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Case Filing
IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION
KingBOB99878 (represented by ElysiaCrynn)
Plaintiff
v.
truffleboy123 (doing business as “AQR”)
Defendant
Proof of Representation:
COMPLAINT
The Plaintiff complains against the Defendant as follows:
WRITTEN STATEMENT FROM THE PLAINTIFF
I. PARTIES
1. KingBOB99878 - Plaintiff
2. truffleboy123 - Defendant, the individual who entered into the Agreement and accepted funds from the Plaintiff while doing business under the name of “AQR”.
At all times relevant to this case, the entity referred to as "AQR" was not a registered in-game company or a legally incorporated entity within the Commonwealth of Redmont. Pursuant to the precedent set in Privacy Matters v. Nexalin [2025] FCR 36, an individual who acts on behalf of a non-existent company is personally and fully liable for all actions, obligations, and debts entered into under that company's name. Therefore, the Defendant is the proper and sole party responsible for the claims herein.
II. FACTS
1. On August 16, 2025, the Plaintiff and Defendant entered into a "Convertible Preferred Share Investment Agreement" (the "Agreement"). (P-001, P-003)
2. The Agreement identified the recipient as the company “AQR”, an entity controlled and operated by the defendant, which the defendant presented themselves as acting on behalf of. (P-001, P-003).
3. The Agreement was formed via discussions on Discord, where the terms were presented via a Google Document and explicitly accepted by truffleboy123 on behalf of the company, stating "I agree to the following under the laws of Redmont" (P-003).
4. Pursuant to the Agreement, the Plaintiff invested $150,000 into a bank account of the Defendant under the name “AQR”. The transfer of these funds was successfully completed on August 16, 2025. (P-004)
5. In exchange for this investment, the Agreement stipulates under Section 2 that the Defendant would pay the Plaintiff a yield of 50% of the initial investment amount per month, equal to $75,000 per month. This payment was due on or before the last day of each calendar month. (P-001)
6. The Defendant has failed to make the required yield payment for the month of August 2025, which was due on or before August 31, 2025.
7. The Defendant has subsequently failed to make the required yield payment for the month of September 2025, which was due on or before September 30, 2025.
8. To date, the Plaintiff has received $0 of the $150,000 in yields owed under the Agreement.
9. Section 5.2 of the Agreement outlines a penalty for default, stating: "the Company shall owe the Investor five (5) times the unpaid yield amount as liquidated damages... and the amount the investor put in will be given back." (P-001)
10. Based on the two missed payments, the liquidated damages owed are $750,000 ($150,000 x 5).
11. The Agreement also stipulates that the original investment of $150,000 is to be returned to the Plaintiff upon such a default.
12. Due to the Defendant's failure to provide the expected returns, the Plaintiff was forced to secure external financing for planned business operations, incurring $20,000 in interest costs on loans that would have otherwise been unnecessary. (P-002 for one of the loans).
III. CLAIMS FOR RELIEF
1. Breach of Contract
A valid and enforceable contract was formed between the Plaintiff and the Defendant, meeting all requirements under Section 4(2) of the Contracts Act:
(a) Offer: The Plaintiff, through the Google Document presented on Discord, made a clear and unequivocal offer by proposing the specific terms of the investment agreement to the Defendant.
(b) Acceptance: The Defendant provided a positive and unambiguous acceptance on Discord, stating, "I agree to the following under the laws of Redmont."
(c) Consideration: Valid consideration was exchanged. The Plaintiff provided $150,000, and the Defendant promised monthly yields and convertible shares in return.
(d) Intent: The formal nature of the written Agreement, the specific financial terms, and the actual transfer of funds demonstrate a clear intention from both parties to create legal obligations.
(e) Capacity: Both parties possessed the legal capacity to enter into the contract.
Under Section 7(1) of the Contracts Act, “A breach of contract occurs when a party fails to fulfil its contractual obligations.” A valid contract was formed between the Plaintiff and the Defendant. As established in Privacy Matters v. Nexalin [2025] FCR 36, the Defendant is the true party to this contract, not the non-existent entity "AQR." The Defendant accepted the Agreement and the Plaintiff's investment and was personally obligated to pay a monthly yield of RD$75,000. The Defendant's failure to make any payments for August and September 2025 constitutes a material breach, causing direct financial harm and triggering the Agreement's penalty clauses.
2. Violation of Good Faith and Fair Dealing
Under Section 14 of the Contracts Act, there exists an "implied covenant of good faith and fair dealing in every contract." The Defendant accepted the Plaintiff's $150,000 investment and then immediately failed to perform any of its primary financial obligations under the Agreement. This conduct demonstrates a lack of honesty and fairness, violating the covenant of good faith and fair dealing.
3. Fraud
Pursuant to the Commercial Standards Act Section 12, Fraud is defined as "the knowing or reckless misrepresentation or omission of a material fact to another, causing reliance and resulting in harm". The Defendant represented an intent to make monthly payments of $75,000. While intending to enter a binding agreement to receive the Plaintiff's funds, the Defendant knowingly or recklessly misrepresented his own ability to fulfill the payment obligations therein. The Plaintiff relied on the Defendant's representation that he would make monthly payments of $75,000. The Defendant's immediate and total failure to perform is compelling evidence that this representation was false and made to fraudulently induce the Plaintiff to invest. This outrageous conduct warrants significant punitive damages to deter the Defendant and others from engaging in such predatory financial schemes.
IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:
1. Compensatory Damages totalling $170,000, comprising:
(a) The return of the principal investment: $150,000
(b) Interest costs on loans taken as a direct result of the breach: $20,000.
2. Liquidated Damages: as stipulated in the Agreement's default clause, calculated as five (5) times the unpaid yield ($150,000), totalling $750,000.
3. Punitive Damages: $200,000 for the Defendant’s outrageous conduct in relation to the breach of the contract, failing to even attempt to comply with the Agreement. Accepting a large sum of money under the promise of extraordinary returns and then immediately defaulting without a single payment is predatory behavior that warrants significant punitive damages to deter the Defendant and others from similar predatory conduct in the future, as established in precedents like MegaMinerM v. Blazora Corporation [2025] FCR 27.
4. Legal fees: An award for legal fees amounting to 30% of the total damages awarded.
Evidence:
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 7th day of October 2025