossetti proposed, Rossetti asked the Greylings to
create a similar “statement” for another previous investor to whom he proposed selling 1.2
million shares of Alterola.  Rossetti implored the Greylings to “make this look sexy he will go,
he is giving me a final decision after he reads the proposal / statement.”
 
38. In March and April 2017, Trends obtained approximately $500,000 from seven
investors who were promised that they were purchasing shares of Alterola directly from Trends.
39. Rossetti sent investors content about Alterola created by the Greylings, and added
various misrepresentations of his own.  For example, on March 6, 2017, Rossetti wrote to one
investor that “[m]y company Trends Investments is merging a cannabis company into ALTA
[Alterola].  The stock is starting to trade today . . . The Stock is Trading at 3 dollars right now.”
In reality, Trends did not own or control Alterola and lacked the ability to merge a private
company into it, and Alterola’s stock was not actively trading.  Alterola stock did not trade at all
on March 6, had last traded just 100 shares on March 3, had not traded at all since February 24
before that, and had a recent history of similarly negligible and infrequent trading volume (or
number of shares traded per day).  Rossetti knew at the time that Alterola stock was not trading
in any meaningful way:  Three days later, on March 9, in an email to Leslie Greyling, he asked,
“When will alta [Alterola] start trading?”
40. In stock purchase agreements sent to investors, Trends falsely represented that it
owned at least the number of shares of Alterola stock that each investor was purchasing, that the
investors would receive “free trading” shares, and that Trends could deliver those shares

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“simultaneously” with the investors’ payments.  The stock purchase agreements for several
investors also falsely represented that Alterola’s common stock was registered with the
Commission under Section 12(g) of the Exchange Act and that, since the date of such
registration, Alterola had timely filed all required reports with the Commission.  Such
registration with the Commission means that a company has undertaken the obligation to make
required periodic filings with the Commission which contain important information about its
business and audited financial statements.  In reality, Alterola’s stock was never registered under
Section 12(g); it was therefore not required to file any periodic reports with the Commission, and
Alterola had not made a voluntary filing of any quarterly or annual report with the Commission
since May 2016 and December 2015, respectively.
THE SCHEME EXPANDED FROM ALTEROLA TO TOKEN
41. By the end of March 2017, the opportunity to purchase the Alterola shell had
fallen through and the Greylings were searching for a different shell company to buy.
Meanwhile, Trends continued to accept new investor funds and retain previously invested funds
from Alterola investors and continued to mislead those investors to believe that they would
receive Alterola share certificates.
42. In early April 2017, the Greylings reached an agreement to acquire a different
shell company, Pacific Media Group Enterprises, Inc. (“Pacific Media”), which purported to be
in the business of developing mobile applications.  The Greylings orchestrated the change of
control of Pacific Media by arranging for the transfer of large blocks of stock of Pacific Media
from various entities controlled by the seller to various entities controlled by Leslie Greyling,
either directly or indirectly through associates, including Trends and Aleutian (Bendelac’s
entity).  Bendelac did not pay for Aleutian’s shares; instead, Trends wired money to the seller’s

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attorney to pay for Aleutian’s shares using funds that Trends had received from investors.  The
company changed its name to Extract Pharmaceuticals Inc. (“Extract”).  Leslie Greyling installed
an associate (whom he controlled) as the CEO of Extract, and Extract purported to change its
business, claiming it was developing new technology for delivering pharmaceuticals, including
cannabis oil, via chewing gum.
43. Trends marketed Extract to investors as a cannabis chewing gum business from
April 2017 until approximately January 2018.  During that period, Trends received
approximately $500,000 from investors who purchased shares of the purported chewing gum
business (whether in the name of Alterola or Extract).  In January 2018, Extract changed its
name to Token Communities Ltd. and purported to enter the blockchain technology sector.
44. In or around March 2018, the Greylings finally acquired a large portion of the
Alterola shell, including a block of purportedly unrestricted or “free-trading” shares.  Although
these share certificates may have appeared to be unrestricted in that they did not bear a restrictive
legend, the share certificates were restricted from public sale because the Greylings were
affiliates of Alterola.  Despite having promised Alterola investors “free-trading” shares a year
earlier, the Greylings did not distribute these shares to investors.
45. Thereafter, Trends aggressively marketed both Token and Alterola to new and
existing investors.  From January 2018 through July 2019, investors paid Trends an additional
$1.3 million in return for Trends’ promises of shares of Token and/or Alterola.
46. Rossetti and Clinton Greyling repeatedly misled investors about when they would
receive their Token and Alterola share certificates, telling them without basis that they would
receive their shares soon or falsely stating that the certificates were currently being processed by
the transfer agent or were already in the mail.  For example, from June to August in 2019,

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Rossetti sent a series of text messages to one investor promising that the investor’s share
certificates would be issued, sent, or delivered: “Friday around noon” (June 26); “1st

thing in the
morning” (July 2); “this week” (July 8); “in the morning” (July 16); “tomorrow around one
o’clock” (“July 17); “this week” (July 22); and “this week for sure” (August 1).  During this
time, Rossetti continued to solicit additional investments from the investor, whose share
certificates in Token and Alterola were not issued until mid-September 2019 and January 2020,
respectively.
47. After some investors had received physical share certificates of Token, Rossetti
and Clinton Greyling repeatedly misled investors about when Token would be current in its
filings with the Commission. This was a critical point for investors, since it would help investors
to deposit their shares with a broker-dealer and thereafter sell their shares in public securities
markets, since broker-dealers often will not accept the deposit of shares of an issuer that is not
current in its filings with the Commission.  In stringing the investors along, Rossetti and Clinton
Greyling repeatedly directed investors to various broker-dealers, knowing it was unlikely that the
broker-dealers would accept deposit of the Token shares under the circumstances.
48. The scheme involved varied acts of deception and misrepresentations to investors,
all designed to keep money coming in, quiet investor concerns, and avoid detection.
49. For example, Rossetti described himself to investors in emails and text messages
as their “broker” or “wealth manager” and referred to the investors as his “clients.”  Rossetti also
described his relationship to investors in ways that suggested he was acting in their best interests.
For example, Rossetti texted one investor that it was Rossetti’s “moral obligation to bring you
these deals . . . .”  Rossetti emailed to another investor, “I work for you now.  At Trends
Investments, we understand the trust and responsibility our clients place in our hands.”  To

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another investor, Rossetti wrote, “I will be managing your account . . . . I will be in the office
premarket with my traders . . . . We can always protect your downside with stop loss orders . . . .
I look forward to making money with you.”
   These statements were misleading in that Rossetti
did not disclose that he was receiving a 40% cut of their investments or that he was not registered
as a broker-dealer, or associated with a registered broker-dealer.
50. An email introduction for Trends’ offer of Token shares, drafted by the Greylings
and sent by Rossetti to potential investors, contained the misleading statement that Token had
“over 50 institutional shareholders such as AT&T Mobility, Bank of America, G[E] Capital,
Comcast to name a few.”  This was misleading in that it suggested that these well-known
companies had made a decision to become investors in Token.  In reality, these entities had
shares of Token because they had been creditors of its predecessor entity when that company
went through bankruptcy proceedings.  The Greylings and Rossetti were informed of this in a
summary document created by the attorney representing the seller of the shell company, Pacific
Media.  As the summary document explained, these well-known companies did not even take
possession of their shares as they “failed to respond to transfer agent requests for tax numbers
and their stock certificates are being held until they comply.”
51. At various points during the scheme, Rossetti and the Greylings offered investors
“free” shares of Alterola as an inducement to invest in Token, or shares of either company as a
bonus to quell various investor concerns about the status of their investments.  For example, on
April 7, 2018, Rossetti wrote an email to Clinton Greyling, which Clinton Greyling forwarded to
Leslie Greyling, listing investors to whom Trends owed shares of either Alterola or Token.  One
investor was described as having invested $10,000 and, nearly a year later, still being owed

17
 
400,000 shares of Token.  Rossetti noted that “this guy has been a pain in my ass bitching to get
him off our back he was compensated” by promising him additional shares.
52. Rossetti promised one investor that for every share of Token he purchased, he
would receive some number of undescribed “Community Coins,” which did not exist.
53. Rossetti often represented to investors that the price at which Trends was offering
them shares was a substantial discount to the market price or to some baseless prediction about
what a market price would be.  For example, in an email sent to an investor in April 2018,
Rossetti stated that Token “is opening on the OTC Markets @ $1.45 per share.  I put aside a
block of 2 million shares @ 50 cents.”  In reality, there was no active market for shares of
Alterola or Token, and Rossetti had no basis for suggesting that an investor could sell their
shares for those prices.
54. Investors who sent money to Trends for shares of Alterola and/or Token
ultimately received little, if anything, of value.  Most Alterola investors who belatedly received
shares received only restricted shares that they would generally be unable to deposit with a
broker-dealer or trade without, at a minimum, obtaining an attorney opinion letter to support the
removal of restrictive legends.  Most Token investors who belatedly received shares were unable
to deposit their shares with any broker-dealer.  Although Token was briefly current in its filings
with the Commission for several months in 2018, its ability to stay current was entirely
dependent on the Greylings paying the associated expenses (such as for the preparation and filing
of periodic reports).  Token did not timely file its annual report for the period ended June 30,
2018, which was not filed until March 2019, and then stopped making periodic filings with the
Commission entirely.  In October 2020, the Commission issued an order revoking the
registration of each class of Token’s securities pursuant to Exchange Act Section 12(j).

18
 
55. In total from 2017 to at least 2020, the defendants defrauded more than 30
investors out of approximately $2.3 million which was wired to Trends and then further divided
among the Greylings and Rossetti.
TRADING TO FACILITATE THE SCHEME
56. The scheme also involved sham trading in Alterola and Token stock, which
created a false appearance of market activity and price to induce investments, quiet investor
concerns, and avoid detection.
57. Clinton Greyling’s primary business, aside from this scheme, had been brokering
the purchase and sale of shell companies between shell company buyers and shell company
sellers in exchange for a fee.  For several years, Bendelac had regularly assisted Clinton
Greyling’s shell company brokering business by receiving small blocks of shares of a shell
company as arranged by Clinton Greyling, depositing the shares in his brokerage account and
then placing a trade, in order to demonstrate to a potential buyer that the issuer’s stock could be
traded electronically.
58. On multiple occasions, Clinton Greyling purchased shares from Bendelac in the
securities market in a coordinated manner to demonstrate to a prospective buyer of a shell
company that the stock was tradeable.  The purchaser would often request that a market trade be
made at a certain price, and Clinton Greyling would coordinate a single small trade with
Bendelac at the requested price.
59. To facilitate the Alterola and Token scheme by inducing further investments,
Clinton Greyling, Brandon Rossetti, and Bendelac placed orders to buy or sell Alterola and/or
Token stock, which created the false appearance of active trading.  Clinton Greyling and
Brandon Rossetti traded in both Alterola and Token stock, and all three individuals traded in

19
 
Token stock.  These misleading data points were then used by Rossetti to make
misrepresentations to private investors to induce them to invest again, or to quiet their concerns.
This trading went well beyond the practice described above whereby Clinton Greyling would
coordinate with Bendelac to create one small market trade at a desired price for the purpose of
demonstrating to a shell buyer that the stock was trading.  The coordinated trades in the Alterola
and Token scheme were designed to induce the purchase of securities by others.
60. Between November 2018 and May 2019, Bendelac placed a series of trades in
Token stock in coordination with Clinton Greyling, often after Rossetti asked Clinton Greyling
to arrange for a trade to help Rossetti sell Token stock to investors in private transactions on
behalf of Trends.  On some occasions, Bendelac sold Token stock in his Aleutian account which
Clinton Greyling or Rossetti purchased in open-market trades.  On other occasions, Bendelac
sold Token stock in his Aleutian account and also purchased Token stock in Capellini’s account
or in Bendelac’s relative’s account in open-market trades.  These manipulative trades are
summarized in Exhibit A, attached hereto.
61. For example, on November 7, 2018, Bendelac’s entity, Aleutian, sold 500 shares
of Token at $1.60 per share.  Clinton Greyling purchased 100 shares of Token at $1.60 per share,
with the stock closing at $1.60 per share, up from $1.01 at open.  The total reported market
volume of shares traded that day was 601.
62. As another example, on February 19, 2019, Clinton Greyling and Bendelac placed
coordinated trades in order to create the false appearance of active trading and to manipulate the
price of Token:  Bendelac through Aleutian sold 100 shares at $2.05 per share; Greyling bought
100 shares at $2.00 per share and 100 shares at $9.95; and Bendelac bought 100 shares at $2.05
per share in Capellini’s account.  However, there was a market transaction between unaffiliated

20
 
parties of 3,350 shares of Token at a price of $0.101 per share which dramatically lowered
Token’s reported price, which closed at $0.101 per share.  Bendelac and Clinton Greyling had
multiple phone calls on the evening of February 19, 2019.
63. The next day, on February 20, 2019, Bendelac sold 200 shares of Token at $2.00
per share in his Aleutian account and purchased 100 shares of Token in his relative’s account at
$2.25 per share.  The total market volume was 400 shares traded that day, and the price closed at
$2.00 per share, up from the prior day’s reported closing price of $0.101 per share.
64. The Greylings and Rossetti monitored the trading activity in Token stock and
used this information in connection with the offer and sale of Token stock to investors.  That
same day, February 20, 2019, Leslie Greyling sent an email to Clinton Greyling and Rossetti
noting that Token’s last trade was $2.25 per share (the trade orchestrated by Bendelac described
in paragraph 66) and providing a link to a website reflecting the same.
65. On various dates through April and May 2019, Bendelac sold small amounts of
Aleutian’s shares of Token, with Greyling, Rossetti, or Bendelac (through Capellini’s account or
Bendelac’s relative’s account) buying small amounts.  These trades, which are summarized in
Exhibit A, comprised a large portion of the reported market activity.
66. Starting in June 2019, the volume and frequency of Bendelac’s Token trading
increased, and some of it involved placing coordinated buy and sell orders using his Aleutian
account and Capellini’s account.  Bendelac’s trades often comprised all or nearly all of the
reported total market volume of Token shares traded, creating the false appearance of market
activity and artificially inflating the reported prices.  For example:

21
 
 
 
67. The purpose of the foregoing trading was to induce investment by others in Token
shares, including (1) private investors to whom Trends was offering Token stock and (2) others
who might purchase stock sold by Bendelac in the public marketplace.  In June 2019, Rossetti
was actively soliciting investors to purchase Token stock from Trends.  For example, Rossetti
took advantage of the manipulative trading in Token to obtain investments from Investor A.  On
June 12, Rossetti described Token shares to Investor A as “selling like hotcakes.”  Between June
17 and 24, 2019, Investor A wired $58,000 to Trends for a combined 116,000 shares of Token
and some “free” Alterola shares.  Rossetti did not tell Investor A that the market sales of Token
shares were orchestrated by the people who controlled Trends and Token.
68. After receiving these investments from Investor A, Rossetti sought to create and
sustain Investor A’s belief that these were profitable investments and continued to solicit him for
additional investments.  On June 25, 2019 at 10:16:14 AM, Rossetti placed an order to purchase
100 shares (the minimum size of a trade that a broker has to report to the market) at $4.80 per
share.  (Aleutian was the principal seller of Token stock in the market that day.)  The stock had
closed the previous day at $4.26 per share.  The trade executed within seconds.  One minute
later, Rossetti sent a text message to Investor A with a screen shot of information about Token
and reflecting a $4.80 per share price and a daily increase of $0.54 per share (12.68%).  Rossetti
then sent a text to Investor A stating, “And you’re [sic] 86000 shares your profitable big time.”
DateAleutian Sale Quantity   Aleutian Sale Proceeds  Capellini Buy QuantityCapellini Buy CostTotal Market Volume
6/11/2019(400)                                    1,815$                                 500                                      (2,255)$                                500                                       
6/12/2019(1,000)                                 4,262$                                 1,000                                  (4,262)$                                1,000                                   
6/13/2019(1,513)                                 6,454$                                 1,500                                  (6,400)$                                2,013                                   
6/14/2019(2,000)                                 8,500$                                 2,000                                  (8,500)$                                2,000                                   
6/17/2019(1,000)                                 4,250$                                 1,100                                  (4,675)$                                1,200                                   
6/19/2019(2,000)                                 8,519$                                 2,000                                  (8,519)$                                2,000                                   
9/5/2019(8,500)                                 17,166$                               8,100                                  (16,318)
$                             9,175                                   
9/9/2019(2,000)                                 5,073$                                 2,000                                  (5,068)$                                2,400                                   
10/18/2019(2,500)                                 6,325$                                 2,500                                  (6,325)$                                2,500                                   
 Aleutian Equity and Capellini Trading in TKCM (Selected Days) 

22
 
69. After receiving the above text from Rossetti, Investor A then asked Rossetti,
“What is going on with ALTA [Alterola]?  It is at $0.20.”  At 10:36 AM, Rossetti purchased 100
shares of Alterola at $0.55 per share.  At 11:10 AM Rossetti responded to Investor A, “Alta
[Alterola] is gonna bounce with the news announcements that come out next week.  Last trader
[sic] saw is around 50[-]60 cents.”
BENDELAC PROVIDED SUBSTANTIAL ASSISTANCE IN THE FRAUD
70. Bendelac knew or was reckless in not knowing that his coordinated trading in
shares of Token was providing substantial assistance to the fraud scheme.
71. Bendelac knowingly engaged in the regular practice of helping Clinton Greyling’s
shell company business by placing small trades before the closing of the transaction at prices
requested by the shell purchasers.
72. Bendelac’s securities deposits and trading at Broker-Dealer A would have been
deemed suspicious by a broker-dealer conducting a reasonable inquiry into the facts and
circumstances surrounding his offer and sale of securities, including Token.  Bendelac’s
activities using the Aleutian brokerage account frequently presented numerous red flags,
including but not limited to a pattern of depositing physical share certificates in thinly-traded
low-priced securities (including companies that had undergone a recent name change), selling
the shares, and wiring out the proceeds.
73. Bendelac took advantage of the lack of scrutiny that Broker-Dealer A applied to
his deposits of stock and subsequent trading in the Aleutian brokerage account.  As noted above,
Bendelac had a personal connection to an employee at Broker-Dealer A who oversaw Bendelac’s
trading through Broker-Dealer A, and Bendelac knew that this meant there would be little or no
meaningful compliance review of his securities deposits or trading activity.

23
 
74. Bendelac expressed in an email to Clinton Greyling that he preferred to receive
physical share certificates (sometimes referred to as “certs”) to deposit with Broker-Dealer A,
rather than to deposit shares in electronic form through the process known as
Deposit/Withdrawal at Custodian, or DWAC.  Bendelac noted, “[t]he broker does extra scrutiny
on DWAC.  I have zero scrutiny on CERTS.”
75. To deposit shares with a broker-dealer, the owner of the security may be required
to provide documentation reflecting how the security owner acquired the shares, and may also be
required to submit documentation showing that he or she paid for the shares.  However,
Bendelac understood that Broker-Dealer A would not conduct any meaningful compliance
scrutiny of his deposits, and suggested to Clinton Greyling that they could document the
transfers to Aleutian with phony stock purchase agreements without Bendelac needing to
actually pay for the stock.  Bendelac wrote to Clinton Greyling, “I need to make no payments as
I need no proof of payments.  Just the Certificate.  You can make the contract with a payable
due.  No need to exchange funds for me to put it in.”
76. Bendelac knew that the Token deal was not part of Clinton Greyling’s shell
company business and that the Greylings had acquired ownership and control of Token.
Bendelac partnered with the Greylings to acquire ownership and control of Token (then named
Pacific Media), and his entity, Aleutian, received a block of shares paid for by Trends using
money obtained from investors.  The purpose of using multiple entities to hold shares was to
disguise the common ownership and control so that the “float” of purportedly unrestricted shares
would appear to be held by non-affiliates.
77. Bendelac knew or was reckless in not knowing, at least as of June 2018, that the
Greylings were selling Token shares to private investors.  Bendelac was a director of Trends

24
 
and he participated in the distribution of shares to some Token investors.  Bendelac signed a
board resolution on behalf of Aleutian resolving that Aleutian would grant shares to seven
Trends investors who had invested in Token or otherwise had been promised shares of Token by
Trends, and provided documents to the transfer agent to facilitate the transactions.
78. Bendelac prepared for substantial coordinated sham trading and took deceptive
actions to make that possible.  In April 2018, the Greylings and Bendelac arranged for a smaller
share certificate of 300,000 Token shares to be carved out of Aleutian’s larger block of
5,400,000 shares.  In September 2018, Bendelac deposited into Aleutian’s account at Broker-
Dealer A the share certificate for 300,000 shares of Token.  In doing so, Bendelac submitted to
Broker-Dealer A a letter from an attorney which falsely stated that the shares were “purchased in
a private transaction for a cost basis of 25 cents per share.”  Bendelac also submitted an opinion
letter from the same attorney which stated that Aleutian was not an affiliate of Token, which
Bendelac knew to be false.
79. In April 2019, just prior to the period of time in which Bendelac conducted his
most active trading in Token, Leslie Greyling included Bendelac as a recipient of two emails
which he also sent to Clinton Greyling, Rossetti, and other associates which referenced there
being news about Token on a financial news website and directed the recipients to a website he
described as “FREE REAL TIME QUOTES SHOWS PRICE PRESS RELEASE AND 8K”
concerning Token’s stock.
80. In April 2020, when Bendelac was asked about his trading in an interview with
the Commission staff, Bendelac made statements to the staff which were demonstrably false and,
in some cases, which were contradicted by his own admissions in an interview with law
enforcement agents the next day.  For example, Bendelac told the Commission staff that he did

25
 
not have access to Capellini’s brokerage account and claimed it was a coincidence that Capellini
bought shares of Token from Aleutian in open market trades.  The next day, Bendelac admitted
to law enforcement agents that Capellini had given Bendelac access to his account.  In a similar
vein, when Bendelac spoke to the Commission staff, he acknowledged that he had access to his
relative’s brokerage account, but claimed that his relative placed all of the relative’s own orders.
When he spoke with law enforcement agents the next day, Bendelac admitted, in sum and
substance, that Bendelac conducted the trading in his relative’s account.
81. In total, Bendelac received approximately $97,000 from his sales of Token stock
in the Aleutian brokerage account.  Approximately $62,000 of these proceeds were from
purchases made through Capellini’s account, funded by Capellini and at least partially
reimbursed by Bendelac, as described below.
CAPELLINI PROVIDED SUBSTANTIAL ASSISTANCE IN THE FRAUD
82. Capellini knowingly or recklessly provided substantial assistance to Bendelac’s
fraudulent securities trading.  Capellini initially provided Bendelac with access to Capellini’s
brokerage account at Broker-Dealer B in 2017 and 2018.  Bendelac used Capellini’s account to
conduct coordinated trades at Clinton Greyling’s instruction, including, for example, the trading
in Millennium described in paragraph 35.
83. In 2019, Capellini’s involvement expanded beyond providing Bendelac with
access to his brokerage account.  Capellini undertook additional activity to assist Bendelac in
May and June of 2019 to fund Bendelac’s trading and to receive reimbursement from Bendelac
through an entity Capellini controlled.
84. On May 21, 2019, Capellini opened up a second brokerage account with Broker-
Dealer B, to which he gave Bendelac access.

26
 
85. On June 5, 2019, Capellini funded the new brokerage account with a transfer of
$100,000.  Bendelac used these funds to purchase stock through Capellini’s accounts, while
Bendelac sold the shares through either the Aleutian account or Bendelac’s relative’s account.
86. On June 13, 2019, Capellini opened two bank accounts at a bank based in the U.S.
in the name of an entity Capellini controlled.
87. Between June and September 2019, Capellini received in one of his entity’s new
bank accounts four payments from three Bendelac-controlled entities totaling $36,450 and
comprising all of the incoming funds in the bank accounts during this period (excluding two
$100 deposits to open the accounts).
FIRST CLAIM FOR RELIEF
FRAUD IN THE OFFER OR SALE OF SECURITIES
 (Violations of Section 17(a) of the Securities Act by Trends, Rossetti, Clinton Greyling, and
Leslie Greyling)

88. Paragraphs 1 through 87 above are re-alleged and incorporated by reference as if
fully set forth herein.
89. During the Relevant Period, the shares of stock of Alterola and Token were
securities under Section 2(a)(1) of the Securities Act [15 U.S.C. § 77b(a)(1)].
90. By reason of the conduct described above, Trends, Rossetti, Clinton Greyling, and
Leslie Greyling, directly or indirectly, in connection with the offer or sale of securities of
Alterola and Token, by the use of the means or instrumentalities of interstate commerce or of the
mails, directly or indirectly, acting intentionally, knowingly, recklessly, or negligently,
(i) employed devices, schemes, or artifices to defraud; (ii) obtained money or property by means
of any untrue statement of a material fact or any omission to state a material fact necessary in
order to make the statements made, in light of the circumstances under which they were made,
not misleading; and (iii) engaged in transactions, practices, or courses of business which

27
 
operated or would operate as a fraud or deceit upon any persons, including purchasers or sellers
of the securities.
91. By reason of the conduct described above, Trends, Rossetti, Clinton Greyling, and
Leslie Greyling violated, and will continue to violate unless enjoined, Securities Act Section
17(a) [15 U.S.C. § 77q(a)].

SECOND CLAIM FOR RELIEF
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES
(Violations of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder by Trends,
Rossetti, Clinton Greyling, and Leslie Greyling)

92. Paragraphs 1 through 87 above are re-alleged and incorporated by reference as if
fully set forth herein.
93. During the Relevant Period, the shares of stock of Alterola and Token were
securities under Section 3(a)(1) of the Exchange Act [15 U.S.C. § 78c(a)(10)].
94. By reason of the conduct described above, Trends, Rossetti, Clinton Greyling, and
Leslie Greyling, directly or indirectly, in connection with the purchase or sale of securities, by
the use of the means or instrumentalities of interstate commerce or of the mails, or of any facility
of any national securities exchange, intentionally, knowingly or recklessly, (i) employed devices,
schemes, or artifices to defraud; (ii) made untrue statements of material fact or omitted to state
material facts necessary to make the statements made, in light of the circumstances under which
they were made, not misleading; and (iii) engaged in acts, practices, or courses of business which
operated or would operate as a fraud or deceit upon any persons, including purchasers or sellers
of the securities.

28
 
95. By reason of the conduct described above, Trends, Rossetti, Clinton Greyling, and
Leslie Greyling violated, and will continue to violate unless enjoined, Exchange Act Section
10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5 [17 C.F.R. § 240.10b-5] thereunder.
THIRD CLAIM FOR RELIEF
 FRAUD IN THE OFFER OR SALE OF SECURITIES
(Violations of Sections 17(a)(1) and (3) of the Securities Act by Bendelac)

96. Paragraphs 1 through 87 above are re-alleged and incorporated by reference as if
fully set forth herein.
97. During the Relevant Period, the shares of stock of Alterola and Token were
securities under Section 2(a)(1) of the Securities Act [15 U.S.C. § 77b(a)(1)].
98. By reason of the conduct described above, Bendelac, directly or indirectly, in
connection with the offer or sale of securities, by the use of the means or instrumentalities of
interstate commerce or of the mails, directly or indirectly, acting intentionally, knowingly,
recklessly, or negligently, (i) employed devices, schemes, or artifices to defraud; and (ii)
engaged in transactions, practices, or courses of business which operated or would operate as a
fraud or deceit upon any persons, including purchasers or sellers of the securities.
99. By reason of the conduct described above, Bendelac violated, and will continue to
violate unless enjoined, Securities Act Sections 17(a)(1) and (3) [15 U.S.C. § 77q(a)(1) and (3)].
FOURTH CLAIM FOR RELIEF
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES
(Violations of Section 10(b) of the Exchange Act and Rules 10b-5(a) and (c) thereunder by
Bendelac)

100. Paragraphs 1 through 87 above are re-alleged and incorporated by reference as if
fully set forth herein.

29
 
101. During the Relevant Period, the shares of stock of Alterola and Token were
securities under Section 3(a)(1) of the Exchange Act [15 U.S.C. § 78c(a)(10)].
102. By reason of the conduct described above, Bendelac, directly or indirectly, in
connection with the purchase or sale of securities, by the use of the means or instrumentalities of
interstate commerce or of the mails, or of any facility of any national securities exchange,
intentionally, knowingly or recklessly, (i) employed devices, schemes, or artifices to defraud;
and (ii) engaged in acts, practices, or courses of business which operated or would operate as a
fraud or deceit upon any persons, including purchasers or sellers of the securities.
103. By reason of the conduct described above, Bendelac violated, and will continue to
violate unless enjoined, Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and Rules 10b-5(a) and
(c) [17 C.F.R. § 240.10b-5(a) and (c)] thereunder.
FIFTH CLAIM FOR RELIEF
MARKET MANIPULATION
(Violations of Section 9(a)(2) of the Exchange Act by Bendelac)

104. Paragraphs 1 through 87 above are re-alleged and incorporated by reference as if
fully set forth herein.
105. During the Relevant Period, the shares of stock of Token were securities under
Section 3(a)(1) of the Exchange Act [15 U.S.C. § 78c(a)(10)].
106. Section 9(a)(2) of the Exchange Act [15 U.S.C. §78i(a)(2)] makes it unlawful for
any person, directly or indirectly, by the use of the mails or any means or instrumentality of
interstate commerce, or of any facility of any national securities exchange, to effect a series of
transactions in a security creating actual or apparent active trading in such security, or raising or
depressing the price of such security, for the purpose of inducing the purchase or sale of such
security by others.

30
 
107. By reason of the conduct described above, Bendelac violated, and will continue to
violate unless enjoined, Exchange Act Section 9(a)(2) [15 U.S.C. § 78i(a)(2)].
SIXTH CLAIM FOR RELIEF
UNREGISTERED BROKER
(Violations of Section 15(a)(1) of the Exchange Act by Rossetti)

108. Paragraphs 1 through 87 above are re-alleged and incorporated by reference as if
fully set forth herein.
109. By engaging in the conduct described above, Rossetti. (a) engaged in the business
of effecting transactions in securities for the account of others; and (b) directly or indirectly,
made use of the mails or the means or instrumentalities of interstate commerce to effect
transactions in, or to induce or attempt to induce the purchase or sale of, securities without being
registered as a broker or dealer with the Commission or associated with a broker or dealer
registered with the Commission.
110. By reason of the conduct described above, Rossetti violated, and will continue to
violate unless enjoined, Section 15(a)(1) of the Exchange Act [15 U.S.C. §78o(a)(1)].
SEVENTH CLAIM FOR RELIEF
AIDING AND ABETTING
(Bendelac’s Aiding and Abetting Violations of Sections 17(a)(1) and (3) of the Securities
Act and Section 10(b) of the Exchange Act and Rules 10b-5(a) and (c) by Trends, Rossetti,
Clinton Greyling, and Leslie Greyling)

111. Paragraphs 1 through 87 above are re-alleged and incorporated by reference as if
fully set forth herein.
112. During the Relevant Period, the shares of stock of Alterola and Token were
securities under Section 2(a)(1) of the Securities Act [15 U.S.C. § 77b(a)(1)] and Section 3(a)(1)
of the Exchange Act [15 U.S.C. § 78c(a)(10)].

31
 
113. By reason of the conduct described above, Trends, Rossetti, Clinton Greyling, and
Leslie Greyling, directly or indirectly, in connection with the offer or sale of securities, by the
use of the means or instrumentalities of interstate commerce or of the mails, directly or
indirectly, acting intentionally, recklessly, or negligently, (i) employed devices, schemes, or
artifices to defraud; and (ii) engaged in transactions, practices, or courses of business which
operated or would operate as a fraud or deceit upon any persons, including purchasers or sellers
of the securities.
114. By reason of the conduct described above, Trends, Rossetti, Clinton Greyling, and
Leslie Greyling, directly or indirectly, in connection with the purchase or sale of securities of
Alterola and Token, by the use of the means or instrumentalities of interstate commerce or of the
mails, intentionally, knowingly or recklessly, (i) employed devices, schemes, or artifices to
defraud; and (ii) engaged in acts, practices, or courses of business which operated or would
operate as a fraud or deceit upon any persons, including purchasers or sellers of the securities.
115. Bendelac knowingly or recklessly provided substantial assistance to Trends,
Rossetti, Clinton Greyling, and Leslie Greyling, in their violations of Sections 17(a)(1) and (3) of
the Securities Act and Section 10(b) of the Exchange Act and Rules 10b-5(a) and (c) thereunder.
116. By reason of the conduct described above, Bendelac aided and abetted violations
of Sections 17(a)(1) and (3) of the Securities Act and Section 10(b) of the Exchange Act and
Rules 10b-5(a) and (c) thereunder, as proscribed by Section 15(b) of the Securities Act [15
U.S.C. §§ 77o(b)] and Section 20(e) of the Exchange Act [15 U.S.C. § 78t(e)].

32
 
EIGHTH CLAIM FOR RELIEF
AIDING AND ABETTING
(Capellini’s Aiding and Abetting Bendelac’s Violations of Sections 17(a)(1) and (3) of the
Securities Act and Sections 9(a)(2) and 10(b) of the Exchange Act and Rules 10b-5(a) and
(c) thereunder)

117. Paragraphs 1 through 87 above are re-alleged and incorporated by reference as if
fully set forth herein.
118. During the Relevant Period, the shares of stock of Alterola and Token were
securities under Section 2(a)(1) of the Securities Act [15 U.S.C. § 77b(a)(1)] and Section 3(a)(1)
of the Exchange Act [15 U.S.C. § 78c(a)(10)].
119. By reason of the conduct described above, Bendelac, directly or indirectly, in
connection with the offer or sale of securities, by the use of the means or instrumentalities of
interstate commerce or of the mails, directly or indirectly, acting intentionally, recklessly, or
negligently, (i) employed devices, schemes, or artifices to defraud; and (ii) engaged in
transactions, practices, or courses of business which operated or would operate as a fraud or
deceit upon any persons, including purchasers or sellers of the securities.
120. By reason of the conduct described above, Bendelac directly or indirectly, by the
use of the mails or any means or instrumentality of interstate commerce, or of any facility of any
national securities exchange, effected a series of transactions in the securities of Token creating
actual or apparent active trading in such security, or raising or depressing the price of such
security, for the purpose of inducing the purchase or sale of such security by others.
121. By reason of the conduct described above, Bendelac, directly or indirectly, in
connection with the purchase or sale of securities of Alterola and Token, by the use of the means
or instrumentalities of interstate commerce or of the mails, intentionally, knowingly or
recklessly, (i) employed devices, schemes, or artifices to defraud; and (ii) engaged in acts,

33
 
practices, or courses of business which operated or would operate as a fraud or deceit upon any
persons, including purchasers or sellers of the securities.
122. Capellini knowingly or recklessly provided substantial assistance to Bendelac in
his violations of Sections 17(a)(1) and (3) of the Securities Act and Sections 9(a)(2) and 10(b) of
the Exchange Act and Rules 10b-5(a) and (c) thereunder.
123. By reason of the conduct described above, Capellini aided and abetted violations
of Sections 17(a)(1) and (3) of the Securities Act and Sections 9(a)(2) and 10(b) of the Exchange
Act and Rules 10b-5(a) and (c) thereunder, as proscribed by Section 15(b) of the Securities Act
[15 U.S.C. §§ 77o(b)] and Section 20(e) of the Exchange Act [15 U.S.C. § 78t(e)].
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that this Court:
A. Enter a permanent injunction restraining each of the defendants, their officers,
agents, servants, employees and attorneys, and those persons in active concert or participation
with them who receive actual notice of the injunction by personal service or otherwise, from
violating 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 Rule 10b-5 thereunder [17 C.F.R. 240.10b-5];
B. Enter a permanent injunction restraining Bendelac and Capellini, their officers,
agents, servants, employees and attorneys, and those persons in active concert or participation
with them who receive actual notice of the injunction by personal service or otherwise, from
violating Section 9(a) of the Exchange Act [15 U.S.C. §78i(a)];
C. Enter a permanent injunction restraining Rossetti, his officers, agents, servants,
employees and attorneys, and those persons in active concert or participation with him who

34
 
receive actual notice of the injunction by personal service or otherwise, from violating Section
15(a)(1) of the Exchange Act [15 U.S.C. §78o(a)(1)].
D. Order the defendants to disgorge, with prejudgment interest, all ill-gotten gains
they obtained by reason of the unlawful conduct alleged in this Complaint pursuant to Section
21(d)(7) of the Exchange Act [15 U.S.C. §78u(d)(7)];
E. Order the defendants to pay 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)];
F. Enter an order prohibiting the defendants from participating in any offering of a
penny stock, pursuant to Section 20(g) of the Securities Act [15 U.S.C. § 77t(g)] and 21(d) of the
Exchange Act [15 U.S.C. § 78u(d)];
G. Retain jurisdiction over this action to implement and carry out the terms of all
orders and decrees that may be entered; and
H. Grant such other and further relief as this Court may deem just and proper.
JURY DEMAND
The Commission demands a jury in this matter for all claims so triable.
DATED this 8th day of June 2022.
                                                            Respectfully            submitted,
                                           /s/ David M. Scheffler
David M. Scheffler (Mass Bar No.670324)
J. Lauchlan Wash (Mass. Bar No. 629092)
SECURITIES AND EXCHANGE COMMISSION
Boston Regional Office
33 Arch St., 24
th
 Floor
Boston, MA 02110
Phone: (617) 573-8810 (Scheffler direct)
[email protected] (Scheffler email)

EXHIBIT A
[1] - The maximum percentage of market volume is 200% which would mean that the Defendants / Associates account for all of the buy-side and sell-side activity in the market that day.
Trade Date
Transaction
Type
ALEUTIAN
(BENDELAC)
THOMAS
CAPELLINI
CLINTON
GREYLING
BRANDON
ROSSETTI
BENDELAC'S
RELATIVE
 Grand
Total
 Total
Market
Volume
Defendants and
Associates Percentage of
Market Volume [1]
11/7/2018BUY100                       100
SELL500                       500
11/7/2018 Total500                       100                       600             601             99.8%
2/19/2019BUY100                       200                       300
SELL100                       100
2/19/2019 Total100                       100                       200                       400             3,650          11.0%
2/20/2019BUY100                       100
SELL200                       200
2/20/2019 Total200                       100                       300             400             75.0%
4/9/2019BUY10                         10
SELL500                       500
4/9/2019 Total500                       10                         510             1,550          32.9%
4/11/2019BUY10                         10
SELL200                       200
4/11/2019 Total200                       10                         210             760             27.6%
4/16/2019BUY100                       100
SELL100                       100
4/16/2019 Total100                       100                       200             300             66.7%
4/17/2019BUY90                         90
SELL
200
 200
4/17/2019 Total200                       90                         290             290             100.0%
4/22/2019BUY20                         300                       320
SELL400                       400
4/22/2019 Total400                       20                         300                       720             550             130.9%
5/10/2019BUY100                       130                       230
SELL100                       100
5/10/2019 Total100                       100                       130                       330             930             35.5%
5/20/2019
B
UY300                       300
SELL300                       100                       400
5/20/2019 Total300                       100                       300                       700             400             175.0%
5/21/2019BUY800                       800
SELL314                       200                       514
5/21/2019 Total314                       1,000                    1,314          1,200          109.5%
5/23/2019BUY250                       250
SELL300                       300
5/23/2019 Total300                       250                       550             550             100.0%
TRADING IN TOKEN BY DEFENDANTS AND ASSOCIATES - SELECTED DAYS

EXHIBIT A
[1] - The maximum percentage of market volume is 200% which would mean that the Defendants / Associates account for all of the buy-side and sell-side activity in the market that day.
Trade Date
Transaction
Type
ALEUTIAN
(BENDELAC)
THOMAS
CAPELLINI
CLINTON
GREYLING
BRANDON
ROSSETTI
BENDELAC'S
RELATIVE
 Grand
Total
 Total
Market
Volume
Defendants and
Associates Percentage of
Market Volume [1]
5/24/2019BUY360                       360
SELL386                       1                           387
5/24/2019 Total386                       361                       747             667             112.0%
6/11/2019BUY500                       500
SELL400                       400
6/11/2019 Total400                       500                       900             500             180.0%
6/12/2019BUY1,000                    1,000
SELL1,000                    1,000
6/12/2019 Total1,000                    1,000                    2,000          1,000          200.0%
6/13/2019BUY1,500                    1,500
SELL1,513                    1,513
6/13/2019 Total1,513                    1,500                    3,013          2,013          149.7%
6/14/2019BUY2,000                    2,000
SELL2,000                    2,000
6/14/2019 Total2,000                    2,000                    4,000          2,000          200.0%
6/17/2019BUY1,100                    1,100
SELL1,000                    1,000
6/17/2019 Total1,000                    1,100                    2,100          1,200          175.0%
6/19/2019BUY2,000                    2,000
SELL2,000                    2,000
6/19/2019 Total2,000                    2,000                    4,000          2,000          200.0%
6/25/2019BUY140                       140
SELL240                       240
6/25/2019 Total240                       140                       380             340             111.8%
8/20/2019BUY100                       100
SELL500                       500
8/20/2019 Total600                       600             800             75.0%
9/5/2019BUY8,100                    8,100
SELL8,500                    8,500
9/5/2019 Total8,500                    8,100                    16,600        9,175          180.9%
9/9/2019BUY2,000                    2,000
SELL2,000                    2,000
9/9/2019 Total2,000                    2,000                    4,000          2,400          166.7%
10/18/2019BUY2,500                    2,500
SELL2,500                    2,500
10/18/2019 Total2,500                    2,500                    5,000          2,500          200.0%
11/13/2019
BUY1,000                    1,000

EXHIBIT A
[1] - The maximum percentage of market volume is 200% which would mean that the Defendants / Associates account for all of the buy-side and sell-side activity in the market that day.
Trade Date
Transaction
Type
ALEUTIAN
(BENDELAC)
THOMAS
CAPELLINI
CLINTON
GREYLING
BRANDON
ROSSETTI
BENDELAC'S
RELATIVE
 Grand
Total
 Total
Market
Volume
Defendants and
Associates Percentage of
Market Volume [1]
43782SELL1,000
1,000
11/13/2019 Total1,000                    1,000                    2,000          1,160          172.4%
12/2/2019BUY2,500                    2,500
SELL1,930                    1,930
12/2/2019 Total1,930                    2,500                    4,430
2,500
177.2%

UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 

 

 
SECURITIES AND EXCHANGE 
COMMISSION, 
    Plaintiff, 
 v. 
 
TRENDS INVESTMENTS INC., 
BRANDON ROSSETTI, CLINTON 
GREYLING, LESLIE GREYLING, 
ROGER BENDELAC, and THOMAS 
CAPELLINI 
    Defendants. 
 

 
 

Civil Action No. 22-CV-____ 
(___) 

 
JURY TRIAL DEMANDED 

 
 

 
COMPLAINT 

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

following against the defendants Trends Investments Inc. (“Trends”), Brandon Rossetti 

(“Rossetti”), Clinton Greyling, Leslie Greyling, Roger Bendelac (“Bendelac”), and Thomas 

Capellini (“Capellini”): 

SUMMARY  

1. This is a securities fraud enforcement action.  Defendants Trends, a company 

which was in the business of selling stock to investors, and Trends’ personnel Brandon Rossetti, 

Clinton Greyling, and Leslie Greyling, engaged in a scheme to defraud investors in private 

offerings of shares in publicly traded companies.  The scheme started in early 2017 when Trends 

offered and sold shares of stock in Alterola Biotech Inc. (“Alterola”) to investors.  Alterola was a 

publicly traded company with no reported revenue that was purportedly developing medicinal 

chewing gum.  Rossetti and the Greylings misled investors to believe that Trends owned the 

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2 
 

shares of Alterola they were offering to sell to investors.  In reality, Trends owned zero shares of 

Alterola.   

2. Trends planned to obtain enough money from investors to purchase all of 

Alterola’s common stock from a seller of public shell companies—companies that lack 

meaningful assets or business operations.  However, although Trends obtained money from 

investors, it did not acquire the Alterola shell at the time, and the scheme evolved over several 

years as the Greylings and Rossetti scrambled to keep investor funds, obtain a different shell 

company, solicit further investments, placate investor concerns, and avoid detection.  Among 

other things, the scheme involved manipulative trading in the securities of one of the companies 

the Greylings and Rossetti were trying to sell to investors. 

3. Rossetti preyed on investors, some of whom are senior citizens, representing 

himself as their “broker” or “wealth manager,” while he and the Greylings misled them with a 

series of misrepresentations in connection with their investments in Alterola and a second 

publicly traded company named Token Communities Ltd. (“Token”).  Rossetti was not 

registered with the Commission as a broker or dealer, nor was he associated with a broker or 

dealer registered with the Commission. 

4. Bendelac was a director of Trends from August 2017 to October 2019 and 

participated in the scheme.  Bendelac was a partner of the Greylings in the plan to acquire a shell 

company using money that was obtained by Trends from investors.  Bendelac, through an entity 

he controlled, acquired a block of shares in Token which was paid for by Trends using money 

that Trends received from investors.  During the time period that Trends was offering and selling 

shares of Token to investors in private offerings, Bendelac worked with Clinton Greyling to 

coordinate trading in Token stock on the public securities markets.  Bendelac used multiple 

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3 
 

brokerage accounts, including Capellini’s (Bendelac’s brother-in-law), to place trades in Token’s 

stock in order to create the false appearance of active trading in Token’s stock and to inflate the 

stock price.  Bendelac placed these manipulative trades in order to induce the purchase of Token 

stock (1) by private investors to whom Trends was offering stock; and (2) by other investors in 

the public marketplace.  In total, Bendelac received approximately $97,000 from the sale of 

Token stock in the public marketplace. 

5. Capellini provided substantial assistance to the scheme and to Bendelac by giving 

Bendelac access to his brokerage account and funding the brokerage account, enabling Bendelac 

to purchase Token stock through Capellini’s account while Bendelac was selling Token stock 

through the brokerage account of an entity controlled by Bendelac.  

6. As a result of the scheme, from 2017 to at least 2020 (the “Relevant Period”), the 

defendants defrauded more than 30 investors out of approximately $2.3 million.   

7. By engaging in the conduct alleged herein, Trends, Rossetti, Clinton Greyling, 

and Leslie Greyling violated Section 17(a) of the Securities Act of 1933 (“Securities Act”) 

[15 U.S.C. § 77q(a)] and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) 

[15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 340.10b-5].    

8. By engaging in the conduct alleged herein, Rossetti also violated Section 15(a)(1) 

of the Exchange Act [15 U.S.C. § 78o(a)(1)].   

9. By engaging in the conduct alleged herein, Bendelac violated Sections 17(a)(1) 

and (3) of the Securities Act [15 U.S.C. § 77q(a)(1) and (3)], Section 9(a)(2) of the Exchange 

Act [15 U.S.C. § 78i(a)(2)], and Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and 

Rules 10b-5(a) and (c) thereunder [17 C.F.R. § 340.10b-5(a) and (c)], and aided and abetted 

Trends’, Clinton Greyling’s, Leslie Greyling’s, and Rossetti’s violations of Sections 17(a)(1) and 

Case 1:22-cv-10889   Document 1   Filed 06/08/22   Page 3 of 37



4 
 

(3) of the Securities Act and Section 10(b) of the Exchange Act and Rules 10b-5(a) and (c) 

thereunder. 

10. By engaging in the conduct alleged herein, Capellini aided and abetted Bendelac’s 

violations of Sections 17(a)(1) and (3) of the Securities Act and Sections 9(a)(2) and 10(b) of the 

Exchange Act and Rules 10b-5(a) and (c) thereunder. 

11. The Commission seeks permanent injunctions against the defendants, 

disgorgement of the defendants’ ill-gotten gains from the unlawful conduct set forth in this 

Complaint, together with prejudgment interest pursuant to Section 21(d)(7) of the Exchange Act 

[15 U.S.C. §78u(d)(7)], 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)], an order barring the 

defendants from participating in any offering of a penny stock, pursuant to Section 20(g) of the 

Securities Act [15 U.S.C. § 77t(g)] and/or 21(d) of the Exchange Act [15 U.S.C. § 78u(d)], and 

such other relief as the Court may deem appropriate. 

JURISDICTION AND VENUE 

12. 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]. 

13. Venue lies in this Court pursuant to Section 22(a) of the Securities Act [15 U.S.C. 

§ 77v(a)] and Section 27 of the Exchange Act [15 U.S.C. § 78aa].  Certain of the acts, practices, 

transactions and courses of business alleged in this Complaint occurred within the District of 

Massachusetts, and were effected, directly or indirectly, by making use of means or 

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

example, during the Relevant Period, Trends solicited and received investments from two 

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5 
 

Massachusetts investors, and Rossetti resided in Massachusetts at various points when he offered 

and sold stock on behalf of Trends. 

DEFENDANTS 

14. Trends Investments Inc. (“Trends”) is a Delaware corporation with a principal 

place of business in Florida.  During the Relevant Period, Trends purported to be in the business 

of selling securities to investors.  Trends was not registered with the Commission as a broker-

dealer or in any other capacity.  

15. Clinton Greyling, age 47, is a resident of Florida and the President of Trends. 

16. Leslie Greyling, age 70, is a South African citizen, a resident of the United 

Kingdom and the father of Clinton Greyling.  Leslie Greyling was deported from the United 

States after he pled guilty to securities fraud in 1997. U.S. v. Greyling, et al., No. 6:96-CR-00035 

(M.D. Fla. 1996).  Although only Clinton Greyling had any formal title with Trends, Leslie 

Greyling exercised authority over Trends through Clinton Greyling and Rossetti, primarily 

behind the scenes from the United Kingdom.   

17. Brandon Rossetti, age 41, was a resident of Florida, Maine, and Massachusetts at 

various points during the Relevant Period. 

18. Roger Bendelac, age 65, is a resident of New York.  Between approximately 1980 

and 2006, Bendelac was employed in the securities industry by a series of broker-dealers, 

including for a period as the Chief Executive Officer of a registered broker-dealer.  Bendelac was 

a director of Trends from August 2017 to October 2019. 

19. Thomas Capellini, age 59, is a resident of New York.  Between approximately 

1994 and 2013, Capellini was employed in the securities industry, including for four years as a 

Compliance Manager at a registered investment adviser.  On September 30, 2020, Capellini 

Case 1:22-cv-10889   Document 1   Filed 06/08/22   Page 5 of 37



6 
 

appeared before officers of the Commission to provide sworn testimony and asserted his Fifth 

Amendment privilege against self-incrimination in response to all questions regarding Bendelac 

and Bendelac’s use of Capellini’s brokerage accounts to conduct coordinated trading in securities 

including Token. 

RELATED ENTITIES 

20. Alterola Biotech Inc. (“Alterola”) is a Nevada corporation with a purported 

principal place of business in the United Kingdom.  It was incorporated in July 2008 under the 

name Jedediah Resources Corp.  In July 2010, the company changed its name to Alterola 

Biotech Inc.  The company’s description of its business in periodic reports voluntarily filed with 

the Commission has evolved from mineral exploration, to medicinal chewing gum, to a drug for 

ethanol based intoxication, back to medicinal chewing gum, to the cannabis industry generally, 

and finally to therapeutic cannabinoids.  The company’s shares are quoted on OTC Link 

operated by OTC Markets Group, Inc.  Prior to December 2019, the company traded under the 

symbol ALTA.  In December 2019, the company changed its trading symbol from ALTA to 

ABTI.  During the Relevant Period, the stock of Alterola was a “penny stock” as set forth in 

Section 3(a)(51) of the Exchange Act and Rule 3a51-1 thereunder. 

21. Token Communities Ltd., (“Token”) is a Delaware corporation with a purported 

principal place of business in Florida.  It was incorporated in March 2014 under the name Pacific 

Media Group Enterprises, Inc., and purported to be in the mobile applications business.  In April 

2017, it changed its name to Extract Pharmaceuticals Inc. and purported to enter the medicinal 

chewing gum business.  In January 2018, it changed its name to Token Communities Ltd. in 

advance of a reverse merger with a private company, Token Communities PLC, which was 

completed in May 2018.  Thereafter, the company purported to enter the blockchain technology 

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7 
 

sector.  Beginning in September 2016, Token had a class of securities registered with the 

Commission under Exchange Act Section 12(g), and its shares were quoted on OTC Link 

operated by OTC Markets Group, Inc.  On October 14, 2020, pursuant to Section 12(j) of the 

Exchange Act, the Commission revoked Token’s securities registration, effective October 15, 

2020, after Token failed to file any periodic reports with the Commission since the period ended 

June 30, 2018. 

BACKGROUND 

22.  “Restricted stock” is stock of a publicly traded company (also known as an 

“issuer”) that is acquired from an issuer, or an affiliate of the issuer, in a private transaction that 

is not registered with the Commission.  Stock held by an issuer or affiliate of an issuer is 

restricted stock.  Absent an exemption under the federal securities laws and rules, restricted stock 

cannot legally be offered or sold to the public unless a securities registration statement has been 

filed with the Commission (for an offer) or is in effect (for a sale).  A registration statement 

contains important information about an issuer’s business operations, financial condition, results 

of operation, risk factors, and management.  It also should disclose any person or group who is 

the beneficial owner of more than 5% of the company’s securities.   

23. An “affiliate” of an issuer is a person or entity that, directly or indirectly through 

one or more intermediaries, controls, is controlled by, or is under common control with, such 

issuer (i.e. a control person).  “Control” means the power to direct management and policies of 

the company in question.  Typically, affiliates include officers, directors and controlling 

shareholders, but any person who is “under common control” with an issuer may also be an 

affiliate.  Absent registration, affiliates are only permitted to sell a small percentage of their stock 

according to SEC Rule 144 [17 C.F.R. 230.144].   

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8 
 

24. “Unrestricted stock” is stock that may legally be offered and sold in the public 

marketplace by a non-affiliate, without registration or restriction, ordinarily having previously 

been subject to a registration statement filed with the Commission.  The term “float” refers to an 

issuer’s purportedly unrestricted stock that is available for trading.  The purportedly unrestricted 

shares are also sometimes referred to as “free-trading” shares. 

25. A “transfer agent” is a company which, among other things, issues and cancels 

certificates of a company’s stock to reflect changes in ownership.  Many companies that have 

publicly traded securities use transfer agents to keep track of the individuals and entities that own 

their stocks.  Share certificates for restricted stock typically bear a “restrictive” legend stating 

that it may not be resold in the public marketplace unless the sale is exempt from the 

Commission’s registration requirements.  Transfer agents commonly remove restrictive legends 

from stock after receiving a legal opinion letter from an attorney attesting, among other things, 

that the owner of the stock is not an “affiliate” of the public company. 

26. DTC eligibility means that a public company’s securities may be deposited 

through the Depository Trust Company (DTC), a depository which holds securities and allows 

for securities to be traded electronically.  Most large U.S. broker-dealers and banks are DTC 

participants, meaning that they deposit and hold securities at DTC.  DTC eligibility is a 

prerequisite to book-entry transfer of securities, which facilitates the exchange of shares by 

broker-dealers in the secondary market.  DTC eligibility enables the deposit of securities in a 

brokerage account so that they may be sold in the secondary market in bulk. 

27. The Over-The-Counter Securities Market (“OTC Markets”) is an inter-dealer 

quotation and reporting service based in New York through which certain stocks are available for 

trading and are publicly purchased and sold through brokered orders. 

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9 
 

28. A “shell company” is a legal entity that lacks meaningful assets or business 

operations.  In a scheme to profit from such companies without actually commencing business 

operations, individuals sometimes file materially false registration statements and other filings to 

make company shares appear to be eligible for public trading and quotation.  As a matter of law, 

acquisition of “free trading” shares by an affiliate means that those free trading shares become 

restricted shares.  However, when such transactions are designed to allow the buyer to disguise 

its affiliate status, the buyer may have the opportunity to control both the company and its 

purportedly “free trading” shares, effectively enabling company insiders to profit by illegally 

dumping shares they control.  Accordingly, such “clean” shells, as they are called, are often 

bought or sold for substantial sums by individuals who seek to skirt the registration requirements 

of the securities laws.   

TRENDS’ ALTEROLA INVESTMENT SCHEME 

29. In or around February 2017, the shell company Alterola was for sale for 

approximately $300,000.  The seller of Alterola offered potential buyers the opportunity to 

control all or substantially all of the shares of Alterola, including the purportedly “free trading” 

shares of Alterola that were purportedly held by independent investors.  

30. Leslie Greyling identified Alterola as a company for Trends to acquire, but 

Trends lacked the funds to purchase the Alterola shell on its own.  To get the money to buy the 

Alterola shell, the Greylings asked Rossetti to solicit investors to buy shares of Alterola from 

Trends, knowing that Trends did not own any such shares.   

31. Clinton Greyling created a document to memorialize the scheme and shared that 

document with Rossetti.  Trends needed to raise $500,000 to purchase Alterola at a cost of 

$300,000, with Rossetti to receive 40% of the funds raised, $200,000.  Instead of raising money 

Case 1:22-cv-10889   Document 1   Filed 06/08/22   Page 9 of 37



10 
 

to buy the Alterola shell transparently, the Greylings and Rossetti schemed to sell shares of 

Alterola to investors in private transactions by falsely claiming in stock purchase agreements that 

Trends already owned Alterola shares and could deliver them “simultaneously” with the 

investors’ payments. 

32. Much of the information sent to investors by Rossetti was created or compiled by 

Leslie Greyling, and both Clinton Greyling and Rossetti regularly provided updates to Leslie 

Greyling about their dealings with investors and potential investors. 

33. The success of the scheme depended, in part, on maintaining the trust of Trends’ 

existing investors and persuading them that Trends was managing their money profitably.  

Accordingly, the Greylings and Rossetti acted to create the false appearance that investors’ prior 

securities purchases from Trends were good investments so that investors would be more likely 

to buy more securities from Trends, or at least not complain to or about Trends.   

34. The securities trading conducted by Roger Bendelac played an important role in 

this aspect of the scheme.  Bendelac was an experienced professional in the securities industry 

and used his skills in furtherance of the scheme.  Bendelac utilized a brokerage account at 

Broker-Dealer A, where he had a personal connection to an employee, to deposit and trade 

various securities in coordination with Clinton Greyling.  Bendelac’s connection at Broker-

Dealer A was responsible for supervising Bendelac’s account, which was in the name of 

Aleutian Equity Holdings LLC (“Aleutian”), an entity Bendelac controlled.  As Bendelac 

described to Clinton Greyling in an email, he had “zero scrutiny” on the deposit of share 

certificates.  Bendelac also had access to brokerage accounts held by (1) a relative and (2) his 

brother-in-law, Thomas Capellini, which Bendelac used to place trades. 

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11 
 

35. Some of the investors whom the defendants viewed as prospective purchasers of 

Alterola stock had made previous purchases from Trends of stock in an issuer named Millennium 

Energy Corp. (“Millennium”).  Millennium stock was not actively trading—there were zero 

reported market trades in Millennium between December 14, 2016 and February 1, 2017.  On 

February 3, 2017, the only reported trades for Millennium were orders less than two minutes 

apart for 100 shares of Millennium at $4.50 per share ($0.50 per share higher than the reported 

closing price on February 2, 2017, a day with zero trading).  This trade was orchestrated by 

Bendelac, who placed matching buy and sell orders by logging into Capellini’s account and into 

Bendelac’s relative’s account from an Internet Protocol address (an identifying number 

associated with a particular account with an internet service provider) registered to Bendelac: 

 Capellini Sell Order Relative’s Buy Order Execution 
Time Qty Price Time Qty Price Time Qty Price 

02:17:19 (100) $4.50 02:19:15 100 $4.50 02:20:58 100 $4.50 
 

36. The matching buy and sell orders placed by Bendelac manipulated Millennium’s 

reported stock price and created the false appearance of a bona fide market trade.  Following this 

trade, there were no trades in Millennium until April 3, 2017.  As a result, the reported market 

price of Millennium remained at $4.50 per share during that time period.   

37. Trends used the manipulated Millennium price in pitching the Alterola investment 

to investors.  For example, on February 21, 2017, Rossetti forwarded to an investor to whom he 

was pitching an Alterola investment a “portfolio report” sent by Leslie Greyling, which 

summarized that investor’s existing investments through Trends.  Those prior investments 

included 475,000 shares of Millennium, purchased for $0.63 per share and 100,000 shares of 

Millennium purchased for $0.50 per share.  The February 2017 “portfolio report” valued all of 

that investor’s Millennium shares at $4.50 per share, with a total value of $2,475,000.  Rossetti’s 

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email also contained a draft stock purchase agreement for the sale to that investor of 200,000 

“FREE TRADING” shares of Alterola, purportedly owned by Trends, for $200,000, with the 

shares to be transferred “[s]imultaneously with the transfer of the [p]ayment.” Although this 

investor did not buy the Alterola shares as Rossetti proposed, Rossetti asked the Greylings to 

create a similar “statement” for another previous investor to whom he proposed selling 1.2 

million shares of Alterola.  Rossetti implored the Greylings to “make this look sexy he will go, 

he is giving me a final decision after he reads the proposal / statement.” 

38. In March and April 2017, Trends obtained approximately $500,000 from seven 

investors who were promised that they were purchasing shares of Alterola directly from Trends.  

39. Rossetti sent investors content about Alterola created by the Greylings, and added 

various misrepresentations of his own.  For example, on March 6, 2017, Rossetti wrote to one 

investor that “[m]y company Trends Investments is merging a cannabis company into ALTA 

[Alterola].  The stock is starting to trade today . . . The Stock is Trading at 3 dollars right now.”  

In reality, Trends did not own or control Alterola and lacked the ability to merge a private 

company into it, and Alterola’s stock was not actively trading.  Alterola stock did not trade at all 

on March 6, had last traded just 100 shares on March 3, had not traded at all since February 24 

before that, and had a recent history of similarly negligible and infrequent trading volume (or 

number of shares traded per day).  Rossetti knew at the time that Alterola stock was not trading 

in any meaningful way:  Three days later, on March 9, in an email to Leslie Greyling, he asked, 

“When will alta [Alterola] start trading?” 

40. In stock purchase agreements sent to investors, Trends falsely represented that it 

owned at least the number of shares of Alterola stock that each investor was purchasing, that the 

investors would receive “free trading” shares, and that Trends could deliver those shares 

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“simultaneously” with the investors’ payments.  The stock purchase agreements for several 

investors also falsely represented that Alterola’s common stock was registered with the 

Commission under Section 12(g) of the Exchange Act and that, since the date of such 

registration, Alterola had timely filed all required reports with the Commission.  Such 

registration with the Commission means that a company has undertaken the obligation to make 

required periodic filings with the Commission which contain important information about its 

business and audited financial statements.  In reality, Alterola’s stock was never registered under 

Section 12(g); it was therefore not required to file any periodic reports with the Commission, and 

Alterola had not made a voluntary filing of any quarterly or annual report with the Commission 

since May 2016 and December 2015, respectively. 

THE SCHEME EXPANDED FROM ALTEROLA TO TOKEN 

41. By the end of March 2017, the opportunity to purchase the Alterola shell had 

fallen through and the Greylings were searching for a different shell company to buy.  

Meanwhile, Trends continued to accept new investor funds and retain previously invested funds 

from Alterola investors and continued to mislead those investors to believe that they would 

receive Alterola share certificates.   

42. In early April 2017, the Greylings reached an agreement to acquire a different 

shell company, Pacific Media Group Enterprises, Inc. (“Pacific Media”), which purported to be 

in the business of developing mobile applications.  The Greylings orchestrated the change of 

control of Pacific Media by arranging for the transfer of large blocks of stock of Pacific Media 

from various entities controlled by the seller to various entities controlled by Leslie Greyling, 

either directly or indirectly through associates, including Trends and Aleutian (Bendelac’s 

entity).  Bendelac did not pay for Aleutian’s shares; instead, Trends wired money to the seller’s 

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attorney to pay for Aleutian’s shares using funds that Trends had received from investors.  The 

company changed its name to Extract Pharmaceuticals Inc. (“Extract”).  Leslie Greyling installed 

an associate (whom he controlled) as the CEO of Extract, and Extract purported to change its 

business, claiming it was developing new technology for delivering pharmaceuticals, including 

cannabis oil, via chewing gum. 

43. Trends marketed Extract to investors as a cannabis chewing gum business from 

April 2017 until approximately January 2018.  During that period, Trends received 

approximately $500,000 from investors who purchased shares of the purported chewing gum 

business (whether in the name of Alterola or Extract).  In January 2018, Extract changed its 

name to Token Communities Ltd. and purported to enter the blockchain technology sector.   

44. In or around March 2018, the Greylings finally acquired a large portion of the 

Alterola shell, including a block of purportedly unrestricted or “free-trading” shares.  Although 

these share certificates may have appeared to be unrestricted in that they did not bear a restrictive 

legend, the share certificates were restricted from public sale because the Greylings were 

affiliates of Alterola.  Despite having promised Alterola investors “free-trading” shares a year 

earlier, the Greylings did not distribute these shares to investors.  

45. Thereafter, Trends aggressively marketed both Token and Alterola to new and 

existing investors.  From January 2018 through July 2019, investors paid Trends an additional 

$1.3 million in return for Trends’ promises of shares of Token and/or Alterola. 

46. Rossetti and Clinton Greyling repeatedly misled investors about when they would 

receive their Token and Alterola share certificates, telling them without basis that they would 

receive their shares soon or falsely stating that the certificates were currently being processed by 

the transfer agent or were already in the mail.  For example, from June to August in 2019, 

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Rossetti sent a series of text messages to one investor promising that the investor’s share 

certificates would be issued, sent, or delivered: “Friday around noon” (June 26); “1st thing in the 

morning” (July 2); “this week” (July 8); “in the morning” (July 16); “tomorrow around one 

o’clock” (“July 17); “this week” (July 22); and “this week for sure” (August 1).  During this 

time, Rossetti continued to solicit additional investments from the investor, whose share 

certificates in Token and Alterola were not issued until mid-September 2019 and January 2020, 

respectively. 

47. After some investors had received physical share certificates of Token, Rossetti 

and Clinton Greyling repeatedly misled investors about when Token would be current in its 

filings with the Commission. This was a critical point for investors, since it would help investors 

to deposit their shares with a broker-dealer and thereafter sell their shares in public securities 

markets, since broker-dealers often will not accept the deposit of shares of an issuer that is not 

current in its filings with the Commission.  In stringing the investors along, Rossetti and Clinton 

Greyling repeatedly directed investors to various broker-dealers, knowing it was unlikely that the 

broker-dealers would accept deposit of the Token shares under the circumstances. 

48. The scheme involved varied acts of deception and misrepresentations to investors, 

all designed to keep money coming in, quiet investor concerns, and avoid detection.   

49. For example, Rossetti described himself to investors in emails and text messages 

as their “broker” or “wealth manager” and referred to the investors as his “clients.”  Rossetti also 

described his relationship to investors in ways that suggested he was acting in their best interests.  

For example, Rossetti texted one investor that it was Rossetti’s “moral obligation to bring you 

these deals . . . .”  Rossetti emailed to another investor, “I work for you now.  At Trends 

Investments, we understand the trust and responsibility our clients place in our hands.”  To 

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another investor, Rossetti wrote, “I will be managing your account . . . . I will be in the office 

premarket with my traders . . . . We can always protect your downside with stop loss orders . . . . 

I look forward to making money with you.”   These statements were misleading in that Rossetti 

did not disclose that he was receiving a 40% cut of their investments or that he was not registered 

as a broker-dealer, or associated with a registered broker-dealer. 

50. An email introduction for Trends’ offer of Token shares, drafted by the Greylings 

and sent by Rossetti to potential investors, contained the misleading statement that Token had 

“over 50 institutional shareholders such as AT&T Mobility, Bank of America, G[E] Capital, 

Comcast to name a few.”  This was misleading in that it suggested that these well-known 

companies had made a decision to become investors in Token.  In reality, these entities had 

shares of Token because they had been creditors of its predecessor entity when that company 

went through bankruptcy proceedings.  The Greylings and Rossetti were informed of this in a 

summary document created by the attorney representing the seller of the shell company, Pacific 

Media.  As the summary document explained, these well-known companies did not even take 

possession of their shares as they “failed to respond to transfer agent requests for tax numbers 

and their stock certificates are being held until they comply.” 

51. At various points during the scheme, Rossetti and the Greylings offered investors 

“free” shares of Alterola as an inducement to invest in Token, or shares of either company as a 

bonus to quell various investor concerns about the status of their investments.  For example, on 

April 7, 2018, Rossetti wrote an email to Clinton Greyling, which Clinton Greyling forwarded to 

Leslie Greyling, listing investors to whom Trends owed shares of either Alterola or Token.  One 

investor was described as having invested $10,000 and, nearly a year later, still being owed 

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400,000 shares of Token.  Rossetti noted that “this guy has been a pain in my ass bitching to get 

him off our back he was compensated” by promising him additional shares. 

52. Rossetti promised one investor that for every share of Token he purchased, he 

would receive some number of undescribed “Community Coins,” which did not exist. 

53. Rossetti often represented to investors that the price at which Trends was offering 

them shares was a substantial discount to the market price or to some baseless prediction about 

what a market price would be.  For example, in an email sent to an investor in April 2018, 

Rossetti stated that Token “is opening on the OTC Markets @ $1.45 per share.  I put aside a 

block of 2 million shares @ 50 cents.”  In reality, there was no active market for shares of 

Alterola or Token, and Rossetti had no basis for suggesting that an investor could sell their 

shares for those prices. 

54. Investors who sent money to Trends for shares of Alterola and/or Token 

ultimately received little, if anything, of value.  Most Alterola investors who belatedly received 

shares received only restricted shares that they would generally be unable to deposit with a 

broker-dealer or trade without, at a minimum, obtaining an attorney opinion letter to support the 

removal of restrictive legends.  Most Token investors who belatedly received shares were unable 

to deposit their shares with any broker-dealer.  Although Token was briefly current in its filings 

with the Commission for several months in 2018, its ability to stay current was entirely 

dependent on the Greylings paying the associated expenses (such as for the preparation and filing 

of periodic reports).  Token did not timely file its annual report for the period ended June 30, 

2018, which was not filed until March 2019, and then stopped making periodic filings with the 

Commission entirely.  In October 2020, the Commission issued an order revoking the 

registration of each class of Token’s securities pursuant to Exchange Act Section 12(j). 

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55. In total from 2017 to at least 2020, the defendants defrauded more than 30 

investors out of approximately $2.3 million which was wired to Trends and then further divided 

among the Greylings and Rossetti. 

TRADING TO FACILITATE THE SCHEME 

56. The scheme also involved sham trading in Alterola and Token stock, which 

created a false appearance of market activity and price to induce investments, quiet investor 

concerns, and avoid detection.   

57. Clinton Greyling’s primary business, aside from this scheme, had been brokering 

the purchase and sale of shell companies between shell company buyers and shell company 

sellers in exchange for a fee.  For several years, Bendelac had regularly assisted Clinton 

Greyling’s shell company brokering business by receiving small blocks of shares of a shell 

company as arranged by Clinton Greyling, depositing the shares in his brokerage account and 

then placing a trade, in order to demonstrate to a potential buyer that the issuer’s stock could be 

traded electronically.   

58. On multiple occasions, Clinton Greyling purchased shares from Bendelac in the 

securities market in a coordinated manner to demonstrate to a prospective buyer of a shell 

company that the stock was tradeable.  The purchaser would often request that a market trade be 

made at a certain price, and Clinton Greyling would coordinate a single small trade with 

Bendelac at the requested price.  

59. To facilitate the Alterola and Token scheme by inducing further investments, 

Clinton Greyling, Brandon Rossetti, and Bendelac placed orders to buy or sell Alterola and/or 

Token stock, which created the false appearance of active trading.  Clinton Greyling and 

Brandon Rossetti traded in both Alterola and Token stock, and all three individuals traded in 

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Token stock.  These misleading data points were then used by Rossetti to make 

misrepresentations to private investors to induce them to invest again, or to quiet their concerns.  

This trading went well beyond the practice described above whereby Clinton Greyling would 

coordinate with Bendelac to create one small market trade at a desired price for the purpose of 

demonstrating to a shell buyer that the stock was trading.  The coordinated trades in the Alterola 

and Token scheme were designed to induce the purchase of securities by others. 

60. Between November 2018 and May 2019, Bendelac placed a series of trades in 

Token stock in coordination with Clinton Greyling, often after Rossetti asked Clinton Greyling 

to arrange for a trade to help Rossetti sell Token stock to investors in private transactions on 

behalf of Trends.  On some occasions, Bendelac sold Token stock in his Aleutian account which 

Clinton Greyling or Rossetti purchased in open-market trades.  On other occasions, Bendelac 

sold Token stock in his Aleutian account and also purchased Token stock in Capellini’s account 

or in Bendelac’s relative’s account in open-market trades.  These manipulative trades are 

summarized in Exhibit A, attached hereto. 

61. For example, on November 7, 2018, Bendelac’s entity, Aleutian, sold 500 shares 

of Token at $1.60 per share.  Clinton Greyling purchased 100 shares of Token at $1.60 per share, 

with the stock closing at $1.60 per share, up from $1.01 at open.  The total reported market 

volume of shares traded that day was 601. 

62. As another example, on February 19, 2019, Clinton Greyling and Bendelac placed 

coordinated trades in order to create the false appearance of active trading and to manipulate the 

price of Token:  Bendelac through Aleutian sold 100 shares at $2.05 per share; Greyling bought 

100 shares at $2.00 per share and 100 shares at $9.95; and Bendelac bought 100 shares at $2.05 

per share in Capellini’s account.  However, there was a market transaction between unaffiliated 

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parties of 3,350 shares of Token at a price of $0.101 per share which dramatically lowered 

Token’s reported price, which closed at $0.101 per share.  Bendelac and Clinton Greyling had 

multiple phone calls on the evening of February 19, 2019. 

63. The next day, on February 20, 2019, Bendelac sold 200 shares of Token at $2.00 

per share in his Aleutian account and purchased 100 shares of Token in his relative’s account at 

$2.25 per share.  The total market volume was 400 shares traded that day, and the price closed at 

$2.00 per share, up from the prior day’s reported closing price of $0.101 per share.   

64. The Greylings and Rossetti monitored the trading activity in Token stock and 

used this information in connection with the offer and sale of Token stock to investors.  That 

same day, February 20, 2019, Leslie Greyling sent an email to Clinton Greyling and Rossetti 

noting that Token’s last trade was $2.25 per share (the trade orchestrated by Bendelac described 

in paragraph 66) and providing a link to a website reflecting the same.   

65. On various dates through April and May 2019, Bendelac sold small amounts of 

Aleutian’s shares of Token, with Greyling, Rossetti, or Bendelac (through Capellini’s account or 

Bendelac’s relative’s account) buying small amounts.  These trades, which are summarized in 

Exhibit A, comprised a large portion of the reported market activity. 

66. Starting in June 2019, the volume and frequency of Bendelac’s Token trading 

increased, and some of it involved placing coordinated buy and sell orders using his Aleutian 

account and Capellini’s account.  Bendelac’s trades often comprised all or nearly all of the 

reported total market volume of Token shares traded, creating the false appearance of market 

activity and artificially inflating the reported prices.  For example: 

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67. The purpose of the foregoing trading was to induce investment by others in Token 

shares, including (1) private investors to whom Trends was offering Token stock and (2) others 

who might purchase stock sold by Bendelac in the public marketplace.  In June 2019, Rossetti 

was actively soliciting investors to purchase Token stock from Trends.  For example, Rossetti 

took advantage of the manipulative trading in Token to obtain investments from Investor A.  On 

June 12, Rossetti described Token shares to Investor A as “selling like hotcakes.”  Between June 

17 and 24, 2019, Investor A wired $58,000 to Trends for a combined 116,000 shares of Token 

and some “free” Alterola shares.  Rossetti did not tell Investor A that the market sales of Token 

shares were orchestrated by the people who controlled Trends and Token. 

68. After receiving these investments from Investor A, Rossetti sought to create and 

sustain Investor A’s belief that these were profitable investments and continued to solicit him for 

additional investments.  On June 25, 2019 at 10:16:14 AM, Rossetti placed an order to purchase 

100 shares (the minimum size of a trade that a broker has to report to the market) at $4.80 per 

share.  (Aleutian was the principal seller of Token stock in the market that day.)  The stock had 

closed the previous day at $4.26 per share.  The trade executed within seconds.  One minute 

later, Rossetti sent a text message to Investor A with a screen shot of information about Token 

and reflecting a $4.80 per share price and a daily increase of $0.54 per share (12.68%).  Rossetti 

then sent a text to Investor A stating, “And you’re [sic] 86000 shares your profitable big time.” 

Date Aleutian Sale Quantity Aleutian Sale Proceeds Capellini Buy Quantity Capellini Buy Cost Total Market Volume

6/11/2019 (400)                                     1,815$                                  500                                       (2,255)$                                 500                                       

6/12/2019 (1,000)                                  4,262$                                  1,000                                   (4,262)$                                 1,000                                   

6/13/2019 (1,513)                                  6,454$                                  1,500                                   (6,400)$                                 2,013                                   

6/14/2019 (2,000)                                  8,500$                                  2,000                                   (8,500)$                                 2,000                                   

6/17/2019 (1,000)                                  4,250$                                  1,100                                   (4,675)$                                 1,200                                   

6/19/2019 (2,000)                                  8,519$                                  2,000                                   (8,519)$                                 2,000                                   

9/5/2019 (8,500)                                  17,166$                                8,100                                   (16,318)$                              9,175                                   

9/9/2019 (2,000)                                  5,073$                                  2,000                                   (5,068)$                                 2,400                                   

10/18/2019 (2,500)                                  6,325$                                  2,500                                   (6,325)$                                 2,500                                   

 Aleutian Equity and Capellini Trading in TKCM (Selected Days) 

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69. After receiving the above text from Rossetti, Investor A then asked Rossetti, 

“What is going on with ALTA [Alterola]?  It is at $0.20.”  At 10:36 AM, Rossetti purchased 100 

shares of Alterola at $0.55 per share.  At 11:10 AM Rossetti responded to Investor A, “Alta 

[Alterola] is gonna bounce with the news announcements that come out next week.  Last trader 

[sic] saw is around 50[-]60 cents.” 

BENDELAC PROVIDED SUBSTANTIAL ASSISTANCE IN THE FRAUD 

70. Bendelac knew or was reckless in not knowing that his coordinated trading in 

shares of Token was providing substantial assistance to the fraud scheme.   

71. Bendelac knowingly engaged in the regular practice of helping Clinton Greyling’s 

shell company business by placing small trades before the closing of the transaction at prices 

requested by the shell purchasers.   

72. Bendelac’s securities deposits and trading at Broker-Dealer A would have been 

deemed suspicious by a broker-dealer conducting a reasonable inquiry into the facts and 

circumstances surrounding his offer and sale of securities, including Token.  Bendelac’s 

activities using the Aleutian brokerage account frequently presented numerous red flags, 

including but not limited to a pattern of depositing physical share certificates in thinly-traded 

low-priced securities (including companies that had undergone a recent name change), selling 

the shares, and wiring out the proceeds. 

73. Bendelac took advantage of the lack of scrutiny that Broker-Dealer A applied to 

his deposits of stock and subsequent trading in the Aleutian brokerage account.  As noted above, 

Bendelac had a personal connection to an employee at Broker-Dealer A who oversaw Bendelac’s 

trading through Broker-Dealer A, and Bendelac knew that this meant there would be little or no 

meaningful compliance review of his securities deposits or trading activity. 

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74. Bendelac expressed in an email to Clinton Greyling that he preferred to receive 

physical share certificates (sometimes referred to as “certs”) to deposit with Broker-Dealer A, 

rather than to deposit shares in electronic form through the process known as 

Deposit/Withdrawal at Custodian, or DWAC.  Bendelac noted, “[t]he broker does extra scrutiny 

on DWAC.  I have zero scrutiny on CERTS.” 

75. To deposit shares with a broker-dealer, the owner of the security may be required 

to provide documentation reflecting how the security owner acquired the shares, and may also be 

required to submit documentation showing that he or she paid for the shares.  However, 

Bendelac understood that Broker-Dealer A would not conduct any meaningful compliance 

scrutiny of his deposits, and suggested to Clinton Greyling that they could document the 

transfers to Aleutian with phony stock purchase agreements without Bendelac needing to 

actually pay for the stock.  Bendelac wrote to Clinton Greyling, “I need to make no payments as 

I need no proof of payments.  Just the Certificate.  You can make the contract with a payable 

due.  No need to exchange funds for me to put it in.” 

76. Bendelac knew that the Token deal was not part of Clinton Greyling’s shell 

company business and that the Greylings had acquired ownership and control of Token.  

Bendelac partnered with the Greylings to acquire ownership and control of Token (then named 

Pacific Media), and his entity, Aleutian, received a block of shares paid for by Trends using 

money obtained from investors.  The purpose of using multiple entities to hold shares was to 

disguise the common ownership and control so that the “float” of purportedly unrestricted shares 

would appear to be held by non-affiliates. 

77. Bendelac knew or was reckless in not knowing, at least as of June 2018, that the 

Greylings were selling Token shares to private investors.  Bendelac was a director of Trends   

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and he participated in the distribution of shares to some Token investors.  Bendelac signed a 

board resolution on behalf of Aleutian resolving that Aleutian would grant shares to seven 

Trends investors who had invested in Token or otherwise had been promised shares of Token by 

Trends, and provided documents to the transfer agent to facilitate the transactions. 

78. Bendelac prepared for substantial coordinated sham trading and took deceptive 

actions to make that possible.  In April 2018, the Greylings and Bendelac arranged for a smaller 

share certificate of 300,000 Token shares to be carved out of Aleutian’s larger block of 

5,400,000 shares.  In September 2018, Bendelac deposited into Aleutian’s account at Broker-

Dealer A the share certificate for 300,000 shares of Token.  In doing so, Bendelac submitted to 

Broker-Dealer A a letter from an attorney which falsely stated that the shares were “purchased in 

a private transaction for a cost basis of 25 cents per share.”  Bendelac also submitted an opinion 

letter from the same attorney which stated that Aleutian was not an affiliate of Token, which 

Bendelac knew to be false. 

79. In April 2019, just prior to the period of time in which Bendelac conducted his 

most active trading in Token, Leslie Greyling included Bendelac as a recipient of two emails 

which he also sent to Clinton Greyling, Rossetti, and other associates which referenced there 

being news about Token on a financial news website and directed the recipients to a website he 

described as “FREE REAL TIME QUOTES SHOWS PRICE PRESS RELEASE AND 8K” 

concerning Token’s stock.  

80. In April 2020, when Bendelac was asked about his trading in an interview with 

the Commission staff, Bendelac made statements to the staff which were demonstrably false and, 

in some cases, which were contradicted by his own admissions in an interview with law 

enforcement agents the next day.  For example, Bendelac told the Commission staff that he did 

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not have access to Capellini’s brokerage account and claimed it was a coincidence that Capellini 

bought shares of Token from Aleutian in open market trades.  The next day, Bendelac admitted 

to law enforcement agents that Capellini had given Bendelac access to his account.  In a similar 

vein, when Bendelac spoke to the Commission staff, he acknowledged that he had access to his 

relative’s brokerage account, but claimed that his relative placed all of the relative’s own orders.  

When he spoke with law enforcement agents the next day, Bendelac admitted, in sum and 

substance, that Bendelac conducted the trading in his relative’s account. 

81. In total, Bendelac received approximately $97,000 from his sales of Token stock 

in the Aleutian brokerage account.  Approximately $62,000 of these proceeds were from 

purchases made through Capellini’s account, funded by Capellini and at least partially 

reimbursed by Bendelac, as described below. 

CAPELLINI PROVIDED SUBSTANTIAL ASSISTANCE IN THE FRAUD 

82. Capellini knowingly or recklessly provided substantial assistance to Bendelac’s 

fraudulent securities trading.  Capellini initially provided Bendelac with access to Capellini’s 

brokerage account at Broker-Dealer B in 2017 and 2018.  Bendelac used Capellini’s account to 

conduct coordinated trades at Clinton Greyling’s instruction, including, for example, the trading 

in Millennium described in paragraph 35. 

83. In 2019, Capellini’s involvement expanded beyond providing Bendelac with 

access to his brokerage account.  Capellini undertook additional activity to assist Bendelac in 

May and June of 2019 to fund Bendelac’s trading and to receive reimbursement from Bendelac 

through an entity Capellini controlled. 

84. On May 21, 2019, Capellini opened up a second brokerage account with Broker-

Dealer B, to which he gave Bendelac access.   

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85. On June 5, 2019, Capellini funded the new brokerage account with a transfer of 

$100,000.  Bendelac used these funds to purchase stock through Capellini’s accounts, while 

Bendelac sold the shares through either the Aleutian account or Bendelac’s relative’s account.   

86. On June 13, 2019, Capellini opened two bank accounts at a bank based in the U.S. 

in the name of an entity Capellini controlled.   

87. Between June and September 2019, Capellini received in one of his entity’s new 

bank accounts four payments from three Bendelac-controlled entities totaling $36,450 and 

comprising all of the incoming funds in the bank accounts during this period (excluding two 

$100 deposits to open the accounts). 

FIRST CLAIM FOR RELIEF 
FRAUD IN THE OFFER OR SALE OF SECURITIES  

 (Violations of Section 17(a) of the Securities Act by Trends, Rossetti, Clinton Greyling, and 
Leslie Greyling) 

 
88. Paragraphs 1 through 87 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

89. During the Relevant Period, the shares of stock of Alterola and Token were 

securities under Section 2(a)(1) of the Securities Act [15 U.S.C. § 77b(a)(1)]. 

90. By reason of the conduct described above, Trends, Rossetti, Clinton Greyling, and 

Leslie Greyling, directly or indirectly, in connection with the offer or sale of securities of 

Alterola and Token, by the use of the means or instrumentalities of interstate commerce or of the 

mails, directly or indirectly, acting intentionally, knowingly, recklessly, or negligently, 

(i) employed devices, schemes, or artifices to defraud; (ii) obtained money or property by means 

of any untrue statement of a material fact or any omission to state a material fact necessary in 

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

not misleading; and (iii) engaged in transactions, practices, or courses of business which 

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27 
 

operated or would operate as a fraud or deceit upon any persons, including purchasers or sellers 

of the securities.  

91. By reason of the conduct described above, Trends, Rossetti, Clinton Greyling, and 

Leslie Greyling violated, and will continue to violate unless enjoined, Securities Act Section 

17(a) [15 U.S.C. § 77q(a)]. 

 
SECOND CLAIM FOR RELIEF 

FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES  
(Violations of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder by Trends, 

Rossetti, Clinton Greyling, and Leslie Greyling) 
 

92. Paragraphs 1 through 87 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

93. During the Relevant Period, the shares of stock of Alterola and Token were 

securities under Section 3(a)(1) of the Exchange Act [15 U.S.C. § 78c(a)(10)].  

94. By reason of the conduct described above, Trends, Rossetti, Clinton Greyling, and 

Leslie Greyling, directly or indirectly, in connection with the purchase or sale of securities, by 

the use of the means or instrumentalities of interstate commerce or of the mails, or of any facility 

of any national securities exchange, intentionally, knowingly or recklessly, (i) employed devices, 

schemes, or artifices to defraud; (ii) made untrue statements of material fact or omitted to state 

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

they were made, not misleading; and (iii) engaged in acts, practices, or courses of business which 

operated or would operate as a fraud or deceit upon any persons, including purchasers or sellers 

of the securities. 

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95. By reason of the conduct described above, Trends, Rossetti, Clinton Greyling, and 

Leslie Greyling violated, and will continue to violate unless enjoined, Exchange Act Section 

10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5 [17 C.F.R. § 240.10b-5] thereunder. 

THIRD CLAIM FOR RELIEF 
 FRAUD IN THE OFFER OR SALE OF SECURITIES  

(Violations of Sections 17(a)(1) and (3) of the Securities Act by Bendelac) 
 

96. Paragraphs 1 through 87 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

97. During the Relevant Period, the shares of stock of Alterola and Token were 

securities under Section 2(a)(1) of the Securities Act [15 U.S.C. § 77b(a)(1)]. 

98. By reason of the conduct described above, Bendelac, directly or indirectly, in 

connection with the offer or sale of securities, by the use of the means or instrumentalities of 

interstate commerce or of the mails, directly or indirectly, acting intentionally, knowingly, 

recklessly, or negligently, (i) employed devices, schemes, or artifices to defraud; and (ii) 

engaged in transactions, practices, or courses of business which operated or would operate as a 

fraud or deceit upon any persons, including purchasers or sellers of the securities.   

99. By reason of the conduct described above, Bendelac violated, and will continue to 

violate unless enjoined, Securities Act Sections 17(a)(1) and (3) [15 U.S.C. § 77q(a)(1) and (3)]. 

FOURTH CLAIM FOR RELIEF 
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES  

(Violations of Section 10(b) of the Exchange Act and Rules 10b-5(a) and (c) thereunder by 
Bendelac) 

 
100. Paragraphs 1 through 87 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

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29 
 

101. During the Relevant Period, the shares of stock of Alterola and Token were 

securities under Section 3(a)(1) of the Exchange Act [15 U.S.C. § 78c(a)(10)].  

102. By reason of the conduct described above, Bendelac, directly or indirectly, in 

connection with the purchase or sale of securities, by the use of the means or instrumentalities of 

interstate commerce or of the mails, or of any facility of any national securities exchange, 

intentionally, knowingly or recklessly, (i) employed devices, schemes, or artifices to defraud; 

and (ii) engaged in acts, practices, or courses of business which operated or would operate as a 

fraud or deceit upon any persons, including purchasers or sellers of the securities. 

103. By reason of the conduct described above, Bendelac violated, and will continue to 

violate unless enjoined, Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and Rules 10b-5(a) and 

(c) [17 C.F.R. § 240.10b-5(a) and (c)] thereunder. 

FIFTH CLAIM FOR RELIEF 
MARKET MANIPULATION  

(Violations of Section 9(a)(2) of the Exchange Act by Bendelac) 
 

104. Paragraphs 1 through 87 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

105. During the Relevant Period, the shares of stock of Token were securities under 

Section 3(a)(1) of the Exchange Act [15 U.S.C. § 78c(a)(10)].  

106. Section 9(a)(2) of the Exchange Act [15 U.S.C. §78i(a)(2)] makes it unlawful for 

any person, directly or indirectly, by the use of the mails or any means or instrumentality of 

interstate commerce, or of any facility of any national securities exchange, to effect a series of 

transactions in a security creating actual or apparent active trading in such security, or raising or 

depressing the price of such security, for the purpose of inducing the purchase or sale of such 

security by others. 

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30 
 

107. By reason of the conduct described above, Bendelac violated, and will continue to 

violate unless enjoined, Exchange Act Section 9(a)(2) [15 U.S.C. § 78i(a)(2)]. 

SIXTH CLAIM FOR RELIEF 
UNREGISTERED BROKER  

(Violations of Section 15(a)(1) of the Exchange Act by Rossetti) 
 

108. Paragraphs 1 through 87 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

109. By engaging in the conduct described above, Rossetti. (a) engaged in the business 

of effecting transactions in securities for the account of others; and (b) directly or indirectly, 

made use of the mails or the means or instrumentalities of interstate commerce to effect 

transactions in, or to induce or attempt to induce the purchase or sale of, securities without being 

registered as a broker or dealer with the Commission or associated with a broker or dealer 

registered with the Commission. 

110. By reason of the conduct described above, Rossetti violated, and will continue to 

violate unless enjoined, Section 15(a)(1) of the Exchange Act [15 U.S.C. §78o(a)(1)]. 

SEVENTH CLAIM FOR RELIEF 
AIDING AND ABETTING 

(Bendelac’s Aiding and Abetting Violations of Sections 17(a)(1) and (3) of the Securities 
Act and Section 10(b) of the Exchange Act and Rules 10b-5(a) and (c) by Trends, Rossetti, 

Clinton Greyling, and Leslie Greyling) 
 

111. Paragraphs 1 through 87 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

112. During the Relevant Period, the shares of stock of Alterola and Token were 

securities under Section 2(a)(1) of the Securities Act [15 U.S.C. § 77b(a)(1)] and Section 3(a)(1) 

of the Exchange Act [15 U.S.C. § 78c(a)(10)].  

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31 
 

113. By reason of the conduct described above, Trends, Rossetti, Clinton Greyling, and 

Leslie Greyling, directly or indirectly, in connection with the offer or sale of securities, by the 

use of the means or instrumentalities of interstate commerce or of the mails, directly or 

indirectly, acting intentionally, recklessly, or negligently, (i) employed devices, schemes, or 

artifices to defraud; and (ii) engaged in transactions, practices, or courses of business which 

operated or would operate as a fraud or deceit upon any persons, including purchasers or sellers 

of the securities. 

114. By reason of the conduct described above, Trends, Rossetti, Clinton Greyling, and 

Leslie Greyling, directly or indirectly, in connection with the purchase or sale of securities of 

Alterola and Token, by the use of the means or instrumentalities of interstate commerce or of the 

mails, intentionally, knowingly or recklessly, (i) employed devices, schemes, or artifices to 

defraud; and (ii) engaged in acts, practices, or courses of business which operated or would 

operate as a fraud or deceit upon any persons, including purchasers or sellers of the securities. 

115. Bendelac knowingly or recklessly provided substantial assistance to Trends, 

Rossetti, Clinton Greyling, and Leslie Greyling, in their violations of Sections 17(a)(1) and (3) of 

the Securities Act and Section 10(b) of the Exchange Act and Rules 10b-5(a) and (c) thereunder. 

116. By reason of the conduct described above, Bendelac aided and abetted violations 

of Sections 17(a)(1) and (3) of the Securities Act and Section 10(b) of the Exchange Act and 

Rules 10b-5(a) and (c) thereunder, as proscribed by Section 15(b) of the Securities Act [15 

U.S.C. §§ 77o(b)] and Section 20(e) of the Exchange Act [15 U.S.C. § 78t(e)]. 

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32 
 

EIGHTH CLAIM FOR RELIEF 
AIDING AND ABETTING 

(Capellini’s Aiding and Abetting Bendelac’s Violations of Sections 17(a)(1) and (3) of the 
Securities Act and Sections 9(a)(2) and 10(b) of the Exchange Act and Rules 10b-5(a) and 

(c) thereunder) 
 

117. Paragraphs 1 through 87 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

118. During the Relevant Period, the shares of stock of Alterola and Token were 

securities under Section 2(a)(1) of the Securities Act [15 U.S.C. § 77b(a)(1)] and Section 3(a)(1) 

of the Exchange Act [15 U.S.C. § 78c(a)(10)].  

119. By reason of the conduct described above, Bendelac, directly or indirectly, in 

connection with the offer or sale of securities, by the use of the means or instrumentalities of 

interstate commerce or of the mails, directly or indirectly, acting intentionally, recklessly, or 

negligently, (i) employed devices, schemes, or artifices to defraud; and (ii) engaged in 

transactions, practices, or courses of business which operated or would operate as a fraud or 

deceit upon any persons, including purchasers or sellers of the securities. 

120. By reason of the conduct described above, Bendelac directly or indirectly, by the 

use of the mails or any means or instrumentality of interstate commerce, or of any facility of any 

national securities exchange, effected a series of transactions in the securities of Token creating 

actual or apparent active trading in such security, or raising or depressing the price of such 

security, for the purpose of inducing the purchase or sale of such security by others. 

121. By reason of the conduct described above, Bendelac, directly or indirectly, in 

connection with the purchase or sale of securities of Alterola and Token, by the use of the means 

or instrumentalities of interstate commerce or of the mails, intentionally, knowingly or 

recklessly, (i) employed devices, schemes, or artifices to defraud; and (ii) engaged in acts, 

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33 
 

practices, or courses of business which operated or would operate as a fraud or deceit upon any 

persons, including purchasers or sellers of the securities. 

122. Capellini knowingly or recklessly provided substantial assistance to Bendelac in 

his violations of Sections 17(a)(1) and (3) of the Securities Act and Sections 9(a)(2) and 10(b) of 

the Exchange Act and Rules 10b-5(a) and (c) thereunder. 

123. By reason of the conduct described above, Capellini aided and abetted violations 

of Sections 17(a)(1) and (3) of the Securities Act and Sections 9(a)(2) and 10(b) of the Exchange 

Act and Rules 10b-5(a) and (c) thereunder, as proscribed by Section 15(b) of the Securities Act 

[15 U.S.C. §§ 77o(b)] and Section 20(e) of the Exchange Act [15 U.S.C. § 78t(e)]. 

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that this Court: 

A. Enter a permanent injunction restraining each of the defendants, their officers, 

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

with them who receive actual notice of the injunction by personal service or otherwise, from 

violating 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 Rule 10b-5 thereunder [17 C.F.R. 240.10b-5]; 

B. Enter a permanent injunction restraining Bendelac and Capellini, their officers, 

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

with them who receive actual notice of the injunction by personal service or otherwise, from 

violating Section 9(a) of the Exchange Act [15 U.S.C. §78i(a)]; 

C. Enter a permanent injunction restraining Rossetti, his officers, agents, servants, 

employees and attorneys, and those persons in active concert or participation with him who 

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34 
 

receive actual notice of the injunction by personal service or otherwise, from violating Section 

15(a)(1) of the Exchange Act [15 U.S.C. §78o(a)(1)]. 

D. Order the defendants to disgorge, with prejudgment interest, all ill-gotten gains 

they obtained by reason of the unlawful conduct alleged in this Complaint pursuant to Section 

21(d)(7) of the Exchange Act [15 U.S.C. §78u(d)(7)]; 

E. Order the defendants to pay 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)];  

F. Enter an order prohibiting the defendants from participating in any offering of a 

penny stock, pursuant to Section 20(g) of the Securities Act [15 U.S.C. § 77t(g)] and 21(d) of the 

Exchange Act [15 U.S.C. § 78u(d)]; 

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

orders and decrees that may be entered; and  

H. Grant such other and further relief as this Court may deem just and proper. 

JURY DEMAND 

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

DATED this 8th day of June 2022. 

     Respectfully submitted, 

                                           /s/ David M. Scheffler  
David M. Scheffler (Mass Bar No.670324) 
J. Lauchlan Wash (Mass. Bar No. 629092) 
SECURITIES AND EXCHANGE COMMISSION 
Boston Regional Office 
33 Arch St., 24th Floor 
Boston, MA 02110 
Phone: (617) 573-8810 (Scheffler direct) 
[email protected] (Scheffler email) 

Case 1:22-cv-10889   Document 1   Filed 06/08/22   Page 34 of 37



EXHIBIT A

[1] - The maximum percentage of market volume is 200% which would mean that the Defendants / Associates account for all of the buy-side and sell-side activity in the market that day.

Trade Date Transaction 
Type

ALEUTIAN 
(BENDELAC)

THOMAS 
CAPELLINI

CLINTON 
GREYLING

BRANDON 
ROSSETTI

BENDELAC'S 
RELATIVE

 Grand 
Total 

 Total 
Market 
Volume 

Defendants and 
Associates Percentage of 

Market Volume [1]

11/7/2018 BUY 100                       100             
SELL 500                       500             

11/7/2018 Total 500                       100                       600             601             99.8%
2/19/2019 BUY 100                       200                       300             

SELL 100                       100             
2/19/2019 Total 100                       100                       200                       400             3,650          11.0%

2/20/2019 BUY 100                       100             
SELL 200                       200             

2/20/2019 Total 200                       100                       300             400             75.0%
4/9/2019 BUY 10                         10               

SELL 500                       500             
4/9/2019 Total 500                       10                         510             1,550          32.9%

4/11/2019 BUY 10                         10               
SELL 200                       200             

4/11/2019 Total 200                       10                         210             760             27.6%
4/16/2019 BUY 100                       100             

SELL 100                       100             
4/16/2019 Total 100                       100                       200             300             66.7%

4/17/2019 BUY 90                         90               
SELL 200                       200             

4/17/2019 Total 200                       90                         290             290             100.0%
4/22/2019 BUY 20                         300                       320             

SELL 400                       400             
4/22/2019 Total 400                       20                         300                       720             550             130.9%

5/10/2019 BUY 100                       130                       230             
SELL 100                       100             

5/10/2019 Total 100                       100                       130                       330             930             35.5%
5/20/2019 BUY 300                       300             

SELL 300                       100                       400             
5/20/2019 Total 300                       100                       300                       700             400             175.0%

5/21/2019 BUY 800                       800             
SELL 314                       200                       514             

5/21/2019 Total 314                       1,000                    1,314          1,200          109.5%
5/23/2019 BUY 250                       250             

SELL 300                       300             
5/23/2019 Total 300                       250                       550             550             100.0%

TRADING IN TOKEN BY DEFENDANTS AND ASSOCIATES - SELECTED DAYS

Case 1:22-cv-10889   Document 1   Filed 06/08/22   Page 35 of 37



EXHIBIT A

[1] - The maximum percentage of market volume is 200% which would mean that the Defendants / Associates account for all of the buy-side and sell-side activity in the market that day.

Trade Date Transaction 
Type

ALEUTIAN 
(BENDELAC)

THOMAS 
CAPELLINI

CLINTON 
GREYLING

BRANDON 
ROSSETTI

BENDELAC'S 
RELATIVE

 Grand 
Total 

 Total 
Market 
Volume 

Defendants and 
Associates Percentage of 

Market Volume [1]

5/24/2019 BUY 360                       360             
SELL 386                       1                           387             

5/24/2019 Total 386                       361                       747             667             112.0%
6/11/2019 BUY 500                       500             

SELL 400                       400             
6/11/2019 Total 400                       500                       900             500             180.0%

6/12/2019 BUY 1,000                    1,000          
SELL 1,000                    1,000          

6/12/2019 Total 1,000                    1,000                    2,000          1,000          200.0%
6/13/2019 BUY 1,500                    1,500          

SELL 1,513                    1,513          
6/13/2019 Total 1,513                    1,500                    3,013          2,013          149.7%

6/14/2019 BUY 2,000                    2,000          
SELL 2,000                    2,000          

6/14/2019 Total 2,000                    2,000                    4,000          2,000          200.0%
6/17/2019 BUY 1,100                    1,100          

SELL 1,000                    1,000          
6/17/2019 Total 1,000                    1,100                    2,100          1,200          175.0%

6/19/2019 BUY 2,000                    2,000          
SELL 2,000                    2,000          

6/19/2019 Total 2,000                    2,000                    4,000          2,000          200.0%
6/25/2019 BUY 140                       140             

SELL 240                       240             
6/25/2019 Total 240                       140                       380             340             111.8%

8/20/2019 BUY 100                       100             
SELL 500                       500             

8/20/2019 Total 600                       600             800             75.0%
9/5/2019 BUY 8,100                    8,100          

SELL 8,500                    8,500          
9/5/2019 Total 8,500                    8,100                    16,600        9,175          180.9%

9/9/2019 BUY 2,000                    2,000          
SELL 2,000                    2,000          

9/9/2019 Total 2,000                    2,000                    4,000          2,400          166.7%
10/18/2019 BUY 2,500                    2,500          

SELL 2,500                    2,500          
10/18/2019 Total 2,500                    2,500                    5,000          2,500          200.0%

11/13/2019 BUY 1,000                    1,000          

Case 1:22-cv-10889   Document 1   Filed 06/08/22   Page 36 of 37



EXHIBIT A

[1] - The maximum percentage of market volume is 200% which would mean that the Defendants / Associates account for all of the buy-side and sell-side activity in the market that day.

Trade Date Transaction 
Type

ALEUTIAN 
(BENDELAC)

THOMAS 
CAPELLINI

CLINTON 
GREYLING

BRANDON 
ROSSETTI

BENDELAC'S 
RELATIVE

 Grand 
Total 

 Total 
Market 
Volume 

Defendants and 
Associates Percentage of 

Market Volume [1]

43782 SELL 1,000                    1,000          
11/13/2019 Total 1,000                    1,000                    2,000          1,160          172.4%

12/2/2019 BUY 2,500                    2,500          
SELL 1,930                    1,930          

12/2/2019 Total 1,930                    2,500                    4,430          2,500          177.2%

Case 1:22-cv-10889   Document 1   Filed 06/08/22   Page 37 of 37