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

[EmmDubz]

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.

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:

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

 

[AmityBlamity]

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.

 

[Kaiserin_]

The Commonwealth is present, your honour.

 

[AmityBlamity]

@Kaiserin_ You have 48 hours to file your Answer to Complaint.

 

[Kaiserin_]

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.

 

[EmmDubz]

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.

 

[Kaiserin_]

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.

 

[AmityBlamity]

My apologies. For some reason, I wasn't notified about updates in this case.

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.

You may make your motion, and then I shall rule on the enjoining.

 

[EmmDubz]

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.

 

[AmityBlamity]

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