EmmDubz
Citizen
- Joined
- Jun 11, 2025
- Messages
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- #1
Case Filing
IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION
National Exchange of Redmont
Plaintiff
v.
Mustafa Masody
Defendant
COMPLAINT
The Plaintiff complains against the Defendant as follows:
I. PARTIES
1. National Exchange of Redmont (Plaintiff)
2. Mustafa Masody (Defendant)
II. FACTS
1. The Defendant, by virtue of using the National Exchange of Redmont (NER) platform, implicitly and explicitly agreed to be bound by the NER Terms of Service.
2. Prior to a recent software update, the NER platform contained a technical error wherein the system did not deduct or reserve funds from a user’s account at the time a buy order was placed, but only upon matching with a sell order.
3. On the 1st of August, 2025, the Defendant placed numerous buy orders for securities at market price, taking advantage of this technical error.
4. The NER platform's matching of the Defendant’s buy orders with the sell orders of other users resulted in the formation of multiple valid and legally binding contracts.
5. Upon formation, these trades were considered settled, creating a binding legal obligation for the Defendant to provide payment and for the NER to honor the credited balances of the sellers.
6. As a direct result of the Defendant's failure to perform their contractual obligation of payment, their account registered a negative balance of $-244,497.68.
7. The securities sold by the innocent third-party sellers have since declined in market value.
8. Forcing a reversal of these settled contracts would cause direct and unfair financial harm to the innocent sellers by returning to them devalued assets. Such an action would conflict with the NER's duty of good faith and fair dealing.
9. The NER’s Terms of Service provides two discretionary remedies for such a situation: reversing a trade (Clause 5.3) or suing for dues (Clause 6.2). Given the harm a reversal would cause, the NER has determined the only equitable remedy is to hold the Defendant liable for the debt.
10. The Defendant was contacted regarding the debt, acknowledged it, and stated they would pay it, but has failed to do so.
III. CLAIMS FOR RELIEF
1. The NER ToS is a binding agreement. Clause 6.2 states: "In case a user uses any Technical Error or Glitch... NER reserves the right to Sue the user to collect any dues from the user." The Defendant used a technical error, resulting in the Defendant accruing a debt of $244,497.68, and is in material breach of the agreement by failing to pay.
2. The Defendant entered into multiple contracts and failed to provide the agreed-upon consideration (payment). This constitutes a material breach of contract. The Plaintiff brings this claim to enforce the Defendant's obligation and fulfill its own duties to the other parties of the contracts.
IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:
1. $244,497.68 in compensatory damages to cover the Defendant's negative balance.
2. $73,349.30 in legal fees (30%)
V. WITNESSES
1. Mg. (Member of Staff at the NER)
VI. EVIDENCE
P-001 - The National Exchange of Redmont Terms of Service
P-002 - Unedited NER trading logs on the 1st and 2nd of August 2025.
P-003 - Annotated Trading Logs on the 1st and 2nd of August 2025.
P-004 - Conversation Logs with the Defendant acknowledging the debt.
P-005 - Withdrawal request from a seller, showing credited funds from the Defendant's trades.
Proof of Representation:
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 21st day of August, 2025
Attachments
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