UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 22-CV-23662

ZEFLON LLC., 

Plaintiff,

v.

WORLD REACH HEALTH, LLC ,

Defendant.

______________________________________/

COMPLAINT

Plaintiff Zeflon LLC (“Zeflon” or “Plaintiff”), as and for its Complaint against World 

Reach Health, LLC (“WRH” or “Defendant”), alleges and states as follows:

Parties

1. Plaintiff is a Delaware Limited Liability Company with its principal place of 

business in Miami Beach, Florida. 

2. Plaintiff is informed and believes, and based thereon alleges, that Defendant is an 

Illinois corporation with its principal place of business in Rolling Meadows, Illinois.

Jurisdiction and Venue

3. This Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1332(a) 

because there is complete diversity of citizenship of the parties and the amount in controversy is 

in excess of $75,000.

4. Venue in this District is proper pursuant to 28 U.S.C. § 1391(b), in that all of the 

acts or omissions that give rise to the claims in this action occurred in this District and further 

have an effect herein.

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General Allegations

5. Zeflon is a limited liability company who sold antigen kits throughout the United 

States during the pandemic.

6. Upon information and belief, Defendant is a purchaser and reseller of antigen kits 

in the United States.

7. In 2021, Plaintiff started selling antigen kits to Defendant.

8. At first, Plaintiff would send antigen kits, and Defendant would pay for them 

within a reasonable amount of time, and as of January 19, 2022, had paid for all the antigen kits 

Plaintiff had sold Defendant up until that date.

9. However, on or about January 31, 2022, and February 1, 2022, Defendant ordered 

$1,147,680 worth of additional antigen kits from Plaintiff.

10. Plaintiff delivered all the antigen kits Defendant ordered to Defendant or its 

customer as requested by Defendant.

11. To date, Defendant has only paid $850,000 from the outstanding balance of 

$1,135,405, leaving an unpaid balance of $285,405 remaining for the last eight months (as of the 

time of this writing).

Count I

(Breach of Contract)

(By Zeflon Against Defendant)

12. Zeflon incorporates by reference and re-alleges each and every one of the 

allegations in paragraphs 1 through 11 as if fully set forth herein.

13. Plaintiff delivered all of the antigen kits as required by the agreement with 

Defendant. 

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14. Although Defendant was obligated to pay for the antigen kits it received from 

Plaintiff, Defendant has failed to pay for the antigen kits in full.

15. Defendant’s failure to satisfy the obligations under the Agreements constitute a 

breach of contract. 

16. As a direct and proximate result of Defendants’ breach of contract, Plaintiff has

suffered damages in the amount of at least $260,655.

17. Accordingly, Plaintiff demands judgment against Defendants for damages in an 

amount no less than $260,655, plus interest, costs, and for such other relief this Court deems just 

and proper.

Prayer for Relief

WHEREFORE, Plaintiff Zeflon prays for judgment against Defendant as follows:

AS TO ALL COUNTS

1. For general, compensatory, and consequential damages according to proof;

2. For costs of suit herein;

3. For reasonable attorney’s and expert witness fees; and

4. For such other and further relief as the court deems proper. 

 Respectfully submitted,

/s/Menachem M. Mayberg

 MENACHEM M. MAYBERG 

Florida Bar No: 0596744

SELTZER MAYBERG LLC.

10750 NW 6th Court

Miami, Florida 33168

Tel: 305.444.1565

Fax: 305.444.1665

m@smfirm.com

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