According to the lawsuit, TFL and the Individual Defendants violated provisions of the Securities Act by selling non-exempt securities without registering it. The complaint alleges that the TFL and Individual Defendants also violated provisions of the Securities Act by participating in TFL’s failure to register the Terra Tokens.

Also according to the lawsuit, Defendants violated provisions of the Exchange Act by carrying out a plan, scheme, and course of conduct that TFL intended to and did deceive retail investors and thereby caused them to purchase Terra Tokens at artificially inflated prices; endorsed false statements they knew or recklessly should have known were materially misleading; and, made untrue statements of material fact and omitted to state material facts necessary to make the statements made not misleading.

The lawsuit further alleges non-securities claims, such as that Defendants violated provisions of the Racketeer Influenced and Corrupt Organizations Act (“RICO”) by conducting the affairs of an enterprise through a pattern of racketeering activity, California common law claims for aiding and abetting and for civil conspiracy, and that the Defendants violated provisions of California common law by possessing the monetary value of Terra Tokens at inflated value which rightfully belongs to the putative members of the Class.

No Class Has Been Certified. Until a class is certified, you are not represented by counsel unless you retain one. You may select counsel of your choice. You may also remain an absent class member and do nothing at this point. An investor’s ability to share in any potential future recovery is not dependent upon serving as lead plaintiff.

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