IN THE UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Spume.IO LTD, 

Plaintiff 

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v. 

Atlantic International Capital LLC, d/b/a AIC 

Digital Assets Group, 

Defendant. 

CASE NO. 9:22-cv-81534 

COMPLAINT 

Plaintiff Spume.IO LTD (“Spume”), by and through its undersigned counsel for its 

Complaint against Defendant Atlantic International Capital LLC, d/b/a AIC Digital Assets Group 

(“AIC”), alleges: 

PRELIMINARY STATEMENT 

1. This is an action against AIC for breach of contract. 

2. AIC marketed itself to Spume as an experienced global team of financial experts 

and authorized agents that partners with “the largest financial institutions, banks and asset 

managers.” 

3. With its experience and connections, AIC promised it could help Spume gain access 

to reputable banking services. 

4. AIC also promised Spume that, based on its experience, knowledge and 

connections with key players in the industry, it could accomplish these tasks for Spume within 

specific timeframes and also obtain waivers of standard deposit requirements. AIC also promised 

to introduce Spume to significant “market makers” and to assist Spume to receive the most 

favorable terms from any vendors it introduced to the company. 

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5. Spume greatly valued having these tasks completed within the promised timeframe, 

and Spume believed, based on AIC’s representations, that AIC had the expertise and connections 

to deliver on its promises, so Spume, in reliance on said promises, paid AIC $1,450,000 to onboard 

Spume on prominent banking and digital asset banking platforms, including Deltec Bank and Trust 

(“Deltec”) and Delchain Limited (“Delchain”). 

6. After receiving payment, however, AIC failed to perform, made excuses, and 

blamed everyone but itself for prolonged delays. Ultimately, AIC failed to onboard Spume on the 

Deltec and Delchain banking platforms at all, much less within the promised 4-6 week period. 

7. Spume eventually discovered that AIC did not have the promised connections and 

could not deliver on its contractual obligations for which Spume paid AIC $1,450,000. 

8. Instead, Spume discovered that AIC was using the services of convicted felons and 

other unqualified individuals with the express plan of stealing Spume’s money and making threats 

against Spume when Spume complained about a lack of performance. Since Spume complained 

to AIC about its lack of performance, AIC has waged a social media campaign against Spume. 

9. Because of AIC’s wrongful conduct, Spume is seeking an award of damages for 

AIC’s breach of contract. 

JURISDICTION 

10. This Court has jurisdiction over this action under 28 U.S.C. § 1332(a)(2) because 

this is a civil action between Plaintiff, a citizen of a foreign state, the British Virgin Islands, and 

Defendant, a citizen of the State of Florida, and the amount in controversy exceeds $75,000, 

exclusive of interest and costs. 

VENUE 

11. Venue is proper in this district under 28 U.S.C. § 1391(b)(1) because Defendant is 

a Florida limited liability company headquartered in this district and under 28 U.S.C. § 1391(b)(3), 

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because Defendant is subject to personal jurisdiction in this district regarding this action. Pursuant 

to the parties’ contract, there is no other district where Plaintiff may otherwise bring this action. 

PARTIES 

12. Plaintiff Spume is a limited company incorporated in the British Virgin Islands and 

has its principal place of business in Tortola, British Virgin Islands. 

13. Defendant AIC is a limited liability company formed under the laws of Florida and 

does business in Boca Raton, Florida. Based upon public records, Defendant AIC has at least one 

member: Richard Iamunno, who is a citizen of Florida. 

FACTS 

14. Spume is a software development company that offers various blockchain-based 

services. 

15. A critical component of Spume’s business plan was to gain services from the Deltec 

and Delchain banking platforms.1 

16. AIC markets itself as an agency that partners “with the largest financial institutions, 

banks, and asset managers to facilitate corporate and individual digital currency opportunities.”2 

17. After discussing Spume’s business plans and objectives, AIC promised it could 

help Spume accomplish its goals. 

18. Specifically, AIC represented that it had a special relationship with key people at 

Deltec and Delchain that would enable it to onboard Spume to these platforms in a much shorter 

period of time than if Spume sought to obtain Deltec and Delchain services by itself. 

 

1

 Deltec is a Bahamas-based, licensed, and regulated financial institution that is widely seen as a leader in the 

cryptocurrency space. Delchain, also Bahamas-based, is a multi-currency banking, asset management, trading and 

advisory firm that supports blockchain companies. Both Deltec and Delchain are part of the Deltec International 

Group, a group of companies that provide banking, wealth management, and trust services. 

2

 https://aicdigitalassets.com/#close. 

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19. Relying on AIC’s representations, on and around June 6, 2022, Spume entered into 

an Advisory Agreement with AIC (“Agreement”), with the specific goal of expeditiously opening 

accounts for Spume with the Deltec and Delchain. 

20. In Section 1 of the Agreement, AIC promised to serve as Spume’s “global services 

agent and advisor . . . for the purposes of assisting onboarding to Deltec/Delchain bank providing 

fiat and crypto banking.” 

21. In Section 2 of the Agreement, AIC promised to provide expedited onboarding with 

both Deltec Bank and Delchain for fiat and crypto banking services within 4-6 weeks of the 

execution of the agreement and waiving standard deposit requirements. 

22. Believing that AIC could do all it promised under the Agreement and trusting AIC, 

Spume promptly paid AIC $1,450,000 upon execution of the Agreement. 

23. After payment, AIC requested that Spume complete some Deltec and Delchain 

intake-related documents. Spume promptly and accurately completed the intake-related documents 

and returned them to AIC. 

24. Beyond submitting the documents, however, AIC did nothing more to expedite 

Spume’s onboarding with Deltec or Delchain. AIC did nothing to and failed to obtain a waiver of 

standard deposit requirements for Spume. AIC failed to procure accounts with either Deltec or 

Delchain for AIC. In short, after receiving payment, AIC failed to perform its most critical 

promises, and there are strong indications that the entire operation was a fraud from the outset as 

Spume has learned that AIC employed or provided services to Spume through convicted felons 

and unsophisticated, incompetent employees, or contractors. 

25. Spume has not received the benefit of its bargain and has been damaged by AIC’s 

failure to meet its most basic promises and material breach of contract. To mitigate its damages 

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for AIC’s breach and failures, Spume was able to claw back approximately one-half of the fee paid 

to AIC. 

26. AIC continues to retain the remainder of the fee that Spume paid to AIC in Tether 

(USDT), totaling $750,000, despite utterly failing to perform any of its obligations under the 

Agreement, and despite Spume’s repeated request that AIC return the $750,000. 

COUNT ONE - BREACH OF CONTRACT 

27. Spume repeats and re-alleges paragraphs 1 through 26, as if fully set forth herein. 

28. On and around June 6, 2022, Spume and AIC entered into a valid and enforceable 

Agreement. 

29. Spume performed its obligations under the Agreement, remitting digital assets 

valued at $1,450,000 as payment for AIC’s services. Spume also timely supplied requested 

documents and information and answered all questions. 

30. AIC failed to perform its obligations under the Agreement, including failing to 

expeditiously onboard Spume Token on the Deltec/Delchain banking platform within the 

promised 4-6 week period. 

31. Because of AIC’s breach, Spume has suffered general and consequential 

damages, including the payment it made to AIC, which AIC has refused to return, and lost 

profits from losing the benefit of the bargain of the Agreement. 

32. These damages flow directly from and are the natural and probable consequences 

of AIC’s breach. These damages were foreseeable and contemplated by the parties before or when 

the Agreement was executed. 

33. Because of the foregoing, AIC is liable to Spume in an amount to be determined at 

trial, plus interest and costs. 

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DEMAND FOR JURY TRIAL 

34. Spume demands a trial by jury under Federal Rule of Civil Procedure 39 for all 

issues triable by jury. 

PRAYER FOR RELIEF 

WHEREFORE, Spume prays for judgment in its favor and against AIC as follows: 

a. That Spume be awarded damages for AIC’s breach of the Agreement; 

b. That Spume be awarded pre-and post-judgment interest on all damages; 

c. That Spume be awarded all its costs and expenses in this action; and 

d. Such further and other relief as the Court may deem just and proper. 

Dated: October 3, 2022 

Respectfully submitted, 

K&L GATES LLP 

By: /s/ Jonathan B. Morton 

Jonathan B. Morton, FL Bar No. 956872 

jonathan.morton@klgates.com 

Southeast Financial Center 

200 South Biscayne Boulevard, Suite 3900 

Miami, Florida 33131 

Telephone: (305) 539-3300 | Facsimile: (305) 358- 7095 

Victoria Oguntoye, FL Bar No. 114114 

victoria.oguntoye@klgates.com 

1717 Main Street, Suite 2800 

Dallas, Texas 75201 

Telephone: (214) 939-5500 | Facsimile: (214) 939-5849 

Attorneys for Plaintiff, Spume.IO LTD

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