Case 3:17-cv-07095-RS Document 13 Filed 12/15/17 Page 1 of 5

1 Reed R. Kathrein (139304)

Peter E. Borkon (212596)
2 Danielle Charles (291237)
HAGENS BERMAN SOBOL SHAPIRO LLP
3 715 Hearst Avenue, Suite 202
Berkeley, CA 94710
4 Telephone: (510) 725-3000
Facsimile: (510) 725-3001
5 reed@hbsslaw.com
peterb@hbsslaw.com
6 daniellec@hbsslaw.com
7
Attorneys for Plaintiffs
8 [Additional counsel listed on signature page]
9 UNITED STATES DISTRICT COURT
10 NORTHERN DISTRICT OF CALIFORNIA
11 BRUCE MACDONALD, Individually and on Case No. 3:17-cv-07095-RS
12 Behalf of All Others Similarly Situated,
STATEMENT OF RECENT
13 Plaintiff, DECISION RELEVANT TO
PLAINTIFF’S EX PARTE
14 v. APPLICATION FOR TEMPORARY
RESTRAINING ORDER AND
15 DYNAMIC LEDGER SOLUTIONS, INC., a ORDER TO SHOW CAUSE WHY A
16 Delaware corporation, TEZOS PRELIMINARY INJUNCTION
STIFTUNG, a Swiss Foundation, SHOULD NOT ISSUE
17 KATHLEEN BREITMAN, an
Individual, ARTHUR BREITMAN,
18 an Individual, TIMOTHY COOK DRAPER, an
individual, DRAPER ASSOCIATES, JOHANN
19
GEVERS, DIEGO PONZ, GUIDO SCHMITZ-
20 KRUMMACHER, BITCOIN SUISSE AG,
NIKLAS NIKOLAJSEN and DOES 1-100,
21 INCLUSIVE,

22 Defendants.
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010721-11 1005104 V1
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Pursuant to Civil Local Rule 7-3(d)(2), Plaintiff Bruce MacDonald respectfully submits the
2
United States District Court for the Eastern District of New York’s recent Order Granting
3
Preliminary Injunction, Asset Freeze, And Other Interim Relief in Securities and Exchange
4
Commission v. Plexcorps, et al., No. 17 Civ. 7007 (CBA), Dkt. No. 25 (E.D.N.Y. Dec. 14, 2017) (the
5
“Plexcorps Order”) (attached hereto as Exhibit A).
6
Yesterday, December 14, 2017, Plaintiff filed an Ex Parte Application for Temporary
7
Restraining Order and Order to Show Cause Why A Preliminary Injunction Should Not Issue (the
8
“TRO Application”). ECF No. 8. The Court has set a hearing on the application for Tuesday,
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December 19, 2017 at 10:00 a.m. ECF No. 10.
10
The Plexcorps Order was entered yesterday at approximately 2:30 p.m. Pacific time—about
11
two hours after Plaintiff filed the TRO Application. Undersigned counsel became aware of the
12
Plexcorps Order when it was reported by news media sources today. The Plexcorps Order is
13
relevant to the issues presented by Plaintiff’s TRO Application. Like this case, the Plexcorps case
14
arises from an initial coin offering (ICO). There, as here, many of the defendants in Plexcorps are
15
not resident in the United States. The Plexcorps court held that: (1) the “PlexCoin Tokens” issued in
16
the ICO were “investment contracts subject to the Securities and Exchange Act,” (2) the SEC had
17
made a substantial showing of a likelihood of success on its claim that the Plexcorps defendants had
18
violated the Securities Act by selling or participating in the sale of unregistered securities and (3)
19
freezing the entity defendants’ assets was necessary to preserve the status quo and protect the Court’s
20
ability to award relief.
21
DATED: December 15, 2017 HAGENS BERMAN SOBOL SHAPIRO LLP
22
By: /s/ Reed R. Kathrein
23 Reed R. Kathrein (139304)
Peter E. Borkon (212596)
24
Danielle Charles (291237)
25 715 Hearst Ave., Suite 202
Berkeley, CA 94710
26 Telephone: (510) 725-3000
Facsimile: (510) 725-3001
27 Email: reed@hbsslaw.com
28
NOTICE OF SUBSEQUENT AUTHORITY - 1
Case No.: 17-cv-07095-RS
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1 peterb@hbsslaw.com
daniellec@hbsslaw.com
2
Steve W. Berman
3
HAGENS BERMAN SOBOL SHAPIRO LLP
4 1918 Eighth Avenue, Suite 3300
Seattle, WA 98101
5 Telephone: (206) 623-7292
Facsimile: (206) 623-0594
6 Email: steve@hbsslaw.com
7 Jason M. Leviton, (Pro Hac Vice to be submitted)
Joel A. Fleming (281264))
8 Jacob A. Walker (271217)
BLOCK & LEVITON LLP
9 155 Federal Street, Suite 400
Boston, MA 02110
10 Telephone: (617) 398-5600
Email: jason@blockesq.com
11 joel@blockesq.com
jake@blockesq.com
12
Attorneys for Plaintiff
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NOTICE OF SUBSEQUENT AUTHORITY - 2
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1 CERTIFICATE OF SERVICE
2 Pursuant to L.R. 5-5, I certify that on December 15, 2017, I caused to be served copies of the
foregoing EX PARTE APPLICATION FOR LEAVE TO EFFECT ELECTRONIC SERVICE ON
3
DEFENDANTS RESIDENT OUTSIDE THE UNITED STATES; MEMORANDUM OF POINTS
4 AND AUTHORITIES on the persons listed below at the addresses listed below.

5 Daniel Louis Sachs Brian E. Klein (258486)

COOLEY LLP Scott M. Malzahn (229204)
6 1299 Pennsylvania Ave NW BAKER MARQUART LLP
Suite 700 2029 Century Park East, Suite 1600
7
Washington, DC 20004 Los Angeles, CA 90067
8 Telephone: (202) 728-7114 Telephone: (424) 652-7814
Facsimile: (202) 842-7899 Facsimile: (424) 652-7850
9 dsachs@cooley.com bklein@bakermarquart.com
smalzahn@bakermarquart.com
10 Jeffrey Michael Kaban
11 Patrick Edward Gibbs Counsel for Arthur Breitman and Kathleen
Samantha Anne Kirby Breitman
12 COOLEY LLP
3175 Hanover Street Timothy Cook Draper
13 Palo Alto, CA 94304 Draper Associates
Telephone: (650) 843-5000 55 E. 3rd Avenue
14 Facsimile: (650) 849-7400 San Mateo, CA 94401
15 kabanjm@cooley.com plans@draper.vc
pgibbs@cooley.com timothy@dfj.com
16 skirby@cooley.com mail@drapervc.com
timothy.draper@msn.com
17 Counsel for Distributed Ledger Solutions, Inc. tim@drapervc.com
tdraper@prosper.com
18 Neal A. Potischman tim@prosper.com
Edmund Polubinski, III
19 Davis Polk & Wardwell LLP Johann Gevers
1600 El Camino Real
20 Menlo Park, CA 94025 c/o Tezos Stiftung
Telephone: (650) 752-2021 Alpenstrasse 9
21 Facsimile: (650) 752-3621 6300 Zug
neal.potischman@davispolk.com Switzerland
22 edmund.polubinski@davispolk.com johann@gevers.net; johann@monetas.net;
23 jgevers@monetas.net;
Counsel for Tezos Stiftung (Tezos Foundation) johann.gevers@monetas.net;
24 johanngevers@monetas.net.
Tezos Stiftung
25 Alpenstrasse 9 Guido Schmitz-Krummacher
6300 Zug, Switzerland c/o Tezos Stiftung
26 Contact@tezos.ch Alpenstrasse 9
27 support@tezos.ch 6300 Zug
Switzerland
28
CERTIFICATE OF SERVICE - 1
Case No.: 17-cv-07095-RS
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1 Diego Ponz guido.schmitz-krummacher@krummacher.com

c/o Tezos Stiftung guido.schmitz-krummacher@talentory.com
2 Alpenstrasse 9 guido@addcon.nl
6300 Zug guidoschmitzkrummacher@addcon.nl
3
Switzerland gschmitzkrummacher@addcon.nl
4 Contact@tezos.ch; support@tezos.ch guidos@addcon.nl
guido.schmitzkrummacher@addcon.nl
5 Niklas Nikolajsen
Bitcoin Suisse AG
6 Park Résidence
Industriestrasse 16
7
CH-6300 Zug
8 Switzerland
inquiry@bitcoinsuisse.ch
9

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11 Dated: December 15, 2017 /s/ Joel Fleming

Joel Fleming
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CERTIFICATE OF SERVICE - 2
Case No.: 17-cv-07095-RS
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Exhibit A
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UNITED ST ATES DISTRICT COURT

EASTERN DISTRICT OF NEW YORK
------------------------------------------------------------------------x
SECURITIES AND EXCHANGE COMMISSION,

Plaintiff, 17 Civ. 7007 (CBA)

- against - ECF Case

PLEXCORPS
(a/k/a and d/b/a PLEXCOIN and SIDEPAY.CA),
DOMINIC LACROIX and
SABRINA PARADIS-ROYER,

Defendants,

----------------------------------------------------------------------- x

ORDER GRANTING PRELIMINARY INJUNCTION, ASSET FREEZE,

AND OTHER INTERIM RELIEF

On December 1, 2017, Plaintiff Securities and Exchange Commission (the "Commission")

filed the instant action against Defendants PlexCorps a/k/a and d/b/a PlexCoin and Sidepay.ca (the

"Entity Defendant"), Dominic Lacroix ("Lacroix"), and Sabrina Paradis-Royer (with Lacroix, the

"Individual Defendants"), alleging securities fraud in vio lation of the Securities Act of 1933 (the

"Securities Act"), 15 U.S.C. § 77a et seq .; the Securities Exchange Act of 1934 (the "Exchange

Act"), 15 U.S.C. § 78a et seq .; and SEC Rule lOb-5 , 17 C.F.R. § 240.lOb-5. That day, the

Commission filed an emergency application (the "Application") for an order to show cause,

temporary restraining order, and asset-freezing order against Defendants, and the Court granted

the application, issuing an ex parte Order to Show Cause, scheduling a preliminary injunction

hearing to take pl ace on December 12, 2017, and requiring Defendants to respond by December

7, 2017, at 5:00 p.m. Plaintiff duly served the Order to Show Cause on Defendants. On December

8, 2017, the Court granted an extension of the temporary restraining order against the Individual

Defendants, who consented, and rescheduled the preliminary injunction hearing to March 5, 2018.
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However, the Entity Defendant neither consented to the extension nor responded to the Court's

Order to Show Cause; in fact, it has not appeared in the instant action. Pursuant to Rule 65(b)(2)

of the Federal Rules of Civil Procedure, the temporary restraining order against the Entity

Defendant remains in effect for a 14-day period ending December 15, 2017.

Before the Court is the Commission's December 12, 2017, letter motion for preliminary

injunction against the Entity Defendant. Normally, the Court applies the test articulated in eBay

Inc. v. MercExchange, LLC, 547 U.S . 388 (2006), to determine whether a preliminary injunction

is warranted. See, e.g., Abbott Labs. v. Adelphia Supply USA, No . 15-CV-5826 (CBA), 2015 WL

10906060, at *5 (E.D.N.Y. Nov. 6, 2015). Under the eBay test, which applies to purely equitable

injunctions, the movant must establish that (1) the movant likely will succeed on the merits; (2) the

movant likely will suffer irreparable harm ; (3) the balance of hardships tips in the movant's favor;

and (4) the preliminary injunction would not disserve the public interest. See eBay, 547 U.S . at

391 ; Malletier v. Burlington Coat Factory Warehouse Corp., 426 F.3d 532, 537 (2d Cir. 2005).

However, because preliminary injunctions in lawsuits brought by the Commission are "creatures

of statute" and not "rooted wholly in the equity jurisdiction of the federal court," the Second Circuit

has not required the Commission to prove the elements of the rigid eBay test. See SEC v. Mgmt.

Dynamics, Inc., 515 F.2d 801 , 808 (2d Cir. 1975). Instead, the Commission "need only make ' a

substantial showing of likelihood of success as to both a current violation and the risk of

repetition. "' Smith v. SEC, 653 F.3d 121 , 127- 28 (2d Cir. 2011) (quoting SEC v. Cavanagh, 155

F.3d 129, 132 (2d Cir. 1998)). A "substantial showing oflikelihood of success" is a sliding-scale

standard; the Commission "should be obliged to make a more persuasive showing of its entitlement

to a preliminary injunction the more onerous ... the burdens of the injunction it seeks." Id. at 128

(quoting SEC v. Unifund SAL, 910 F.2d 1028, 1039 (2d Cir. 1990)).

2
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To show a violation of Section lO(b) of the Exchange Act and SEC Rule lOb-5, the

Commission must show that Defendants "(1) made a material misrepresentation or a material

omission as to which he had a duty to speak, or used a fraudulent device; (2) with scienter; (3) in

connection with the purchase or sale of securities." SEC v. Pentagon Capital Mgmt. PLC, 725

F.3d 279, 285 (2d Cir. 2013). "The requirements for a vio lation of Section 17(a) apply only to a

sale of securities but in other respects are the same as Section lO(b) and Rule lOb-5, except that

'no showing of scienter is required for the SEC to obtain an injunction under [Section 17] (a)(2)

or (a)(3)." Id. (alterations in original) (quoting SEC v. Monarch Funding Corp., 192 F.3d 295, 308

(2d Cir. 1999)). Finally, "to state a cause of action under Section 5 [of the Securities Act], one

must show ' (1) [the] lack of a registration statement as to the subject securities; (2) the offer or

sale of the securities; and (3) the use of interstate transportation or communication and the mails

in connection with the offer or sale." Cavanagh, 445 F.3d 105, 111 n.13 (2d Cir. 2006) (quoting

Eur. & Overseas Commodity Traders, S.A. v. Banque Paribas London, 147 F.3d 118, 124 n.4 (2d

Cir. 1998)).

The Court has considered the exhibits to the letter motion and the filings associated with

the Commission's December 1, 2017, Application. Based upon those documents, the Court finds

the fo llowing:

1. The Commission has made a substantial showing of likelihood of success on the merits of

the securities violation; in particular, it likely will demonstrate that the Entity Defendant

has violated Sections 5(a), 5(c), and 17(a) of the Securities Act; Section lO(b) of the

Exchange Act; and SEC Rule lOb-5.

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2. The Commission likely will establish that the Entity Defendant participated in a scheme to

obtain more than $15 million in proceeds from unlawful activities related to "PlexCoin

Tokens," which are investment contracts subject to the Securities Act and Exchange Act.

3. The Commission has made a substantial showing of likelihood of success on the merits

with respect to establishing a risk ofrepetition of the securities violations.

4. Freezing the Entity Defendant's assets is necessary to preserve the status quo and to protect

the Court's ability to award relief in the form of disgorgement of ill-gotten gains,

prejudgment interest, and civil penalties.

5. The Entity Defendant or its associates likely have contemplated destroying evidence

relating to the allegations in the Complaint. An order prohibiting the Entity Defendant or

its associates from destroying, altering, or concealing records of any kind-including

documents concerning the allegations in the complaint or the assets, finances, or business

operations of the Entity Defendant- is necessary to ensure compliance with the asset

freeze imposed on the Entity Defendant and to protect the integrity of the instant litigation.

6. The Court likely has subject-matter jurisdiction over the instant action and personal

jurisdiction over the Entity Defendant. It is also likely that venue properly lies in the

Eastern District.

NOW, THEREFORE,

I.

IT IS HEREBY ORDERED that the Commission's Motion for a Preliminary Injunction

with respect to Defendant PlexCorps a/k/a and d/b/a PlexCoin and Sidepay.ca is GRANTED.

4
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II.

IT IS FURTHER ORDERED that, pending a final disposition of this action, Defendant

PlexCorps a/k/a and d/b/a PlexCoin and Sidepay.ca; each of its agents, servants, employees, and

attorneys ; and those persons or entities that are in active concert or participation with it and receive

actual notice of this Order, by personal service or otherwise, are preliminarily enjoined and

restrained from, directly or indirectly, singly or in concert, in the offer or sale of any security, by

the use of any means or instruments of transportation or communication in interstate commerce or

by use of the mails:

(a) employing any device, scheme or a1iifice to defraud ;

(b) obtaining money or property by means of an untrue statement of material fact or

omitting to state a material fact necessary to make the statements made, in light of the

circumstances under which they were made, not misleading; and

(c) engaging in any transaction, practice, or course of business that operates or would

operate as a fraud or deceit upon the purchaser,

in violation of Section 17(a) of the Securities Act.

III.

IT IS FURTHER ORDERED that, pending a final disposition of this action, Defendant

PlexCorps a/k/a and d/b/a PlexCoin and Sidepay.ca; each of its agents, servants, employees, and

attorneys; and those persons or entities that are in active concert or participation with it and receive

actual notice of this Order, by personal service or otherwise, are preliminarily enjoined and

restrained from , directly or indirectly, singly or in concert, in connection with the purchase or sale

of any security, by use of the means or instrumentalities of interstate commerce, or of the mails,

or of any facility of any national securities exchange:

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(a) employing any device, scheme, or artifice to defraud;

(b) making any untrue statement of a material fact or omitting to state a material fact

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

which they were made, not misleading; or

(c) engaging in any act, practice, or course of business that operates or would operate as a

fraud or deceit upon any person,

in violation of Section 1O(b) of the Exchange Act and SEC Rule 1Ob-5.

IV.

IT IS FURTHER ORDERED that, pending a final disposition of this action, Defendant

PlexCorps a/k/a and d/b/a PlexCoin and Sidepay.ca; each of its agents, servants, employees, and

attorneys; and those persons or entities that are in active concert or participation with it and receive

actual notice of this Order, by personal service or otherwise, are preliminarily enjoined and

restrained from, directly or indirectly, singly or in concert, engaging in the offering of unregistered

securities or vio lating Sections 5(a) and 5(c) of the Securities Act by:

(a) without a registration statement in effect as to that security, making use of the means

and instruments of transportation or communications in interstate commerce and of the

mails to sell securities through the use of means of a prospectus; or

(b) making use of the means and instruments of transportation or communication in

interstate commerce and of the mails to offer to sell through the use of a prospectus,

securities as to which no registration statement has been filed.

v.
IT IS FURTHER ORDERED that, pending a final disposition of this action, Defendant

PlexCorps a/k/a and d/b/a PlexCoin and Sidepay.ca; each of its financial and brokerage

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institutions, agents, servants, employees, and attorneys; those persons or entities that are in active

concert or participation with it and receive actual notice of this Order by personal service or

otherwise; and each of them:

(a) hold and retain within their control and otherwise prevent any withdrawal, transfer,

pledge, encumbrance, assignment, dissipation, concealment, or other disposal

(including the use of any credit cards or any other incurrence of debt) of any assets,

funds, or other property (including money; virtual currency or other digital asset, real,

or personal property; securities; commodities; choses in action; or other property of

any kind whatsoever, in whatever form such assets may presently exist and wherever

located) of, held by, or under the control of Defendant PlexCorps a/k/a and d/b/a

PlexCoin and Sidepay.ca, whether held in its name or for its direct or indirect beneficial

interest, and

(b) direct each of the financial or brokerage institutions, debtors and bailees, or any other

person or entity holding such assets, funds , or other property of Defendant PlexCorps

a/k/a and d/b/a PlexCoin and Sidepay.ca to hold or retain within his, her, or its control

and prohibit the withdrawal, removal, transfer, or other disposal of any such assets,

funds, or other properties (including but not limited to all assets listed on Schedule A

and all other assets, funds, or properties) held by, in the name of, or under the control

of Defendant PlexCorps a/k/a and d/b/a PlexCoin and Sidepay.ca.

VI.

IT IS FURTHER ORDERED that, pending a final disposition of this action, Defendant

PlexCorps a/k/a and d/b/a PlexCoin and Sidepay.ca and any person or entity acting at the direction

of or on behalf of it, are preliminarily enjoined and restrained from destroying, altering, or

7
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concealing all documents, books, and records (including documents that concern the allegations

in the Complaint or PlexCorps a/k/a and d/b/a PlexCoin and Sidepay.ca's assets, finances, or

business operations) that are in the possession, custody, or contro l of Defendant PlexCorps a/k/a

and d/b/a PlexCoin and Sidepay.ca; its respective agents, servants, employees, and attorneys; and

those persons or entities that are in active concert or participation with it.

VII.

IT IS FURTHER ORDERED that a copy of this Order and the papers supporting the

Commission' s December 12, 2017, letter motion for preliminary injunction be served upon

Defendant PlexCorps a/k/a and d/b/a PlexCoin and Sidepay.ca (or an attorney who represents it

and agrees to accept service on its behalf) on or before December 15, 2017, by personal delivery;

facsimile; overnight courier, international express mail, or first-class mail to it at 355 rue Gaudias-

Villeneuve, Quebec City QC G2N OK8, Canada, and 72 High Street, Haslemere, Surrey GU27

2LA, United Kingdom; to its attorney Jean-Francois Hudon at Hudon Avocats, 417 rue Saint-

Pierre, Bureau 700, Monetral QC H2Y 2M4, Canada; or to its agent FK Corporate Services

Limited at 72 High Street, Haslemere GU27 2LA, United Kingdom; or email at

account@plexcoin.com, doom.lacroix@hotmail.com, or sabrina.paradis@hotmail.fr with a

request for a "read receipt. "

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The Order shall be binding upon Defendant PlexCorps a/k/a and d/b/a PlexCoin and

Sidepay.ca (and each of its officers, agents, servants, employees, and attorneys) when it is properly

served pursuant to this Order. The Order shall be binding upon any person or entity in active

concert or paiticipation with Defendant PlexCorps a/k/a and d/b/a PlexCoin and Sidepay.ca when

the person or entity receives actual notice of this Order by personal service or otherwise.

SO ORDERED.

Dated: December If,

2017

~~~
Brooklyn, New York
/s/ Carol Bagley Amon

United States District Judge

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Schedule A

Financial Institution Account Name

Stripe Account with owner email address

doom.lacroix@hotmail.com

Stripe Account with owner email address

sabrina. paradis@hotmail .fr

Stripe Account with owner email address

account@plexcoin.com
Ox722fd3bd3f5156e5fc352elf211173e5f7732cef
Ethereum Blockchain Address

Ox2576ba9bb62e75dcd3eb6ca880bc126c435ffflf
Ethereum Blockchain Address

1HJiV9emxcJ mLXyk4 7HBqXeP2BeRZVPEzi

Bitcoin Blockchain Address

Square Account in the name of "Sidepay," which has

"LEGACY ID"# 30174265
Square Account in the name of "PlexCoin," which has
"LEGACY ID" #29035035