SEC v. Vy Pham, No. 1:24-cv-12588-AK, District of Massachusetts (Oct. 15, 2024) — Complaint

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

SECURITIES AND EXCHANGE
COMMISSION,

    Plaintiff,
            v.

VY PHAM, a/k/a/ “msvy_crypto,”

                                                Defendant.

Civil Action No. 24-CV-____(___)

JURY TRIAL DEMANDED

COMPLAINT
 Plaintiff, Securities and Exchange Commission (the “Commission” or “SEC”), alleges
the following against the defendant, Vy Pham, a/k/a/ “msvy_crypto”:
SUMMARY
1. This action arises from Defendant Vy Pham’s unregistered offers and sales of two
crypto assets as securities, and from her schemes to manipulate the market for those securities.
2. In the spring of 2021, Pham participated in the launch of “Saitama Inu”
(“Saitama”)—a crypto asset that was offered and sold as a security.  Pham and other individuals
led a project to increase the value of Saitama.  They claimed that the token would create wealth
for investors through passive income and would supposedly promote financial literacy and global
financial well-being.  They then manipulated the price and trading volume of that crypto asset
through coordinated purchases designed to lure in new investors by creating the illusion of
growing market interest in Saitama.  Pham’s involvement in the Saitama project was short lived,
however.  Soon after pumping up the price and trading volume of Saitama through manipulative
trading, she had a falling out with other members of Saitama’s leadership team, sold her Saitama

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holdings, and left the project in the summer of 2021.  Other leaders of the Saitama project
continued without her and have been charged with numerous violations of the federal securities
laws.  See SEC v. Russell Armand et al. (D. Mass. 2024).
3. Later in 2021, Pham launched a different crypto asset called the “Robo Inu
Finance token” (“Robo Inu”)—a token “inspired by NASA’s ambitious plan to launch Robo-
dogs to Mars.”  Pham once again promised investors that she would build a fintech “ecosystem”
designed to “maximize value” for the holders of Robo Inu.
4. Upon offering Robo Inu to the investing public, Pham and others at her behest
worked to create active secondary markets on which Robo Inu could be traded.  But there was
little natural market interest in Robo Inu.  So Pham hired Gotbit Consulting LLC (“Gotbit”) to
engage in manipulative trading on her behalf.  Gotbit, which purports to provide “market
making” services to crypto asset projects, generated millions of dollars in artificial daily trading
volume by trading Robo Inu with itself and, in the process, creating the illusion of public interest
and enthusiasm for Robo Inu.  The purpose of this self-trading, also known as “wash trading,”
was to induce the purchase of Robo Inu by the investing public.
5. This manipulation campaign ran from February 2022 through at least June 2023.
While Gotbit was artificially inflating Robo Inu’s trading volume, Pham and other leaders of the
Robo Inu project promoted Robo Inu to the investing public through social media and other
public communication channels, including X (formerly Twitter), YouTube, Reddit, and the
publishing platform Medium, along with a website and a whitepaper describing Robo Inu and the
efforts of Pham and others to create an ecosystem of applications that would generate value for
Robo Inu holders.

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6. Pham offered and sold both Saitama and Robo Inu to the investing public as
securities.  She was therefore required to register those offers and sales with the SEC unless an
exemption from registration was available.  Pham did not file a registration statement with the
SEC for those offers or sales, and no exemption from registration was available.
7. Moreover, Pham’s conduct has caused significant harm—to the integrity of the
markets and to the investor victims who traded in crypto assets fraudulently lured by the fake
volumes and prices that she procured.
VIOLATIONS
 
8. As a result of the conduct alleged herein, Pham violated, and unless restrained and
enjoined will continue to violate, Sections 5(a), 5(c), 17(a)(1), and 17(a)(3) of the Securities Act
of 1933 (“Securities Act”) [15 U.S.C. §§ 77e(a) and (c), and 77q(a)(1) and (a)(3)], Sections
9(a)(2) and 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C.
§§ 78i(a)(2) and 78j(b)], and Rules 10b-5(a) and (c) thereunder [17 C.F.R. §§ 240.10b-5(a) and
(c)].
RELIEF SOUGHT
9. The Commission seeks permanent injunctions against Pham, disgorgement of all
ill-gotten gains from the unlawful conduct set forth in this Complaint, together with prejudgment
interest pursuant to Sections 21(d)(5) and (7) of the Exchange Act [15 U.S.C. § 78u(d)(5) and
(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 pursuant to Section 20(e)
of the Securities Act [15 U.S.C. § 77t(e)] and Section 21(d)(2) of the Exchange Act [15 U.S.C.
§ 78u(d)(2)] barring Pham from acting as an officer or director of any issuer that has a class of
securities registered pursuant to Section 12 of the Exchange Act [15 U.S.C. § 78l] or that is

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required to file reports pursuant to Section 15(d) of the Exchange Act [15 U.S.C. § 78o(d)]; and
an order prohibiting Pham from participating, directly or indirectly, including but not limited to
through any entity controlled by her, in any offering of securities, including any crypto asset
security, provided however, that such injunction shall not prevent her from purchasing or selling
securities, including crypto asset securities, for her personal account; and such other relief as the
Court may deem appropriate.
JURISDICTION AND VENUE
10. 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].
11. 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.
Specifically, the Defendant offered securities to individuals who reside in the District, and
promoted those securities to individuals residing in the District via social media and other
communications platforms.
DEFENDANT
12. Vy Pham is a citizen of Vietnam and resides in Los Angeles, California.  At all
relevant times, she has held herself out publicly as the leader of the project related to Robo Inu
and as a founder and Chief Executive Officer of Robo Global Investment PTE, Ltd.

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RELATED INDIVIDUALS AND ENTITIES
13. Russell Armand, a/k/a “Saitamaguru1,” 42, resides in Texas.  At all relevant
times, Armand was the Chief Executive Officer of the Saitama project.
14. Maxwell Hernandez, a/k/a “MaxEquation,” 36, resides in Massachusetts.  At all
relevant times, Hernandez was the Chief Technology Officer of the Saitama project.
15. Manpreet Singh Kohli, a/k/a “Mkay Saitama,” a/k/a “mannythehitman,” 39,
resides in India and London, England.  At all relevant times, Kohli was the Chief Financial
Officer of the Saitama project.
16. Nam Tran, a/k/a “Ntran1234,” 49, is believed to reside in Washington.  At all
relevant times, Tran was the Chief Business Officer of the Saitama project.
17. The Commission has charged Armand, Hernandez, Kohli, and Tran with federal
securities law violations in a separate complaint.  See SEC v. Russell Armand et al. (D. Mass.
2024).  They are referred to herein as the “Saitama Defendants.”  With Pham and Individual 1
(the Saitama CMO), they are collectively referred to as the leaders of the Saitama project.
18. Robo Global Investment PTE, Ltd. (“Robo Global”) is a limited company that
was founded by Pham and was organized in Singapore in 2022.  Per its website, Robo Global
purportedly “aspires to create an open ecosystem where anyone . . . can gain financial freedom”
through the development of the Robo Inu token and related applications.
19. Gotbit Consulting LLC, a/k/a Gotbit Hedge Fund, (“Gotbit”) is a limited liability
company registered under the laws of Belize, with a registered office in Belize City, Belize.
Gotbit was founded in or around 2017 and purports to have offices in Armenia, Portugal, Turkey,
Vietnam, the United Arab Emirates, and the United Kingdom.
20. Fedor Kedrov is believed to reside in Russia.  According to his LinkedIn profile,

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Kedrov is Gotbit’s Chief Operating Officer.  Gotbit’s website states that Kedrov is also the
“Director of [the] Market Making Department.”
21. The Commission has charged Gotbit and Kedrov with securities fraud in a
separate complaint.  See SEC v. Gotbit Consulting LLC et al. (D. Mass. 2024).
22. “Individual 1,” 36, resides in Texas.  Individual 1 was the Chief Marketing
Officer of the Saitama project (the “Saitama CMO”).
23. “Individual 2” resides in Australia and worked with Pham to manipulate the
market for Robo Inu.
24. An individual who identifies himself in private chats on the encrypted messaging
platform Telegram as “Vladislav Trader” works for Gotbit.
25. An individual who identifies himself on Telegram as “Vladimir” works for
Gotbit.
26. An individual who identifies himself on Telegram as “Kavi JLL” works for
Gotbit.
REGULATORY BACKGROUND
27.  As the Supreme Court has recently reemphasized, the Securities Act and the
Exchange Act “form the backbone of American securities law.”  Slack Tech., LLC v. Pirani, 598
U.S. 759, 762 (2023).  Together, these Acts provide for the regulation of various activities in the
markets for securities and define “security” broadly to include a wide range of assets, including
“investment contracts.”  Securities Act § 2(a)(1) [15 U.S.C. § 77b(a)(1)]; Exchange Act
§ 3(a)(10) [15 U.S.C. § 78c(a)(10)].
28. Congress enacted the Exchange Act in part to provide for the regulation of the
national securities markets.  Congress created the SEC and charged it with protecting investors,

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preserving fair and orderly markets, and facilitating capital formation.  In keeping with
Congress’ goals, these Acts contain broad anti-fraud and anti-manipulation prohibitions.
29. Sections 5(a) and 5(c) of the Securities Act generally require an issuer of
securities to register an offering of securities through an effective registration statement before
the securities are offered and sold to the public.  See 15 U.S.C. §§ 77e(a) and (c).  Registration
statements for a securities offering provide public investors with material information about the
issuer and the securities to be offered and sold.
30. Over seventy years ago, the Supreme Court in SEC v. W.J. Howey Co., 328 U.S.
293 (1946), set forth the relevant test for determining whether an instrument is an investment
contract subject to regulation under U.S. securities laws.
31. Investment contracts are transactions, contracts, or schemes through which a
person invests money in a common enterprise and reasonably expects profits or returns derived
from the entrepreneurial or managerial efforts of others.
32. Congress defined “security” broadly to embody a “flexible rather than a static
principle, one that is capable of adaptation to meet the countless and variable schemes devised by
those who seek the use of the money of others on the promise of profits.”  Id. at 299.
BACKGROUND ON CRYPTO ASSETS
33. As used herein, the terms “crypto asset” or “token” generally refer to an asset
issued and/or transferred using blockchain or distributed ledger technology, including assets
referred to colloquially as a “digital asset,” “cryptocurrency,” “virtual currency,” and digital
“coin.”
34. A blockchain or distributed ledger is a database spread across a network of
computers that records all transactions in theoretically unchangeable, digitally recorded data

8
 
packages, referred to as “blocks.”  The system relies on cryptographic techniques for secure
recording of transactions.
35. The Ethereum blockchain is an example of a blockchain.  Ether (or “ETH”) is the
Ethereum blockchain’s native token.  (Some crypto assets may be “native tokens” to a particular
blockchain—meaning that they are represented on their own blockchain, though other crypto
assets may also be represented on that same blockchain, as is the case with the Ethereum
blockchain.)
36. ERC-20 is a standard protocol (or technical specification of the type of crypto
token) currently used on the Ethereum blockchain to create and represent tokens on that
blockchain.
37. A crypto asset “wallet” is hardware or software that enables users to store private
keys, which function like passwords that are used to access and transfer crypto assets.
38. Crypto asset trading platforms allow their customers to purchase and sell crypto
assets for fiat currency (legal tender issued by a country) or for other crypto assets, depending on
the platform.  “Off-chain” transactions are tracked in the internal recordkeeping mechanisms of
the platform but do not involve transferring crypto assets from one wallet to another, while “on-
chain” transactions are those involving the transfer of a crypto asset from one blockchain address
to another.
39. On July 25, 2017, the SEC issued the Report of Investigation Pursuant to Section
21(a) of the Securities Exchange Act of 1934:  The DAO, advising “those who would use . . .
distributed ledger or blockchain-enabled means for capital raising[] to take appropriate steps to
ensure compliance with the U.S. federal securities laws,” and finding that the offering of crypto
assets at issue in that report involved investment contracts and thus securities.

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BACKGROUND ON MARKET MAKERS
40. “Market makers” are in the business of buying securities from those who wish to
sell, and selling securities to those who wish to buy, and operate in many traditional securities
markets.  Market makers “make markets” by continuously and publicly quoting both a price at
which they are willing to buy a security (the “bid”) and a higher price at which they are willing
to sell the security (the “ask”).  The difference between these prices is known as the “bid-ask
spread,” (or just “the spread”) and is one of the ways market makers earn money through both
buying and selling—i.e., “making a market” for—securities.
41. Market makers can affect the liquidity, depth, and efficiency of markets by
ensuring that there is always a counterparty willing to transact with buyers and sellers at publicly
quoted prices.  This is especially the case for thinly traded securities, where there may be few
“natural” (or “organic”) buyers and sellers in the market.  A market maker can provide liquidity
to a seller of a security when it is difficult to find a natural buyer, or to a buyer of a security
when it is difficult to find a natural seller.
42. In traditional securities markets, trading platforms such as national securities
exchanges frequently offer incentives for market makers to provide real liquidity to traders on
the platform, even for illiquid securities and during periods of market stress.
43. In traditional securities markets, market makers and other market participants are
regulated with a view toward promoting benefits to the overall market and deterring any conflicts
of interest or unfair trading advantages.  Market makers are subject to requirements regarding
registration, capital, trade reporting, and business conduct standards, among other things.  By
contrast, self-described market makers operating on unregistered crypto asset trading platforms
do not adhere to these requirements.  In such an environment and in the absence of regulatory

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compliance and its concomitant oversight, market makers have ample opportunities to act on
powerful incentives to manipulate a token’s price and/or trading volume.
44. For example, unlike in the traditional, regulatorily compliant markets, in the
crypto asset markets it is often the token offeror who pays these market makers a monthly fee,
and they may pay these fees for artificially inflating trading volumes to create the false
impression that there is a robust market for what is in reality a thinly traded crypto asset.  A
market maker might accomplish this by using one or more accounts it directly or indirectly
controls to trade against its own quotation.  Here, there is no change in beneficial ownership of
the asset traded but the appearance of a market-driven transaction.  This phenomenon is known
as “wash trading.”
45. Similarly, the token offeror might seek to have one or more market makers create
artificial volume to meet minimum requirements for having their crypto asset made available on
one or more crypto asset trading platforms.  This would give the crypto asset greater prominence
and potentially could attract more natural buyers and sellers.
46. Manipulative trading can benefit both the offeror and the market maker at the
expense of natural investors; each has incentives to generate public interest in the token so that
they can liquidate their token supplies at higher prices—particularly if the crypto asset’s offerors
and their affiliates have retained large portions of the assets at inception (as is common in the
crypto asset markets), which they cannot monetize absent demand from natural buyers.
FACTS

SAITAMA

47. The Saitama token is an ERC-20 standard token on the Ethereum blockchain.
48. No later than June 2021, the leaders of the Saitama project published a website

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and a whitepaper in which they described Saitama as a “platform that promotes global financial
wellbeing by empowering the youth to be in control of their money and create their own wealth
opportunities.”
1

49. According to the whitepaper, the Saitama project leaders would build an
“ecosystem” of products and services specifically built for Saitama, including:
a. a smart wallet application called “SaitaMask,” which the Saitama project
leaders described in the whitepaper as “a safe and smart wallet that will allow
the community to store their digital assets like $SAITAMA and learn about
finance and investment opportunities”;
b. a marketplace called “SaitaMarket” in which individuals could “use $Saitama
and other partner tokens to purchase goods and services”;
c. a platform for creating and trading so-called non-fungible tokens (“NFTs”)
called “SaitaMaker” in which users could “create, launch and promote
projects based on the $SAITAMA monetary system”; and
d. a “multi-channel content platform” called “Saitama Edutainment” that would
educate young investors “on how to save, invest, manage money and create
wealth opportunities while entertaining our audience.”
I. Pham Engaged in Unregistered Offers and Sales of Saitama.
50. Pham offered and sold Saitama as a security, specifically as an investment
contract, on numerous crypto asset trading platforms.
51. First, Saitama purchasers, including those who bought it on crypto asset trading
 
1
  According to the Saitama whitepaper, the Saitama “brand and token name took inspiration from the
legend of a mysterious ‘ghost dog’ that is said to be roaming the mountains in the region of Saitama in
Japan” and is revered as “a guardian against misfortune.”

12
 
platforms, invested money—specifically U.S. dollars, Bitcoin, or ETH—when they purchased
Saitama.
52. Second, all Saitama purchasers invested in a common enterprise with each other
and with the Saitama project leaders, who at all relevant times retained significant Saitama
holdings.  Because the value of Saitama rose or fell together for all holders, all Saitama holders
profited or suffered losses equally in amounts proportionate to their Saitama holdings.  As such,
their financial fortunes—including the realization of future profits—were inextricably tied to the
financial fortunes of each other as well as those of the Saitama project leaders.
53. Pham and other Saitama project leaders offered and sold Saitama to the investing
public both to enrich themselves personally, and to collectively fund their efforts to develop the
“Saitama ecosystem.”
54. In addition, Saitama investors’ financial fortunes depended on the Saitama project
leaders’ efforts to grow the Saitama ecosystem, including by creating new uses for Saitama such
that its utility would increase, thereby increasing the demand for, and correspondingly the price
of, Saitama.
55. Moreover, for each on-chain Saitama transaction, two percent of the value of the
transaction was redistributed to Saitama holders in proportion to their Saitama holdings, and
another two percent of the value of the transaction was “burned” or destroyed, decreasing the
supply of Saitama.
2
  These automatic redistributions of Saitama further ensured that the financial
fortunes of the Saitama project leaders (who held large positions in Saitama and were developing
uses for the token, including with the proceeds of Saitama sales) and the financial fortunes of
 
2
 “Burning” crypto assets refers to sending those assets to an inaccessible wallet from which the tokens
cannot be withdrawn, thereby removing them from circulation.

13
 
other investors were intertwined.
56. Third, the Saitama project leaders led Saitama investors to reasonably expect that
they would profit from their Saitama investments, based on the Saitama project leaders’
entrepreneurial and managerial efforts.
57. Through the Saitama website, whitepaper, social media, and other public outlets,
Pham, Individual 1, and the Saitama Defendants held themselves out as the leaders of the
Saitama project and the driving force behind the creation and future development, maintenance,
and growth of the Saitama ecosystem from which Saitama derived its value.
58. In the Saitama whitepaper that the Saitama project leaders published in June
2021, they expressly and repeatedly described Saitama as an investment with the potential for
substantial profit while describing themselves as the individuals who would undertake the efforts
needed to achieve those profits—specifically, as “a group of committed individuals” that “took
over [the Saitama] project and continued developing it.”  That development took the form of
creating various applications, including those previously described, in which investors could
supposedly use and trade Saitama tokens.
59. Investors were led to reasonably expect not only that the Saitama project leaders’
development of these applications would increase demand for Saitama and therefore its price, but
also that such uses would lead to additional Saitama transactions.  As described above, each on-
chain transaction resulted in a two-percent redistribution to existing Saitama holders and an
additional two-percent burn.  From the earliest iterations of their Saitama website and
whitepaper, the Saitama project leaders touted these aspects of Saitama as a way for investors to
earn passive income on their Saitama holdings.
60. Beyond their statements on the Saitama website and whitepapers, the Saitama

14
 
project leaders periodically explained their ongoing efforts to generate profits for Saitama
investors in a series of public “ask me anything” interviews on YouTube, in which investors and
potential investors could pose questions to the Saitama project leaders.
61. On June 25, 2021, Pham moderated one of those interviews and presented
extensive information about Saitama.  She was joined by other Saitama project leaders, including
Armand, Hernandez, and Kohli.  During that interview, they described their plans for the project,
including marketing, product development, and their intention to have Saitama listed on various
trading platforms.
62. At all relevant times, the Saitama project leaders encouraged investors to purchase
Saitama, and provided specific instructions on how to do so on the Saitama website.
63. As a result of the above representations and the economic reality of what Pham
and other Saitama project leaders were offering and selling, Saitama investors had a reasonable
expectation of profiting from the efforts of Pham and other leaders of the above-described
project to develop the Saitama ecosystem and list Saitama on crypto asset trading platforms.
64. In June and July 2021, Pham sold approximately $69,500 worth of Saitama to the
investing public.
II. Pham Engaged in Manipulative Trading of Saitama.
65. In early July 2021, Pham and other Saitama project leaders were part of a group
that engaged in a series of coordinated Saitama purchases intended specifically to:  (1) induce
holders of large quantities of Saitama (referred to as “whales”) to sell their positions; (2) induce
members of the investing public to buy Saitama; and (3) increase the price of Saitama.
66. The Saitama project leaders were particularly concerned that if the existing
“whales” liquidated their Saitama holdings, the price of Saitama would fall, undermining the

15
 
Saitama project leaders’ efforts to inflate the price of the token and increase the number of
Saitama holders.  So the Saitama project leaders sought to buy out these whales through
coordinated purchases.  As Pham put it in a private Telegram group chat regarding one such
whale:  “[W]e need to lure this idiot to empty his wallet.”  Doing so would then enable the
Saitama project leaders to inflate the price of Saitama without fear of large holders later cashing
out and depressing the price.
67. The plan worked.  Through their coordinated purchases across numerous wallets
in relatively small increments, Pham and other Saitama project leaders successfully induced
large Saitama holders to sell their positions while simultaneously attracting new Saitama
purchasers.  During their approximately two-day buying spree, the price of Saitama increased by
approximately 60 percent.
68. Pham and other Saitama project leaders described their plan—and their successful
execution of it—on July 3 and 4, 2021 in a private group chat on Telegram.
69. In the private Telegram group chat, Armand explained that he was creating a
separate public Telegram “shill group” to promote Saitama to potential investors.  Armand was
confident that if he initially populated his “shill group” with some people and “some bots,” then
“a lot of [people] will join.”  He explained:  “If we add this to a pump we create.  A lot of
[people] will FOMO in.”
3
  Pham asked:  “How much are we gonna pump now?”  Armand
responded:  “We will create an illusion of massive buys and new holders. . . .  It’ll incite [people]
to buy more.”  Armand continued, stating the group was “[b]asically creating our own pump
through illusion.”
70. Kohli and Tran reported to the group that they were ready to buy, and Individual 1
 
3
  In this context, “FOMO” or “fear of missing out” refers to investors’ “fear” that they may lose out on
profiting from an increase in a crypto asset’s price.

16
 
(the Saitama CMO) demonstrated his agreement with the plan with the following GIF:

71. Pham, Armand, Kohli, Tran, and Individual 1 continued to discuss the optimal
size of their purchases to accomplish the “pump.”
72. The Saitama project leaders coordinated their purchases with Armand’s public
“shilling” of Saitama on Telegram.  As potential investors joined Armand’s public Telegram
group, Pham and the rest of the Saitama project leaders each began purchasing Saitama.  Armand
instructed them to purchase two to three trillion Saitama per transaction.  Although numerically
large, two to three trillion Saitama was small relative to the total initial supply of Saitama, which
was approximately 100 quadrillion.  Armand explained, “W[e] want [a] list of small buys to look
like it’s mor[e] buyers.”  Pham, Kohli, Hernandez, Tran, and Individual 1 all began purchasing
Saitama at Armand’s direction and discussed their transactions in the private Telegram group
chat.
73. For instance, Tran noted that people were joining Armand’s public Telegram chat
group and told other Saitama project leaders to begin buying immediately.  Armand responded:
“Is like fishing with dynamite.”  Pham, Tran, and Individual 1 agreed, each responding “Lol.”
Pham repeatedly emphasized the need for the group to closely coordinate its purchasing (the
timing, volume, and number of wallets), in order to maximize its impact on price and to convince
the “whales” to sell.
74. Pham, Individual 1, and all the Saitama Defendants participated in the

17
 
coordinated purchases of Saitama, which occurred in multiple rounds over the course of July 3
and July 4, 2021.  Tran, for instance, announced in the private Telegram group chat:  “Round 2
start [sic] now!”  Hernandez responded that he “bought a few times.”  Tran later asked the other
Saitama project leaders:  “Round 3?”  Armand responded:  “Yea small buys,” again advising the
Saitama project leaders to make multiple small purchases to create the appearance of broad
public interest in Saitama and obscure the fact that a small number of Saitama insiders were
responsible for the increased demand.  In response, Pham, Tran, and Kohli each confirmed they
were once again buying Saitama.  Pham noted:  “[T]his is where new holders will get attracted
. . . and give people confidence.”
75. A few hours later, Armand told Kohli again to keep his purchases small,
explaining that “the idea is to keep the [price] chart trending upward to generate traction and
stability[.]  Will keep [people] from wanting to sell and will instead buy more.”  Kohli indicated
he understood the plan:  “Gaaaaat it.”

76. The Saitama project leaders discussed in their private Telegram group chat how
their coordinated purchases were in fact succeeding in inducing new investors to purchase
Saitama.  Relatively early in their efforts, Armand reported that their purchases were increasing
the number of Saitama holders:  “Soooo success so far.”  Hernandez agreed:  “[Y]es holder
increase is pretty steady.”  Armand later reported to the group:  “Holders are increasing nicely
and distribution is looking much better.  We have a better foundation today then [sic] we did last
week from the eyes of a future investor.”  Kohli responded:  “And sell again on high what we
created.”
77. Armand apprised the group of the status of their efforts, stating for example,
“We’ve already bled out most of the big wallets[;] there’s only a couple that remain.”  After a

18
 
few hours of continued coordinated purchases by leaders of the Saitama project, Armand
reported that one of the wallets they targeted sold roughly 800 trillion Saitama, leading Armand
to conclude:  “Mission semi-accomplished.”
78. The Saitama project leaders recognized the need to hide their coordinated
purchases from the investing public not only by breaking their Saitama purchases into small
transactions, but also by using multiple wallets to disguise their coordinated activity.  For
example, after making a series of Saitama purchases, Kohli asked others in the private group chat
whether he should use another account, noting “all from same looks weird.”  The Saitama CMO
responded:  “Yes . . . Use two or 3 wallets.”  Later, Kohli commented, “I think too many from
my address wallet,” referring to the number of Saitama purchases he made from the same wallet
address.  Armand replied, “Yea need new wallet.”
79. The Saitama project leaders understood that they needed to keep their coordinated
purchases hidden from the investing public.  Kohli, for instance, warned the participants in the
private Telegram group chat:  “Don’t involve too many in group. . . .  It will really bring
downfall if someone take screen shot and start posting.”
80. After two days of coordinated purchases of Saitama that eliminated many large
wallets and expanded the number of Saitama investors, Armand complimented Pham and the rest
of the Saitama project leaders:  “Ladies and gentlemen that is how you start a hype.  Perfectly
executed well done all[.]  Still have to keep small buys incoming if it pulls though.  Lot of ppl
[people] watching chart right now.”  Later in the day, after continued discussion of their
manipulation of Saitama, Tran posted to the group
:

19
 

81. Later in the conversation, Individual 1 (the Saitama CMO) added:

82. Working in the manner and for the specific purposes described above, Pham
purchased approximately 258.81 trillion Saitama for approximately $8,859.
ROBO INU

83. The Robo Inu token is an ERC-20 standard token on the Ethereum blockchain,
with ticker symbol RBIF.
84. In or around November 2021, Pham and other leaders of the Robo Inu project
began promoting the Robo Inu token on a website and through several social media and
communications platforms, including X (formerly Twitter), YouTube, Reddit, and the publishing
platform Medium.  All of these communications were aimed at the investing public, including
investors in the United States.
85. Across these platforms, Pham and other project leaders encouraged others—
sometimes expressly referred to as “investors”—to purchase the token based on, among other
things, Robo Inu’s “tokenomics” (aspects of a crypto asset’s design, including transaction fees
imbedded into the smart contract) and the efforts of Pham and others to undertake a project to

20
 
generate value for Robo Inu investors.
86. Pham also published a whitepaper describing what the project would entail—
efforts of her and her leadership team to create an “ecosystem” of products and services that
would rely on or utilize Robo Inu, all of which were purportedly designed to maximize value for
Robo Inu investors.  At that time, the Robo Inu token was available for trading on the Uniswap
trading platform.
87. In or around February 2022, Robo Inu was made available for trading on the
Bitmart trading platform.
88. In addition to promoting the token on social media, leaders of the Robo Inu
project team continued to update its website and develop the white paper over time.  According
to the June 2022 version of the whitepaper, the Robo Inu ecosystem included the following
projects, some of which then remained under development:
a. a crypto asset wallet called “RGI Wallet”;
b. an “incubator for potential projects with real use cases” that are “checked and
moderated by the Robo Inu Finance Team” called “RoboLaunchpad”;
c. a platform for trading so-called non-fungible tokens (“NFTs”) called
“RoboNFT Marketplace”;
d. a platform called “RoboDAO” on which Robo Inu holders could vote on
governance proposals related to Robo Global;
e. a crypto asset trading platform called “RoboEx”;
f. a venture fund called RoboVentures, which, as Pham explained in a Medium
post, “will invest into SpaceX and TSLA stocks to allow $RBIF token holders
to earn a piece of that space pie.”

21
 
89. Over time, Pham and her leadership team launched several of these products,
including RGI Wallet, RoboDAO, and RoboEx.
III. Pham Engaged in Unregistered Offers and Sales of Robo Inu.
90. At all relevant times, Robo Inu was offered and sold as a security, specifically an
investment contract.
91.  First, Robo Inu purchasers, including those who bought it on crypto asset trading
platforms such as Uniswap and Bitmart, invested money—specifically U.S. dollars, Bitcoin, or
ETH—when they purchased Robo Inu.
92. Second, Robo Inu purchasers invested in a common enterprise with each other
and with Pham, Robo Global, and other Robo Inu project leaders, who at all relevant times
retained significant Robo Inu holdings.  Because the value of Robo Inu tokens rose or fell
together for all holders, all Robo Inu holders profited or suffered losses in amounts proportional
to their Robo Inu holdings.  As such, their financial fortunes—including the realization of future
profits—were inextricably tied together, including to the financial fortunes of Robo Global,
Pham, and other Robo Inu project leaders.
93. In addition, Robo Inu investors’ financial fortunes depended on Pham and other
project leaders’ ability to grow the Robo Inu ecosystem, including by developing applications
that Pham had publicly claimed would “bring the token higher and higher.”  If Pham and other
leaders of the Robo Inu project were able to create new uses for Robo Inu, its utility would
increase, thereby increasing the demand for (and, correspondingly, the price of) Robo Inu.
94. Moreover, according to the Robo Inu whitepaper, each Robo Inu purchase or sale
was subject to a “tax” designed “to fuel the growth of Robo Inu Finance’s ecosystem.”
Specifically, all Robo Inu on-chain purchases were subject to a four-percent tax, with one

22
 
percent redistributed to Robo Inu holders in proportion to their Robo Inu holdings, and three
percent transferred to a Robo Inu marketing wallet that Pham could use to promote Robo Inu.
Similarly, all Robo Inu on-chain sales or transfers were subject to a ten-percent tax, with three
percent redistributed to Robo Inu holders in proportion to their Robo Inu holdings, and seven
percent transferred to a Robo Inu marketing wallet.
4
  These automatic redistributions of Robo
Inu further ensured that the financial fortunes of Pham and other project leaders (who held large
positions in Robo Inu and were purporting to use proceeds from additional sales to develop uses
for the token) and the financial fortunes of other investors were intertwined.
95. Third, Pham led Robo Inu investors to reasonably expect that they would profit
from their Robo Inu investments, based on the entrepreneurial and managerial efforts of Pham
and other leaders of the Robo Inu project.
96. Through the Robo Inu website, whitepaper, social media, and other public outlets,
Pham held herself out as the leader in charge of the Robo Inu project and the driving force
behind the creation of the ecosystem from which Robo Inu derived its value.  As Pham posted on
Reddit:  “My mission is very simple To Finish What I started, and create wealth for many . . . .
We are in this just for one reason- W.E.A.L.T.H.” (emphasis original).  On X, she wrote:  “Buy
RBIF and retire[.]”  In another Reddit post, Pham wrote:  “My goal is still 1bil MC [market
capitalization,] and I will not let anything or anyone get in my ways [sic] . . . .  I can guarantee
you that you will never regret walking down this journey with me.”
97. Pham also set forth a plan in the June 2022 Robo Inu whitepaper to grow the
utility and value of the token in phases that were tied to the number of Robo Inu investors.
 
4
  In or around July 2023, Robo Inu migrated to Version 2, which altered the tax and redistribution
structure, but still retained a five-percent tax on on-chain all sales, from which one percent was
redistributed pro rata to existing Robo Inu holders.

23
 
Those phases included, among other things, various new product launches (including some of the
products identified above), listing Robo Inu on additional crypto asset trading platforms, and
“[a]ggressive [m]arketing.”
98. Investors were led to reasonably expect not only that Pham’s development of
these products would increase demand for Robo Inu and therefore its price, but also that such
efforts would lead to additional Robo Inu transactions (as Pham and other project leaders
increased the number of ways the token could be used), which, as described above, would result
in additional distributions of proceeds to existing Robo Inu holders.
99. This redistribution enabled Pham to promote Robo Inu as a passive investment
vehicle in which investors could profit simply through buying and holding Robo Inu.  As she
posted on Reddit on November 27, 2021:  “The more you hold the more you get.”  On January
16, 2022, she explained on X to potential investors that among the “things you will gain from
buying and holding #RoboInu $RBIF ๞๟๠ ๞๟๠ ๞๟๠” is “reflections as passive income,” referring to
the one- or three-percent redistribution (or “reflection”) awarded to existing token holders.
100. Pham’s pitch of Robo Inu to potential investors was not subtle.  For example, on
March 1, 2024, Pham posted on her personal account on X:  “Come and support us #RoboInu
$RBIF.  Promise you will get rich.”
101. In speaking to investors, Pham expressly tied her work in developing applications
for Robo Inu to its growth and value.  On October 3, 2022, for example, she wrote to the Robo
Inu community on Reddit:  “I am still here, personally involving [sic] in every single meeting of
developments to make sure we are in sync . . . .  What can’t change is us, dev [development]
team, our commitment to deliver what we need to.”  Similarly, on March 1, 2024, she posted on
X:  “Still have chance to accumulate $RBIF . . . #RGIWallet and #RoboEx are ready to bring the

24
 
token higher and higher.”
102. Pham also led investors to reasonably expect to profit from their Robo Inu
investments by publicly touting the results of her efforts to have Robo Inu listed on multiple
trading platforms, where investors would be able to sell their Robo Inu.  Robo Inu initially traded
on Uniswap, then on Bitmart for a certain period, and finally on RoboEx, the platform created by
Pham and other leaders of the Robo Inu project.  At all relevant times, Robo Inu was available to
United States investors on those trading platforms.
103. As a result of the above and other representations and the economic reality of
what Pham was offering and selling, Robo Inu investors had a reasonable expectation of
profiting from Pham’s efforts to develop the Robo Inu ecosystem.
IV. Pham Hired Gotbit to Artificially Inflate Robo Inu’s Trading Volume.

104. Beginning in or around February 2022, Pham and the other leaders of the Robo
Inu project initiated a private Telegram group chat with several Gotbit employees, including
Kedrov, “Vladislav Trader,” “Vladimir,” and “Kavi JLL,” among others, to solicit their market
manipulation services.
105. Pham stated in the group chat that, despite having spent $250,000 on “marketing,”
the response from investors had not been “satisfactor[y],” so she and her team were “thinking
about increasing the volume via MM” (i.e., a “market maker”).
106. Pham said in the group chat that the purpose of hiring Gotbit to increase and
maintain trading volume was “to attract people to the [Robo Inu] token.”  Gotbit personnel
confirmed they understood that this was the purpose.  Throughout the parties’ relationship,
various individuals representing Gotbit communicated with Pham and other leaders of the Robo
Inu project about ways to create investor “FOMO” through artificial trading volume.  For

25
 
example, one of Gotbit’s employees on the Telegram group chat, “Vladislav Trader,” stated that
he was “trying to trigger organics”—i.e., individuals or entities other than Gotbit—“to buy”
Robo Inu.
107. Between approximately February 2022 and June 2023, Pham and others working
with her paid Gotbit approximately $3,000 to $6,000 per month to, among other things,
manipulate the trading volume of Robo Inu through automated wash trading on Bitmart and
through automated buying and selling on Uniswap.  Gotbit told leaders of the Robo Inu project
that it would be using a trading “bot,” an automated crypto asset trading program, to execute this
manipulative trading.
A. Gotbit Artificially Inflated Robo Inu’s Trading Volume on Bitmart.

108. To facilitate manipulative trading on Bitmart, Pham and other Robo Inu project
leaders, at Kedrov’s request, provided Gotbit with a supply of both Robo Inu and USDT (or
“Tether”), another crypto asset.  Gotbit used this supply of Robo Inu and Tether to trade with
itself—not to meet organic investor demand—and to artificially inflate the trading volume to
whatever level Pham and her associates desired.
109. In February 2022, Kedrov told Pham and other Robo Inu project leaders in their
private Telegram group chat that Gotbit could achieve “[a]ny volume you want.”  Kedrov
recommended that Robo Inu start with $200,000 in artificial daily volume.
110. On multiple occasions, Gotbit personnel in the Telegram group chat confirmed
that its manipulative trades accounted for most of the observed Robo Inu trading volume that
was reported to websites that investors use to track crypto assets, such as CoinMarketCap and
CoinGecko, which compile trading data from crypto asset trading platforms, including Uniswap,
Bitmart, and many others.

26
 
111. For instance, in April 2022, “Vladimir” posted to the group chat that Gotbit “did
about 250k per day average volume at current price,” and that that volume was generated “only
by our MM,” meaning that Gotbit was trading about $250,000 of Robo Inu per day with itself—
not other market participants—creating the false impression of organic buying and selling.
112. Similarly, in June 2022, “Vladimir” again indicated to Robo Inu project leaders in
the group chat that the observed trading volume was “mostly . . . our [i.e., Gotbit’s] volume.”
113. In late March 2023, “Vladislav Trader” posted to the group chat that “organic”
volume accounted for less than 10 percent of Robo Inu’s total trading volume.  The rest was
Gotbit trading with itself through automated wash trading.
114. Gotbit generally maintained a stable floor of artificial trading volume on Bitmart
at the direction of the leaders of the Robo Inu project.  The parties agreed to increase that
artificial trading volume ahead of news announcements or other marketing efforts by Pham and
other Robo Inu project leaders.  For example, in March 2022, in response to Pham previewing
Robo Inu news events for Gotbit, “Vladimir” stated that he had “slightly increased the volumes
on Bitmart before the announcements.”
115. Similarly, in December 2022, a leader of the Robo Inu project posted to the group
chat:  “We’ll have a trending campaign on CG [i.e., CoinGecko] and CMC [i.e.,
CoinMarketCap] tomorrow, it starts around 4-6pm UTC.  So please increase the volume once the
campaign starts.”  Kedrov responded:  “Awesome news, sure - we start increasing the volume
smoothly!”
116. These trades were intended to mislead the investing public to believe that the
market was reacting positively to Robo Inu news and/or the information conveyed in Robo Inu
marketing.

27
 
117. In several instances, Pham and her associates directed Gotbit to significantly
increase the daily trading volume of Robo Inu, sometimes above $1 million.  Gotbit attempted to
execute these manipulations in a manner that would disguise the fact that nearly all the trading
volume was artificial.
118. For instance, on February 25, 2022, Pham posted to the group chat with Gotbit a
request to “slowly increase the volume” because she was attempting to get the “token trending
on cmc” i.e., CoinMarketCap.  Gotbit employee “Vladimir” responded:  “Yeah we can increase
more volume gradually[.]  But it is important that our market looks organic.”
119. Similarly, in January 2023, one of Pham’s associates posted to the group chat
with Gotbit:  “[C]an you raise the volume on Bitmart please, above 1.1mil daily!  Thank you
very much.”  Kedrov responded:  “Sure, will be done.”  But another Gotbit employee cautioned
against inflating the trading volume to $1.1 million all at once:  “Yesterday I already raised
volume above 120k, I suggest not to put 1.1 million at once, and raise it step by step, for
example, tomorrow make 200k and in couple days 300 and so on, this has to be done because
CMC [i.e., CoinMarketCap] itself can detect suspicious activity in the market and exclude
volumes from bitmart.”
120. The purpose of this wash trading was always the same—to use the artificial
trading volume to lure investors to buy Robo Inu.  Some of these increases in trading volume
lasted days and occurred alongside Pham’s efforts to promote Robo Inu to the investing public.
Additional examples of this volume manipulation are summarized below.
B. March 5 - 9, 2023:  At Pham’s Direction, Gotbit Artificially Inflated Robo
Inu’s Daily Trading Volume Above $1 Million.

121. On March 5, 2023, Pham sought to generate interest in Robo Inu by having it
appear on CoinMarketCap as one of the “most viewed” crypto assets by visitors to that website.

28
 
122. To accomplish this, Pham hired an individual she referred to as “Lara” to increase
Robo Inu’s viewership rankings on CoinMarketCap.  Pham and “Lara” communicated via a
private Telegram chat that was separate from Pham’s group chat with Kedrov and other Gotbit
employees.  In that separate, private chat, “Lara” told Pham that if Robo Inu’s daily trading
volume reached $1 million, she could inflate Robo Inu’s viewership rankings for a fee of $500.
123. Robo Inu’s daily trading volume was, at the time, less than $200,000—and most
of that volume consisted of Gotbit trading the token with itself.  Pham responded to “Lara” that
she would “check with our MM [market maker]” to see if it could artificially inflate Robo Inu’s
24-hour trading volume to $1 million.
124. Pham immediately messaged the Gotbit Telegram group chat:  “How much and
how long will it take for us to raise the volume on bitmart to 1mil?”  “Vladislav Trader”
responded:  “I can do it in a [sic] ~6 hours, it will cost about 200$.”
125. Pham reported this information to “Lara” (“Just now my mm said they will help
increaae [sic] vol to 1mil in 6 hour”).  “Lara” stated she would need Robo Inu’s trading volume
to remain at $1 million for about 8 to 12 hours in order to manipulate the asset’s place on
CoinMarketCap’s “most viewed” rankings.
126. Pham immediately returned to the Gotbit Telegram group chat:  “Can we start
now?  When will it get to 1mil” in trading volume?  Gotbit’s “Vladislav Trader” confirmed he
could begin increasing Robo Inu’s trading volume immediately.  Pham asked if he still needed 6
hours to accomplish the inflation, and “Vladislav Trader” responded that he could “try faster, but
at least need[ed] about 3-4 hours.”
127. At approximately 8:48 a.m. on March 6th, “Vladislav Trader” reported Gotbit was

29
 
“starting” the volume manipulation.
5
  At the time of this exchange, Robo Inu’s cumulative 24-
hour trading volume was approximately $213,800.
6

128. Over the next several hours, “Lara” and Pham continued to monitor Robo Inu’s
24-hour trading volume.  By 2:04 p.m. that day, “Lara” told Pham “We are above 1m,” and
Gotbit separately reported to Pham that the “volume” was “done.”
129. Pham initially decided to maintain the inflated trading volume and the
manipulated viewership rankings for about 24 hours, having consulted with both “Lara” and
Gotbit on these issues.  At approximately 1:48 a.m. on March 7, 2023, Pham instructed Gotbit to
“please make sure we have 1mil volume for the next 24 hours or so,” noting that Robo Inu had
been trending as one of the most viewed tokens on CoinMarketCap for several hours.  Around
the time of this exchange Robo Inu’s 24-hour trading volume had reached over $1.7 million—
more than 8 times the 24-hour trading volume before Pham’s request.
130. Later that morning, at approximately 4:52 a.m., “Vladislav Trader” reported to
Pham that he had spent $380 thus far and had increased Robo Inu’s trading volume to $1.9
million.  Consistent with Gotbit’s description, public market data indicate that Robo Inu’s 24-
hour trading volume was in fact just above $1.9 million at the time.  Gotbit recommended that
Pham reduce the 24-hour trading volume to $1.1 million at a cost of $220 per day.
 
5
  All times are approximate.  Unless otherwise indicated, all times are either EST or EDT depending on
the communication date.
6
  Unless otherwise indicated, all price and trading volume data was obtained from public sources
including CoinGecko.com and/or CoinMarketCap.com.  These are the sources that the leaders of the
Robo Inu project regularly consulted and promoted to Robo Inu investors.  Each hour of the day,
CoinGecko provides a cumulative total of the trading volume for the preceding 24 hours.  Here, for
example, the publicly available data on CoinGecko indicated that as of 8:00 a.m. on March 6, 2023, the
cumulative trading volume over the preceding 24 hours (i.e., the total trading volume from 8:00 a.m. on
March 5, 2023, to 8:00 a.m. on March 6, 2023) was approximately $213,800.  This cumulative 24-hour
total is referred to herein as the “24-hour trading volume.”

30
 
131. “Vladislav Trader” asked how high Robo Inu ranked on CoinMarketCap’s most
viewed listing:  “By the way, what place in trending have we reached?”  Pham responded that
Robo Inu had reached “8th,” meaning that Robo Inu was the eighth most-viewed crypto asset on
CoinMarketCap.
132. Around 11:49 a.m., Pham, continuing the Telegram group chat, asked Gotbit to
continue pumping Robo Inu’s trading volume for another day.  “Vladislav Trader” responded:
“Okay, do you want to maintain 2M or 1.1M will be enough?”  Pham replied:  “No 1.1M is
enough[.]  We just need to stay on most viewed page.”  “Vladislav Trader” stated he would
maintain that volume, and Pham sent him a link to CoinMarketCap’s “most viewed” page.
“Vladislav Trader” noted that he had just checked the website and confirmed Robo Inu’s place in
CoinMarketCap’s rankings.  At the time of this exchange, Robo Inu’s 24-hour trading volume
was nearly $1.9 million; it began to fall steadily thereafter, as directed by Pham.
133. On March 7, 2023, at 10:21 p.m., Pham asked Gotbit to “please maintain the
volume,” noting that she planned to “do a twitter space” the next day at 7 p.m.
7

134. “Vladislav Trader” confirmed that he was “maintaining 1.1M as promised.”
Around the time of these messages, Robo Inu’s 24-hour trading volume was roughly $1.2
million.  The purpose of maintaining this level of artificial trading volume was to mislead
investors to believe there was substantial market interest in Robo Inu while Pham was promoting
it to current and potential investors.
135. On March 8, 2023, at 9:32 p.m., following her Twitter Space event, Pham
instructed Gotbit:  “Let’s bring down the volume to normal . . . [S]lowly reduce over the next
 
7
  Twitter spaces (now “X Spaces”) are live audio events hosted on the social media platform.  Pham used
these to promote Robo Inu to the investing public.

31
 
days.”  Robo Inu’s 24-hour trading volume around the time of her message was roughly $1.29
million.
136. A few hours later, at 12:09 a.m. on March 9, 2023, “Vladislav Trader” responded:
“Hey, okay, I have changed the settings of our bot.”  After Gotbit “changed the settings of [its]
bot,” Robo Inu’s 24-hour trading volume steadily dropped from roughly $1.5 million to about
$213,000 the next day—an artificial floor of wash trading that Gotbit had previously set.
137. This example of the manipulation of Robo Inu’s trading volume, orchestrated by
Pham and executed by Gotbit from March 5 to March 9, 2023, is summarized in the chart below.
Robo Inu 24-Hour Trading Volume:  March 6 - 10, 2023

138. Following this trading volume spike, Pham asked Gotbit in the private Telegram
group chat whether there is “a tool for people to know this is not organic volume.”  “Vladislav
Trader” replied that “ordinary users can not accurately determine whether these transactions are

32
 
made by our bot, only by indirect signs, which we try to make as organic as possible.”
139. Pham followed up by asking whether an “investment fund” as opposed to an
ordinary user would “be able to identify whether this [trading] is organic or bot?”  “Vladislav
Trader” responded that there was no tool that could conclusively establish that “these volumes
are not organic,” noting that, while other traders might assume the trading volume “was done by
a bot,” Gotbit “make[s] it so that it is not very noticeable,” such as by not “mak[ing] trades with
the same amounts” and not “mak[ing] the same volume candle.”
8

C. May 21 - 27, 2023:  At Pham’s Direction, Gotbit Artificially Inflated Robo
Inu’s Daily Trading Volume Above $1 Million.

140. In late May 2023, again working at Pham’s direction, Gotbit engaged in wash
trades to create a spike in Robo Inu’s trading volume, so that Pham could once again cause Robo
Inu to “trend[]”—as she put it—on CoinMarketCap.  Pham provided a series of instructions to
Gotbit, which they executed to inflate Robo Inu’s 24-hour trading volume by a factor of 10 in a
matter of hours.
141. On May 21, 2023, at 12:21 a.m., Pham messaged Gotbit via the private Telegram
group chat:  “Please help me to increase the volume slowly.”  She continued:  “Target to hit 1mil
and above tomorrow about 9am PST.  Maintain vol of 1mil and above throughout the day until I
say to stop.  Thank you.”  At 3:27 a.m., “Vladislav Trader” responded:  “Hello, okay no problem,
starting now.”  At that time, Robo Inu’s 24-hour trading volume was less than $100,000.
142. Over the course of the day, Gotbit slowly increased Robo Inu’s trading volume
 
8
  A “candle” is a graphic snapshot of whether the market price of a security moved positively or
negatively and to what degree.  The “candlestick” measures the opening and closing prices during a given
timeframe, and the “wick” measures the highest and lowest prices.  A “green candle” shows that a
security’s market price has increased during the relevant period, whereas a “red candle” shows that a
security’s market price has decreased during the relevant period.

33
 
through automated wash trading.  At approximately 10:00 p.m., Robo Inu’s 24-hour trading
volume had risen to approximately $345,000.
143. Unsatisfied with the progress Gotbit had made, at 10:22 p.m., Pham instructed
Gotbit:  “Pls increase the volume to 1mil.”  “Vladislav Trader” replied:  “Hello!  I will do it.”
Less than two hours later, at 12:00 a.m. on May 22nd, Robo Inu’s 24-hour trading volume was
more than $1.4 million.
144. Gotbit maintained that inflated 24-hour trading volume until 12:00 a.m. on May
23rd, when its large spike in wash trading (from 12:00 a.m. the day before) rolled off the
cumulative 24-hour trading total, causing that cumulative total to drop to approximately
$623,000.  Robo Inu’s 24-hour trading volume continued to fall steadily to roughly $209,000 by
6:00 p.m.
145. At 6:15 p.m., Pham asked both “Vladimir” and “Vladislav Trader”:  “Why dont
[sic] maintain the volume?  I hvnt [sic] said stop though.”  “Vladislav Trader” explained that he
had lowered the wash-trading volume “cause organic sellers tried to sell into our bot,” but agreed
to “increase it back fast.”
146. Gotbit then ramped up its automated wash trading, pushing the 24-hour trading
volume to more than $875,000 by 8:00 p.m.
147. At 11:26 p.m., Gotbit reported to Pham that Robo Inu’s trading volume was $1.15
million.  Gotbit maintained Robo Inu’s 24-hour trading volume at more than $1 million
(generally between $1.1 and $1.4 million) until the evening of May 24, 2023.  At that point, at
the request of Pham and another leader of the Robo Inu project, Gotbit agreed to slowly reduce
the trading volume.
148. Over the next hour, Gotbit reduced the 24-hour trading volume from more than $1

34
 
million to approximately $740,000.  Gotbit then slowly reduced its wash trading further
throughout May 26, 2023.  By 1:00 a.m. on the morning of May 27, 2023, the 24-hour trading
volume was approximately $102,000.
149. This example of the manipulation of Robo Inu’s trading volume, orchestrated by
Pham and executed by Gotbit from May 21 to May 27, 2023, is summarized in the chart below.
Robo Inu 24-Hour Trading Volume:  May 21 - 27, 2023

V. Gotbit Artificially Inflated Robo Inu’s Trading Volume on Uniswap.

150. Pham also sought to have Gotbit increase Robo Inu’s daily trading volume by
buying and selling Robo Inu tokens in roughly equal proportion on Uniswap.  This artificial
trading was intended to create the false impression that a robust market existed for Robo Inu on
Uniswap.  Leaders of the Robo Inu project and Gotbit both believed that this artificial trading

35
 
would, in turn, encourage the investing public to trade Robo Inu.
151. Gotbit started its manipulative trading on Uniswap on or about March 18, 2022.
152. This trading served no legitimate economic purpose.  It was designed and
intended to give the appearance to unsuspecting, would-be Robo Inu investors that Robo Inu’s
trading volume was robust across trading platforms.  The lack of economic purpose is
demonstrated, in part, by the steep cost in Ethereum network fees—which are required to
conduct transactions on the Ethereum blockchain—that Gotbit incurred to engage in these trades
on Uniswap, only to end up with a low net position in Robo Inu.
153. To minimize these Ethereum network fees, often called “gas,” Gotbit decided to
keep the number of daily transactions low, which necessitated increasing the size of each trade in
order to reach the daily trading volume target Gotbit set with Pham.  A consequence of this
manipulative trading strategy was large swings in Robo Inu’s price on Uniswap.  These price
swings were visible to the investing public, which could view Robo Inu’s price and trading
volume in real time in graphs and charts available on websites such as CoinMarketCap,
CoinGecko, and DEXTools.
154. Gotbit and Pham watched those graphs and charts closely.  Pham was concerned
that Gotbit’s volume pumping strategy caused the “chart” to “look[] unnatural” and could drive
away investors instead of luring them to buy Robo Inu.
155. Below is a March 19, 2022 excerpt from the private Telegram group chat
involving Pham and several Gotbit employees, among others.  In this excerpt, Pham and Gotbit
discussed their intention to inflate the volume of daily trading on Uniswap to draw new investors
to Robo Inu; the difficulty of doing so without incurring substantial network fees; and their
desire to have the trading appear to be organic to the investing public, and not the result of Pham

38
 
VI. At Pham’s Direction, Gotbit Manipulated Robo Inu’s Price.

158. In addition to artificially inflating the trading volume of Robo Inu, Gotbit also
manipulated the price of Robo Inu.
159. For instance, on March 8, 2023, Pham asked Gotbit to calculate how much it
would cost to increase the price of Robo Inu by 30 percent.  After Gotbit replied that it would
cost more than $19,000, one of Pham’s associates responded:  “OK let us try.”
160. Members of Robo Inu’s leadership team then set about pumping up Robo Inu’s
price on Uniswap, while Gotbit simultaneously pumped Robo Inu’s price on Bitmart.  Publicly
available price data indicate that, in the hour that this exchange took place, the price of Robo Inu
increased approximately 30.8 percent.
VII. Pham Planned to Further Manipulate the Price and Trading Volume of Robo Inu
Though a Series of Coordinated Purchases Before Law Enforcement Intervened.

161. In or around February 2024, Pham decided to inflate the price of Robo Inu by
coordinating a series of purchases by a group of investors and project participants.  It was
essentially the same plan she had executed with other leaders of the Saitama project in July 2021
to inflate the price of Saitama.
162. On February 8, 2024, Pham created a private group chat on Telegram with
Individual 2 and Hernandez, whom Pham introduced to Individual 2.  The purpose was to
discuss plans to manipulate the price and trading volume of Robo Inu, among other things.
163. On February 9, 2024, Individual 2 sent a message to the group:  “What RBIF
needs now is trading volume and more holder growth to break out.”
164. On February 12, 2024, Hernandez responded that Pham “and myself definitely
know this from the Saitama days as with out [sic] volume there is no hype, movement or fomo so
to speak.”  Individual 2 stated that he agreed with Hernandez and that “a project without volume

39
 
will die day by day; new investors will only look at volume to decide whether to invest or not.”
Individual 2 suggested either creating a “bot” to “pump price, draw beautiful charts, increase
volume appropriately” or to hire a “market maker” to do the same.
165. Pham stated that the plan was to “instil[l] the hype and fomo elements” as had
previously been done “successfully at saitama,” referring to the manipulation of Saitama’s price
through coordinated purchases in July 2021.
166. On February 13, 2024, having discussed various technical issues regarding the
Robo Inu ecosystem, Pham told the group:  “Next step is to hype and pump.”
167.  On February 16, 2024, Pham touted her affiliation with Saitama on X, asserting
that she had previously led the “#SaitamaWolfPack,” and stated:  “[L]et’s watch everything
slowly unfold in the coming weeks/months and what the right leadership with passion can do and
maybe I will make that history again.”
168. Meanwhile, Pham began contacting others to participate in her scheme to
manipulate the price of Robo Inu.
169. On February 27, 2024, Pham, Individual 2, Hernandez, and others participated in
a video call during which Pham and Individual 2 discussed their plans to manipulate the price of
Robo Inu through a series of coordinated purchases.
170. A purported venture capital investor on the call stated to Pham and Individual 2:
“It sounds like you have a plan in place basically to run back kinda like the Saitama playbook.
Coordinated buys you spread them across the wallets.  Obviously, that’s key to pushing the
volume and the price, attracting new buys, we love that plan.”  The purported investor then
asked:  “I was just wondering what is your timeline looking like for this?”
171. Pham responded, “We are already ready” and reiterated that the plan was “push

40
 
the volume” and cause “FOMO and the, you know, the hype.”
172. In early March 2024, Pham contacted several individuals to enlist their
involvement in coordinated purchases to pump up the price of Robo Inu.
173. Law enforcement intervened to prevent Pham from executing her plan to
manipulate the price of Robo Inu.
FIRST CLAIM FOR RELIEF
UNREGISTERED OFFERINGS OF SECURITIES
(Violations of Sections 5(a) and 5(c) of the Securities Act)

174. Paragraphs 1 through 173 above are re-alleged and incorporated by reference as if
fully set forth herein.
175. At all relevant times, Saitama and Robo Inu were each offered and sold as a
security under Section 2(a)(10) of the Securities Act [15 U.S.C. § 77b(a)(10)].
176. By reason of the conduct described above, the Defendant, directly or indirectly:
(i) made use of the means or instruments of transportation or communication in interstate
commerce or of the mails to sell, through the use or medium of a prospectus or otherwise,
securities as to which no registration statement has been in effect and for which no exemption
from registration has been available; and/or (ii) made use of the means or instruments of
transportation or communication in interstate commerce or of the mails to offer to sell, through
the use or medium of a prospectus or otherwise, securities as to which no registration statement
has been filed and for which no exemption from registration has been available.
177. As a result, the Defendant violated Sections 5(a) and (c) of the Securities Act
[15 U.S.C. §§ 77e(a) and (c)] and will continue to violate those sections unless enjoined.

41
 
SECOND CLAIM FOR RELIEF
FRAUD IN THE OFFER OR SALE OF SECURITIES
(Violations of Sections 17(a)(1) and (3) of the Securities Act)

178. Paragraphs 1 through 173 above are re-alleged and incorporated by reference as if
fully set forth herein.
179. At all relevant times, Saitama and Robo Inu were each offered and sold as a
security under Section 2(a)(1) of the Securities Act [15 U.S.C. § 77b(a)(1)].
180. By reason of the conduct described above, Defendant, 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.
181. By reason of the conduct described above, Defendant Pham violated Securities
Act Sections 17(a)(1) and (3) [15 U.S.C. §§ 77q(a)(1) and (3)] and will continue to violate those
sections unless enjoined.
THIRD 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))

182. Paragraphs 1 through 173 above are re-alleged and incorporated by reference as if
fully set forth herein.
183. At all relevant times, Saitama and Robo Inu were each offered and sold as a
security under Section 3(a)(10) of the Exchange Act [15 U.S.C. § 78c(a)(10)].
184. By reason of the conduct described above, Defendant, directly or indirectly, in
connection with the purchase or sale of securities, by the use of the means or instrumentalities of

42
 
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.
185. By reason of the conduct described above, Defendant violated 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 and will continue to violate those provisions unless enjoined.
FOURTH CLAIM FOR RELIEF
MARKET MANIPULATION
(Violations of Section 9(a)(2) of the Exchange Act)

186. Paragraphs 1 through 173 above are re-alleged and incorporated by reference as if
fully set forth herein.
187. At all relevant times, Saitama and Robo Inu were each offered and sold as a
security under Section 3(a)(10) of the Exchange Act [15 U.S.C. § 78c(a)(10)].
188. By reason of the conduct described above, Defendant Pham, directly or indirectly,
effected a series of transactions in a security not registered on a national securities exchange,
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.
189. By reason of the conduct described above, Defendant Pham violated Exchange
Act Section 9(a)(2) [15 U.S.C. § 78i(a)(2)] and will continue to violate that section unless
enjoined.
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that this Court:

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A. Enter a permanent injunction restraining the Defendant, her agents, servants,
employees and attorneys, and those persons in active concert or participation with her who
receive actual notice of the injunction by personal service or otherwise, from violating Sections
5(a) and (c), and 17(a)(1) and (3) of the Securities Act [15 U.S.C. §§ 77e(a) and (c); 77q(a)(1)
and (3)], and Sections 9(a)(2) and 10(b) of the Exchange Act [15 U.S.C. §§ 78i(a)(2) and 78j(b)]
and Rules 10b-5(a) and (c) thereunder [17 C.F.R. §§ 240.10b-5(a) and (c)];
B. Order Defendant to disgorge, with prejudgment interest, all ill-gotten gains
obtained by reason of the unlawful conduct alleged in this Complaint pursuant to Sections
21(d)(5) and (7) of the Exchange Act [15 U.S.C. §§ 78u(d)(5) and (7)];
C. Order Defendant 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)];
D. Enter an order
 pursuant to Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)]
and Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)] barring Defendant from acting
as an officer or director of any issuer that has a class of securities registered pursuant to Section
12 of the Exchange Act [15 U.S.C. § 78l] or that is required to file reports pursuant to Section
15(d) of the Exchange Act [15 U.S.C. § 78o(d)];
E. Enter an order prohibiting Defendant from participating, directly or indirectly,
including but not limited to through any entity controlled by her, in any offering of securities,
including any crypto asset security; provided however, that such injunction shall not prevent her
from purchasing or selling securities, including crypto asset securities, for her own account.
F. Retain jurisdiction over this action to implement and carry out the terms of all
orders and decrees that may be entered; and

44
 
G. 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:  October 9, 2024.

                                                                        Respectfully            submitted,
/s/ David J. D’Addio
David J. D’Addio (Mass. Bar No. 665790)
Amy Harman Burkart (Mass. Bar No. 651828)
Ivan Panchenko (Mass. Bar No. 693552)
Jeffrey Cook (Fla. Bar No. 647578)
Joy Guo (N.Y. Bar No. 5294764)

      SECURITIES AND EXCHANGE COMMISSION
Boston Regional Office
33 Arch St., 24
th
 Floor
Boston, MA 02110
Phone:  (617) 573-4526 (D’Addio direct)
Fax:  (617) 573-4590 (fax)
[email protected] (D’Addio email)

UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 

 

 
SECURITIES AND EXCHANGE 
COMMISSION, 
 
    Plaintiff, 
 v. 
 
VY PHAM, a/k/a/ “msvy_crypto,” 
 
    Defendant. 
 

 
 

 
 

 
Civil Action No. 24-CV-____(___) 

 
JURY TRIAL DEMANDED 

 
 

 
COMPLAINT 

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

the following against the defendant, Vy Pham, a/k/a/ “msvy_crypto”: 

SUMMARY  

1. This action arises from Defendant Vy Pham’s unregistered offers and sales of two 

crypto assets as securities, and from her schemes to manipulate the market for those securities.  

2. In the spring of 2021, Pham participated in the launch of “Saitama Inu” 

(“Saitama”)—a crypto asset that was offered and sold as a security.  Pham and other individuals 

led a project to increase the value of Saitama.  They claimed that the token would create wealth 

for investors through passive income and would supposedly promote financial literacy and global 

financial well-being.  They then manipulated the price and trading volume of that crypto asset 

through coordinated purchases designed to lure in new investors by creating the illusion of 

growing market interest in Saitama.  Pham’s involvement in the Saitama project was short lived, 

however.  Soon after pumping up the price and trading volume of Saitama through manipulative 

trading, she had a falling out with other members of Saitama’s leadership team, sold her Saitama 

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holdings, and left the project in the summer of 2021.  Other leaders of the Saitama project 

continued without her and have been charged with numerous violations of the federal securities 

laws.  See SEC v. Russell Armand et al. (D. Mass. 2024). 

3. Later in 2021, Pham launched a different crypto asset called the “Robo Inu 

Finance token” (“Robo Inu”)—a token “inspired by NASA’s ambitious plan to launch Robo-

dogs to Mars.”  Pham once again promised investors that she would build a fintech “ecosystem” 

designed to “maximize value” for the holders of Robo Inu.   

4. Upon offering Robo Inu to the investing public, Pham and others at her behest 

worked to create active secondary markets on which Robo Inu could be traded.  But there was 

little natural market interest in Robo Inu.  So Pham hired Gotbit Consulting LLC (“Gotbit”) to 

engage in manipulative trading on her behalf.  Gotbit, which purports to provide “market 

making” services to crypto asset projects, generated millions of dollars in artificial daily trading 

volume by trading Robo Inu with itself and, in the process, creating the illusion of public interest 

and enthusiasm for Robo Inu.  The purpose of this self-trading, also known as “wash trading,” 

was to induce the purchase of Robo Inu by the investing public.   

5. This manipulation campaign ran from February 2022 through at least June 2023.  

While Gotbit was artificially inflating Robo Inu’s trading volume, Pham and other leaders of the 

Robo Inu project promoted Robo Inu to the investing public through social media and other 

public communication channels, including X (formerly Twitter), YouTube, Reddit, and the 

publishing platform Medium, along with a website and a whitepaper describing Robo Inu and the 

efforts of Pham and others to create an ecosystem of applications that would generate value for 

Robo Inu holders.   

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6. Pham offered and sold both Saitama and Robo Inu to the investing public as 

securities.  She was therefore required to register those offers and sales with the SEC unless an 

exemption from registration was available.  Pham did not file a registration statement with the 

SEC for those offers or sales, and no exemption from registration was available.   

7. Moreover, Pham’s conduct has caused significant harm—to the integrity of the 

markets and to the investor victims who traded in crypto assets fraudulently lured by the fake 

volumes and prices that she procured.   

VIOLATIONS 

8. As a result of the conduct alleged herein, Pham violated, and unless restrained and 

enjoined will continue to violate, Sections 5(a), 5(c), 17(a)(1), and 17(a)(3) of the Securities Act 

of 1933 (“Securities Act”) [15 U.S.C. §§ 77e(a) and (c), and 77q(a)(1) and (a)(3)], Sections 

9(a)(2) and 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. 

§§ 78i(a)(2) and 78j(b)], and Rules 10b-5(a) and (c) thereunder [17 C.F.R. §§ 240.10b-5(a) and 

(c)].   

RELIEF SOUGHT 

9. The Commission seeks permanent injunctions against Pham, disgorgement of all 

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

interest pursuant to Sections 21(d)(5) and (7) of the Exchange Act [15 U.S.C. § 78u(d)(5) and 

(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 pursuant to Section 20(e) 

of the Securities Act [15 U.S.C. § 77t(e)] and Section 21(d)(2) of the Exchange Act [15 U.S.C. 

§ 78u(d)(2)] barring Pham from acting as an officer or director of any issuer that has a class of 

securities registered pursuant to Section 12 of the Exchange Act [15 U.S.C. § 78l] or that is 

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required to file reports pursuant to Section 15(d) of the Exchange Act [15 U.S.C. § 78o(d)]; and 

an order prohibiting Pham from participating, directly or indirectly, including but not limited to 

through any entity controlled by her, in any offering of securities, including any crypto asset 

security, provided however, that such injunction shall not prevent her from purchasing or selling 

securities, including crypto asset securities, for her personal account; and such other relief as the 

Court may deem appropriate. 

JURISDICTION AND VENUE 

10. 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]. 

11. 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.  

Specifically, the Defendant offered securities to individuals who reside in the District, and 

promoted those securities to individuals residing in the District via social media and other 

communications platforms.   

DEFENDANT 

12. Vy Pham is a citizen of Vietnam and resides in Los Angeles, California.  At all 

relevant times, she has held herself out publicly as the leader of the project related to Robo Inu 

and as a founder and Chief Executive Officer of Robo Global Investment PTE, Ltd.    

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RELATED INDIVIDUALS AND ENTITIES 

13. Russell Armand, a/k/a “Saitamaguru1,” 42, resides in Texas.  At all relevant 

times, Armand was the Chief Executive Officer of the Saitama project.   

14. Maxwell Hernandez, a/k/a “MaxEquation,” 36, resides in Massachusetts.  At all 

relevant times, Hernandez was the Chief Technology Officer of the Saitama project.   

15. Manpreet Singh Kohli, a/k/a “Mkay Saitama,” a/k/a “mannythehitman,” 39, 

resides in India and London, England.  At all relevant times, Kohli was the Chief Financial 

Officer of the Saitama project.   

16. Nam Tran, a/k/a “Ntran1234,” 49, is believed to reside in Washington.  At all 

relevant times, Tran was the Chief Business Officer of the Saitama project. 

17. The Commission has charged Armand, Hernandez, Kohli, and Tran with federal 

securities law violations in a separate complaint.  See SEC v. Russell Armand et al. (D. Mass. 

2024).  They are referred to herein as the “Saitama Defendants.”  With Pham and Individual 1 

(the Saitama CMO), they are collectively referred to as the leaders of the Saitama project. 

18. Robo Global Investment PTE, Ltd. (“Robo Global”) is a limited company that 

was founded by Pham and was organized in Singapore in 2022.  Per its website, Robo Global 

purportedly “aspires to create an open ecosystem where anyone . . . can gain financial freedom” 

through the development of the Robo Inu token and related applications.  

19. Gotbit Consulting LLC, a/k/a Gotbit Hedge Fund, (“Gotbit”) is a limited liability 

company registered under the laws of Belize, with a registered office in Belize City, Belize.  

Gotbit was founded in or around 2017 and purports to have offices in Armenia, Portugal, Turkey, 

Vietnam, the United Arab Emirates, and the United Kingdom.       

20. Fedor Kedrov is believed to reside in Russia.  According to his LinkedIn profile, 

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6 
 

Kedrov is Gotbit’s Chief Operating Officer.  Gotbit’s website states that Kedrov is also the 

“Director of [the] Market Making Department.” 

21. The Commission has charged Gotbit and Kedrov with securities fraud in a 

separate complaint.  See SEC v. Gotbit Consulting LLC et al. (D. Mass. 2024).   

22. “Individual 1,” 36, resides in Texas.  Individual 1 was the Chief Marketing 

Officer of the Saitama project (the “Saitama CMO”).   

23. “Individual 2” resides in Australia and worked with Pham to manipulate the 

market for Robo Inu. 

24. An individual who identifies himself in private chats on the encrypted messaging 

platform Telegram as “Vladislav Trader” works for Gotbit.   

25. An individual who identifies himself on Telegram as “Vladimir” works for 

Gotbit.   

26. An individual who identifies himself on Telegram as “Kavi JLL” works for 

Gotbit.   

REGULATORY BACKGROUND 

27.  As the Supreme Court has recently reemphasized, the Securities Act and the 

Exchange Act “form the backbone of American securities law.”  Slack Tech., LLC v. Pirani, 598 

U.S. 759, 762 (2023).  Together, these Acts provide for the regulation of various activities in the 

markets for securities and define “security” broadly to include a wide range of assets, including 

“investment contracts.”  Securities Act § 2(a)(1) [15 U.S.C. § 77b(a)(1)]; Exchange Act 

§ 3(a)(10) [15 U.S.C. § 78c(a)(10)]. 

28. Congress enacted the Exchange Act in part to provide for the regulation of the 

national securities markets.  Congress created the SEC and charged it with protecting investors, 

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preserving fair and orderly markets, and facilitating capital formation.  In keeping with 

Congress’ goals, these Acts contain broad anti-fraud and anti-manipulation prohibitions. 

29. Sections 5(a) and 5(c) of the Securities Act generally require an issuer of 

securities to register an offering of securities through an effective registration statement before 

the securities are offered and sold to the public.  See 15 U.S.C. §§ 77e(a) and (c).  Registration 

statements for a securities offering provide public investors with material information about the 

issuer and the securities to be offered and sold.   

30. Over seventy years ago, the Supreme Court in SEC v. W.J. Howey Co., 328 U.S. 

293 (1946), set forth the relevant test for determining whether an instrument is an investment 

contract subject to regulation under U.S. securities laws.  

31. Investment contracts are transactions, contracts, or schemes through which a 

person invests money in a common enterprise and reasonably expects profits or returns derived 

from the entrepreneurial or managerial efforts of others.   

32. Congress defined “security” broadly to embody a “flexible rather than a static 

principle, one that is capable of adaptation to meet the countless and variable schemes devised by 

those who seek the use of the money of others on the promise of profits.”  Id. at 299. 

BACKGROUND ON CRYPTO ASSETS 

33. As used herein, the terms “crypto asset” or “token” generally refer to an asset 

issued and/or transferred using blockchain or distributed ledger technology, including assets 

referred to colloquially as a “digital asset,” “cryptocurrency,” “virtual currency,” and digital 

“coin.”   

34. A blockchain or distributed ledger is a database spread across a network of 

computers that records all transactions in theoretically unchangeable, digitally recorded data 

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packages, referred to as “blocks.”  The system relies on cryptographic techniques for secure 

recording of transactions. 

35. The Ethereum blockchain is an example of a blockchain.  Ether (or “ETH”) is the 

Ethereum blockchain’s native token.  (Some crypto assets may be “native tokens” to a particular 

blockchain—meaning that they are represented on their own blockchain, though other crypto 

assets may also be represented on that same blockchain, as is the case with the Ethereum 

blockchain.) 

36. ERC-20 is a standard protocol (or technical specification of the type of crypto 

token) currently used on the Ethereum blockchain to create and represent tokens on that 

blockchain. 

37. A crypto asset “wallet” is hardware or software that enables users to store private 

keys, which function like passwords that are used to access and transfer crypto assets. 

38. Crypto asset trading platforms allow their customers to purchase and sell crypto 

assets for fiat currency (legal tender issued by a country) or for other crypto assets, depending on 

the platform.  “Off-chain” transactions are tracked in the internal recordkeeping mechanisms of 

the platform but do not involve transferring crypto assets from one wallet to another, while “on-

chain” transactions are those involving the transfer of a crypto asset from one blockchain address 

to another. 

39. On July 25, 2017, the SEC issued the Report of Investigation Pursuant to Section 

21(a) of the Securities Exchange Act of 1934:  The DAO, advising “those who would use . . . 

distributed ledger or blockchain-enabled means for capital raising[] to take appropriate steps to 

ensure compliance with the U.S. federal securities laws,” and finding that the offering of crypto 

assets at issue in that report involved investment contracts and thus securities. 

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BACKGROUND ON MARKET MAKERS 

40. “Market makers” are in the business of buying securities from those who wish to 

sell, and selling securities to those who wish to buy, and operate in many traditional securities 

markets.  Market makers “make markets” by continuously and publicly quoting both a price at 

which they are willing to buy a security (the “bid”) and a higher price at which they are willing 

to sell the security (the “ask”).  The difference between these prices is known as the “bid-ask 

spread,” (or just “the spread”) and is one of the ways market makers earn money through both 

buying and selling—i.e., “making a market” for—securities. 

41. Market makers can affect the liquidity, depth, and efficiency of markets by 

ensuring that there is always a counterparty willing to transact with buyers and sellers at publicly 

quoted prices.  This is especially the case for thinly traded securities, where there may be few 

“natural” (or “organic”) buyers and sellers in the market.  A market maker can provide liquidity 

to a seller of a security when it is difficult to find a natural buyer, or to a buyer of a security 

when it is difficult to find a natural seller. 

42. In traditional securities markets, trading platforms such as national securities 

exchanges frequently offer incentives for market makers to provide real liquidity to traders on 

the platform, even for illiquid securities and during periods of market stress. 

43. In traditional securities markets, market makers and other market participants are 

regulated with a view toward promoting benefits to the overall market and deterring any conflicts 

of interest or unfair trading advantages.  Market makers are subject to requirements regarding 

registration, capital, trade reporting, and business conduct standards, among other things.  By 

contrast, self-described market makers operating on unregistered crypto asset trading platforms 

do not adhere to these requirements.  In such an environment and in the absence of regulatory 

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compliance and its concomitant oversight, market makers have ample opportunities to act on 

powerful incentives to manipulate a token’s price and/or trading volume. 

44. For example, unlike in the traditional, regulatorily compliant markets, in the 

crypto asset markets it is often the token offeror who pays these market makers a monthly fee, 

and they may pay these fees for artificially inflating trading volumes to create the false 

impression that there is a robust market for what is in reality a thinly traded crypto asset.  A 

market maker might accomplish this by using one or more accounts it directly or indirectly 

controls to trade against its own quotation.  Here, there is no change in beneficial ownership of 

the asset traded but the appearance of a market-driven transaction.  This phenomenon is known 

as “wash trading.” 

45. Similarly, the token offeror might seek to have one or more market makers create 

artificial volume to meet minimum requirements for having their crypto asset made available on 

one or more crypto asset trading platforms.  This would give the crypto asset greater prominence 

and potentially could attract more natural buyers and sellers. 

46. Manipulative trading can benefit both the offeror and the market maker at the 

expense of natural investors; each has incentives to generate public interest in the token so that 

they can liquidate their token supplies at higher prices—particularly if the crypto asset’s offerors 

and their affiliates have retained large portions of the assets at inception (as is common in the 

crypto asset markets), which they cannot monetize absent demand from natural buyers. 

FACTS 
 

SAITAMA 
 

47. The Saitama token is an ERC-20 standard token on the Ethereum blockchain.  

48. No later than June 2021, the leaders of the Saitama project published a website 

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and a whitepaper in which they described Saitama as a “platform that promotes global financial 

wellbeing by empowering the youth to be in control of their money and create their own wealth 

opportunities.”1   

49. According to the whitepaper, the Saitama project leaders would build an 

“ecosystem” of products and services specifically built for Saitama, including:   

a. a smart wallet application called “SaitaMask,” which the Saitama project 

leaders described in the whitepaper as “a safe and smart wallet that will allow 

the community to store their digital assets like $SAITAMA and learn about 

finance and investment opportunities”; 

b. a marketplace called “SaitaMarket” in which individuals could “use $Saitama 

and other partner tokens to purchase goods and services”; 

c. a platform for creating and trading so-called non-fungible tokens (“NFTs”) 

called “SaitaMaker” in which users could “create, launch and promote 

projects based on the $SAITAMA monetary system”; and 

d. a “multi-channel content platform” called “Saitama Edutainment” that would 

educate young investors “on how to save, invest, manage money and create 

wealth opportunities while entertaining our audience.”   

I. Pham Engaged in Unregistered Offers and Sales of Saitama.  

50. Pham offered and sold Saitama as a security, specifically as an investment 

contract, on numerous crypto asset trading platforms.   

51. First, Saitama purchasers, including those who bought it on crypto asset trading 

 
1  According to the Saitama whitepaper, the Saitama “brand and token name took inspiration from the 
legend of a mysterious ‘ghost dog’ that is said to be roaming the mountains in the region of Saitama in 
Japan” and is revered as “a guardian against misfortune.”  

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platforms, invested money—specifically U.S. dollars, Bitcoin, or ETH—when they purchased 

Saitama. 

52. Second, all Saitama purchasers invested in a common enterprise with each other 

and with the Saitama project leaders, who at all relevant times retained significant Saitama 

holdings.  Because the value of Saitama rose or fell together for all holders, all Saitama holders 

profited or suffered losses equally in amounts proportionate to their Saitama holdings.  As such, 

their financial fortunes—including the realization of future profits—were inextricably tied to the 

financial fortunes of each other as well as those of the Saitama project leaders.  

53. Pham and other Saitama project leaders offered and sold Saitama to the investing 

public both to enrich themselves personally, and to collectively fund their efforts to develop the 

“Saitama ecosystem.”   

54. In addition, Saitama investors’ financial fortunes depended on the Saitama project 

leaders’ efforts to grow the Saitama ecosystem, including by creating new uses for Saitama such 

that its utility would increase, thereby increasing the demand for, and correspondingly the price 

of, Saitama.   

55. Moreover, for each on-chain Saitama transaction, two percent of the value of the 

transaction was redistributed to Saitama holders in proportion to their Saitama holdings, and 

another two percent of the value of the transaction was “burned” or destroyed, decreasing the 

supply of Saitama.2  These automatic redistributions of Saitama further ensured that the financial 

fortunes of the Saitama project leaders (who held large positions in Saitama and were developing 

uses for the token, including with the proceeds of Saitama sales) and the financial fortunes of 

 
2 “Burning” crypto assets refers to sending those assets to an inaccessible wallet from which the tokens 
cannot be withdrawn, thereby removing them from circulation.   

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other investors were intertwined.   

56. Third, the Saitama project leaders led Saitama investors to reasonably expect that 

they would profit from their Saitama investments, based on the Saitama project leaders’ 

entrepreneurial and managerial efforts.   

57. Through the Saitama website, whitepaper, social media, and other public outlets, 

Pham, Individual 1, and the Saitama Defendants held themselves out as the leaders of the 

Saitama project and the driving force behind the creation and future development, maintenance, 

and growth of the Saitama ecosystem from which Saitama derived its value.   

58. In the Saitama whitepaper that the Saitama project leaders published in June 

2021, they expressly and repeatedly described Saitama as an investment with the potential for 

substantial profit while describing themselves as the individuals who would undertake the efforts 

needed to achieve those profits—specifically, as “a group of committed individuals” that “took 

over [the Saitama] project and continued developing it.”  That development took the form of 

creating various applications, including those previously described, in which investors could 

supposedly use and trade Saitama tokens.   

59. Investors were led to reasonably expect not only that the Saitama project leaders’ 

development of these applications would increase demand for Saitama and therefore its price, but 

also that such uses would lead to additional Saitama transactions.  As described above, each on-

chain transaction resulted in a two-percent redistribution to existing Saitama holders and an 

additional two-percent burn.  From the earliest iterations of their Saitama website and 

whitepaper, the Saitama project leaders touted these aspects of Saitama as a way for investors to 

earn passive income on their Saitama holdings.   

60. Beyond their statements on the Saitama website and whitepapers, the Saitama 

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project leaders periodically explained their ongoing efforts to generate profits for Saitama 

investors in a series of public “ask me anything” interviews on YouTube, in which investors and 

potential investors could pose questions to the Saitama project leaders.   

61. On June 25, 2021, Pham moderated one of those interviews and presented 

extensive information about Saitama.  She was joined by other Saitama project leaders, including 

Armand, Hernandez, and Kohli.  During that interview, they described their plans for the project, 

including marketing, product development, and their intention to have Saitama listed on various 

trading platforms.    

62. At all relevant times, the Saitama project leaders encouraged investors to purchase 

Saitama, and provided specific instructions on how to do so on the Saitama website.  

63. As a result of the above representations and the economic reality of what Pham 

and other Saitama project leaders were offering and selling, Saitama investors had a reasonable 

expectation of profiting from the efforts of Pham and other leaders of the above-described 

project to develop the Saitama ecosystem and list Saitama on crypto asset trading platforms.   

64. In June and July 2021, Pham sold approximately $69,500 worth of Saitama to the 

investing public.   

II. Pham Engaged in Manipulative Trading of Saitama. 

65. In early July 2021, Pham and other Saitama project leaders were part of a group 

that engaged in a series of coordinated Saitama purchases intended specifically to:  (1) induce 

holders of large quantities of Saitama (referred to as “whales”) to sell their positions; (2) induce 

members of the investing public to buy Saitama; and (3) increase the price of Saitama.   

66. The Saitama project leaders were particularly concerned that if the existing 

“whales” liquidated their Saitama holdings, the price of Saitama would fall, undermining the 

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Saitama project leaders’ efforts to inflate the price of the token and increase the number of 

Saitama holders.  So the Saitama project leaders sought to buy out these whales through 

coordinated purchases.  As Pham put it in a private Telegram group chat regarding one such 

whale:  “[W]e need to lure this idiot to empty his wallet.”  Doing so would then enable the 

Saitama project leaders to inflate the price of Saitama without fear of large holders later cashing 

out and depressing the price. 

67. The plan worked.  Through their coordinated purchases across numerous wallets 

in relatively small increments, Pham and other Saitama project leaders successfully induced 

large Saitama holders to sell their positions while simultaneously attracting new Saitama 

purchasers.  During their approximately two-day buying spree, the price of Saitama increased by 

approximately 60 percent.   

68. Pham and other Saitama project leaders described their plan—and their successful 

execution of it—on July 3 and 4, 2021 in a private group chat on Telegram.   

69. In the private Telegram group chat, Armand explained that he was creating a 

separate public Telegram “shill group” to promote Saitama to potential investors.  Armand was 

confident that if he initially populated his “shill group” with some people and “some bots,” then 

“a lot of [people] will join.”  He explained:  “If we add this to a pump we create.  A lot of 

[people] will FOMO in.”3  Pham asked:  “How much are we gonna pump now?”  Armand 

responded:  “We will create an illusion of massive buys and new holders. . . .  It’ll incite [people] 

to buy more.”  Armand continued, stating the group was “[b]asically creating our own pump 

through illusion.”  

70. Kohli and Tran reported to the group that they were ready to buy, and Individual 1 

 
3  In this context, “FOMO” or “fear of missing out” refers to investors’ “fear” that they may lose out on 
profiting from an increase in a crypto asset’s price. 

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(the Saitama CMO) demonstrated his agreement with the plan with the following GIF:  

 

71. Pham, Armand, Kohli, Tran, and Individual 1 continued to discuss the optimal 

size of their purchases to accomplish the “pump.”   

72. The Saitama project leaders coordinated their purchases with Armand’s public 

“shilling” of Saitama on Telegram.  As potential investors joined Armand’s public Telegram 

group, Pham and the rest of the Saitama project leaders each began purchasing Saitama.  Armand 

instructed them to purchase two to three trillion Saitama per transaction.  Although numerically 

large, two to three trillion Saitama was small relative to the total initial supply of Saitama, which 

was approximately 100 quadrillion.  Armand explained, “W[e] want [a] list of small buys to look 

like it’s mor[e] buyers.”  Pham, Kohli, Hernandez, Tran, and Individual 1 all began purchasing 

Saitama at Armand’s direction and discussed their transactions in the private Telegram group 

chat.   

73. For instance, Tran noted that people were joining Armand’s public Telegram chat 

group and told other Saitama project leaders to begin buying immediately.  Armand responded:  

“Is like fishing with dynamite.”  Pham, Tran, and Individual 1 agreed, each responding “Lol.”  

Pham repeatedly emphasized the need for the group to closely coordinate its purchasing (the 

timing, volume, and number of wallets), in order to maximize its impact on price and to convince 

the “whales” to sell.   

74. Pham, Individual 1, and all the Saitama Defendants participated in the 

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coordinated purchases of Saitama, which occurred in multiple rounds over the course of July 3 

and July 4, 2021.  Tran, for instance, announced in the private Telegram group chat:  “Round 2 

start [sic] now!”  Hernandez responded that he “bought a few times.”  Tran later asked the other 

Saitama project leaders:  “Round 3?”  Armand responded:  “Yea small buys,” again advising the 

Saitama project leaders to make multiple small purchases to create the appearance of broad 

public interest in Saitama and obscure the fact that a small number of Saitama insiders were 

responsible for the increased demand.  In response, Pham, Tran, and Kohli each confirmed they 

were once again buying Saitama.  Pham noted:  “[T]his is where new holders will get attracted 

. . . and give people confidence.”   

75. A few hours later, Armand told Kohli again to keep his purchases small, 

explaining that “the idea is to keep the [price] chart trending upward to generate traction and 

stability[.]  Will keep [people] from wanting to sell and will instead buy more.”  Kohli indicated 

he understood the plan:  “Gaaaaat it.”   

76. The Saitama project leaders discussed in their private Telegram group chat how 

their coordinated purchases were in fact succeeding in inducing new investors to purchase 

Saitama.  Relatively early in their efforts, Armand reported that their purchases were increasing 

the number of Saitama holders:  “Soooo success so far.”  Hernandez agreed:  “[Y]es holder 

increase is pretty steady.”  Armand later reported to the group:  “Holders are increasing nicely 

and distribution is looking much better.  We have a better foundation today then [sic] we did last 

week from the eyes of a future investor.”  Kohli responded:  “And sell again on high what we 

created.”   

77. Armand apprised the group of the status of their efforts, stating for example, 

“We’ve already bled out most of the big wallets[;] there’s only a couple that remain.”  After a 

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few hours of continued coordinated purchases by leaders of the Saitama project, Armand 

reported that one of the wallets they targeted sold roughly 800 trillion Saitama, leading Armand 

to conclude:  “Mission semi-accomplished.” 

78. The Saitama project leaders recognized the need to hide their coordinated 

purchases from the investing public not only by breaking their Saitama purchases into small 

transactions, but also by using multiple wallets to disguise their coordinated activity.  For 

example, after making a series of Saitama purchases, Kohli asked others in the private group chat 

whether he should use another account, noting “all from same looks weird.”  The Saitama CMO 

responded:  “Yes . . . Use two or 3 wallets.”  Later, Kohli commented, “I think too many from 

my address wallet,” referring to the number of Saitama purchases he made from the same wallet 

address.  Armand replied, “Yea need new wallet.” 

79. The Saitama project leaders understood that they needed to keep their coordinated 

purchases hidden from the investing public.  Kohli, for instance, warned the participants in the 

private Telegram group chat:  “Don’t involve too many in group. . . .  It will really bring 

downfall if someone take screen shot and start posting.” 

80. After two days of coordinated purchases of Saitama that eliminated many large 

wallets and expanded the number of Saitama investors, Armand complimented Pham and the rest 

of the Saitama project leaders:  “Ladies and gentlemen that is how you start a hype.  Perfectly 

executed well done all[.]  Still have to keep small buys incoming if it pulls though.  Lot of ppl 

[people] watching chart right now.”  Later in the day, after continued discussion of their 

manipulation of Saitama, Tran posted to the group:    

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81. Later in the conversation, Individual 1 (the Saitama CMO) added:   

 

82. Working in the manner and for the specific purposes described above, Pham 

purchased approximately 258.81 trillion Saitama for approximately $8,859. 

ROBO INU 
 

83. The Robo Inu token is an ERC-20 standard token on the Ethereum blockchain, 

with ticker symbol RBIF.  

84. In or around November 2021, Pham and other leaders of the Robo Inu project 

began promoting the Robo Inu token on a website and through several social media and 

communications platforms, including X (formerly Twitter), YouTube, Reddit, and the publishing 

platform Medium.  All of these communications were aimed at the investing public, including 

investors in the United States.   

85. Across these platforms, Pham and other project leaders encouraged others—

sometimes expressly referred to as “investors”—to purchase the token based on, among other 

things, Robo Inu’s “tokenomics” (aspects of a crypto asset’s design, including transaction fees 

imbedded into the smart contract) and the efforts of Pham and others to undertake a project to 

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generate value for Robo Inu investors.   

86. Pham also published a whitepaper describing what the project would entail—

efforts of her and her leadership team to create an “ecosystem” of products and services that 

would rely on or utilize Robo Inu, all of which were purportedly designed to maximize value for 

Robo Inu investors.  At that time, the Robo Inu token was available for trading on the Uniswap 

trading platform.  

87. In or around February 2022, Robo Inu was made available for trading on the 

Bitmart trading platform.  

88. In addition to promoting the token on social media, leaders of the Robo Inu 

project team continued to update its website and develop the white paper over time.  According 

to the June 2022 version of the whitepaper, the Robo Inu ecosystem included the following 

projects, some of which then remained under development: 

a. a crypto asset wallet called “RGI Wallet”; 

b. an “incubator for potential projects with real use cases” that are “checked and 

moderated by the Robo Inu Finance Team” called “RoboLaunchpad”; 

c. a platform for trading so-called non-fungible tokens (“NFTs”) called 

“RoboNFT Marketplace”;  

d. a platform called “RoboDAO” on which Robo Inu holders could vote on 

governance proposals related to Robo Global;  

e. a crypto asset trading platform called “RoboEx”; 

f. a venture fund called RoboVentures, which, as Pham explained in a Medium 

post, “will invest into SpaceX and TSLA stocks to allow $RBIF token holders 

to earn a piece of that space pie.” 

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89. Over time, Pham and her leadership team launched several of these products, 

including RGI Wallet, RoboDAO, and RoboEx.   

III. Pham Engaged in Unregistered Offers and Sales of Robo Inu.  

90. At all relevant times, Robo Inu was offered and sold as a security, specifically an 

investment contract.  

91.  First, Robo Inu purchasers, including those who bought it on crypto asset trading 

platforms such as Uniswap and Bitmart, invested money—specifically U.S. dollars, Bitcoin, or 

ETH—when they purchased Robo Inu. 

92. Second, Robo Inu purchasers invested in a common enterprise with each other 

and with Pham, Robo Global, and other Robo Inu project leaders, who at all relevant times 

retained significant Robo Inu holdings.  Because the value of Robo Inu tokens rose or fell 

together for all holders, all Robo Inu holders profited or suffered losses in amounts proportional 

to their Robo Inu holdings.  As such, their financial fortunes—including the realization of future 

profits—were inextricably tied together, including to the financial fortunes of Robo Global, 

Pham, and other Robo Inu project leaders. 

93. In addition, Robo Inu investors’ financial fortunes depended on Pham and other 

project leaders’ ability to grow the Robo Inu ecosystem, including by developing applications 

that Pham had publicly claimed would “bring the token higher and higher.”  If Pham and other 

leaders of the Robo Inu project were able to create new uses for Robo Inu, its utility would 

increase, thereby increasing the demand for (and, correspondingly, the price of) Robo Inu.   

94. Moreover, according to the Robo Inu whitepaper, each Robo Inu purchase or sale 

was subject to a “tax” designed “to fuel the growth of Robo Inu Finance’s ecosystem.”  

Specifically, all Robo Inu on-chain purchases were subject to a four-percent tax, with one 

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percent redistributed to Robo Inu holders in proportion to their Robo Inu holdings, and three 

percent transferred to a Robo Inu marketing wallet that Pham could use to promote Robo Inu.  

Similarly, all Robo Inu on-chain sales or transfers were subject to a ten-percent tax, with three 

percent redistributed to Robo Inu holders in proportion to their Robo Inu holdings, and seven 

percent transferred to a Robo Inu marketing wallet.4  These automatic redistributions of Robo 

Inu further ensured that the financial fortunes of Pham and other project leaders (who held large 

positions in Robo Inu and were purporting to use proceeds from additional sales to develop uses 

for the token) and the financial fortunes of other investors were intertwined.   

95. Third, Pham led Robo Inu investors to reasonably expect that they would profit 

from their Robo Inu investments, based on the entrepreneurial and managerial efforts of Pham 

and other leaders of the Robo Inu project. 

96. Through the Robo Inu website, whitepaper, social media, and other public outlets, 

Pham held herself out as the leader in charge of the Robo Inu project and the driving force 

behind the creation of the ecosystem from which Robo Inu derived its value.  As Pham posted on 

Reddit:  “My mission is very simple To Finish What I started, and create wealth for many . . . . 

We are in this just for one reason- W.E.A.L.T.H.” (emphasis original).  On X, she wrote:  “Buy 

RBIF and retire[.]”  In another Reddit post, Pham wrote:  “My goal is still 1bil MC [market 

capitalization,] and I will not let anything or anyone get in my ways [sic] . . . .  I can guarantee 

you that you will never regret walking down this journey with me.”   

97. Pham also set forth a plan in the June 2022 Robo Inu whitepaper to grow the 

utility and value of the token in phases that were tied to the number of Robo Inu investors.  

 
4  In or around July 2023, Robo Inu migrated to Version 2, which altered the tax and redistribution 
structure, but still retained a five-percent tax on on-chain all sales, from which one percent was 
redistributed pro rata to existing Robo Inu holders.  

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Those phases included, among other things, various new product launches (including some of the 

products identified above), listing Robo Inu on additional crypto asset trading platforms, and 

“[a]ggressive [m]arketing.” 

98. Investors were led to reasonably expect not only that Pham’s development of 

these products would increase demand for Robo Inu and therefore its price, but also that such 

efforts would lead to additional Robo Inu transactions (as Pham and other project leaders 

increased the number of ways the token could be used), which, as described above, would result 

in additional distributions of proceeds to existing Robo Inu holders.   

99. This redistribution enabled Pham to promote Robo Inu as a passive investment 

vehicle in which investors could profit simply through buying and holding Robo Inu.  As she 

posted on Reddit on November 27, 2021:  “The more you hold the more you get.”  On January 

16, 2022, she explained on X to potential investors that among the “things you will gain from 

buying and holding #RoboInu $RBIF   ” is “reflections as passive income,” referring to 

the one- or three-percent redistribution (or “reflection”) awarded to existing token holders.   

100. Pham’s pitch of Robo Inu to potential investors was not subtle.  For example, on 

March 1, 2024, Pham posted on her personal account on X:  “Come and support us #RoboInu 

$RBIF.  Promise you will get rich.”   

101. In speaking to investors, Pham expressly tied her work in developing applications 

for Robo Inu to its growth and value.  On October 3, 2022, for example, she wrote to the Robo 

Inu community on Reddit:  “I am still here, personally involving [sic] in every single meeting of 

developments to make sure we are in sync . . . .  What can’t change is us, dev [development] 

team, our commitment to deliver what we need to.”  Similarly, on March 1, 2024, she posted on 

X:  “Still have chance to accumulate $RBIF . . . #RGIWallet and #RoboEx are ready to bring the 

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token higher and higher.”   

102. Pham also led investors to reasonably expect to profit from their Robo Inu 

investments by publicly touting the results of her efforts to have Robo Inu listed on multiple 

trading platforms, where investors would be able to sell their Robo Inu.  Robo Inu initially traded 

on Uniswap, then on Bitmart for a certain period, and finally on RoboEx, the platform created by 

Pham and other leaders of the Robo Inu project.  At all relevant times, Robo Inu was available to 

United States investors on those trading platforms. 

103. As a result of the above and other representations and the economic reality of 

what Pham was offering and selling, Robo Inu investors had a reasonable expectation of 

profiting from Pham’s efforts to develop the Robo Inu ecosystem. 

IV. Pham Hired Gotbit to Artificially Inflate Robo Inu’s Trading Volume. 
 

104. Beginning in or around February 2022, Pham and the other leaders of the Robo 

Inu project initiated a private Telegram group chat with several Gotbit employees, including 

Kedrov, “Vladislav Trader,” “Vladimir,” and “Kavi JLL,” among others, to solicit their market 

manipulation services.   

105. Pham stated in the group chat that, despite having spent $250,000 on “marketing,” 

the response from investors had not been “satisfactor[y],” so she and her team were “thinking 

about increasing the volume via MM” (i.e., a “market maker”).   

106. Pham said in the group chat that the purpose of hiring Gotbit to increase and 

maintain trading volume was “to attract people to the [Robo Inu] token.”  Gotbit personnel 

confirmed they understood that this was the purpose.  Throughout the parties’ relationship, 

various individuals representing Gotbit communicated with Pham and other leaders of the Robo 

Inu project about ways to create investor “FOMO” through artificial trading volume.  For 

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example, one of Gotbit’s employees on the Telegram group chat, “Vladislav Trader,” stated that 

he was “trying to trigger organics”—i.e., individuals or entities other than Gotbit—“to buy” 

Robo Inu.   

107. Between approximately February 2022 and June 2023, Pham and others working 

with her paid Gotbit approximately $3,000 to $6,000 per month to, among other things, 

manipulate the trading volume of Robo Inu through automated wash trading on Bitmart and 

through automated buying and selling on Uniswap.  Gotbit told leaders of the Robo Inu project 

that it would be using a trading “bot,” an automated crypto asset trading program, to execute this 

manipulative trading.  

A. Gotbit Artificially Inflated Robo Inu’s Trading Volume on Bitmart. 
 

108. To facilitate manipulative trading on Bitmart, Pham and other Robo Inu project 

leaders, at Kedrov’s request, provided Gotbit with a supply of both Robo Inu and USDT (or 

“Tether”), another crypto asset.  Gotbit used this supply of Robo Inu and Tether to trade with 

itself—not to meet organic investor demand—and to artificially inflate the trading volume to 

whatever level Pham and her associates desired.   

109. In February 2022, Kedrov told Pham and other Robo Inu project leaders in their 

private Telegram group chat that Gotbit could achieve “[a]ny volume you want.”  Kedrov 

recommended that Robo Inu start with $200,000 in artificial daily volume.   

110. On multiple occasions, Gotbit personnel in the Telegram group chat confirmed 

that its manipulative trades accounted for most of the observed Robo Inu trading volume that 

was reported to websites that investors use to track crypto assets, such as CoinMarketCap and 

CoinGecko, which compile trading data from crypto asset trading platforms, including Uniswap, 

Bitmart, and many others. 

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111. For instance, in April 2022, “Vladimir” posted to the group chat that Gotbit “did 

about 250k per day average volume at current price,” and that that volume was generated “only 

by our MM,” meaning that Gotbit was trading about $250,000 of Robo Inu per day with itself—

not other market participants—creating the false impression of organic buying and selling.   

112. Similarly, in June 2022, “Vladimir” again indicated to Robo Inu project leaders in 

the group chat that the observed trading volume was “mostly . . . our [i.e., Gotbit’s] volume.”   

113. In late March 2023, “Vladislav Trader” posted to the group chat that “organic” 

volume accounted for less than 10 percent of Robo Inu’s total trading volume.  The rest was 

Gotbit trading with itself through automated wash trading.   

114. Gotbit generally maintained a stable floor of artificial trading volume on Bitmart 

at the direction of the leaders of the Robo Inu project.  The parties agreed to increase that 

artificial trading volume ahead of news announcements or other marketing efforts by Pham and 

other Robo Inu project leaders.  For example, in March 2022, in response to Pham previewing 

Robo Inu news events for Gotbit, “Vladimir” stated that he had “slightly increased the volumes 

on Bitmart before the announcements.”   

115. Similarly, in December 2022, a leader of the Robo Inu project posted to the group 

chat:  “We’ll have a trending campaign on CG [i.e., CoinGecko] and CMC [i.e., 

CoinMarketCap] tomorrow, it starts around 4-6pm UTC.  So please increase the volume once the 

campaign starts.”  Kedrov responded:  “Awesome news, sure - we start increasing the volume 

smoothly!”    

116. These trades were intended to mislead the investing public to believe that the 

market was reacting positively to Robo Inu news and/or the information conveyed in Robo Inu 

marketing.   

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117. In several instances, Pham and her associates directed Gotbit to significantly 

increase the daily trading volume of Robo Inu, sometimes above $1 million.  Gotbit attempted to 

execute these manipulations in a manner that would disguise the fact that nearly all the trading 

volume was artificial.   

118. For instance, on February 25, 2022, Pham posted to the group chat with Gotbit a 

request to “slowly increase the volume” because she was attempting to get the “token trending 

on cmc” i.e., CoinMarketCap.  Gotbit employee “Vladimir” responded:  “Yeah we can increase 

more volume gradually[.]  But it is important that our market looks organic.”   

119. Similarly, in January 2023, one of Pham’s associates posted to the group chat 

with Gotbit:  “[C]an you raise the volume on Bitmart please, above 1.1mil daily!  Thank you 

very much.”  Kedrov responded:  “Sure, will be done.”  But another Gotbit employee cautioned 

against inflating the trading volume to $1.1 million all at once:  “Yesterday I already raised 

volume above 120k, I suggest not to put 1.1 million at once, and raise it step by step, for 

example, tomorrow make 200k and in couple days 300 and so on, this has to be done because 

CMC [i.e., CoinMarketCap] itself can detect suspicious activity in the market and exclude 

volumes from bitmart.”   

120. The purpose of this wash trading was always the same—to use the artificial 

trading volume to lure investors to buy Robo Inu.  Some of these increases in trading volume 

lasted days and occurred alongside Pham’s efforts to promote Robo Inu to the investing public.  

Additional examples of this volume manipulation are summarized below.   

B. March 5 - 9, 2023:  At Pham’s Direction, Gotbit Artificially Inflated Robo 
Inu’s Daily Trading Volume Above $1 Million. 
 

121. On March 5, 2023, Pham sought to generate interest in Robo Inu by having it 

appear on CoinMarketCap as one of the “most viewed” crypto assets by visitors to that website.   

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122. To accomplish this, Pham hired an individual she referred to as “Lara” to increase 

Robo Inu’s viewership rankings on CoinMarketCap.  Pham and “Lara” communicated via a 

private Telegram chat that was separate from Pham’s group chat with Kedrov and other Gotbit 

employees.  In that separate, private chat, “Lara” told Pham that if Robo Inu’s daily trading 

volume reached $1 million, she could inflate Robo Inu’s viewership rankings for a fee of $500.   

123. Robo Inu’s daily trading volume was, at the time, less than $200,000—and most 

of that volume consisted of Gotbit trading the token with itself.  Pham responded to “Lara” that 

she would “check with our MM [market maker]” to see if it could artificially inflate Robo Inu’s 

24-hour trading volume to $1 million.     

124. Pham immediately messaged the Gotbit Telegram group chat:  “How much and 

how long will it take for us to raise the volume on bitmart to 1mil?”  “Vladislav Trader” 

responded:  “I can do it in a [sic] ~6 hours, it will cost about 200$.”   

125. Pham reported this information to “Lara” (“Just now my mm said they will help 

increaae [sic] vol to 1mil in 6 hour”).  “Lara” stated she would need Robo Inu’s trading volume 

to remain at $1 million for about 8 to 12 hours in order to manipulate the asset’s place on 

CoinMarketCap’s “most viewed” rankings.   

126. Pham immediately returned to the Gotbit Telegram group chat:  “Can we start 

now?  When will it get to 1mil” in trading volume?  Gotbit’s “Vladislav Trader” confirmed he 

could begin increasing Robo Inu’s trading volume immediately.  Pham asked if he still needed 6 

hours to accomplish the inflation, and “Vladislav Trader” responded that he could “try faster, but 

at least need[ed] about 3-4 hours.”   

127. At approximately 8:48 a.m. on March 6th, “Vladislav Trader” reported Gotbit was 

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“starting” the volume manipulation.5  At the time of this exchange, Robo Inu’s cumulative 24-

hour trading volume was approximately $213,800.6   

128. Over the next several hours, “Lara” and Pham continued to monitor Robo Inu’s 

24-hour trading volume.  By 2:04 p.m. that day, “Lara” told Pham “We are above 1m,” and 

Gotbit separately reported to Pham that the “volume” was “done.”  

129. Pham initially decided to maintain the inflated trading volume and the 

manipulated viewership rankings for about 24 hours, having consulted with both “Lara” and 

Gotbit on these issues.  At approximately 1:48 a.m. on March 7, 2023, Pham instructed Gotbit to 

“please make sure we have 1mil volume for the next 24 hours or so,” noting that Robo Inu had 

been trending as one of the most viewed tokens on CoinMarketCap for several hours.  Around 

the time of this exchange Robo Inu’s 24-hour trading volume had reached over $1.7 million—

more than 8 times the 24-hour trading volume before Pham’s request.   

130. Later that morning, at approximately 4:52 a.m., “Vladislav Trader” reported to 

Pham that he had spent $380 thus far and had increased Robo Inu’s trading volume to $1.9 

million.  Consistent with Gotbit’s description, public market data indicate that Robo Inu’s 24-

hour trading volume was in fact just above $1.9 million at the time.  Gotbit recommended that 

Pham reduce the 24-hour trading volume to $1.1 million at a cost of $220 per day.   

 
5  All times are approximate.  Unless otherwise indicated, all times are either EST or EDT depending on 
the communication date.   

6  Unless otherwise indicated, all price and trading volume data was obtained from public sources 
including CoinGecko.com and/or CoinMarketCap.com.  These are the sources that the leaders of the 
Robo Inu project regularly consulted and promoted to Robo Inu investors.  Each hour of the day, 
CoinGecko provides a cumulative total of the trading volume for the preceding 24 hours.  Here, for 
example, the publicly available data on CoinGecko indicated that as of 8:00 a.m. on March 6, 2023, the 
cumulative trading volume over the preceding 24 hours (i.e., the total trading volume from 8:00 a.m. on 
March 5, 2023, to 8:00 a.m. on March 6, 2023) was approximately $213,800.  This cumulative 24-hour 
total is referred to herein as the “24-hour trading volume.”    

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131. “Vladislav Trader” asked how high Robo Inu ranked on CoinMarketCap’s most 

viewed listing:  “By the way, what place in trending have we reached?”  Pham responded that 

Robo Inu had reached “8th,” meaning that Robo Inu was the eighth most-viewed crypto asset on 

CoinMarketCap.  

132. Around 11:49 a.m., Pham, continuing the Telegram group chat, asked Gotbit to 

continue pumping Robo Inu’s trading volume for another day.  “Vladislav Trader” responded:  

“Okay, do you want to maintain 2M or 1.1M will be enough?”  Pham replied:  “No 1.1M is 

enough[.]  We just need to stay on most viewed page.”  “Vladislav Trader” stated he would 

maintain that volume, and Pham sent him a link to CoinMarketCap’s “most viewed” page.  

“Vladislav Trader” noted that he had just checked the website and confirmed Robo Inu’s place in 

CoinMarketCap’s rankings.  At the time of this exchange, Robo Inu’s 24-hour trading volume 

was nearly $1.9 million; it began to fall steadily thereafter, as directed by Pham.   

133. On March 7, 2023, at 10:21 p.m., Pham asked Gotbit to “please maintain the 

volume,” noting that she planned to “do a twitter space” the next day at 7 p.m.7 

134. “Vladislav Trader” confirmed that he was “maintaining 1.1M as promised.”  

Around the time of these messages, Robo Inu’s 24-hour trading volume was roughly $1.2 

million.  The purpose of maintaining this level of artificial trading volume was to mislead 

investors to believe there was substantial market interest in Robo Inu while Pham was promoting 

it to current and potential investors.   

135. On March 8, 2023, at 9:32 p.m., following her Twitter Space event, Pham 

instructed Gotbit:  “Let’s bring down the volume to normal . . . [S]lowly reduce over the next 

 
7  Twitter spaces (now “X Spaces”) are live audio events hosted on the social media platform.  Pham used 
these to promote Robo Inu to the investing public.   

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days.”  Robo Inu’s 24-hour trading volume around the time of her message was roughly $1.29 

million.   

136. A few hours later, at 12:09 a.m. on March 9, 2023, “Vladislav Trader” responded:  

“Hey, okay, I have changed the settings of our bot.”  After Gotbit “changed the settings of [its] 

bot,” Robo Inu’s 24-hour trading volume steadily dropped from roughly $1.5 million to about 

$213,000 the next day—an artificial floor of wash trading that Gotbit had previously set.    

137. This example of the manipulation of Robo Inu’s trading volume, orchestrated by 

Pham and executed by Gotbit from March 5 to March 9, 2023, is summarized in the chart below.   

Robo Inu 24-Hour Trading Volume:  March 6 - 10, 2023 

 

138. Following this trading volume spike, Pham asked Gotbit in the private Telegram 

group chat whether there is “a tool for people to know this is not organic volume.”  “Vladislav 

Trader” replied that “ordinary users can not accurately determine whether these transactions are 

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made by our bot, only by indirect signs, which we try to make as organic as possible.” 

139. Pham followed up by asking whether an “investment fund” as opposed to an 

ordinary user would “be able to identify whether this [trading] is organic or bot?”  “Vladislav 

Trader” responded that there was no tool that could conclusively establish that “these volumes 

are not organic,” noting that, while other traders might assume the trading volume “was done by 

a bot,” Gotbit “make[s] it so that it is not very noticeable,” such as by not “mak[ing] trades with 

the same amounts” and not “mak[ing] the same volume candle.”8 

C. May 21 - 27, 2023:  At Pham’s Direction, Gotbit Artificially Inflated Robo 
Inu’s Daily Trading Volume Above $1 Million. 
 

140. In late May 2023, again working at Pham’s direction, Gotbit engaged in wash 

trades to create a spike in Robo Inu’s trading volume, so that Pham could once again cause Robo 

Inu to “trend[]”—as she put it—on CoinMarketCap.  Pham provided a series of instructions to 

Gotbit, which they executed to inflate Robo Inu’s 24-hour trading volume by a factor of 10 in a 

matter of hours.  

141. On May 21, 2023, at 12:21 a.m., Pham messaged Gotbit via the private Telegram 

group chat:  “Please help me to increase the volume slowly.”  She continued:  “Target to hit 1mil 

and above tomorrow about 9am PST.  Maintain vol of 1mil and above throughout the day until I 

say to stop.  Thank you.”  At 3:27 a.m., “Vladislav Trader” responded:  “Hello, okay no problem, 

starting now.”  At that time, Robo Inu’s 24-hour trading volume was less than $100,000.   

142. Over the course of the day, Gotbit slowly increased Robo Inu’s trading volume 

 
8  A “candle” is a graphic snapshot of whether the market price of a security moved positively or 
negatively and to what degree.  The “candlestick” measures the opening and closing prices during a given 
timeframe, and the “wick” measures the highest and lowest prices.  A “green candle” shows that a 
security’s market price has increased during the relevant period, whereas a “red candle” shows that a 
security’s market price has decreased during the relevant period. 

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through automated wash trading.  At approximately 10:00 p.m., Robo Inu’s 24-hour trading 

volume had risen to approximately $345,000.   

143. Unsatisfied with the progress Gotbit had made, at 10:22 p.m., Pham instructed 

Gotbit:  “Pls increase the volume to 1mil.”  “Vladislav Trader” replied:  “Hello!  I will do it.”  

Less than two hours later, at 12:00 a.m. on May 22nd, Robo Inu’s 24-hour trading volume was 

more than $1.4 million.   

144. Gotbit maintained that inflated 24-hour trading volume until 12:00 a.m. on May 

23rd, when its large spike in wash trading (from 12:00 a.m. the day before) rolled off the 

cumulative 24-hour trading total, causing that cumulative total to drop to approximately 

$623,000.  Robo Inu’s 24-hour trading volume continued to fall steadily to roughly $209,000 by 

6:00 p.m.   

145. At 6:15 p.m., Pham asked both “Vladimir” and “Vladislav Trader”:  “Why dont 

[sic] maintain the volume?  I hvnt [sic] said stop though.”  “Vladislav Trader” explained that he 

had lowered the wash-trading volume “cause organic sellers tried to sell into our bot,” but agreed 

to “increase it back fast.”   

146. Gotbit then ramped up its automated wash trading, pushing the 24-hour trading 

volume to more than $875,000 by 8:00 p.m.  

147. At 11:26 p.m., Gotbit reported to Pham that Robo Inu’s trading volume was $1.15 

million.  Gotbit maintained Robo Inu’s 24-hour trading volume at more than $1 million 

(generally between $1.1 and $1.4 million) until the evening of May 24, 2023.  At that point, at 

the request of Pham and another leader of the Robo Inu project, Gotbit agreed to slowly reduce 

the trading volume.   

148. Over the next hour, Gotbit reduced the 24-hour trading volume from more than $1 

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million to approximately $740,000.  Gotbit then slowly reduced its wash trading further 

throughout May 26, 2023.  By 1:00 a.m. on the morning of May 27, 2023, the 24-hour trading 

volume was approximately $102,000.   

149. This example of the manipulation of Robo Inu’s trading volume, orchestrated by 

Pham and executed by Gotbit from May 21 to May 27, 2023, is summarized in the chart below. 

Robo Inu 24-Hour Trading Volume:  May 21 - 27, 2023 
 

 
  
V. Gotbit Artificially Inflated Robo Inu’s Trading Volume on Uniswap. 

 
150. Pham also sought to have Gotbit increase Robo Inu’s daily trading volume by 

buying and selling Robo Inu tokens in roughly equal proportion on Uniswap.  This artificial 

trading was intended to create the false impression that a robust market existed for Robo Inu on 

Uniswap.  Leaders of the Robo Inu project and Gotbit both believed that this artificial trading 

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would, in turn, encourage the investing public to trade Robo Inu. 

151. Gotbit started its manipulative trading on Uniswap on or about March 18, 2022.    

152. This trading served no legitimate economic purpose.  It was designed and 

intended to give the appearance to unsuspecting, would-be Robo Inu investors that Robo Inu’s 

trading volume was robust across trading platforms.  The lack of economic purpose is 

demonstrated, in part, by the steep cost in Ethereum network fees—which are required to 

conduct transactions on the Ethereum blockchain—that Gotbit incurred to engage in these trades 

on Uniswap, only to end up with a low net position in Robo Inu.   

153. To minimize these Ethereum network fees, often called “gas,” Gotbit decided to 

keep the number of daily transactions low, which necessitated increasing the size of each trade in 

order to reach the daily trading volume target Gotbit set with Pham.  A consequence of this 

manipulative trading strategy was large swings in Robo Inu’s price on Uniswap.  These price 

swings were visible to the investing public, which could view Robo Inu’s price and trading 

volume in real time in graphs and charts available on websites such as CoinMarketCap, 

CoinGecko, and DEXTools.   

154. Gotbit and Pham watched those graphs and charts closely.  Pham was concerned 

that Gotbit’s volume pumping strategy caused the “chart” to “look[] unnatural” and could drive 

away investors instead of luring them to buy Robo Inu.   

155. Below is a March 19, 2022 excerpt from the private Telegram group chat 

involving Pham and several Gotbit employees, among others.  In this excerpt, Pham and Gotbit 

discussed their intention to inflate the volume of daily trading on Uniswap to draw new investors 

to Robo Inu; the difficulty of doing so without incurring substantial network fees; and their 

desire to have the trading appear to be organic to the investing public, and not the result of Pham 

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VI. At Pham’s Direction, Gotbit Manipulated Robo Inu’s Price. 
 
158. In addition to artificially inflating the trading volume of Robo Inu, Gotbit also 

manipulated the price of Robo Inu.   

159. For instance, on March 8, 2023, Pham asked Gotbit to calculate how much it 

would cost to increase the price of Robo Inu by 30 percent.  After Gotbit replied that it would 

cost more than $19,000, one of Pham’s associates responded:  “OK let us try.”   

160. Members of Robo Inu’s leadership team then set about pumping up Robo Inu’s 

price on Uniswap, while Gotbit simultaneously pumped Robo Inu’s price on Bitmart.  Publicly 

available price data indicate that, in the hour that this exchange took place, the price of Robo Inu 

increased approximately 30.8 percent. 

VII. Pham Planned to Further Manipulate the Price and Trading Volume of Robo Inu 
Though a Series of Coordinated Purchases Before Law Enforcement Intervened.  

 
161. In or around February 2024, Pham decided to inflate the price of Robo Inu by 

coordinating a series of purchases by a group of investors and project participants.  It was 

essentially the same plan she had executed with other leaders of the Saitama project in July 2021 

to inflate the price of Saitama.   

162. On February 8, 2024, Pham created a private group chat on Telegram with 

Individual 2 and Hernandez, whom Pham introduced to Individual 2.  The purpose was to 

discuss plans to manipulate the price and trading volume of Robo Inu, among other things.  

163. On February 9, 2024, Individual 2 sent a message to the group:  “What RBIF 

needs now is trading volume and more holder growth to break out.” 

164. On February 12, 2024, Hernandez responded that Pham “and myself definitely 

know this from the Saitama days as with out [sic] volume there is no hype, movement or fomo so 

to speak.”  Individual 2 stated that he agreed with Hernandez and that “a project without volume 

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will die day by day; new investors will only look at volume to decide whether to invest or not.”  

Individual 2 suggested either creating a “bot” to “pump price, draw beautiful charts, increase 

volume appropriately” or to hire a “market maker” to do the same.   

165. Pham stated that the plan was to “instil[l] the hype and fomo elements” as had 

previously been done “successfully at saitama,” referring to the manipulation of Saitama’s price 

through coordinated purchases in July 2021.   

166. On February 13, 2024, having discussed various technical issues regarding the 

Robo Inu ecosystem, Pham told the group:  “Next step is to hype and pump.” 

167.  On February 16, 2024, Pham touted her affiliation with Saitama on X, asserting 

that she had previously led the “#SaitamaWolfPack,” and stated:  “[L]et’s watch everything 

slowly unfold in the coming weeks/months and what the right leadership with passion can do and 

maybe I will make that history again.”   

168. Meanwhile, Pham began contacting others to participate in her scheme to 

manipulate the price of Robo Inu.   

169. On February 27, 2024, Pham, Individual 2, Hernandez, and others participated in 

a video call during which Pham and Individual 2 discussed their plans to manipulate the price of 

Robo Inu through a series of coordinated purchases.   

170. A purported venture capital investor on the call stated to Pham and Individual 2:  

“It sounds like you have a plan in place basically to run back kinda like the Saitama playbook.  

Coordinated buys you spread them across the wallets.  Obviously, that’s key to pushing the 

volume and the price, attracting new buys, we love that plan.”  The purported investor then 

asked:  “I was just wondering what is your timeline looking like for this?”  

171. Pham responded, “We are already ready” and reiterated that the plan was “push 

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the volume” and cause “FOMO and the, you know, the hype.” 

172. In early March 2024, Pham contacted several individuals to enlist their 

involvement in coordinated purchases to pump up the price of Robo Inu.   

173. Law enforcement intervened to prevent Pham from executing her plan to 

manipulate the price of Robo Inu.  

FIRST CLAIM FOR RELIEF 
UNREGISTERED OFFERINGS OF SECURITIES 

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

174. Paragraphs 1 through 173 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

175. At all relevant times, Saitama and Robo Inu were each offered and sold as a 

security under Section 2(a)(10) of the Securities Act [15 U.S.C. § 77b(a)(10)]. 

176. By reason of the conduct described above, the Defendant, directly or indirectly:  

(i) made use of the means or instruments of transportation or communication in interstate 

commerce or of the mails to sell, through the use or medium of a prospectus or otherwise, 

securities as to which no registration statement has been in effect and for which no exemption 

from registration has been available; and/or (ii) made use of the means or instruments of 

transportation or communication in interstate commerce or of the mails to offer to sell, through 

the use or medium of a prospectus or otherwise, securities as to which no registration statement 

has been filed and for which no exemption from registration has been available. 

177. As a result, the Defendant violated Sections 5(a) and (c) of the Securities Act 

[15 U.S.C. §§ 77e(a) and (c)] and will continue to violate those sections unless enjoined.    

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

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

178. Paragraphs 1 through 173 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

179. At all relevant times, Saitama and Robo Inu were each offered and sold as a 

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

180. By reason of the conduct described above, Defendant, 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.   

181. By reason of the conduct described above, Defendant Pham violated Securities 

Act Sections 17(a)(1) and (3) [15 U.S.C. §§ 77q(a)(1) and (3)] and will continue to violate those 

sections unless enjoined. 

THIRD 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))  
 

182. Paragraphs 1 through 173 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

183. At all relevant times, Saitama and Robo Inu were each offered and sold as a 

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

184. By reason of the conduct described above, Defendant, directly or indirectly, in 

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

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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. 

185. By reason of the conduct described above, Defendant violated 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 and will continue to violate those provisions unless enjoined. 

FOURTH CLAIM FOR RELIEF 
MARKET MANIPULATION 

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

186. Paragraphs 1 through 173 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

187. At all relevant times, Saitama and Robo Inu were each offered and sold as a 

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

188. By reason of the conduct described above, Defendant Pham, directly or indirectly, 

effected a series of transactions in a security not registered on a national securities exchange, 

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. 

189. By reason of the conduct described above, Defendant Pham violated Exchange 

Act Section 9(a)(2) [15 U.S.C. § 78i(a)(2)] and will continue to violate that section unless 

enjoined.   

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that this Court: 

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A. Enter a permanent injunction restraining the Defendant, her agents, servants, 

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

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

5(a) and (c), and 17(a)(1) and (3) of the Securities Act [15 U.S.C. §§ 77e(a) and (c); 77q(a)(1) 

and (3)], and Sections 9(a)(2) and 10(b) of the Exchange Act [15 U.S.C. §§ 78i(a)(2) and 78j(b)] 

and Rules 10b-5(a) and (c) thereunder [17 C.F.R. §§ 240.10b-5(a) and (c)]; 

B. Order Defendant to disgorge, with prejudgment interest, all ill-gotten gains 

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

21(d)(5) and (7) of the Exchange Act [15 U.S.C. §§ 78u(d)(5) and (7)]; 

C. Order Defendant 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)];  

D. Enter an order pursuant to Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)] 

and Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)] barring Defendant from acting 

as an officer or director of any issuer that has a class of securities registered pursuant to Section 

12 of the Exchange Act [15 U.S.C. § 78l] or that is required to file reports pursuant to Section 

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

E. Enter an order prohibiting Defendant from participating, directly or indirectly, 

including but not limited to through any entity controlled by her, in any offering of securities, 

including any crypto asset security; provided however, that such injunction shall not prevent her 

from purchasing or selling securities, including crypto asset securities, for her own account. 

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

orders and decrees that may be entered; and  

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G. 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:  October 9, 2024. 

 

      Respectfully submitted, 

/s/ David J. D’Addio 
David J. D’Addio (Mass. Bar No. 665790) 
Amy Harman Burkart (Mass. Bar No. 651828) 
Ivan Panchenko (Mass. Bar No. 693552) 
Jeffrey Cook (Fla. Bar No. 647578) 
Joy Guo (N.Y. Bar No. 5294764) 

 
      SECURITIES AND EXCHANGE COMMISSION 

Boston Regional Office 
33 Arch St., 24th Floor  
Boston, MA 02110 
Phone:  (617) 573-4526 (D’Addio direct)  
Fax:  (617) 573-4590 (fax) 
[email protected] (D’Addio email) 

 

Case 1:24-cv-12588   Document 1   Filed 10/09/24   Page 44 of 44