Lawsuit: In Session Privacy Matters v. Nexalin [2025] FCR 36

Your honor,

As the current Secretary of Commerce, I wish to file an Amicus Brief regarding the corporate structure of Vanguard & Co and how that may impact the defendant of this case.
You may do so.
 

Brief


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
AMICUS BRIEF

Your honor,
The current question that is posed in the court is whether or not Nexalin is liable for the liabilities of Vanguard Securities LLC. I wish this brief will give some more context on the corporate structure of Vanguard & Co so the court will be able to make an informed decision on if Nexalin can be considered liable for Vanguard Securities LLC.

Looking at a literal sense, Vanguard Securities LLC is owned by Nexalin directly. As Vanguard Securities LLC is a sole properitorship, the owner of the DB would be liable for any liabilities that the company may take on. This means that the debt will pass onto Nexalin.

However, Vanguard Securities LLC was also publicly shown multiple times as owned by Vanguard & Co. As shown in the attached diagram, Vanguard Securities was a subsidiary of Vanguard & Co. This diagram was published in #economics on April 9th, 2025. More instances of this diagram was also shown to DOC employees in classified channels or chats deleted by Nexalin. This isnt just a one-off instance of Nexalin claiming this, he showed this to Department of Commerce employees and released it in public, showing it was at least true until the time Vanguard & Co was seized by the DOC.

What does this mean? While Vanguard Securities LLC is a sole propertiorship and the in-game owner of said firm is the one liable, you can bring a good point that Vanguard & Co actually was the one to own the sole properiorship of Vanguard Securities LLC as shown by the diagram. While they aren't the in-game owner of the firm, it can be argued that Vanguard & Co couldn't directly own Vanguard Securities LLC due to limitations in the plugin.

I hope from this information that the court may be able to come to a much better consensus on how to rule on this case. While the defendant of this case may not matter as much, it does give precedent that sole properitorships may not be owned by individual companies. The court should be informed of this information so that they dont unwillingly create precedent that may be against the court's intentions. Allowing Nexalin to be sued for the actions of Vanguard Securities LLC implies that sole properitorships may not be owned by non-player entities and does have an impact on corporate law. While the court may be willing to create this precedent, the court should be informed that it will be creating such a precedent.

Message Link of Diagram in Discord

Screenshot 2025-07-24 at 12.29.09 PM.png

 
I edited the brief to fix the broken message link
 
@ToadKing, please provide a brief explaining the purpose of requesting punitive damages on behalf of the other 33 users. As a class action group, do you plan to distribute winnings amongst the other users not listed as plaintiffs in this case?

In the brief, you may include any other information you deem relevant.
 
@ToadKing, please provide a brief explaining the purpose of requesting punitive damages on behalf of the other 33 users. As a class action group, do you plan to distribute winnings amongst the other users not listed as plaintiffs in this case?

In the brief, you may include any other information you deem relevant.
Notification and update on this.
The judgement will be ready to be posted 24 hours after the time the quoted post was made. If a brief is not filed before then, it will not be considered in the judgement.
 
Notification and update on this.
The judgement will be ready to be posted 24 hours after the time the quoted post was made. If a brief is not filed before then, it will not be considered in the judgement.
Your Honour,

I will be unable to provide an answer in the time required. I humbly request a 24-hour extension so I can finish writing a response to your questions.
 
Pursuant to Rule 3.3 (Amendment to Complaint), the Plaintiff amends the Prayer for Relief section of the Complaint as follows:

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:

1. Punitive damages in the amount of $50,000 per named Plaintiff (6 plaintiffs x $50,000 = $300,000) for the Defendant's outrageous conduct in violation of the Privacy Act;

2. Additional punitive damages in the amount of $1,650,000, representing damages for the estimated 33 additional affected users, calculated as follows:
- VMA's Discord server contains 104 members
- Subtracting 3 Discord bots and 1 Defendant = 100 potential users
- Applying a conservative estimate of one-third actual platform usage = 33 affected users
- 33 users x $50,000 per user = $1,650,000

3. 30% Legal fees, totalling $585,000 as provided by Section 9 of the Legal Damages Act.


2. Additional punitive damages in the amount of $5,800,000, representing damages for the 116 additional affected users, calculated as follows:
- VMA had 123 total registered users (P-015)
- Subtracting 6 current named plaintiffs and 1 defendant (Nexalin) = 116 affected users
- 116 users x $50,000 per user = $5,800,000

3. Legal fees in the amount of $1,830,000, as provided by Section 9 of the Legal Damages Act.


EXPLANATION FOR AMENDMENT:
This amendment updates the damages calculation based on the actual number of VMA users, replacing previous estimates with concrete data showing 123 total registered users affected by the alleged Privacy Act violations.


Brief


Pursuant to Your Honour's request for clarification regarding punitive damages for additional users, the Plaintiff submits this brief:

@ToadKing, please provide a brief explaining the purpose of requesting punitive damages on behalf of the other 33 users.
1. Section 5(1)(a) of the Legal Damages Act provides that punitive damages serve "to punish them for their outrageous conduct and to deter them and others like them from similar conduct in the future." The systematic privacy violations affected all VMA users uniformly, making each user entitled to equal protection and remedy under the Privacy Act.

2. The Defendant has AFFIRMED that "These practices affected all VMA users in a uniform manner" (Answer 9). The Privacy Act violations - including the absence of privacy policies, false claims about disclosures, and undisclosed data sharing - harmed every user regardless of whether they are named plaintiffs.

3. The requested punitive damages reflect the true scope of Nexalin's outrageous conduct affecting over 100 users and provide both meaningful compensation for victims and effective deterrence against future privacy violations by financial institutions and other organisations. Privacy matters.

As a class action group, do you plan to distribute winnings amongst the other users not listed as plaintiffs in this case?
4. Now that we have obtained the complete list of all VMA users, MZLD would initiate an outreach program to contact all affected users and inform them of their rights to claim their portion of any damages awarded.

5. Each of the 116 non-plaintiff users will be contacted directly through available means (Discord, in-game, etc.) and informed that they are entitled to claim damages from this case.

 
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