Lawsuit: In Session Vendeka Inc. and Pepecuu v. Department of Commerce [2025] FCR 107

EmmDubz

EmmDubz

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Case Filing


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION


Vendeka Inc. & Pepecuu
Plaintiff

v.

Department of Commerce
Defendant

COMPLAINT
The Plaintiff complains against the Defendant as follows:

WRITTEN STATEMENT FROM THE PLAINTIFF

This is a case for breach of contract and the Defendant's failure to adhere to its own crisis management policies. The Defendant, as the legal successor to the commandeered entity "The Exchange Inc.," defaulted on the repayment of the TEX-001 bonds held by the Plaintiffs.

Following the seizure, the Defendant published the "Financial Crisis Mitigation Plan," which created a distinct classification for the Plaintiffs as "Secured Creditors" based on their holding of "financial securities." The Defendant has since violated its own plan by improperly attempting to relegate the Plaintiffs' specific contractual claims to the State Owned Withdrawal Facility (SOWF), a separate process designed for depositors. The Plaintiffs seek to enforce their contractual rights and compel the Defendant to follow its own published rules.
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I. PARTIES
1. Vendeka Inc. (Plaintiff)
2. Pepecuu (Plaintiff)
3. Department of Commerce (Defendant)

II. FACTS
1. On April 24, 2025, The Exchange Inc. issued the "TEX-001" bonds, creating a binding loan contract with a mandatory maturity date of July 24, 2025. The Plaintiffs purchased a combined 2,452 units of these financial securities.
2. On June 27, 2025, the Defendant invoked its power under the Taxation Act to "commandeer" The Exchange Inc., choosing not to declare the entity bankrupt and thereby maintaining its legal continuity and inheriting its liabilities.
3. On the 5th of July 2025, and subsequently on the 5th of August, the second and third interest payments respectively were not paid out.
4. On July 13, 2025, the Defendant published the "Financial Crisis Mitigation Plan," which explicitly defined "Secured Creditors" to include entities holding "financial securities in the Exchange."
5. On July 24, 2025, while under the Defendant's direct control, the TEX-001 bonds reached their maturity date. The Defendant failed to repay the principal owed, constituting a material breach of contract.
6. In subsequent communications, the Defendant has contradicted its own Mitigation Plan by directing the Plaintiffs to the SOWF, a facility the plan reserves for "Depositors."

III. CLAIMS FOR RELIEF
1. The Defendant, as the successor-in-interest to The Exchange Inc., is liable for the material breach of the TEX-001 bond contract.
2. The Defendant is acting in an arbitrary manner by violating its own "Financial Crisis Mitigation Plan" and improperly classifying the Plaintiffs' claims.

IV. PRAYER FOR RELIEF
The Plaintiffs seeks the following from the Defendant:
1. $490,400 in compensatory damages, representing the principal value of 2,452 units of TEX-001 bonds at $200 per unit.
2. $29,424 in compensatory damages, representing two months of unpaid, accrued interest at the contractual rate of 3.0% per month.
3. $155,947.20 in legal fees, equalling 30% the compensatory damages.

V. EVIDENCE

1. P-001: The bond offering announcement for TEX-001.
2. P-002: An announcement from the Secretary of Commerce, dated the 27th of June 2025, confirming the commandeering of The Exchange.
3. P-003: The "Financial Crisis Mitigation Plan".
3. P-004: The "Voyager & The Exchange | Assessment of Health And Federal Seizure" report.
5. P-005: Proof of ownership of TEX-001 bonds for Vendeka Inc. & Pepecuu.
6. P-006: Transcript of DoC support ticket between Vendeka Inc. (EmmDubz) & the DoC.
7. P-007: First interest payment announcement.

Proof of Representation:

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By making this submission, I agree I understand the penalties of lying in court and the fact that I am subject to perjury should I knowingly make a false statement in court.

DATED: This 14th day of October 2025

 

Attachments

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  • P-004.pdf
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  • P-003.pdf
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Writ of Summons

@Kaiserin_ is required to appear before the federal Court in the case of Vendeka Inc. and Pepecuu v. Department of Commerce [2025] FCR 107

Failure to appear within 72 hours of this summons will result in a default judgement based on the known facts of the case.

Both parties should make themselves aware of the Court Rules and Procedures, including the option of an in-game trial should both parties request one.

 
The Commonwealth is present, your honour.
 
@Kaiserin_ You have 48 hours to file your Answer to Complaint.
 
Your Honour,

This case shares striking similarity with the unsettled matter of Gribble19 v. The Exchange, Inc. [2025] FCR 102. Crucial to both cases are such matters of law as whether or not The Exchange exists as a legal entity, whether or not the Commonwealth is liable for its debts, whether or not its being commandeered has resulted in a force majeure, and whether or not it is insolvent, among others.

As FCR 102 was filed before this case, we asked that this case be enjoined until such time as FCR 102 has reached a verdict, or at least until the crucial matters of law regarding the legal status of The Exchange have been settled within that case. This would ensure that the same matters are not being litigated several times at once, and ensure consistency in the application of the law to these incredibly high value cases, so that no mistake is made.
 
Your honour, we would like to respectfully request your permission to file a proper response to this motion to enjoin.

The Defendant's motion correctly states the need to "ensure consistency in the application of the law... so that no mistake is made." However we believe that our response is necessary to aid the court in achieving this as there are significant material differences between this case & Gribble19 v. The Exchange, Inc, [2025] FCR 102 which could result in harm to the Plaintiffs if these differences are not heard.
 
Your honour,

Seeing as the request for enjoinment has yet to be ruled upon, the defence requests an extension of 48 hours on our Answer to Complaint.
 
My apologies. For some reason, I wasn't notified about updates in this case.

EmmDubz said:
Your honour, we would like to respectfully request your permission to file a proper response to this motion to enjoin.

The Defendant's motion correctly states the need to "ensure consistency in the application of the law... so that no mistake is made." However we believe that our response is necessary to aid the court in achieving this as there are significant material differences between this case & Gribble19 v. The Exchange, Inc, [2025] FCR 102 which could result in harm to the Plaintiffs if these differences are not heard.
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You may make your motion, and then I shall rule on the enjoining.
 
Thank you your honour.

This case should be allowed to continue due to a number of factors, including the fact that the Defendant in this case is the DoC, not The Exchange (TEX) as is the case in Gribble19 v. The Exchange, Inc. [2025] FCR 102 (Gribble). This difference is not simply one in presentation, but material, and results in the fact that while both cases are aimed at the TEX-001 bond default, they are not interchangeable. This single change nullifies multiple arguments brought by the Defence in Gribble, including defences B & C as noted in their Answer to Complaint.

Defence B in Gribble argues that the government takeover was an unforeseeable event and as such, Force Majeure would free The Exchange of its liabilities. However this defence is not applicable once the Defendant ceases to be TEX, and instead the DoC. The DoC would not be able to argue its own premeditated actions were "unforseen", and therefore excuse itself from its own obligations.

Likewise, Defence C in Gribble argues that "The Exchange, Inc. is insolvent and simply cannot pay." This defence becomes irrelevant again as this case features the defendant as the DoC, not TEX.

Furthermore, this case introduces critical legal arguments that are entirely absent from Gribble. The case we've presented is grounded in the direct legal consequences of the Defendant's own policies under the law. By choosing to commandeer TEX, while refusing to declare bankrupty, the Defendant made a deliberate choice to maintain the company's legal existence. As a result, all of TEX's contractual obligations, including the TEX-001 bonds, remain legally valid. The Defendant, as the sole party in control of TEX, are therefore responsible for ensuring it fulfills those obligations. This argument is not being made in the Gribble case.

Additionally, evidence presented in our complaint, including P-003, and P-006 shows that the Defendant is not following its own published policy, another aspect unique to this case.

The Defendant's motion correctly states the need to "ensure consistency... so that no mistake is made." However, a greater mistake would be to allow a ruling in a separate, less comprehensive case to set the precedent for this matter. The central legal questions: the direct liability of the DoC, and the fundamental principle of holding a government department accountable to its own established procedures, are only being properly argued here.

It is with all these reasons in mind that we respectfully ask the court to deny the motion to enjoin, and allow this case to proceed.
 

Court Order


While the plaintiff's arguments are insightful and worthy of consideration, I do believe that the safest course of action is to enjoin this case until such time Gribble19 v The Exchange, Inc. [2025] FCR 102 is resolved.

So ordered,
Judge AmityBlamity

 
AmityBlamity said:

Court Order


While the plaintiff's arguments are insightful and worthy of consideration, I do believe that the safest course of action is to enjoin this case until such time Gribble19 v The Exchange, Inc. [2025] FCR 102 is resolved.

So ordered,
Judge AmityBlamity

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Good afternoon your honour.

We would like to request this case to be permitted to resume due to the dismissal of Gribble19 v The Exchange, Inc. [2025] FCR 102 in the courts.
 
EmmDubz said:
Good afternoon your honour.

We would like to request this case to be permitted to resume due to the dismissal of Gribble19 v The Exchange, Inc. [2025] FCR 102 in the courts.
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Granted.

@Kaiserin_ you have 48 hours to file an Answer to Complaint.
 

Answer to Complaint


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
ANSWER TO COMPLAINT

Vendeka Inc. & Pepecuu
Plaintiff

v.

Commonwealth of Redmont
Defendant

I. ANSWER TO COMPLAINT
1. AFFIRM that the TEX-001 bonds were issued with the maturity date listed, and that Plaintiffs purchased 2,452 units of such.
2. AFFIRM that the DOC commandeered The Exchange, Inc. (hereafter "TEX") on June 27, that it was not declared bankrupt at the time, and that it maintained its legal continuity as a distinct entity. DENY that the DOC inherited TEX's liabilities.
3. AFFIRM that the TEX-001 bonds have not yet been paid out.
4. AFFIRM that the DOC published the Financial Crisis Mitigation Plan on July 13.
5. AFFIRM that the bonds reached their maturity date. DENY that this was a material breach of contract, NOTING that this is an interpretation of law, not a fact.
6. DENY that the DOC has contradicted the Mitigation Plan: said plan prescribes discreet processes for non-depositor creditors, and Plaintiff evidently misunderstands the process laid out by that plan.

II. DEFENCES
1. TEX is a legally distinct non-government entity under directorship of the government (Gribble v. Exchange). Directors are not personally liable for corporations they control (Legal Entity Act § 8) barring DOC intervention (Taxation Act § 8.(3).(d)).
2. The Commonwealth is constitutionally unable to grant the requested relief under Justice Compass v. Commonwealth.
3. TEX was declared bankrupt on November 11 (D-002). Its debts are moot.
4. The True Economic Redemption Act (hereafter "TERA"), and the associated Financial Crisis Mitigation Plan, were drafted specifically to provide a legal framework under which depositors and creditors of institutions which became insolvent during the 2025 financial crisis could receive repayment. Even though the original plan advises creditors to write off the TEX-001 debts, the DOC still plans to pay back part of the TEX-001 bonds as an act of executive discretion. In short, Plaintiffs' grievances as to the first claim for relief are being addressed outside the courts already, and a lawsuit is not the proper avenue for them to pursue redress.
5. As to the second claim for relief, Plaintiffs fundamentally misunderstand the TERA and Mitigation Plan. The Financial Asset Management Corporation (interchangeably FAMC or FAMF) is charged with the management and repayment of investment securities issued by covered institutions, and is associated with the State-Owned Withdrawal Facility (SOWF). The Mitigation Plan reads:

Investors may claim their securities by making a ticket in SOWF. They are asked to simply write their name or the name of their company that the securities are listed on. The FAMF employees (DoC personnel) will go through with the investor of what is happening with each of their securities and compensate them as needed.
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The Commonwealth did not act arbitrarily in directing Plaintiffs to the SOWF - it acted directly in line with established policy.
6. The failure of Plaintiffs to follow the DOC's directions in seeking compensation in line with the Mitigation Plan represents a breach of Plaintiffs' duty to mitigate damages. This lawsuit was filed pre-emptively, as the proper legal avenues for pursuing repayment of the debts in question were not utilised.

EVIDENCE
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WITNESS LIST
ElysiaCrynn, DOC Secretary.

By making this submission, I agree I understand the penalties of lying in court and the fact that I am subject to perjury should I knowingly make a false statement in court.

DATED: This eighth day of December, 2025.


Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION TO STRIKE

Plaintiffs' counsel states in fact 5 that "The Defendant failed to repay the principal owed, constituting a material breach of contract." The allegation that this was a breach of contract is a legal interpretation, and not a fact. As such, it should be struck.

 
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Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
Motion to Dismiss - Rule 2.1, Standing Application

The Defence moves that this case be dismissed, and in support thereof, respectfully alleges:

Rule 2.1, Part 3 grants that in order for Plaintiff to have standing, the following condition must be met:

Remedy is applicable under relevant law that can be granted by a favorable decision.
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Plaintiff requests solely compensatory damages and legal fees from the Commonwealth for the alleged breach of contract. As a matter of law, these cannot be granted.

The Defence brings Your Honour's attention to three points of law:

  • TEX has a balance of $0.01 (D-003) and its associated bank a balance of $0 (D-001). It is a covered institution under the True Economic Redemption Act, and is bankrupt under the Bankruptcy Band-Aid Act (D-002). It certainly is unable to pay the debts that Plaintiff seeks payment of, and it has no assets which could be used by the Commonwealth to pay them.
  • Your Honour held in Gribble that The Exchange, Inc. (hereafter TEX) is a separate legal entity from the Commonwealth and the Department of Commerce, and that the DOC is the director, but not the owner, of TEX ([2025] FCR 102, Nov. 1). TEX is a corporation, and was never nationalised. Legal Entity Act § 8.(10) grants that the only personal liabilities that directors of institutions hold in relation to the corporations they control are the duty of care and the duty of loyalty. Neither of these require payment of corporate debts from personal assets, barring intervention from the DOC itself under Taxation Act § 8.(3).(d).
  • Hon. Judge Muggy21 held in Justice Compass, Ltd. v. Commonwealth [2025] FCR 98 that:
    [...]a judgment, no matter how sound, cannot conjure what reality will not supply. A court cannot order the sky blue or blood from a stone, for judicial authority reaches only those remedies the law and the world can meaningfully deliver. The Department of Homeland Security did not violate this Court’s order in Vanguard and did not violate Plaintiff’s rights for failing to pay the verdict; DHS’s failure to employ every conceivable enforcement measure does not create a civil right of action against the Commonwealth.
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    This precedent is directly relevant. In Justice Compass, the DHS was ordered by a prior court to unfine the Plaintiff a certain amount of money. But because it was unable to do so without reaching into unappropriated DCGovernment funds, the Court found that the DHS was under no obligation to ensure that the Plaintiff received the money. A binding court order surely carries more force than a private debt, and yet even such an order was insufficient to force the Commonwealth's hand in ensuring that non-government entities pay their debts.

It is not just that the Commonwealth is not liable for whatever debts TEX may owe - though this is undoubtedly true - rather, it is constitutionally unable to pay those debts, and there is no statute under which the Commonwealth could be forced to do so. TEX is legally distinct from the government, and thus, if it has any debts at all, they belong solely to itself, not to the DOC. Congress holds the power of the purse. Therefore, absent an appropriation from Congress and associated discretionary action from the Executive, the Commonwealth cannot pay other entities' debts with taxpayer money. Plaintiff's prayers for relief ask the Commonwealth to do just that. We need not even arrive at Plaintiff's second claim for relief; they request no relief associated with it. As all of Plaintiff's prayers cannot constitutionally be granted, even if they were ordered by this Court, this case carries no standing, and must be dismissed.

 
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The Plaintiffs' respectfully submit this response to the Defendant's Motion to Strike, & Motion to Dismiss.​

I. Response to Motion to Dismiss Pursuant of Rule 2.1​

1. Justice Compass Explicitly Exempts this Conduct from Immunity

The Defence relies on Justice Compass v. Commonwealth to argue that the Government is immune from suit due to a lack of appropriation. This is a misapplication of the ruling. Judge Muggy21 held that immunity applies to "good-faith fiscal collection efforts." However, the Court explicitly made exception for cases where the government's own conduct is at issue:
"Where State Power is exercised in a manner that exceeds lawful authority, is tainted by bad faith, or infringes protected rights, the doors of the Court remain fully open."
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This case falls within this boundary. The Plaintiffs are not alleging a failure to collect, they allege misconduct that infringees upon their protected contractual rights.
- The Defendant exceeded lawful authority by violating its own "Financial Crisis Mitigation Plan"​
- The Defendant infringed protected rights by defaulting on a valid loan contract while in full control of the debtor entity​
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As the Plaintiffs allege a direct violation of rights and an excess of authority, the limited authority described in Justice Compass does not apply.

2. Statutory Duties Override Director Protections

The Defendant claims that the DoC is a "Director" and therefore immune. This ignores the statutory condition of that protection. Legal Entity Act 8(10) shields directors only if they fulfill their fiduciary duties.
- Legal Entity Act 8(10)(a) mandates that a Director must:​
"(iv) [act] in a manner that is in the best interests of the Corporation"​
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- The Defendant, as Director, held The Exchange Inc. for months without declaring bankruptcy, during which time it defaulted on the entity's debts (TEX-001) while prioritising other policy interests.​
- This failure to act in the Corporation's best interests constitutes gross negligence. Therefore the Defendant can be held liable for its own mismanagement.​
​

II. Response to Motion to Strike​


Under the Contracts Act 7(1), the law defines a breach clearly:
"(1) A breach of contract occurs when a party fails to fulfil its contractual obligations."
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It is an undisputed fact that the Defendant failed to pay the principal balance upon maturity. Therefore, describing this non-payment as a "breach" is not a subjective legal opinion, it's a statement of fact derived directly from the statutory definition required to describe this event.

III. Notice of Intent to Amend Complaint​


Pursuant to Rule 3.3, the Plaintiffs' hereby notify the Court of our intent to Amend the Complaint. This amendment is necessary due to material developments that have occured during the prolonged enjoinment of this case, specifically the Defendant's declaration of bankruptcy for The Exchange Inc. on the 11th of November 2025.

Proposed Amendments:

- Reflect the timeline of the bankruptcy declaration, establishing that the Defendant held the entity for months after the default occured.
- Explicitly cite the breach of fiduciary duty and gross negligence under the Legal Entity Act 8(10). This claim arises from the Defendant's mismanagement of the entity between the date of seizure and the date of bankruptcy.​
 
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