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IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TEXAS
AUSTIN DIVISION
DON HOLLAND, individually and on behalf of all
others similarly situated,
Plaintiff,
vs.
Civil Action No. 1:23-cv-110
CRYPTOZOO INC., a Delaware Corporation,
LOGAN PAUL, DANIELLE STROBEL, JEFFREY
LEVIN, EDUARDO IBANEZ, JAKE
GREENBAUM a/k/a CRYPTO KING, and OPHIR
BENTOV a/k/a BEN ROTH,
Defendants.
______________________________________________/
LOGAN PAUL,
Cross-Plaintiff,
vs.
EDUARDO IBANEZ and
JAKE GREENBAUM a/k/a CRYPTO KING
Cross-Defendants.
______________________________________________/
LOGAN PAUL’S ANSWER, AFFIRMATIVE DEFENSES, AND CROSSCLAIM
AGAINST EDUARDO IBANEZ AND JAKE GREENBAUM a/k/a CRYPTO KING
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TABLE OF CONTENTS
TABLE OF CONTENTS............................................................................................................... i
ANSWER....................................................................................................................................... 1
I. NATURE OF THE ACTION ........................................................................................... 1
II. SUBJECT-MATTER JURISDICTION AND VENUE.................................................... 2
III. PARTIES AND PERSONAL JURISDICTION ............................................................... 3
IV. BACKGROUND ON DIGITAL ASSETS, CRYPTOCURRENCY, AND NFTS........... 3
V. MISNOMER/ALTER EGO ............................................................................................. 4
VI. PRINCIPAL-AGENT LIABILITY.................................................................................. 4
VII. FACTUAL ALLEGATIONS AS TO PLAINTIFF........................................................... 5
VIII. CLASS ALLEGATIONS ................................................................................................. 6
Commonality ........................................................................................................................... 6
Typicality ................................................................................................................................. 6
Adequacy ................................................................................................................................. 6
Superiority ............................................................................................................................... 7
IX. CAUSES OF ACTION .................................................................................................... 7
A. COUNT ONE: FRAUD ................................................................................................... 7
B. COUNT TWO: EXPRESS BREACH OF CONTRACT................................................. 7
C. COUNT THREE: IMPLIED BREACH OF CONTRACT .............................................. 8
D. COUNT FOUR: UNJUST ENRICHMENT .................................................................... 9
E. COUNT FIVE: VIOLATION OF TEXAS’S DECEPTIVE TRADE PRACTICES ACT
(“DTPA”)................................................................................................................................. 9
F. COUNT SIX: NEGLIGENCE ....................................................................................... 10
G. COUNT SEVEN: FRAUDULENT MISREPRESENTATION ..................................... 10
H. COUNT EIGHT: CONSPIRACY TO COMMIT FRAUD.............................................11
X. DAMAGES .....................................................................................................................11
XI. PUNITIVE DAMAGES..................................................................................................11
XII. ATTORNEY’S FEES......................................................................................................11
XIII. INCORPORATION OF PARAGRAPHS .......................................................................11
XIV. PRAYER FOR RELIEF ................................................................................................. 12
DEMAND FOR JURY TRIAL.................................................................................................. 12
AFFIRMATIVE DEFENSES .................................................................................................... 12
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First Affirmative Defense (Intervening and Superseding Cause) ............................................. 12
Second Affirmative Defense (Good Faith)................................................................................ 12
Third Affirmative Defense (Assumption of Risk)..................................................................... 12
Fourth Affirmative Defense (Economic Loss Rule) ................................................................. 13
Fifth Affirmative Defense (Adequate Remedy at Law)............................................................ 13
Sixth Affirmative Defense (No Capacity to Defraud)............................................................... 13
Seventh Affirmative Defense (Contributory Negligence)......................................................... 13
Eighth Affirmative Defense (Failure to Mitigate)..................................................................... 13
Ninth Affirmative Defense (No Fraudulent, Malicious, Intentionally Harmful, Willful, Wanton,
or Reckless Conduct) ................................................................................................................ 13
Tenth Affirmative Defense (Overbroad Class Definition - Standing)....................................... 14
Eleventh Affirmative Defense (Overbroad Class Definition - Failure to State a Claim).......... 14
Twelfth Affirmative Defense (Inadequate Class Representative/No Standing)........................ 14
Thirteenth Affirmative Defense (Case not Appropriate for Class Certification) ...................... 14
Fourteenth Affirmative Defense (Texas Constitutional and Statutory Cap on Punitive
Damages)................................................................................................................................... 14
Defenses Reserved .................................................................................................................... 14
PRAYER FOR RELIEF............................................................................................................. 15
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CROSSCLAIM TABLE OF CONTENTS
CROSSCLAIM ........................................................................................................................... 15
INTRODUCTION....................................................................................................................... 15
PARTIES, JURISDICTION, AND VENUE............................................................................. 17
BACKGROUND ......................................................................................................................... 17
Background on Cryptocurrency and NFTs................................................................................ 17
CryptoZoo is Conceived as a Blockchain Game where Players Breed Animals Using NFTs.. 19
Mr. Paul Assembles a Team to Successfully Deliver the CryptoZoo Game. ............................ 19
Mr. Greenbaum and Mr. Ibanez Assume Roles with CryptoZoo.............................................. 21
Mr. Greenbaum Creates and Launches the Token Liquidity Pool. ........................................... 23
Suspicious Trading Activity Occurs in the Liquidity Pool Immediately After Launch. ........... 25
Mr. Paul Publicly Announces the CryptoZoo Project After Receiving Assurances of Progress
from the CryptoZoo Team......................................................................................................... 27
Mr. Paul Uncovers Mr. Greenbaum’s Deceit and Ousts Him from CryptoZoo........................ 30
The Egg Sale Does Not Proceed as Planned and Mr. Paul Continues to Receive False Promises
from Mr. Ibanez about the Progress of the Game’s Development ............................................ 32
Mr. Paul Discovers that Mr. Ibanez is a Complete Fraud. ........................................................ 35
Mr. Paul Is Repeatedly Assured CryptoZoo is Still in Development........................................ 36
Mr. Paul Pledges to Buyback all of the CryptoZoo Egg NFTs. ................................................ 37
CLAIMS FOR RELIEF ............................................................................................................. 38
COUNT I FRAUDULENT INDUCEMENT............................................................................ 38
COUNT II FRAUDULENT MISREPRESENTATION............................................................ 39
PRAYER FOR RELIEF............................................................................................................. 40
DEMAND FOR JURY TRIAL.................................................................................................. 40
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Defendant Logan Paul hereby answers the Complaint brought by Plaintiff Don Holland, brings
a crossclaim against Defendant Eduardo Ibanez and Defendant Jake Greenbaum a/k/a Crypto
King, and states as follows:
ANSWER
All allegations not expressly admitted are denied. The Complaint includes a number of
headings. Mr. Paul denies all headings to the extent they contain factual allegations or
characterizations against Mr. Paul. Mr. Paul responds to the corresponding numbered allegations
of the Complaint as set forth below.
I. NATURE OF THE ACTION
1. Mr. Paul lacks knowledge or information sufficient to admit or deny the allegations
set forth in paragraph 1 of the Complaint, and therefore denies paragraph 1.
2. Admitted to the extent that CryptoZoo, Inc. (“CryptoZoo”), was incorporated in the
state of Delaware and that Non-Fungible Tokens (“NFTs”) are a form of digital assets that can be
bought, sold, and transferred on blockchains. In all other respects, Mr. Paul denies the allegations
set forth in paragraph 2 of the Complaint.
3. Admitted.
4. Admitted that Mr. Paul considered Ms. Strobel as one of the founders of CryptoZoo.
Denied that Ms. Strobel is still his assistant.
5. Admitted.
6. Admitted that Mr. Ibanez was the lead developer of CryptoZoo. Denied that Mr.
Ibanez is still the lead developer of CryptoZoo.
7. Admitted.
8. Admitted that Mr. Bentov was the manager of the CryptoZoo community. Denied
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that Mr. Bentov is still the manager of the CryptoZoo community.
9. Denied.
10. Denied.
11. Denied.
12. Mr. Paul admits that he released a video on January 13, 2023, but denies that he
“promised” to take any action in that video. Mr. Paul denies the remaining allegations set forth in
paragraph 12.
13. The image set forth in paragraph 13 speaks for itself, and Mr. Paul denies any
allegations inconsistent with the image set forth in paragraph 13.
14. The image set forth in paragraph 14 speaks for itself, and Mr. Paul denies any
allegations inconsistent with the image set forth in paragraph 14, including, but not limited to, the
allegation that Mr. Paul “fram[ed] CryptoZoo as an investment.”
15. The image set forth in paragraph 15 speaks for itself, and Mr. Paul denies any
allegations inconsistent with the image set forth in paragraph 15.
16. Mr. Paul lacks knowledge or information sufficient to admit or deny allegations of
Plaintiff’s intentions in bringing this action, and therefore denies the same. Mr. Paul otherwise
denies the allegations set forth in paragraph 16.
17. Mr. Paul lacks knowledge or information sufficient to admit or deny allegations
about Plaintiff’s relationship to CryptoZoo, and therefore denies Plaintiff’s allegation that he
purchased CryptoZoo tokens. Mr. Paul otherwise denies the allegations set forth in paragraph 17.
II. SUBJECT-MATTER JURISDICTION AND VENUE
18. The allegations in paragraph 18 are legal conclusions to which no response is
required. To the extent a response is required, Mr. Paul lacks knowledge or information sufficient
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to admit or deny the allegations set forth in paragraph 18, and therefore denies them.
19. The allegations in paragraph 19 are legal conclusions to which no response is
required. To the extent a response is required, Mr. Paul lacks knowledge or information sufficient
to admit or deny the allegations set forth in paragraph 19, and therefore denies them.
III. PARTIES AND PERSONAL JURISDICTION
20. Admitted.
21. Admitted.
22. Mr. Paul lacks knowledge or information sufficient to admit or deny the allegations
set forth in paragraph 22, and therefore denies them.
23. Mr. Paul lacks knowledge or information sufficient to admit or deny the allegations
set forth in paragraph 23, and therefore denies them.
24. Mr. Paul lacks knowledge or information sufficient to admit or deny the allegations
set forth in paragraph 24, and therefore denies them.
25. Mr. Paul lacks knowledge or information sufficient to admit or deny the allegations
set forth in paragraph 25, and therefore denies them.
26. Mr. Paul lacks knowledge or information sufficient to admit or deny the allegations
set forth in paragraph 26, and therefore denies them.
IV. BACKGROUND ON DIGITAL ASSETS, CRYPTOCURRENCY, AND NFTS
27. Admitted only to the extent that Plaintiff alleges that “cryptocurrencies” are digital
assets in which transactions are verified, and records maintained, by a decentralized system using
cryptography. Mr. Paul denies the remaining allegations set forth in paragraph 27.
28. Admitted.
29. Admitted only to the extent that Plaintiff alleges that cryptocurrency wallets have
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public and private keys. Mr. Paul lacks knowledge or information sufficient to admit or deny the
remaining allegations set forth in paragraph 29, and therefore denies them.
30. Admitted.
31. Admitted only to the extent that Plaintiff alleges that each cryptocurrency wallet
address is unique, and all transactions are recorded on a blockchain, which acts as a digital ledger,
and are viewable by the public. Mr. Paul denies the remaining allegations set forth in paragraph
31.
32. Admitted only to the extent that Plaintiff alleges that NFTs are digital assets that
exist in the form of tokens that are viewable and can be transferred on blockchains. Mr. Paul lacks
knowledge or information sufficient to admit or deny the remaining allegations set forth in
paragraph 32, and therefore denies them.
33. Mr. Paul lacks knowledge or information sufficient to admit or deny the allegations
set forth in paragraph 33, and therefore denies them.
34. Admitted only to the extent that Plaintiff alleges that NFTs are created through a
process called “minting” out of a “smart contract.” Mr. Paul lacks knowledge or information
sufficient to admit or deny the remaining allegations set forth in paragraph 34, and therefore denies
them.
V. MISNOMER/ALTER EGO
35. The allegations set forth in paragraph 35 of the Complaint are legal conclusions to
which no response is required. Mr. Paul denies the allegations set forth in paragraph 35 to the
extent that a response is required.
VI. PRINCIPAL-AGENT LIABILITY
36. The allegations set forth in paragraph 36 of the Complaint are legal conclusions to
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VIII. CLASS ALLEGATIONS
46. Denied. Mr. Paul denies the claims asserted against him and that a class should be
certified.
47. Denied. Mr. Paul denies the claims asserted against him and that a class should be
certified.
48. Denied. Mr. Paul denies the claims asserted against him and that a class should be
certified.
49. Denied. Mr. Paul denies the claims asserted against him and that a class should be
certified.
50. Denied. Mr. Paul denies the claims asserted against him and that a class should be
certified.
Commonality
51. Denied. Mr. Paul denies the claims asserted against him and that a class should be
certified.
52. Denied. Mr. Paul denies the claims asserted against him and that a class should be
certified.
Typicality
53. Denied. Mr. Paul denies the claims asserted against him and that a class should be
certified.
Adequacy
54. Denied. Mr. Paul denies the claims asserted against him and that a class should be
certified.
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Superiority
55. Denied. Mr. Paul denies the claims asserted against him and that a class should be
certified.
IX. CAUSES OF ACTION
A. COUNT ONE: FRAUD
56. Mr. Paul repeats and realleges each and every response contained in the foregoing
paragraphs as if set forth fully herein.
57. Denied.
58. Denied.
59. Denied.
60. Denied.
61. Denied.
B. COUNT TWO: EXPRESS BREACH OF CONTRACT
62. Mr. Paul repeats and realleges each and every response contained in the foregoing
paragraphs of the Complaint as if set forth fully herein.
63. Denied.
64. Denied.
65. Denied.
66. Denied.
67. Mr. Paul admits that the Terms of Service attached to the Complaint [D.E. 1-2]
represent that CryptoZoo, Inc. would “strive to do the best for the project and the community,” but
denies that he is the author of that statement, that it can be attributed to him as an individual, and
that it can serve as the basis for any contract between Mr. Paul and Plaintiff or any other consumer.
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96. Denied.
97. Denied.
98. Denied.
99. Denied.
F. COUNT SIX: NEGLIGENCE
100. Mr. Paul repeats and realleges each and every response contained in the foregoing
paragraphs of the Complaint as if set forth fully herein.
101. Denied.
102. Denied.
103. Denied.
104. Denied.
105. Denied.
G. COUNT SEVEN: FRAUDULENT MISREPRESENTATION
106. Mr. Paul repeats and realleges each and every response contained in the foregoing
paragraphs of the Complaint as if set forth fully herein.
107. Denied.
108. Denied.
109. Denied.
110. Denied.
111. Mr. Paul lacks knowledge or information sufficient to admit or deny allegations set
forth in paragraph 111 about Plaintiff’s state of mind, and therefore denies any such allegations set
forth in paragraph 111 of the Complaint. Mr. Paul denies the remainder of paragraph 111.
112. Denied.
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XIV. PRAYER FOR RELIEF
Plaintiff’s Prayer for Relief sets forth no allegations of fact, and as such, does not require
an admission or denial. Mr. Paul denies that Plaintiffs are entitled to any relief, as requested in his
Prayer for Relief or otherwise.
DEMAND FOR JURY TRIAL
Pursuant to Federal Rule of Civil Procedure 38(b), Mr. Paul demands a trial by jury in
this action on all the issues triable by a jury.
AFFIRMATIVE DEFENSES
Mr. Paul alleges the following defenses without assuming any burden of proof he would
not otherwise bear.
First Affirmative Defense
(Intervening and Superseding Cause)
Any injuries Plaintiff suffered, to the extent they exist, were caused by Jake Greenbaum
a/k/a Crypto King and Eduardo Ibanez, and not by Mr. Paul, including, without limitation, the
prior, intervening or superseding conduct of Messrs. Greenbaum and Ibanez.
Second Affirmative Defense
(Good Faith)
Mr. Paul’s statements and actions were undertaken in good faith, and constitute lawful,
proper, and justified conduct, consistent with reasonable consumer expectations and applicable
laws and regulations.
Third Affirmative Defense
(Assumption of Risk)
Plaintiff, a seasoned cryptocurrency investor, was aware of the risks associated with
investing in digital assets and assumed all risk for any potential losses.
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violate his constitutional rights under applicable law.
Tenth Affirmative Defense
(Overbroad Class Definition - Standing)
Plaintiff’s class definition is overbroad because it includes putative class members who
suffered no damages, and therefore lack standing to pursue claims against Mr. Paul or any
Defendant.
Eleventh Affirmative Defense
(Overbroad Class Definition - Failure to State a Claim)
Plaintiff’s class definition is overbroad because putative class members suffered no
damages, and therefore cannot state any claim against Mr. Paul or any Defendant.
Twelfth Affirmative Defense
(Inadequate Class Representative/No Standing)
Mr. Paul asserts that Plaintiff does not qualify as a class representative and lacks standing
to assert any claim on behalf of others.
Thirteenth Affirmative Defense
(Case not Appropriate for Class Certification)
This case is not appropriate for certification as a class action, and thus all class allegations
should be dismissed or stricken.
Fourteenth Affirmative Defense
(Texas Constitutional and Statutory Cap on Punitive Damages)
Plaintiff’s claims for punitive damages against Mr. Paul are limited to the caps on non- economic damages established by the Texas Constitution and Tex. Civ. Prac. & Rem. Code §
41.008.
Defenses Reserved
The foregoing defenses are raised by Mr. Paul without waiver of any other defenses that
may come to light during the discovery proceeding in this case, or otherwise. Mr. Paul hereby
reserves the right to amend or supplement this answer to assert any other related defenses as they
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project would define his reputation in the crypto space and more generally bear on his hard-earned
reputation as a successful content creator and influencer. But he believed strongly in his vision for
what he believed was a cutting-edge project with the potential to expose a greater audience to the
world of blockchain technology and NFTs. To realize that vision, though, Mr. Paul needed help.
4. Recognizing that he lacked the technical skill to build and launch CryptoZoo
himself, Mr. Paul assembled a team of purported specialists to execute the vision. Or at least he
thought he did. In the spring of 2021, Defendants Eduardo Ibanez and Jake Greenbaum a/k/a
Crypto King joined CryptoZoo as founding team members. Mr. Greenbaum and Mr. Ibanez
promoted themselves to Mr. Paul as experts who possessed the specialized knowledge and
expertise necessary to develop and launch the game. Mr. Greenbaum touted himself as a
“crypto/NFT expert,” who could oversee and consult on all blockchain-related aspects of the
project. Mr. Ibanez had previously founded a (now defunct) marketing and data analytics company
and purported to be an MIT-educated developer who had substantial cryptocurrency knowledge
and experience.
5. Mr. Greenbaum and Mr. Ibanez were con artists. Unbeknownst to Mr. Paul, both
men lied about their resumes, knowledge, experience, and intentions. Through fraud and deceit,
Mr. Greenbaum and Mr. Ibanez sabotaged the CryptoZoo project and prevented it from ever
realizing Mr. Paul’s vision.
6. While Mr. Paul has not sold a single ZOO Token or CryptoZoo NFT, has not made
any profit off the game, and has actually lost hundreds of thousands of dollars due to the duplicity
and deceit of those he trusted, Mr. Greenbaum and Mr. Ibanez have pocketed millions of dollars
as a result of their fraud.
7. This action seeks redress from Mr. Greenbaum and Mr. Ibanez for defrauding Mr.
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Philadelphia Eagles, which he had supposedly helped win a Super Bowl. Moreover, several
successful businessmen and entrepreneurs, including J. Christopher Burch, knew Mr. Ibanez
personally and vouched for him.
28. On or about February 19, 2021, Mr. Paul hosted an in-person kick-off meeting in
Los Angeles to brainstorm and flesh out the CryptoZoo concept. The meeting included Mr.
Greenbaum, Mr. Ibanez, and several members of Mr. Paul’s inner circle, including his manager
Jeffrey Levin, and his personal assistant Danielle Strobel. Because of this group’s involvement in
the project from the outset, they sometimes referred to themselves thereafter as the “founders” of
the project.
29. Ophir Bentov was not a founder in this respect, but he started working on the project
in the summer of 2021, primarily by managing the online community and by helping Mr. Paul
investigate Mr. Greenbaum’s suspected misdeeds. More on that below.
Mr. Greenbaum and Mr. Ibanez Assume Roles with CryptoZoo.
30. At the brainstorming meeting in February 2021, Mr. Greenbaum and Mr. Ibanez
recommended creating and incorporating a token into the Game. Under this token concept, animal
NFTs would yield “ZOO Tokens” to players in amounts that varied depending on the rarity of the
animal they owned, and players would then be able spend those Tokens in a virtual marketplace
and on a variety of in-game features and enhancements.
31. Unaware of the logistical and other potential implications of the decision to
incorporate a token, Mr. Paul was initially enthusiastic about the idea because he saw the potential
for a token to increase the Game’s virality and create a more dynamic and immersive player
experience. Unfortunately, the token concept set the stage for Mr. Greenbaum and Mr. Ibanez to
each undermine and sabotage the project for their own financial benefit.
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32. Consistent with what Mr. Paul understood to be their respective skillsets, following
the February 2021 meeting, Mr. Greenbaum and Mr. Ibanez proceeded to take ownership of and
advise on various aspects of the project. Mr. Greenbaum advised on all blockchain and
cryptocurrency-related aspects of the project, including the advantages and disadvantages of
selling NFTs on the Ethereum network versus the Binance Smart Chain (“BSC”) network.
33. Mr. Greenbaum also was responsible for the “economics” of the Zoo Tokens and
NFTs—i.e., the amounts that would be created, how they would be allocated, pricing, in-game
fees, and so forth—and he prepared the initial draft of CryptoZoo’s “whitepaper.”
34. Mr. Ibanez was responsible for the development of the Game, including the
gameplay, user interface, and website design. As with Mr. Greenbaum, Mr. Ibanez claimed to have
significant knowledge of cryptocurrency, blockchain technology, and the attributes of successful
projects in this space, and he acted as another advisor in these respects.
35. For his part, Mr. Paul was eventually to be responsible for marketing and promoting
the Game at the appropriate time. Between February and August 2021, however, Mr. Paul
contributed primarily by creating the rules of the Game; assigning names and rarities to the animals
that would be featured in the Game; providing high-level input on in-game features, design, and
functionality; and assisting to hire and oversee artists to work on graphics and animation.
36. During this time, Mr. Paul incurred approximately $220,000 in out-of-pocket
expenses for the project, most of which was spent on paying artists.
37. Mr. Ibanez, who represented himself as wealthy, told Mr. Paul he would come out
of pocket to pay for development costs, which would include paying a team of developers working
under his direction. Mr. Paul’s expenses were eventually reimbursed from the proceeds of the NFT
sales, and his understanding was that Mr. Ibanez’s development expenses would be similarly
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reimbursed.
38. In the weeks and months after the February 2021 brainstorming meeting, Mr. Paul
would regularly follow up with Mr. Ibanez about the status of development and related
deliverables. At every step of the way, Mr. Ibanez provided glowing updates about his progress
and solicited further input on Mr. Paul’s preferences to be incorporated into the Game.
Mr. Greenbaum Creates and Launches the Token Liquidity Pool.
39. In May 2021, as Mr. Paul was increasingly consumed with preparation for his
upcoming boxing match with Floyd Mayweather Jr., Mr. Greenbaum started planning for the
creation of a liquidity pool for the ZOO Token. Liquidity pools are markets created on a blockchain
for specific tokens; creating a liquidity pool essentially creates the first market where users are
able to transact with that token on the blockchain. It was in connection with the liquidity pool that
Mr. Paul started to suspect Mr. Greenbaum did not have CryptoZoo’s best interests at heart.
40. As Mr. Greenbaum explained to Mr. Paul and the other founders, it was appropriate
to create a liquidity pool for the ZOO Token at that stage, even though the project was still in
development, and the pool’s purposes were to (1) create a market for the ZOO Token, and stabilize
that market through trading activity, (2) lock a portion of the total ZOO Tokens in the pool to be
distributed later as in-game rewards for players, and (3) preserve another portion of Tokens for
distribution to the founders.
41. As Mr. Greenbaum further explained, the creation of a liquidity pool for the ZOO
Token would not be announced publicly, and nobody would know about it other than the founders.
From Mr. Paul’s standpoint, there was nothing nefarious about that secrecy; it was entirely
consistent with the purposes as set forth by Mr. Greenbaum, which both Mr. Greenbaum and Mr.
Ibanez told Mr. Paul were not only legitimate, but indeed standard.
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42. Thus, on June 11, 2021, without an official announcement, Mr. Greenbaum created
a liquidity pool for the ZOO Token on the Binance blockchain, thereby creating a market wherein
ZOO Tokens could be swapped for BNB Coin.
43. On that day, which the founders referred to as “Zoo Day,” the founders other than
Mr. Paul met in person in Los Angeles in order to take turns acquiring Zoo Tokens and adding to
the liquidity pool. Having just finished his Mayweather match days earlier (on June 6, 2021), Mr.
Paul participated in this process remotely from Puerto Rico.
44. Mr. Paul relied on Mr. Greenbaum with respect to all aspects of the liquidity pool.
This is evident from the founders’ communications on Zoo Day and the weeks leading up to it. On
May 16, 2023, Mr. Paul asked the founders, “who’s in charge of the liquidity/token pool blah blah
blah like idk how any of that shit works.” Mr. Greenbaum wrote that he was taking responsibility
for it “as part of [his] role for tokenomics and daily monitoring of the pool/funds.”
45. Mr. Greenbaum and Mr. Ibanez assured Mr. Paul and the other co-founders that
creating and trading in the liquidity pool did not present regulatory issues, and in that way was
distinguishable from selling the Tokens in a presale.
46. Based on Mr. Greenbaum’s claimed experience and expertise, as Mr. Paul was
buying ZOO Tokens and adding to the liquidity pool on Zoo Day, he sought directions primarily
from Mr. Greenbaum on when and how to buy, when and how to add to the liquidity pool, and in
what quantities. In one illustrative communication to his co-founders that day, Mr. Paul wrote, “idk
how this liquidity thing works or what the return looks like so explain it to me tomorrow
sometime.”
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Greenbaum from the project altogether. It was another several months, however, before Mr. Paul
was able to validate his suspicions about Mr. Greenbaum.
Mr. Paul Publicly Announces the CryptoZoo Project After Receiving Assurances of
Progress from the CryptoZoo Team.
57. CryptoZoo was Mr. Paul’s passion project. Because of his drive to build a
successful project, Mr. Paul would constantly challenge and reevaluate the key decisions and
assumptions underlying the project. That is why, even after the liquidity pool was created and Mr.
Paul and his co-founders had spent hundreds of thousands of dollars acquiring ZOO Tokens, he
still continued to question whether the Game should incorporate a token at all.
58. On August 7, 2021, Mr. Paul asked Mr. Greenbaum and Mr. Ibanez whether there
were other successful NFT projects that utilized a token. Mr. Paul wondered whether the Token
made the game “gimmicky,” and whether “the strength of our NFTs and the art can speak for itself
/ And it becomes solely collectible based / Like the banger projects [right now].” Mr. Greenbaum
and Mr. Ibanez responded by offering examples of other NFT games that utilized tokens. Together,
they convinced Mr. Paul that the ZOO Token was intertwined with the CryptoZoo concept and
integral to the success of the Game.
59. From the time of the founders’ brainstorming meeting in February 2021, Mr. Paul
had repeatedly expressed that he would not be marketing or promoting CryptoZoo until
development was complete.
60. To that end, between February and August 2021, Mr. Paul often rejected efforts by
Mr. Greenbaum and Mr. Ibanez to fast-track development in order to take advantage of what they
perceived as a thriving but mercurial NFT market—a market that Mr. Greenbaum at one point
described as a “house of cards.”
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61. On Zoo Day, for example, Mr. Paul asked about next steps following the creation
of the liquidity pool. Mr. Greenbaum and Mr. Ibanez responded with a list of tasks, including
setting up a website and social media accounts, setting up an online community on both Discord
and Telegram, conducting an egg NFT sale, and finishing development and launching the Game.
Mr. Greenbaum insisted that these tasks were “[a]ll short term as in 1-2 days.” Mr. Paul responded,
“no rush boys please / until development is done and checked THOROUGHLY I don’t want to
start doing other shit super publicly / Gotta make sure platform is FLAWLESSSSS.”
62. On August 7, 2021, Mr. Greenbaum followed up to ask about the timing of the
project’s announcement, noting, “Bullish momentum right now with NFTs and coins couldn’t be
more perfect.” Mr. Paul told Mr. Greenbaum to “chill,” responding, “Project needs to be perfect
before we launch / Market is hot but more important we get this right.”
63. Within the next few days, Mr. Ibanez started providing Mr. Paul with explicit,
unequivocal assurances that CryptoZoo’s development had progressed to its final stages and that
Mr. Paul therefore could confidently announce the Game and at the same time provide the public
with a specific launch date for the sale of egg NFTs (the “Egg Sale”).
64. For example, on August 9, 2021, Mr. Ibanez informed Mr. Paul that the NFTs were
ready to be sold to the public, saying “Eggs are good to go.” When Mr. Ibanez proposed September
1, 2021 as the date for the Egg Sale, Mr. Paul asked for confirmation that everything would be
ready by then, reiterating that it “Needs to be perfect.” Mr. Ibanez provided this confirmation,
responding, “For Egg pre-sale 1000%.” “For game also,” he added.
65. The following week, on August 15, 2021, Mr. Paul sought confirmation that nothing
had changed, asking Mr. Ibanez, “[S]till feeling good about September 1?” To which Mr. Ibanez
responded, “On Dev [i.e., development] yes. Marketing I’m trusting you.”
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66. Mr. Ibanez substantiated his assurances to Mr. Paul through a series of text
messages, phone calls, and videoconferences, during which he detailed the items that were
outstanding and provided timeframes for their completion.
67. Mr. Ibanez further validated his assurances to Mr. Paul by representing that he (Mr.
Ibanez) had been consulting with lawyers about the rollout of the project. Mr. Ibanez had told Mr.
Paul and the other founders, for example, that steps had been taken to obtain a CryptoZoo
trademark and that he had received the “go ahead from legal that we can launch.” Mr. Paul had
also instructed Mr. Levin, as his manager, to ensure that “[a]ll paperwork and legalities” were
completed, and Mr. Levin confirmed that he had been discussing these matters with Mr. Ibanez.
68. Having no reason at that time to question the information he was receiving from
Mr. Ibanez, whom he trusted, Mr. Paul proceeded to publicly announce CryptoZoo on his
Impaulsive podcast on August 17, 2021.
69. The plan was for the project to be released in phases: The Egg Sale would take
place several weeks later, on September 1, but the gameplay components—which included the
ability to actually hatch the eggs and breed animals, and the ability of those animals to yield ZOO
Tokens—would take place at dates to be determined and announced thereafter.
70. In the days following Mr. Paul’s announcement, Mr. Ibanez continued to represent
that development of all phases was on track, at one point informing Mr. Paul that the entire Game—
not just the components needed for the Egg Sale—would be completed by August 20, 2021.
71. Mr. Paul was ecstatic for the world to finally be introduced to CryptoZoo. He hoped
for the project to be successful and profitable, but his overarching focus was on seeing his vision
for the Game fulfilled. When Mr. Ibanez reached out to inform Mr. Paul on the day of the
announcement that the market capitalization had reached $100 million, Mr. Paul responded, “Bro
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who cares / Honestly fuck all that / I hope people find the stupid satisfaction we find with hatching
their hybrids / That’s what I want / Fuck the token / Fuck everything / I want someone to laugh out
loud about this:”—and he then sent a picture of a “Pandacat,” one of the hybrid animals that would
be featured in the Game.
72. Around the same time, Mr. Paul wrote to his co-founders, “When this shit goes
crazy. Everyone stay calm. I swear to god just breathe & don’t make it a big deal. We just came
to make people live out their wildest imaginary dreams / Everything else is a bonus.”
Mr. Paul Uncovers Mr. Greenbaum’s Deceit and Ousts Him from CryptoZoo.
73. As anticipated, after Mr. Paul publicly announced CryptoZoo, the price of ZOO
Tokens skyrocketed. Troublingly, as that happened, ZOO Tokens were being sold from wallets that
had held volumes so significant they could only have been held by one of the founders, in violation
of the trading rules the founders had previously agreed to amongst themselves.
74. Mr. Paul was incensed by this and told his co-founders, “Your tokens do not leave
your wallet / this is a game / not a shitcoin / and as of now / the coin went up / because I said
something about it / so when someone else is capitalizing on it and jeopardizing the integrity of a
very honest and legitimate project, who do you think takes the blame publicly?”
75. At Mr. Paul’s direction, between August 18 and August 24, 2021, Mr. Bentov
helped investigate the source of the trading activity and determined that dozens of wallets selling
ZOO Tokens were either controlled by, or had received their Tokens from, Mr. Greenbaum.
76. In or around this timeframe, Mr. Paul also learned, as he had suspected, that third
parties had learned about ZOO Tokens from Mr. Greenbaum or had purchased their Tokens directly
from him. Mr. Paul confirmed that Mr. Greenbaum had in fact been selling ZOO Tokens behind
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the-table cash deals.
77. When confronted, Mr. Greenbaum denied that he personally had been selling
Tokens. Although he admitted to distributing Tokens to third parties, he claimed to have believed
that the founders had authorized such distributions, and he attempted to defend the reasonableness
of the third parties’ respective decisions to sell in the current market environment. He told Mr. Paul
that he was overreacting in light of public enthusiasm for the project, which he attributed to NFT
influencers promoting the project at his (i.e., Mr. Greenbaum’s) request.
78. Outraged, and having lost all trust and confidence in Mr. Greenbaum, Mr. Paul
agreed with a plan conceived by several of the co-founders to remove him from the project. A new
version of the ZOO Token was launched, and wallets that held the original version of the Token
were credited 1:1, replacing each original ZOO Token with the new version of the Token. In doing
so, the wallets that were traceable to Mr. Greenbaum were effectively “blacklisted.”
79. When Mr. Greenbaum realized what was happening, he called Mr. Paul a scam
artist and accused him of betraying his community and orchestrating a rug pull.
80. By that point, however, Mr. Paul knew that CryptoZoo—which had yet to even
launch—would never be able to realize its potential with someone like Mr. Greenbaum sabotaging
the project from the inside for his own financial gain. Mr. Paul told the other founders: “The game
is beyond him. Wait until we successfully launch our eggs and I explain this fucking surgical
maneuver we pulled off to remove the snake from the grass it is fucking legendary / That’s the
thing about honesty and authenticity boys / Can’t lose when you’re true to yourself and others.”
81. Mr. Greenbaum would later admit that he had made millions of dollars through his
surreptitious sale of ZOO Tokens. But unbeknownst to Mr. Paul until much later, Mr. Greenbaum
was not the only founder engaging in this type of deception.
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82. Once Mr. Paul informed the co-founders that he would be publicly announcing
CryptoZoo on his podcast, Mr. Ibanez started trading in the ZOO Token liquidity pool in order to
profit from the forthcoming announcement. Starting on August 16, 2021, the day before the
announcement, he started adding liquidity to the liquidity pool. Then, on August 20, 2021, several
days after the announcement, Mr. Ibanez closed his liquidity pool position and cashed out after the
price of ZOO Tokens spiked. The timing of this maneuver alone netted Mr. Ibanez approximately
85 BNB (approximately $38,000.00).
83. Moreover, contrary to what he had been representing to the founders at the time,
Mr. Ibanez had also been divesting himself of the ZOO Tokens he had acquired on Zoo Day.
Between Zoo Day and Mr. Paul’s Impaulsive announcement, Mr. Ibanez transferred more than 36
billion ZOO Tokens to unattributed wallets. Over the nine days following the announcement, he
transferred his remaining balance of Tokens—totaling more than 71 billion Tokens—to additional
unattributed wallets. The 23 unattributed wallets to which Mr. Ibanez had sent Tokens proceeded
to transfer those Tokens to dozens more unattributed wallets, many of which then started selling.
84. Based on public reports, Mr. Ibanez made approximately $1.7 million from selling
ZOO Tokens, an amount Mr. Paul has not independently substantiated but has no reason to refute.
At the time, Mr. Paul did not know of Mr. Ibanez’s trading activity. He was, however, about to
learn the hard way that Mr. Ibanez was not who he had claimed to be, and that he had been deceived
all along about Mr. Ibanez’s ability to deliver the Game.
The Egg Sale Does Not Proceed as Planned and Mr. Paul Continues to Receive False
Promises from Mr. Ibanez about the Progress of the Game’s Development
85. Despite Mr. Ibanez’s repeated assurances to Mr. Paul that the Egg Sale would be
ready by September 1, 2021, it was not. Because of Mr. Ibanez’s lack of preparedness, the Egg
Sale was delayed from September 1 until September 3. Frustrated, Mr. Paul told Mr. Ibanez at the
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time that “If we give a release date, we have to hit it.” But, unfortunately, the issues were only
beginning.
86. On launch day, the rollout of the Egg Sale experienced significant technical
difficulties, causing general confusion and frustration in the online community. For example, the
plan as advertised to the community had been for 5,000 egg NFTs to be sold on OpenSea and made
available for purchase using Ethereum, and for another 5,000 egg NFTs to be sold on CryptoZoo.co
and made available for purchase using BNB. But the OpenSea component experienced delays,
glitches, and suspected bots that made the NFTs difficult to acquire, eventually leading to the
majority of the NFTs having to be sold for BNB.
87. These technical issues and delays were compounded by the presence of scammers
selling fake egg NFTs that were unaffiliated with the project, the fact that some non-blacklisted
holders of the original ZOO Token had failed to receive the 1:1 airdrop of the new version of the
Token, and a general inability of Mr. Ibanez and his development team to resolve issues as they
arose and ensure the community was being kept informed.
88. Although the egg NFTs sold out, Mr. Paul was horrified by how the Egg Sale had
transpired. On September 5, 2021, Mr. Paul wrote to Mr. Ibanez and the rest of the team to address
their deceit about their level of preparedness: “The problem is that we are extremely understaffed,
underequipped, under-experienced and bit off more than we can chew and none of it was relayed
to me / Manage my expectations / If something can’t be done I need to know / And so far nothing
has been done on time or as it was told to me. . . .”
89. Mr. Paul instructed Mr. Ibanez to “hire more devs [i.e., developers]” immediately
to ensure the Game was completed properly. He instructed him to hire four or five more developers
and “bring them on tomorrow,” saying, “I don’t care how much it costs.”
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90. Mr. Levin traveled to New York City to oversee Mr. Ibanez and his team of
developers and to try and gain comfort that development was on track and that they had adequate
support. But in the weeks that followed, the project only continued to spiral further out of control.
91. As Mr. Paul was shown aspects of the Game that supposedly were far-along in their
development, he grew increasingly concerned. As one example, on September 8, 2021, Mr. Paul
was shown a test of CryptoZoo’s virtual marketplace. Mr. Paul’s impression was that it was
confusing and felt like an “incomplete product.” He told Mr. Ibanez that they only had one shot at
a first impression, and that his own first impression was “Wtf is this.” Mr. Paul told his
management team that he regretted using Mr. Ibanez, but by then it was too late.
92. On September 29, 2021, Mr. Paul learned that Mr. Ibanez’s lead developer had
apparently stolen the code to the Game and was holding it hostage, trying to extort Mr. Paul and
the other founders for $1 million. Mr. Ibanez relayed that his developer “went rouge [sic], I had
to launch a new token to kill him as he was talking shit and trying to extort us. . . . I’ve never had
this happen—I am very pissed and I take full responsibility for this. We are focusing on game and
getting it out and KO’ing and making it rock.”
93. Mr. Ibanez had, inexplicably, hired as his lead developer a rumored former felon
who previously had been incarcerated for armed robbery and who, even before stealing the code,
had been badmouthing Mr. Paul and the very project he was tasked with building in online forums.
94. Mr. Paul was beside himself with frustration. On September 30, 2021, he messaged
Mr. Ibanez and the rest of the team and said: “Absolutely fucking ridiculous. All of this. I’m
baffled. Everyone will be publicly held accountable for any errors, blunders, or missteps or
betrayals that took place for this project—I’m not sure there’s a worse feeling than putting your
trust in a team that continually fails in the biggest way possible. I’ve done all I can & for the first
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time in my life I’m completely powerless—but I will not go down here, because I’m not
responsible, and I WILL execute this game properly with the right people.”
Mr. Paul Discovers that Mr. Ibanez is a Complete Fraud.
95. In late October 2021, Mr. Paul learned for the first time that Mr. Ibanez may have
misrepresented his credentials. Mr. Bentov messaged Mr. Paul and said Mr. Ibanez is a “con artist
the biggest I’ve ever met.” Mr. Paul asked, “IS he a con? Or is he just a pathetic miserable loser,”
to which Mr. Bentov insisted, “Nah he is a con.”
96. Mr. Bentov relayed an unconfirmed rumor that Mr. Ibanez had never attended MIT,
to which Mr. Paul responded, “fuckkk . . . I’m gonna kill Mike [Majlak] for introducing me to this
fucking guy under the guise of genius development.”
97. In that conversation with Mr. Bentov, Mr. Paul wondered what possible reason there
could be for Mr. Ibanez to have misled him for the preceding eight months about his ability to
develop the Game. The answer to that question came a few months later in February 2022, when
a local Philadelphia news outlet ran an article about Mr. Ibanez that detailed a lifetime of
deception.1
98. It turned out that Mr. Ibanez’s entire backstory was a fabrication, including the
credentials that had caused Mr. Paul to entrust the project to him in the first place. Not only had
Mr. Ibanez never attended MIT or worked for NFL teams, but he also had misrepresented a variety
of other accomplishments and skillsets. He previously had been accused by an LDS church of
attempting to access and misappropriate sensitive information of its members, his defunct data
1 See Adam Robb, “Philly-born tech founder who falsely claimed he had an Eagles Super Bowl
Ring and helped the CIA hunt terrorists got $1.5 million in PPP loans as his company went up in flames,”
Billy Penn at WHYY (Feb. 14, 2022), https://billypenn.com/2022/02/14/eddie-ibanez-zenabi-eagles- dolphins-logan-paul/.
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analytics firm was under federal investigation for suspected PPP fraud, he was currently being
sued by a landlord for more than $100,000 in back rent and property damage, and judgments
against him from other creditors had already started to accumulate. None of this had been known
by Mr. Paul (or the various other businesspeople who Mr. Ibanez had conned over the years).
Mr. Paul Is Repeatedly Assured CryptoZoo Is Still in Development.
99. Following the Egg Sale and the development issues that became apparent in the
days and weeks that followed, Mr. Paul became less involved in the day-to-day of CryptoZoo.
100. From September 2021 through 2022, Mr. Levin attempted to get the project back
on track, including by working with new development teams to take over Mr. Ibanez’s
responsibilities. During that time, as Mr. Paul waited for the go-ahead from his manager to
reengage with the project, Mr. Paul would periodically receive updates from Mr. Levin and Mr.
Bentov who made clear that the project was progressing—albeit slowly.
101. On January 4, 2022, Mr. Levin informed Mr. Paul that a recently hired developer,
Vatom, was building out the project and was “doing great.” Mr. Levin said, “Unfortunately slower
than we expected but we now have a very capable and excited team building.” That same day, Mr.
Bentov told Mr. Paul that the project was “starting to look up” and that the new developers were
“A+.”
102. Because Mr. Paul understood the project was not a matter of if, but when, in late
January 2022 he purchased the cryptozoo.com domain name that he had long coveted.
103. In the months that followed, he continued receiving positive and reassuring updates
about the status of the slow-moving development of CryptoZoo.
104. In June 2022, with development still underway, Mr. Paul asked Mr. Levin and Mr.
Bentov whether he should publicly discuss what had caused the unexpected and ongoing delays.
Mr. Levin responded that, “The solve is being worked out. We are working on an updated roadmap
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and timeline. Upon that we will explain past and future.” Mr. Paul asked how the project could be
successfully revived at that point, to which Mr. Levin responded, “By building. Which we are
working on.”
105. In the same conversation, Mr. Paul begged Mr. Levin, “don’t let me down or the
CryptoZoo heads. PLS MAKE SOMETHING DOPE.” Given that Mr. Paul did not control the
CryptoZoo game wallets that held proceeds from NFT sales, and did not know what had become
of them, he also suggested that “someone should explain [to the public] what’s going on. And be
transparent about funds. Cuz I’m curious too.”
Mr. Paul Pledges to Buyback all of the CryptoZoo Egg NFTs.
106. In January 2023, Mr. Paul announced that he was personally committing 1,000
Ethereum to a buyback program, whereby disappointed holders of egg NFTs and base animal NFTs
would be able to return those NFTs for the mint price of .1 Ethereum. Contemporaneously with
the filing of the crossclaims asserted herein, Mr. Paul is announcing the launch of the promised
buyback.
107. Mr. Paul spent hundreds of thousands of dollars trying to continue to develop
CryptoZoo. But he eventually learned that the Game, as he envisioned it, was not feasible because
of regulatory issues of which he had never previously been apprised.
108. Throughout the history of CryptoZoo, Mr. Paul has only ever desired the creation
of a fun, blockchain-based digital collectibles game. Unlike Mr. Ibanez or Mr. Greenbaum, he has
not sold a single ZOO Token or NFT and has not made any profit off the game; to the contrary,
Mr. Paul has lost hundreds of thousands of dollars due to the duplicity and deceit of those he
trusted.
109. Mr. Paul brings these crossclaims to hold Defendants Jake Greenbaum and Eddie
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Ibanez responsible for the harm he has been caused by their misconduct, which includes significant
reputational harm and out-of-pocket expenses relating to the project.
CLAIMS FOR RELIEF
COUNT I
FRAUDULENT INDUCEMENT
against Mr. Ibanez and Mr. Greenbaum
110. Mr. Paul incorporates by reference paragraphs 1 through 114 as though set forth
herein.
111. Mr. Ibanez and Mr. Greenbaum held themselves out to Mr. Paul as subject-matter
experts qualified to successfully launch CryptoZoo. Mr. Ibanez represented that he was an MIT- educated computer developer capable of developing the computer game at the center of the NFT
project. Mr. Greenbaum represented he was a cryptocurrency and blockchain expert that could
handle all token and blockchain related aspects of the CryptoZoo project.
112. Mr. Ibanez did not attend MIT and was not an expert computer developer.
113. Mr. Greenbaum was not a blockchain or cryptocurrency expert. Mr. Greenbaum
did not possess the deep technical knowledge he claimed, but. knew just enough to loot
CryptoZoo for his personal gain.
114. Mr. Paul relied on Mr. Ibanez’s and Mr. Greenbaum’s representations about their
skills, experience, and expertise in deciding to bring them on to the CryptoZoo team.
115. Mr. Paul relied on Mr. Greenbaum and Mr. Ibanez to execute his vision and
oversee CryptoZoo in good faith and would not have retained them had he known that they
would exploit the CryptoZoo project for personal gain.
116. As a result of Mr. Ibanez and Mr. Greenbaum’s misrepresentations to Mr. Paul,
Mr. Paul has suffered significant monetary damages as well as reputational harm.
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WHEREFORE, Mr. Paul demands judgment against Eduardo Ibanez and Jake Greenbaum
a/k/a Crypto King, for fraudulent misrepresentation, awarding damages, attorneys’ fees, costs, pre- and post-judgment interest, and any other relief this Court finds just.
COUNT II
FRAUDULENT MISREPRESENTATION
against Mr. Ibanez and Mr. Greenbaum
117. Mr. Paul incorporates by reference paragraphs 1 through 114 as though set forth
herein.
118. Mr. Ibanez and Mr. Greenbaum misrepresented to Mr. Paul team that they would
not sell ZOO Tokens for their own financial gain and/or that they would not purchase ZOO
Tokens from the liquidity pool from unknown cryptocurrency wallets.
119. Both Mr. Greenbaum and Mr. Ibanez also failed to disclose material facts about
the CryptoZoo project to Mr. Paul. Both men, for example, failed to disclose that they started
trading out of the liquidity pool as early as June 11, 2021, for their own financial gain.
120. Mr. Ibanez and Mr. Greenbaum knew these representations and omissions were
false and sought to conceal the truth from Mr. Paul so they could financially benefit by selling
ZOO Tokens without Mr. Paul’s knowledge, which they did.
121. Mr. Ibanez and Mr. Greenbaum intended for Mr. Paul to rely on these
misrepresentations, so they would continue as part of the CryptoZoo project, and thereby line
their own pockets at Mr. Paul’s expense.
122. Mr. Paul did in fact rely on Mr. Ibanez’s and Mr. Greenbaum’s misrepresentations
about the ZOO Tokens and allowed Mr. Ibanez and Mr. Greenbaum to remain members of the
CryptoZoo team, even after they surreptitiously traded ZOO Tokens for their own benefit
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without Mr. Paul’s knowledge. team and further enrich themselves.
123. As a result of Mr. Ibanez’s and Mr. Greenbaum’s fraud, Mr. Paul has suffered
significant monetary damages as well as reputational harm.
WHEREFORE, Mr. Paul demands judgment against Eduardo Ibanez, and Jake Greenbaum
a/k/a Crypto King, for fraud, awarding damages, attorneys’ fees, costs, pre- and post-judgment
interest, and any other relief this Court finds just.
PRAYER FOR RELIEF
Mr. Paul requests that the Court award him relief against Mr. Ibanez and Mr. Greenbaum
as follows:
(1) Actual and compensatory damages, including interest, his reasonable attorneys’
fees, and costs, as allowed by law;
(2) Punitive damages, as allowed by law;
(3) Pre-judgment and post-judgment interest as provided by law;
(4) Any further and different relief as this case may require or as determined by this
Court to be just, equitable, and proper under the circumstances.
DEMAND FOR JURY TRIAL
Pursuant to Federal Rule of Civil procedure 38(b), Mr. Paul demands a jury trial for any
and all issues triable by a jury.
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CERTIFICATE OF SERVICE
I hereby certify a copy of the above and foregoing has been served upon all counsel of
record by using the Court’s electronic filing system on the 4th day of January 2024.
/s/ Shelby O’Brien_________________
Shelby O’Brien
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