Lawsuit: Adjourned TheStockExchange LLC vs. President antonfr [2026] FCR 91

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Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
EMERGENCY INJUNCTION

Plaintiff respectfully prays for the following:

1. An interim injunction, for the duration of this case, prohibiting the Department of Commerce from collecting any fee under Section 16(12) from the Plaintiff, and from taking any action under Section 18(3) of the Redmont Commerce and Finance Actagainst the Plaintiff on the ground of non-payment of such a fee.
2. An interim order, for the duration of this case, tolling the periods in RCFA Section 59(5) as they apply to the Plaintiff, such that the period for filing a capital plan and the period for meeting the capital requirement in Section 16(5) begin to run again only from the date of final judgment, and prohibiting the Department from acting under Section 59(6) or Part X against the Plaintiff on the ground of non-compliance with those requirements during that time.

GROUNDS FOR THE MOTION

I. Urgency
1. The RCFA was enacted on September 12, 2026. Under Section 59(5), the Plaintiff must file a capital plan with the Department on or about October 12, 2026, and must hold capital of $250,000 by on or about December 11, 2026. Section 59(5) provides that "the Department may not extend" this period. Only this Court can grant relief before those dates pass.
2. Under Section 16(12)(e), the supervisory fee challenged in this action is payable with each of the Plaintiff's monthly reports. Each reporting period that passes without relief results in a further payment of a charge the Plaintiff contends is unconstitutional.


II. On the Merits
3. Plaintiff has a strong case on the merits. The Constitution provides that "Congress controls taxation, government spending, appropriations, and borrowing." Section 16(12) permits the Department of Commerce to set, by its own rule, a mandatory charge of between 1% and 5% of a license class's capital figure, paid into the general DCGovernment account. A compulsory charge that funds general revenue, is calculated from a capital figure rather than the cost of any service, and is enforced by the threat of license revocation is a tax in substance. The RCFA itself requires that substance prevail over form (Section 4(1)(a)).
4. Congress retains no binding control over the rate. The only check the RCFA provides is disallowance by "resolution" under Section 7(7), and the Constitution defines resolutions as non-binding. By contrast, in the Taxation Act enacted the same day, Congress provided that every tax rate "may be changed only by an Act of Congress."


III. Irreparable Harm
5. If the Section 59(5) period expires before judgment, Section 59(6) requires the Plaintiff to surrender its Class F license or change its license class. Either outcome would end the Plaintiff's liability to the Class F fee, could deprive the Plaintiff of standing, and could render this case moot before the constitutional question is decided. The loss of the ability to obtain a ruling at all is harm that cannot be remedied after the fact.
6. Surrendering the license would also require the Plaintiff to cease operating its exchange and return customer funds under Section 59(6), causing lasting damage to its business, its listed companies and their investors that no later judgment could undo.
7. The alternative, meeting the capital requirement, is also irreversible in practice. Section 16(8) prohibits disposal of the capital for 90 days after licensing and makes any transaction returning it to an owner voidable by the Department. If the Plaintiff prevails, those funds could not be promptly freed.

 

Case Filing


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION

TheStockExchange LLC
TSEInvestmentBank LLC
Plaintiffs

v.

President Antonfr_ Fontaine, in his official capacity
Commonwealth of Redmont
Defendants

COMPLAINT
The Plaintiff complains against the Defendant as follows:

WRITTEN STATEMENT FROM THE PLAINTIFF

The Constitution provides that "Congress controls taxation, government spending, appropriations, and borrowing." Section 16(12) of the Redmont Commerce and Finance Act nonetheless allows the Department of Commerce to set, by its own rule, a mandatory annual charge of between 1% and 5% of a licence class's capital figure, paid into the general government account. Whatever it is called, this is a tax, and its rate is set by the Executive rather than by Congress. The only check the Act gives Congress is a "resolution," which the Constitution defines as non-binding. The Stock Exchange is now required to pay this charge. I ask the Court to declare Section 16(12) unconstitutional and sever it from the Act.
Click to expand...

I. PARTIES
1. TSEInvestmentBank LLC (Plaintiff), hereinafter "TSE"
2. President Fontaine (Co-Defendant)
3. Commonwealth of Redmont (Co-Defendant)

II. FACTS
1. The Redmont Commerce and Finance Act ("RCFA") was granted Presidential Assent and enacted on September 12, 2026.
2. TSE was registered as a Stock Exchange before that date and, under RCFA Section 59(1)(d), is deemed to hold a Class F licence. (P-002)
3. RCFA Section 16(5)(c) sets the capital figure for a Class F Stock Exchange at $250,000.
4. RCFA Section 16(12) provides that "The Department may by rule set fees for each license class," including "(a) an application fee, not exceeding 1% of the capital figure for that class" and "(b) a supervisory fee, payable on the same cycle as the institution's reporting period under section 31, of not less than 1% and not more than 5% of that capital figure in aggregate over any 12 month period."
5. RCFA Section 16(12)(g) provides that "fee revenue is directed to the DCGovernment account." The Act does not reserve that revenue for the costs of supervision.
6. RCFA Section 16(12)(h) provides that "an unpaid fee is recoverable as a debt and is a ground for action under section 18(3)," which permits the Department to refuse, condition, suspend or revoke a license.
7. Under RCFA Section 31(1)(a), every holder of a Class F license is a Tier 1 reporting person and reports monthly, regardless of its size. Under Section 16(12)(e), the supervisory fee is payable with each report.
8. As of September 26th, 2026, the Department has failed to provide the fee structure for any license.
9. As of September 26th, 2026, the Department has failed to provide guidance as to how these taxes will be payable.
10. RCFA Section 7(7) provides that "Congress may disallow a rule by resolution of both chambers."
11. In the TaxationAct, enacted by the same Congress and assented to on the same date, Congress provided that balance tax rates "may be changed only by an Act of Congress" (Section 6(2)) and that the chestshop sales tax rate "may be changed only by an Act of Congress" (Section 13(3)).
12. RCFA Section 59(5) provides that an institution licensed under Section 59(1) "has 90 days from the enactment of this Act to meet the capital requirement in section 16(5), and shall file a plan to do so within 30 days. This period is a maximum and the Department may not extend it." With enactment on September 12, 2026, the plan is due on or about October 12, 2026 and full compliance on or about December 11, 2026.
13. RCFA Section 59(6) provides that an institution that does not meet the requirement within that period "shall either surrender its license and return customer funds in an orderly manner, or apply for a license class whose requirement it does meet."
14. RCFA Section 16(8) requires the capital to be held in unencumbered liquid assets and prohibits its disposal for 90 days after licensing. A transaction returning that capital to an owner is voidable at the instance of the Department.

III. CLAIMS FOR RELIEF

Claim 1: Section 16(12) imposes a tax by Executive rule, contrary to Congress's Power of the Purse
4. The Constitution is "the highest law of the Commonwealth" and "overrides any law or authority that conflicts with it." Under Part I, Section 2 (Powers of Congress), clause (4), "Congress controls taxation, government spending, appropriations, and borrowing."
5. Section 23 of the Constitution confines the Executive to administering and enforcing the law "as written by the legislature." It does not permit the Executive to set the rate of a tax.
6. The supervisory fee under Section 16(12)(b) is a tax in substance, for the following reasons:
(a) Its revenue is paid into the general DCGovernment account under Section 16(12)(g), and is not reserved for, or limited to, the cost of supervising the payer.
(b) It is calculated by reference to a statutory capital figure, not the cost of any service provided. The mandatory floor of 1% applies even where the Department's actual cost of supervising an institution is negligible.
(c) It is compulsory, recoverable as a debt, and enforced by the threat of license revocation.
(d) The rate is uniform across each license class under Section 16(12)(c), rather than individually assessed against the supervisory work performed.
7. The RCFA itself directs that "the economic substance and practical effect of a transaction, instrument or arrangement prevails over its legal form, label or characterisation" (Section 4(1)(a)). The Defendant cannot rely on the label "fee" to avoid the constitutional requirements that govern a tax.
8. Section 16(12) permits the Department to choose the rate anywhere within a fivefold range. The decision of how much tax a class of citizens must pay is therefore made by the Executive, not by Congress. That is a transfer of a power the Constitution reserves to Congress.
9. Congress's own practice confirms that it regards setting tax rates as its exclusive function. In the Taxation Act, enacted the same day, Congress provided that each tax rate "may be changed only by an Act of Congress." RCFA Section 16(12) departs from that principle without justification.
10. RCFA Section 16(12) is therefore inconsistent with Part I, Section 2, clause (4) of the Constitution and is void.

Claim 2: Congress retains no binding control over the rate, so the delegation cannot be sustained
11. If the Defendant argues that Congress controls the charge by having set its range, that argument fails because the Act leaves Congress no binding means to control the rate once the Department sets it.
12. The only mechanism the RCFA provides is Section 7(7), which permits Congress to "disallow a rule by resolution of both chambers."
13. Under Part I, Section 2 (Powers of Congress), clause (5), resolutions are "non-binding" instruments passed "to express opinions or make formal requests." A non-binding resolution cannot lawfully void a rule. Section 7(7) purports to give a resolution a binding legal effect that the Constitution denies it.
14. Congress's only binding remedy is therefore to pass a new Act, which is subject to Presidential veto and can be overridden only by a supermajority. In practical terms, the Executive sets the rate of a revenue charge and Congress cannot prevent it by ordinary legislative means. That is not Congressional "control" of taxation within the meaning of clause (4).

Claim 3 (in the alternative): The rate set is not proportionate as the Act requires
15. If the Court finds that Section 16(12) validly delegates the setting of a regulatory fee, the rule setting the Class F fee is nevertheless invalid. Section 16(12)(d) requires that "a fee must be proportionate to the supervisory burden the class imposes," and Section 7(2) requires every rule to be "reasonably tailored" to a legitimate purpose.


Severability
17. RCFA Section 62 provides that "If any provision of this Act is held invalid or unenforceable, the remainder continues in full force and effect." Section 16(12) can be struck without affecting the operation of the rest of the Act.


IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:
1. A declaratory judgment that RCFA Section 16(12) is inconsistent with Part I, Section 2 (Powers of Congress), clause (4) of the Constitution and is void, and that it is severed from the Act under Section 62.
2. A declaratory judgment that any rule made by the Department of Commerce under Section 16(12) is void.
3. In the alternative, a declaratory judgment that the rule setting the Class F supervisory fee is invalid for failing to meet Sections 7(2) and 16(12)(d) of the RCFA.
4. Legal fees and court costs as permitted by law.
5. Any other relief the Court considers just.

EVIDENCE
P-002: <https://www.democracycraft.net/threads/tse-investment-bank.35259/>



WITNESSES
None

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 26th day of September, in the 2026th year of Tuk.

 
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Muggy21 said:

Case Filing


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION

TheStockExchange LLC
TSEInvestmentBank LLC
Plaintiffs

v.

President Fontaine, in his official capacity
Commonwealth of Redmont
Defendants

COMPLAINT
The Plaintiff complains against the Defendant as follows:

WRITTEN STATEMENT FROM THE PLAINTIFF


I. PARTIES
1. TSEInvestmentBank LLC (Plaintiff), hereinafter "TSE"
2. President Fontaine (Co-Defendant)
3. Commonwealth of Redmont (Co-Defendant)

II. FACTS
1. The Redmont Commerce and Finance Act ("RCFA") was granted Presidential Assent and enacted on September 12, 2026.
2. TSE was registered as a Stock Exchange before that date and, under RCFA Section 59(1)(d), is deemed to hold a Class F licence. (P-002)
3. RCFA Section 16(5)(c) sets the capital figure for a Class F Stock Exchange at $250,000.
4. RCFA Section 16(12) provides that "The Department may by rule set fees for each license class," including "(a) an application fee, not exceeding 1% of the capital figure for that class" and "(b) a supervisory fee, payable on the same cycle as the institution's reporting period under section 31, of not less than 1% and not more than 5% of that capital figure in aggregate over any 12 month period."
5. RCFA Section 16(12)(g) provides that "fee revenue is directed to the DCGovernment account." The Act does not reserve that revenue for the costs of supervision.
6. RCFA Section 16(12)(h) provides that "an unpaid fee is recoverable as a debt and is a ground for action under section 18(3)," which permits the Department to refuse, condition, suspend or revoke a license.
7. Under RCFA Section 31(1)(a), every holder of a Class F license is a Tier 1 reporting person and reports monthly, regardless of its size. Under Section 16(12)(e), the supervisory fee is payable with each report.
8. As of September 26th, 2026, the Department has failed to provide the fee structure for any license.
9. As of September 26th, 2026, the Department has failed to provide guidance as to how these taxes will be payable.
10. RCFA Section 7(7) provides that "Congress may disallow a rule by resolution of both chambers."
11. In the TaxationAct, enacted by the same Congress and assented to on the same date, Congress provided that balance tax rates "may be changed only by an Act of Congress" (Section 6(2)) and that the chestshop sales tax rate "may be changed only by an Act of Congress" (Section 13(3)).
12. RCFA Section 59(5) provides that an institution licensed under Section 59(1) "has 90 days from the enactment of this Act to meet the capital requirement in section 16(5), and shall file a plan to do so within 30 days. This period is a maximum and the Department may not extend it." With enactment on September 12, 2026, the plan is due on or about October 12, 2026 and full compliance on or about December 11, 2026.
13. RCFA Section 59(6) provides that an institution that does not meet the requirement within that period "shall either surrender its license and return customer funds in an orderly manner, or apply for a license class whose requirement it does meet."
14. RCFA Section 16(8) requires the capital to be held in unencumbered liquid assets and prohibits its disposal for 90 days after licensing. A transaction returning that capital to an owner is voidable at the instance of the Department.

III. CLAIMS FOR RELIEF

Claim 1: Section 16(12) imposes a tax by Executive rule, contrary to Congress's Power of the Purse
4. The Constitution is "the highest law of the Commonwealth" and "overrides any law or authority that conflicts with it." Under Part I, Section 2 (Powers of Congress), clause (4), "Congress controls taxation, government spending, appropriations, and borrowing."
5. Section 23 of the Constitution confines the Executive to administering and enforcing the law "as written by the legislature." It does not permit the Executive to set the rate of a tax.
6. The supervisory fee under Section 16(12)(b) is a tax in substance, for the following reasons:
(a) Its revenue is paid into the general DCGovernment account under Section 16(12)(g), and is not reserved for, or limited to, the cost of supervising the payer.
(b) It is calculated by reference to a statutory capital figure, not the cost of any service provided. The mandatory floor of 1% applies even where the Department's actual cost of supervising an institution is negligible.
(c) It is compulsory, recoverable as a debt, and enforced by the threat of license revocation.
(d) The rate is uniform across each license class under Section 16(12)(c), rather than individually assessed against the supervisory work performed.
7. The RCFA itself directs that "the economic substance and practical effect of a transaction, instrument or arrangement prevails over its legal form, label or characterisation" (Section 4(1)(a)). The Defendant cannot rely on the label "fee" to avoid the constitutional requirements that govern a tax.
8. Section 16(12) permits the Department to choose the rate anywhere within a fivefold range. The decision of how much tax a class of citizens must pay is therefore made by the Executive, not by Congress. That is a transfer of a power the Constitution reserves to Congress.
9. Congress's own practice confirms that it regards setting tax rates as its exclusive function. In the Taxation Act, enacted the same day, Congress provided that each tax rate "may be changed only by an Act of Congress." RCFA Section 16(12) departs from that principle without justification.
10. RCFA Section 16(12) is therefore inconsistent with Part I, Section 2, clause (4) of the Constitution and is void.

Claim 2: Congress retains no binding control over the rate, so the delegation cannot be sustained
11. If the Defendant argues that Congress controls the charge by having set its range, that argument fails because the Act leaves Congress no binding means to control the rate once the Department sets it.
12. The only mechanism the RCFA provides is Section 7(7), which permits Congress to "disallow a rule by resolution of both chambers."
13. Under Part I, Section 2 (Powers of Congress), clause (5), resolutions are "non-binding" instruments passed "to express opinions or make formal requests." A non-binding resolution cannot lawfully void a rule. Section 7(7) purports to give a resolution a binding legal effect that the Constitution denies it.
14. Congress's only binding remedy is therefore to pass a new Act, which is subject to Presidential veto and can be overridden only by a supermajority. In practical terms, the Executive sets the rate of a revenue charge and Congress cannot prevent it by ordinary legislative means. That is not Congressional "control" of taxation within the meaning of clause (4).

Claim 3 (in the alternative): The rate set is not proportionate as the Act requires
15. If the Court finds that Section 16(12) validly delegates the setting of a regulatory fee, the rule setting the Class F fee is nevertheless invalid. Section 16(12)(d) requires that "a fee must be proportionate to the supervisory burden the class imposes," and Section 7(2) requires every rule to be "reasonably tailored" to a legitimate purpose.


Severability
17. RCFA Section 62 provides that "If any provision of this Act is held invalid or unenforceable, the remainder continues in full force and effect." Section 16(12) can be struck without affecting the operation of the rest of the Act.


IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:
1. A declaratory judgment that RCFA Section 16(12) is inconsistent with Part I, Section 2 (Powers of Congress), clause (4) of the Constitution and is void, and that it is severed from the Act under Section 62.
2. A declaratory judgment that any rule made by the Department of Commerce under Section 16(12) is void.
3. In the alternative, a declaratory judgment that the rule setting the Class F supervisory fee is invalid for failing to meet Sections 7(2) and 16(12)(d) of the RCFA.
4. Legal fees and court costs as permitted by law.
5. Any other relief the Court considers just.

EVIDENCE
P-002: <https://www.democracycraft.net/threads/tse-investment-bank.35259/>



WITNESSES
None

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 26th day of September, in the 2026th year of Tuk.

Click to expand...
The Court inquires as to the inclusion of "President Fontaine, in his official capacity" as a Co-Defendant. For one, the reference is ambigous, there are two Presidents to which it could plausibly refer to ("antonfr" and "xXTheoryXx"). Secondly, the Court is puzzled as to why the party was included; all prayers for relief are to be fulfilled by the Commonwealth.

The Emergency Injunction will not be ruled on before an answer to this inquiry is posted.
 
Talion77 said:
The Court inquires as to the inclusion of "President Fontaine, in his official capacity" as a Co-Defendant. For one, the reference is ambigous, there are two Presidents to which it could plausibly refer to ("antonfr" and "xXTheoryXx"). Secondly, the Court is puzzled as to why the party was included; all prayers for relief are to be fulfilled by the Commonwealth.

The Emergency Injunction will not be ruled on before an answer to this inquiry is posted.
Click to expand...

Your Honour,

The Constitution vests in the President the responsibility for the "execution and enforcement of the law." Having President Fontaine (in this case antonfr, the current President) be a co-defendant is exactly what the Constitution itself requires. Further, the corporate entity statutes of this fair commonwealth distinguish the various branches of government; In naming the President, I'm directing my complaint at the Executive itself.
 
Muggy21 said:
Your Honour,

The Constitution vests in the President the responsibility for the "execution and enforcement of the law." Having President Fontaine (in this case antonfr, the current President) be a co-defendant is exactly what the Constitution itself requires. Further, the corporate entity statutes of this fair commonwealth distinguish the various branches of government; In naming the President, I'm directing my complaint at the Executive itself.
Click to expand...
You are ordered to clarify the referral to President antonfr in the case title and in your complaint. The Court will issue a ruling on the emergency injunction shortly.
 
Muggy21 said:

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
EMERGENCY INJUNCTION

Plaintiff respectfully prays for the following:

1. An interim injunction, for the duration of this case, prohibiting the Department of Commerce from collecting any fee under Section 16(12) from the Plaintiff, and from taking any action under Section 18(3) of the Redmont Commerce and Finance Actagainst the Plaintiff on the ground of non-payment of such a fee.
2. An interim order, for the duration of this case, tolling the periods in RCFA Section 59(5) as they apply to the Plaintiff, such that the period for filing a capital plan and the period for meeting the capital requirement in Section 16(5) begin to run again only from the date of final judgment, and prohibiting the Department from acting under Section 59(6) or Part X against the Plaintiff on the ground of non-compliance with those requirements during that time.

GROUNDS FOR THE MOTION

I. Urgency
1. The RCFA was enacted on September 12, 2026. Under Section 59(5), the Plaintiff must file a capital plan with the Department on or about October 12, 2026, and must hold capital of $250,000 by on or about December 11, 2026. Section 59(5) provides that "the Department may not extend" this period. Only this Court can grant relief before those dates pass.
2. Under Section 16(12)(e), the supervisory fee challenged in this action is payable with each of the Plaintiff's monthly reports. Each reporting period that passes without relief results in a further payment of a charge the Plaintiff contends is unconstitutional.


II. On the Merits
3. Plaintiff has a strong case on the merits. The Constitution provides that "Congress controls taxation, government spending, appropriations, and borrowing." Section 16(12) permits the Department of Commerce to set, by its own rule, a mandatory charge of between 1% and 5% of a license class's capital figure, paid into the general DCGovernment account. A compulsory charge that funds general revenue, is calculated from a capital figure rather than the cost of any service, and is enforced by the threat of license revocation is a tax in substance. The RCFA itself requires that substance prevail over form (Section 4(1)(a)).
4. Congress retains no binding control over the rate. The only check the RCFA provides is disallowance by "resolution" under Section 7(7), and the Constitution defines resolutions as non-binding. By contrast, in the Taxation Act enacted the same day, Congress provided that every tax rate "may be changed only by an Act of Congress."


III. Irreparable Harm
5. If the Section 59(5) period expires before judgment, Section 59(6) requires the Plaintiff to surrender its Class F license or change its license class. Either outcome would end the Plaintiff's liability to the Class F fee, could deprive the Plaintiff of standing, and could render this case moot before the constitutional question is decided. The loss of the ability to obtain a ruling at all is harm that cannot be remedied after the fact.
6. Surrendering the license would also require the Plaintiff to cease operating its exchange and return customer funds under Section 59(6), causing lasting damage to its business, its listed companies and their investors that no later judgment could undo.
7. The alternative, meeting the capital requirement, is also irreversible in practice. Section 16(8) prohibits disposal of the capital for 90 days after licensing and makes any transaction returning it to an owner voidable by the Department. If the Plaintiff prevails, those funds could not be promptly freed.

Click to expand...

Court Order


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
Court Order - Emergency Injunction

The Court will be granting the emergency injunction in full.

1. For the duration of this case, the Department of Commerce shall be barred from collecting any fee under § 16(12) of the Redmont Commerce and Finance Act from the Plaintiff, and from taking any action under id. § 18(3) against the Plaintiff on the grounds of non-payment of such a fee.
2. For the duration of this case, the periods in id. § 59(5), as they apply to the Plaintiff, are tolled, such that the period for filing a capital plan and the period for meeting the capital requirement in id. § 16(5) begin to run again only from the date of final judgment, and the Department is prohibited from acting under id. § 59(6) or id. at Part X against the Plaintiff on the grounds of non-compliance with the requirements set forth in id. §§ 16(5) and 59(5) during that time.

So ordered.

Signed,
Judge Talion Montclair-Contour

 
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Writ of Summons

The Attorney General (@Nacho) is hereby commanded to appear before the Federal Court in the case of TheStockExchange LLC vs. President antonfr [2026] FCR 91.

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.

 
Talion77 said:
The Defence shall submit an answer to the complaint within 72 hours.
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Your Honour, the Government has failed to Answer. Will the Court permit me to file a motion for judgment as matter of law as permitted under Rule 9.2? The Government didn't file an opposition to my claims.
 
Muggy21 said:
Your Honour, the Government has failed to Answer. Will the Court permit me to file a motion for judgment as matter of law as permitted under Rule 9.2? The Government didn't file an opposition to my claims.
Click to expand...
You may file a motion for judgement as a matter of law. Should you choose to do so, please show cause why we should not proceed into an inquest proceeding in your motion.
 
The defence formally apollogieses for the delays, the Dpeartment of Justice is severly backed up with piles of cases, and we lack a clerk to alert us of upcoming deadlines, I will ensure that this does not happen again.

Answer to Complaint


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
ANSWER TO COMPLAINT
TheStockExchange LLC
TSEInvestmentBank LLC
Plaintiffs

v.

President Antonfr_ Fontaine, in his official capacity
Commonwealth of Redmont
Defendants

I. ANSWER TO COMPLAINT
1. NEITHER AFFIRMS OR DENIES: The Redmont Commerce and Finance Act ("RCFA") was granted Presidential Assent and enacted on September 12, 2026.
2. NEITHER AFFIRMS OR DENIES: TSE was registered as a Stock Exchange before that date and, under RCFA Section 59(1)(d), is deemed to hold a Class F licence. (P-002)
3. NEITHER AFFIRMS OR DENIES: RCFA Section 16(5)(c) sets the capital figure for a Class F Stock Exchange at $250,000.
4. NEITHER AFFIRMS OR DENIES: RCFA Section 16(12) provides that "The Department may by rule set fees for each license class," including "(a) an application fee, not exceeding 1% of the capital figure for that class" and "(b) a supervisory fee, payable on the same cycle as the institution's reporting period under section 31, of not less than 1% and not more than 5% of that capital figure in aggregate over any 12 month period."
5. NEITHER AFFIRMS OR DENIES: RCFA Section 16(12)(g) provides that "fee revenue is directed to the DCGovernment account." The Act does not reserve that revenue for the costs of supervision.
6. NEITHER AFFIRMS OR DENIES: RCFA Section 16(12)(h) provides that "an unpaid fee is recoverable as a debt and is a ground for action under section 18(3)," which permits the Department to refuse, condition, suspend or revoke a license.
7. NEITHER AFFIRMS OR DENIES: Under RCFA Section 31(1)(a), every holder of a Class F license is a Tier 1 reporting person and reports monthly, regardless of its size. Under Section 16(12)(e), the supervisory fee is payable with each report.
8. NEITHER AFFIRMS OR DENIES: As of September 26th, 2026, the Department has failed to provide the fee structure for any license.
9. NEITHER AFFIRMS OR DENIES: As of September 26th, 2026, the Department has failed to provide guidance as to how these taxes will be payable.
10. NEITHER AFFIRMS OR DENIES: RCFA Section 7(7) provides that "Congress may disallow a rule by resolution of both chambers."
11. NEITHER AFFIRMS OR DENIES: In the Taxation Act, enacted by the same Congress and assented to on the same date, Congress provided that balance tax rates "may be changed only by an Act of Congress" (Section 6(2)) and that the chestshop sales tax rate "may be changed only by an Act of Congress" (Section 13(3)).
12. NEITHER AFFIRMS OR DENIES: RCFA Section 59(5) provides that an institution licensed under Section 59(1) "has 90 days from the enactment of this Act to meet the capital requirement in section 16(5), and shall file a plan to do so within 30 days. This period is a maximum and the Department may not extend it." With enactment on September 12, 2026, the plan is due on or about October 12, 2026 and full compliance on or about December 11, 2026.
13. NEITHER AFFIRMS OR DENIES: RCFA Section 59(6) provides that an institution that does not meet the requirement within that period "shall either surrender its license and return customer funds in an orderly manner, or apply for a license class whose requirement it does meet."
14. NEITHER AFFIRMS OR DENIES: RCFA Section 16(8) requires the capital to be held in unencumbered liquid assets and prohibits its disposal for 90 days after licensing. A transaction returning that capital to an owner is voidable at the instance of the Department.

DEFENSES:
None.



Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR JUDGEMENT AS A MATTER OF LAW

Your Honor, the Commonwealth of Redmont moves for judgement as matter of law, since it doesn't contest any of the facts presented.

 

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR JUDGMENT AS A MATTER OF LAW (Rule 9.2)


GROUNDS FOR THE MOTION

I. Government's Answer Puts No Matter in Issue

  1. The Court ordered Defense to answer within 72 hours. The Answer was filed after that period expired and after Plaintiffs had noted the default. Defense sought no leave and showed no cause beyond general workload.
  2. The Answer responds to each of the fourteen factual allegations with "neither affirms or denies." Most of those allegations only recite the text of the Redmont Commerce and Finance Act and the Taxation Act and the dates of their enactment. These are matters of public law within the Commonwealth's own knowledge. Defense does not claim it lacks the knowledge to respond. It simply declines to respond.
  3. An answer that takes no position on any allegation does not contest it. The statutory provisions recited are, in any event, matters of law that require no proof.
  4. The Answer raises no defenses, and Defense's accompanying motion states that the Commonwealth "doesn't contest any of the facts presented."

II. Cause Why No Inquest Is Required
5. An inquest determines the relief owed once liability is established. No such determination is needed here.
6. The principal relief sought is declaratory and requires no quantification.
7. Nominal damages under Part III, Section 4 of the Redmont Civil Code Act require no proof of loss and are capped at $7,500. Section 4(3) provides that no defenses or diminution apply. Nothing remains to be assessed.
8. Legal fees are fixed by formula under Part III, Section 7. Thirty percent of the case value falls below the Federal Court minimum, so the minimum of $6,000 under Section 7(2)(c) applies.
9. The facts are undisputed and the questions presented are purely legal. An inquest would add nothing to the record and would only delay final judgment while the Court's interim injunction remains in force.


III. On the Merits
10. On the undisputed record, Section 16(12) of the RCFA authorizes the Department of Commerce to set, by its own rule, a compulsory charge of between 1% and 5% of a license class's capital figure. The charge is paid into the general DCGovernment account, is unconnected to the cost of any service, and is enforced by the threat of license revocation under Section 18(3).
11. Section 4(1)(a) of the RCFA provides that substance prevails over form. The charge is a tax in substance, and its rate is set by the Executive. This is contrary to Part I, Section 2, clause (4) of the Constitution, which provides that "Congress controls taxation, government spending, appropriations, and borrowing."
12. The only check Congress retains over the rate is disallowance by resolution under Section 7(7). Part I, Section 2, clause (5) of the Constitution defines resolutions as non-binding. Congress therefore has no binding means to control the rate short of a new Act subject to Presidential veto. That is not Congressional control of taxation.
13. Defense has offered no argument on either point. Claims 1 and 2 stand unopposed.
14. Claim 3 is pleaded in the alternative. Because Claims 1 and 2 dispose of Section 16(12) on its face, the Court need not reach Claim 3.
15. Under Section 62 of the RCFA, Section 16(12) is severable, and the remainder of the Act continues in force.


IV. Nominal Damages
16. Section 16(12) subjects the Plaintiffs, under colour of law, to a charge that the Constitution permits only Congress to impose. Part III, Section 1(3)(a) of the Redmont Civil Code Act provides that damages need not be expressly stated as a remedy to be sought as relief. Part III, Section 4 provides for nominal damages in recognition that a legal cause of action has been established, even where no substantial loss is shown. The Plaintiffs seek nominal damages of $7,500 under the Complaint's prayer for any other relief the Court considers just.


V. The Defendant's Motion for Judgment as a Matter of Law
17. The Commonwealth moves for judgment as a matter of law but identifies no legal ground on which it would be entitled to judgment. Its only stated basis is that it does not contest the facts. That concession supports judgment for the Plaintiffs, not for the Commonwealth.
18. To the extent Defendant's motion asks the Court to decide this matter on the undisputed record, Plaintiffs agree and ask that judgment be entered in their favor. To the extent it seeks judgment for the Defendant, it should be denied.

Plaintiffs respectfully pray for the following:

  1. An order deeming Facts 1 through 14 of the Complaint admitted or, in the alternative, taking judicial notice of the statutory provisions recited in Facts 1, 3 through 7, and 10 through 14.
  2. An order denying the Defendant's Motion for Judgment as a Matter of Law.
  3. Judgment as a matter of law in favor of Plaintiffs, without an inquest proceeding.
  4. A declaratory judgment that Section 16(12) of the Redmont Commerce and Finance Act is inconsistent with Part I, Section 2, clause (4) of the Constitution, is void, and is severed from the Act under Section 62.
  5. A declaratory judgment that the Department of Commerce has no authority to make any rule under Section 16(12), and that any rule purportedly made under it is void.
  6. Nominal damages of $7,500 under Part III, Section 4 of the Redmont Civil Code Act.
  7. Legal fees of $6,000 under Part III, Section 7(2)(c) of the Redmont Civil Code Act.
  8. Any other relief the Court considers just.

 
DETECTIVHOLMES said:

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR JUDGEMENT AS A MATTER OF LAW

Your Honor, the Commonwealth of Redmont moves for judgement as matter of law, since it doesn't contest any of the facts presented.

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Denied. Defendant's motion violates Rule 9.2 as it does not specify the judgment sought and the law and facts that entitle the movant to the judgment. The Court believes that the Defendant may have confused the motion with a motion for summary judgement.
 
Muggy21 said:

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR JUDGMENT AS A MATTER OF LAW (Rule 9.2)


GROUNDS FOR THE MOTION

I. Government's Answer Puts No Matter in Issue

  1. The Court ordered Defense to answer within 72 hours. The Answer was filed after that period expired and after Plaintiffs had noted the default. Defense sought no leave and showed no cause beyond general workload.
  2. The Answer responds to each of the fourteen factual allegations with "neither affirms or denies." Most of those allegations only recite the text of the Redmont Commerce and Finance Act and the Taxation Act and the dates of their enactment. These are matters of public law within the Commonwealth's own knowledge. Defense does not claim it lacks the knowledge to respond. It simply declines to respond.
  3. An answer that takes no position on any allegation does not contest it. The statutory provisions recited are, in any event, matters of law that require no proof.
  4. The Answer raises no defenses, and Defense's accompanying motion states that the Commonwealth "doesn't contest any of the facts presented."

II. Cause Why No Inquest Is Required
5. An inquest determines the relief owed once liability is established. No such determination is needed here.
6. The principal relief sought is declaratory and requires no quantification.
7. Nominal damages under Part III, Section 4 of the Redmont Civil Code Act require no proof of loss and are capped at $7,500. Section 4(3) provides that no defenses or diminution apply. Nothing remains to be assessed.
8. Legal fees are fixed by formula under Part III, Section 7. Thirty percent of the case value falls below the Federal Court minimum, so the minimum of $6,000 under Section 7(2)(c) applies.
9. The facts are undisputed and the questions presented are purely legal. An inquest would add nothing to the record and would only delay final judgment while the Court's interim injunction remains in force.


III. On the Merits
10. On the undisputed record, Section 16(12) of the RCFA authorizes the Department of Commerce to set, by its own rule, a compulsory charge of between 1% and 5% of a license class's capital figure. The charge is paid into the general DCGovernment account, is unconnected to the cost of any service, and is enforced by the threat of license revocation under Section 18(3).
11. Section 4(1)(a) of the RCFA provides that substance prevails over form. The charge is a tax in substance, and its rate is set by the Executive. This is contrary to Part I, Section 2, clause (4) of the Constitution, which provides that "Congress controls taxation, government spending, appropriations, and borrowing."
12. The only check Congress retains over the rate is disallowance by resolution under Section 7(7). Part I, Section 2, clause (5) of the Constitution defines resolutions as non-binding. Congress therefore has no binding means to control the rate short of a new Act subject to Presidential veto. That is not Congressional control of taxation.
13. Defense has offered no argument on either point. Claims 1 and 2 stand unopposed.
14. Claim 3 is pleaded in the alternative. Because Claims 1 and 2 dispose of Section 16(12) on its face, the Court need not reach Claim 3.
15. Under Section 62 of the RCFA, Section 16(12) is severable, and the remainder of the Act continues in force.


IV. Nominal Damages
16. Section 16(12) subjects the Plaintiffs, under colour of law, to a charge that the Constitution permits only Congress to impose. Part III, Section 1(3)(a) of the Redmont Civil Code Act provides that damages need not be expressly stated as a remedy to be sought as relief. Part III, Section 4 provides for nominal damages in recognition that a legal cause of action has been established, even where no substantial loss is shown. The Plaintiffs seek nominal damages of $7,500 under the Complaint's prayer for any other relief the Court considers just.


V. The Defendant's Motion for Judgment as a Matter of Law
17. The Commonwealth moves for judgment as a matter of law but identifies no legal ground on which it would be entitled to judgment. Its only stated basis is that it does not contest the facts. That concession supports judgment for the Plaintiffs, not for the Commonwealth.
18. To the extent Defendant's motion asks the Court to decide this matter on the undisputed record, Plaintiffs agree and ask that judgment be entered in their favor. To the extent it seeks judgment for the Defendant, it should be denied.

Plaintiffs respectfully pray for the following:

  1. An order deeming Facts 1 through 14 of the Complaint admitted or, in the alternative, taking judicial notice of the statutory provisions recited in Facts 1, 3 through 7, and 10 through 14.
  2. An order denying the Defendant's Motion for Judgment as a Matter of Law.
  3. Judgment as a matter of law in favor of Plaintiffs, without an inquest proceeding.
  4. A declaratory judgment that Section 16(12) of the Redmont Commerce and Finance Act is inconsistent with Part I, Section 2, clause (4) of the Constitution, is void, and is severed from the Act under Section 62.
  5. A declaratory judgment that the Department of Commerce has no authority to make any rule under Section 16(12), and that any rule purportedly made under it is void.
  6. Nominal damages of $7,500 under Part III, Section 4 of the Redmont Civil Code Act.
  7. Legal fees of $6,000 under Part III, Section 7(2)(c) of the Redmont Civil Code Act.
  8. Any other relief the Court considers just.

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The court is considering judgement as a matter of law. Until then, the further progression of the case is stayed.
 
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Muggy21 said:

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR JUDGMENT AS A MATTER OF LAW (Rule 9.2)


GROUNDS FOR THE MOTION

I. Government's Answer Puts No Matter in Issue

  1. The Court ordered Defense to answer within 72 hours. The Answer was filed after that period expired and after Plaintiffs had noted the default. Defense sought no leave and showed no cause beyond general workload.
  2. The Answer responds to each of the fourteen factual allegations with "neither affirms or denies." Most of those allegations only recite the text of the Redmont Commerce and Finance Act and the Taxation Act and the dates of their enactment. These are matters of public law within the Commonwealth's own knowledge. Defense does not claim it lacks the knowledge to respond. It simply declines to respond.
  3. An answer that takes no position on any allegation does not contest it. The statutory provisions recited are, in any event, matters of law that require no proof.
  4. The Answer raises no defenses, and Defense's accompanying motion states that the Commonwealth "doesn't contest any of the facts presented."

II. Cause Why No Inquest Is Required
5. An inquest determines the relief owed once liability is established. No such determination is needed here.
6. The principal relief sought is declaratory and requires no quantification.
7. Nominal damages under Part III, Section 4 of the Redmont Civil Code Act require no proof of loss and are capped at $7,500. Section 4(3) provides that no defenses or diminution apply. Nothing remains to be assessed.
8. Legal fees are fixed by formula under Part III, Section 7. Thirty percent of the case value falls below the Federal Court minimum, so the minimum of $6,000 under Section 7(2)(c) applies.
9. The facts are undisputed and the questions presented are purely legal. An inquest would add nothing to the record and would only delay final judgment while the Court's interim injunction remains in force.


III. On the Merits
10. On the undisputed record, Section 16(12) of the RCFA authorizes the Department of Commerce to set, by its own rule, a compulsory charge of between 1% and 5% of a license class's capital figure. The charge is paid into the general DCGovernment account, is unconnected to the cost of any service, and is enforced by the threat of license revocation under Section 18(3).
11. Section 4(1)(a) of the RCFA provides that substance prevails over form. The charge is a tax in substance, and its rate is set by the Executive. This is contrary to Part I, Section 2, clause (4) of the Constitution, which provides that "Congress controls taxation, government spending, appropriations, and borrowing."
12. The only check Congress retains over the rate is disallowance by resolution under Section 7(7). Part I, Section 2, clause (5) of the Constitution defines resolutions as non-binding. Congress therefore has no binding means to control the rate short of a new Act subject to Presidential veto. That is not Congressional control of taxation.
13. Defense has offered no argument on either point. Claims 1 and 2 stand unopposed.
14. Claim 3 is pleaded in the alternative. Because Claims 1 and 2 dispose of Section 16(12) on its face, the Court need not reach Claim 3.
15. Under Section 62 of the RCFA, Section 16(12) is severable, and the remainder of the Act continues in force.


IV. Nominal Damages
16. Section 16(12) subjects the Plaintiffs, under colour of law, to a charge that the Constitution permits only Congress to impose. Part III, Section 1(3)(a) of the Redmont Civil Code Act provides that damages need not be expressly stated as a remedy to be sought as relief. Part III, Section 4 provides for nominal damages in recognition that a legal cause of action has been established, even where no substantial loss is shown. The Plaintiffs seek nominal damages of $7,500 under the Complaint's prayer for any other relief the Court considers just.


V. The Defendant's Motion for Judgment as a Matter of Law
17. The Commonwealth moves for judgment as a matter of law but identifies no legal ground on which it would be entitled to judgment. Its only stated basis is that it does not contest the facts. That concession supports judgment for the Plaintiffs, not for the Commonwealth.
18. To the extent Defendant's motion asks the Court to decide this matter on the undisputed record, Plaintiffs agree and ask that judgment be entered in their favor. To the extent it seeks judgment for the Defendant, it should be denied.

Plaintiffs respectfully pray for the following:

  1. An order deeming Facts 1 through 14 of the Complaint admitted or, in the alternative, taking judicial notice of the statutory provisions recited in Facts 1, 3 through 7, and 10 through 14.
  2. An order denying the Defendant's Motion for Judgment as a Matter of Law.
  3. Judgment as a matter of law in favor of Plaintiffs, without an inquest proceeding.
  4. A declaratory judgment that Section 16(12) of the Redmont Commerce and Finance Act is inconsistent with Part I, Section 2, clause (4) of the Constitution, is void, and is severed from the Act under Section 62.
  5. A declaratory judgment that the Department of Commerce has no authority to make any rule under Section 16(12), and that any rule purportedly made under it is void.
  6. Nominal damages of $7,500 under Part III, Section 4 of the Redmont Civil Code Act.
  7. Legal fees of $6,000 under Part III, Section 7(2)(c) of the Redmont Civil Code Act.
  8. Any other relief the Court considers just.

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Court Order


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
Court Order

The Court finds that facts 1 through 14 of the complaint are established for the purposes of this case.

However, the Court denies Judgement as a Matter of Law. The Court does not accept to hold Plaintiff's legal conclusions as true simply because the facts are fully established. The legal effect of the established facts is a matter for the Court to determine.

Further, as no genuine factual dispute remains, the Court is inclined to proceed to summary judgement proceedings. Both parties shall submit to the Court whether they are content with such proceedings.

So ordered.

Judge Talion Montclair-Contour

 
Talion77 said:

Court Order


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
Court Order

The Court finds that facts 1 through 14 of the complaint are established for the purposes of this case.

However, the Court denies Judgement as a Matter of Law. The Court does not accept to hold Plaintiff's legal conclusions as true simply because the facts are fully established. The legal effect of the established facts is a matter for the Court to determine.

Further, as no genuine factual dispute remains, the Court is inclined to proceed to summary judgement proceedings. Both parties shall submit to the Court whether they are content with such proceedings.

So ordered.

Judge Talion Montclair-Contour

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Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
Motion to Reconsider

Your Honour, with all due respect, that's what a Rule 9.2 motion is. My previous motion only asks this Court to consider the facts as settled, but leaves the actual adjudication of law to the Court.

Plaintiffs did not rely on the Defendant's silence as a substitute for legal analysis. Part III of the Motion set out the legal argument on its own terms. It explained why the Section 16(12) charge is a tax in substance under RCFA Section 4(1)(a). It showed why setting its rate by Executive rule conflicts with Part I, Section 2, clause (4) of the Constitution. It showed why the resolution mechanism in Section 7(7) gives Congress no binding control, given clause (5). And it showed why Section 16(12) is severable under Section 62. The observation that Defense offered no argument in response was made in addition to that analysis, not in place of it.

 
Muggy21 said:

Motion


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
Motion to Reconsider

Your Honour, with all due respect, that's what a Rule 9.2 motion is. My previous motion only asks this Court to consider the facts as settled, but leaves the actual adjudication of law to the Court.

Plaintiffs did not rely on the Defendant's silence as a substitute for legal analysis. Part III of the Motion set out the legal argument on its own terms. It explained why the Section 16(12) charge is a tax in substance under RCFA Section 4(1)(a). It showed why setting its rate by Executive rule conflicts with Part I, Section 2, clause (4) of the Constitution. It showed why the resolution mechanism in Section 7(7) gives Congress no binding control, given clause (5). And it showed why Section 16(12) is severable under Section 62. The observation that Defense offered no argument in response was made in addition to that analysis, not in place of it.

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The Court is puzzled by Plaintiff's interpretation of a Rule 9.2 motion.

The Court Rules and Procedures state:

A motion for judgment as a matter of law may be made at any time before closing statements are posted, as that is the last time new arguments or evidence may be submitted. The motion must specify the judgment sought and the law and facts that entitle the movant to the judgment.

If the Court determines that it has fully heard an issue during a trial, and the court finds no legally sufficient evidentiary basis to find for the party on that issue, the court may resolve the issue against the party and grant a motion for judgment as a matter of law against the party on a claim or defense.
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A granted motion for judgement as a matter of law therefore must lead to judgement entered or the moving party (on a claim). Contrary to what was stated in the motion to reconsider, this is also what the initial motion by the Plaintiff prays for.

For a motion for judgement as a matter of law to be granted, three prerequisites have to be met:

1. the motion is filed in a procedurally proper manner;
2. the Court determines that it has fully heard an issue;
3. the Court finds no legally sufficient evidentiary basis to find for the non-moving party.

The Court is satisfied that the first two elements have been met. The motion was filed before closing statements, and specified the judgement sought that the facts that alledgedly entitle the movant to the judgement. The Court has also fully heard the issue factually, inline with its earlier order.
However, the Court does not believe that there is no legally sufficient evidentiary basis to find for the non-moving party regardless of the interpretation of the law in this case.

The Court will withhold its ruling on the motion to reconsider until Plaintiff has elaborated on their interpretation of this matter, which they shall do within 72 hours.
 

Verdict


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
Verdict

I. FACTS​

The Court already determined that this case contains no factual dispute. The Court will, for its verdict, use facts 1 through 14 of plaintiff's complaint as the factual basis, namely:

1. The Redmont Commerce and Finance Act ("RCFA") was granted Presidential Assent and enacted on September 12, 2026.
2. TSE was registered as a Stock Exchange before that date and, under RCFA Section 59(1)(d), is deemed to hold a Class F licence. (P-002)
3. RCFA Section 16(5)(c) sets the capital figure for a Class F Stock Exchange at $250,000.
4. RCFA Section 16(12) provides that "The Department may by rule set fees for each license class," including "(a) an application fee, not exceeding 1% of the capital figure for that class" and "(b) a supervisory fee, payable on the same cycle as the institution's reporting period under section 31, of not less than 1% and not more than 5% of that capital figure in aggregate over any 12 month period."
5. RCFA Section 16(12)(g) provides that "fee revenue is directed to the DCGovernment account." The Act does not reserve that revenue for the costs of supervision.
6. RCFA Section 16(12)(h) provides that "an unpaid fee is recoverable as a debt and is a ground for action under section 18(3)," which permits the Department to refuse, condition, suspend or revoke a license.
7. Under RCFA Section 31(1)(a), every holder of a Class F license is a Tier 1 reporting person and reports monthly, regardless of its size. Under Section 16(12)(e), the supervisory fee is payable with each report.
8. As of September 26th, 2026, the Department has failed to provide the fee structure for any license.
9. As of September 26th, 2026, the Department has failed to provide guidance as to how these taxes will be payable.
10. RCFA Section 7(7) provides that "Congress may disallow a rule by resolution of both chambers."
11. In the TaxationAct, enacted by the same Congress and assented to on the same date, Congress provided that balance tax rates "may be changed only by an Act of Congress" (Section 6(2)) and that the chestshop sales tax rate "may be changed only by an Act of Congress" (Section 13(3)).
12. RCFA Section 59(5) provides that an institution licensed under Section 59(1) "has 90 days from the enactment of this Act to meet the capital requirement in section 16(5), and shall file a plan to do so within 30 days. This period is a maximum and the Department may not extend it." With enactment on September 12, 2026, the plan is due on or about October 12, 2026 and full compliance on or about December 11, 2026.
13. RCFA Section 59(6) provides that an institution that does not meet the requirement within that period "shall either surrender its license and return customer funds in an orderly manner, or apply for a license class whose requirement it does meet."
14. RCFA Section 16(8) requires the capital to be held in unencumbered liquid assets and prohibits its disposal for 90 days after licensing. A transaction returning that capital to an owner is voidable at the instance of the Department.
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II. APPLICATION OF THE LAW​

II.I CLAIM 1 — EXECUTIVE TAXATION​

Plaintiff’s first claim, in substance, alleges that the charges authorised under Redmont Commerce and Finance Act Part V, § 16(12) (“the charges”) constitute a tax, and that the rate may therefore not be set by the executive.

This claim rests on two assumptions:

(1) the charges constitute a tax; and
(2) setting of tax rates cannot be delegated to the Executive by statute.

Should both assumptions hold weight, the claim must hold weight as well. Should one fail, the claim fails.

II.I.I TAXES AND FEES​

As there is no comprehensive definition of what a tax or a fee actually is, the Court interprets, inline with zLost v. The Commonwealth of Redmont [2023] FCR 75 and other applicable laws, the terms as follows:

Tax
A charge that serves the purpose of general revenue collection, is not related to any service the government provides, and is not calculated based on the cost of such services.

Fee
A charge that is levied in return for a specific service provided and that is calculated based on the cost of such service.

II.I.I.I PLAINTIFF’S POSITION — THE CHARGE IS A TAX

Plaintiff argues that the charges constitute taxes because:

(a) Its revenue is paid into the general DCGovernment account under Section 16(12)(g), and is not reserved for, or limited to, the cost of supervising the payer.
(b) It is calculated by reference to a statutory capital figure, not the cost of any service provided. The mandatory floor of 1% applies even where the Department's actual cost of supervising an institution is negligible.
(c) It is compulsory, recoverable as a debt, and enforced by the threat of license revocation.
(d) The rate is uniform across each license class under Section 16(12)(c), rather than individually assessed against the supervisory work performed.
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The Court rejects the first argument. The fact that revenue is paid into the Treasury does not, in substance, constitute a tax.

The Court also rejects the second argument. While charges being calculated not based on the cost of any service provided is a strong indicator of such a charge not being a fee, the Court believes that the intent of Congress was to utilise the statutory capital figures as a proxy for regulatory burden, as different kinds institutions predictably require a different burden of supervision. Flexibility was granted to the Department of Commerce by delegating it the authority to determine the concrete fee based on license class.

The Court rejects the third argument as well. A charge being compulsory for utilising a government service does not mean it is a tax. See zLost v. The Commonwealth of Redmont [2023] FCR 75.

At last, the Court rejects the fourth argument. An individually assessed rate on a case-by-case basis is not grounds to classify such a charge as a tax. As Congress clearly intended to establish different license classes to serve as a proxy for regulatory burden, the Court determines that the charge is calculated in a manner specific enough not to satisfy the generality of a tax.

II.I.I.II IS THE CHARGE A FEE

The Court has interpreted the term fee as:

A charge that is levied in return for a specific service provided and that is calculated based on the cost of such service.
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After having rejected Plaintiff’s arguments for whether the charge is a tax, the determination to make is whether the charges constitute a fee. The charge is levied in exchange to a specific purpose, namely being the supervisory burden of the Department of Commerce in relation to the different kinds of financial institutions. The charges are also, by id. § 16(12)(d) required to be proportionate to the supervisory burden the class imposes. Coupled with the earlier determination that the license classes were established to serve as a proxy for regulatory burden, the Court holds that the charges constitute fees.

II.I.II DELEGATION OF TAXATION POWER​

As the charges are fees, the question whether taxation power was unconstitutionally delegated, becomes moot.

II.I.III CONCLUSION ON CLAIM 1​

As the Court has held that the charges authorised under Redmont Commerce and Finance Act Part V, § 16(12) constitute fees and not taxes, the claim fails.

II.II CLAIM 2 — CONGRESS RETAINS NO BINDING CONTROL OVER THE RATE​

For Plaintiff’s second claim, the determination that the charges are taxes is essential, as only taxes and not fees fall under the power granted to Congress by C. R. Const. Part I, § 2(4) . As the Court has determined that the charges are fees, the claim fails.

II.III CLAIM 3 — THE RATE IS NOT SET PROPORTIONALLY AS THE ACT REQUIRES​

The Court is dumbfounded in regards to this claim. The factual record establishes that no rule has been set. See complaint fact 8. As such, there is no rule to invalidate. The claim is rejected.

The Court of course holds, inline with the plain meaning of the Redmont Commerce and Finance Act, that any fee under § 12(16) must be proportionate to the supervisory burden the respective class imposes and that every rule under the Act must be reasonably tailored to a specific purpose.

III. VERDICT​

The Court rules in favour of the Defendant, and plaintiff’s requested relief is denied. The injunction is lifted.

All parties are thanked for their time and effort.

So ordered.

Signed,
Judge Talion Montclair-Contour

 
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