UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

RANGAN BANDYOPADHYAY, an individual, 

Plaintiff,

v.

DEFENDANT “1” a/k/a SUXIA OBEI a/k/a 

SASHA, and JOHN DOES 1-20, as yet unidentified 

Individuals, Business Entities and/or Unincorporated 

Associations, 

Defendant.

 

 

 

 CASE NO.

COMPLAINT FOR VIOLATION OF THE

RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT

Plaintiff, RANGAN BANDYOPADHYAY, by and through undersigned counsel, sue 

DEFENDANT “1” a/k/a SUXIA OBEI a/k/a SASHA and DOES 1-20, as follows:

PRELIMINARY STATEMENT

1. Defendants stole cryptocurrency from Plaintiff which at the time of the theft had 

an approximate value of Nine Hundred Fifty-Eight Thousand Six Hundred Forty-Eight Dollars 

and Forty-One Cents ($958,648.41) pursuant to a sophisticated global internet cryptocurrency 

fraud and conversion scheme. 

2. Defendant “1” played material role in the theft of Plaintiff’s assets, and upon 

information and belief, currently possess all or a significant portion of Plaintiff’s stolen 

property. 

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3. Plaintiff brings this lawsuit to recover his stolen assets.

SUBJECT MATTER JURISDICTION AND VENUE

4. This is an action for damages including pursuant to 18 U.S.C. § 1964 (the 

“Racketeer Influenced and Corrupt Organizations Act” or “RICO”). This Court has subject 

matter jurisdiction over this action pursuant to 28 U.S.C. § 1331 (federal question).

5. Venue is proper in this District pursuant to 18 U.S.C. § 1965(a) and (b), and 28 

U.S.C. § 1391(b) and (c).

THE PARTIES AND PERSONAL JURISDICTION

6. Plaintiff RANGAN BANDYOPADHYAY is an individual, is sui juris, and is a 

resident and citizen of Washington. 

7. Defendant “1” is an individual, is sui juris, and is subject to the personal 

jurisdiction of this Court. Defendant “1” represented to Plaintiff that her name was “Suxia 

Obei” and “Sasha.” Defendant represented to Plaintiff that she was Chinese and the parties’ 

communications consistently demonstrated Defendant “1” was of Chinese descent and was 

located in China.

8. Defendants JOHN DOE 1-20 are as of yet unidentified Individuals, Business 

Entities, And/or Unincorporated Associations, cohorts of Defendant “1,” are sui juris, and are 

subject to the personal jurisdiction of this Court.

9. At all times material hereto, Defendants have maintained and continue to 

maintain, private cryptocurrency wallets and cryptocurrency exchange accounts in which all 

of or a portion of Plaintiff’s stolen cryptocurrency currently sits.

10. Defendants are subject to personal jurisdiction in this district, because they 

direct business activities toward and conduct business with consumers throughout the United 

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States, including within the State of Florida and this district through at least the e-mail address 

(Suxiaobei56230412@gmail.com) accessible from Florida. Alternatively, Defendants are 

subject to personal jurisdiction in this district pursuant to Federal Rule of Civil Procedure 

4(k)(2) because (i) Defendants are not subject to jurisdiction in any state’s court of general 

jurisdiction; and (ii) exercising jurisdiction is consistent with the United States Constitution 

and laws.

ALLEGATIONS COMMON TO ALL COUNTS

A. Defendants Execute an International Cryptocurrency Theft Scheme

11. On or about December 8, 2021, Defendant “1” connected with Plaintiff through 

WhatsApp, a messaging application that uses the internet to send messages. 

12. Defendant “1” misrepresented that she was successfully engaged in the trading 

of cryptocurrency investments. 

13. Defendant “1” misrepresented that her grandfather was a successful trading 

expert that worked in the financial market for many years. 

14. Defendant “1” misrepresented that she would utilize her expertise to trade 

cryptocurrencies with great success.

15. Defendant “1” supported the above misrepresentations by texts (cellular mobile 

phone and WhatsApp internet service), interstate (cellular and internet) phone calls, international 

(cellular and internet) phone calls, and e-mail (from Suxiaobei56230412@gmail.com). 

16. On or about December 23, 2021, Plaintiff joined the following liquidity mining 

platform recommended by Defendant “1”: defi.ethereumt.vip (“DEFIEVIP”). Mining 

platforms are computer software that use the user’s computing power to process “mine”

cryptocurrency. In exchange for the user’s mining operation, the user receives a monetary 

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reward in the form of digital currency. In cryptocurrency liquidity mining, the user earns

rewards by letting a decentralized trading service work with some of the user’s cryptocurrency 

tokens. These tokens then facilitate trades between other cryptocurrency holders.

17. After familiarizing himself with the process of liquidity mining and the 

DEFIEVIP platform recommended by Defendant “1,” and in reliance on the foregoing false and 

fraudulent misrepresentations, Plaintiff started to use the platform to invest into the liquidity 

mining project recommended by Defendant “1.”

18. In reality, the DEFIEVIP platform was fraudulently operated by Defendants.

19. Plaintiff’s cryptocurrency account was operated by Coinbase, a legitimate third 

party online platform for buying, selling, transferring, and storing cryptocurrency. Plaintiff 

linked his Coinbase wallet to the DEFIEVIP platform.

20. On January 25, 2022, when Plaintiff received information on scams perpetrated 

on cryptocurrency account holders, he attempted to withdraw funds and/or lock his Coinbase 

account without success. Plaintiff was then informed by DEFIEVIP, fraudulently posing as 

Coinbase support, that there was no fraudulent activity suspected on his Coinbase account. In 

reality, Defendants took control of Plaintiff’s Coinbase wallet and proceeded to steal Plaintiff’s 

cryptocurrency.

21. In this manner Defendants also mimic an actual business (i.e., Coinbase) to 

ensnare unsuspecting investment victims. 

B. Plaintiff’s Forensic Tracking of His Stolen Cryptocurrency

22. When a transaction is made on the blockchain it is assigned a “transaction hash” 

(“TXID”). A transaction hash is a unique string of characters that is given to every transaction 

that is verified and added to the blockchain. A TXID is used to uniquely identify a particular 

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transaction. All on-chain transactions (the transactions from or to external addresses) have a 

unique TXID that can be seen in transaction details. All on-chain transactions (depositing and 

withdrawing of funds) have a unique TXID that can be found in transaction details.

23. On January 26, 2022, at 9:06 a.m. Plaintiff’s Coinbase wallet sent an 

unauthorized cryptocurrency (i.e., Tether (“USDT”)) transaction to a virtual wallet address 

controlled by Defendant “1” 0x6ce27f036ccbd6134aee5dc5ee56ee33fd940a58 (“Defendant 

“1” Wallet”) from the Plaintiff’s virtual wallet address 

0xae4abcde02bc7ec3826d735cca24ed036bd87e92 (“Plaintiff’s Wallet”). 

24. The USDT transaction was sent to the Defendant “1” Wallet as shown in the 

following transaction:

Date 

(EST) Amount Sent Defendant “1” Wallet Address Transaction ID

01/26/22 

at 

9:06am

957,281.50 

USDT

0x6ce27f036ccbd6134aee5dc5ee56ee33f

d940a58

0xaff582f40ed41dcd2aadfaa0a132c61cdb

1204fdfcf738ddc6cd8059ae89941a

25. Defendant “1” then transferred the Plaintiff’s funds from the Defendant “1”

Wallet to the wallet address as shown in the following transaction:

Date 

(EST) Amount Sent JOHN DOE Secondary Wallet Address Transaction ID

01/26/22 

at 

9:17am

961,849.90 

USDT

0xeaa1ee125b02b127c5a4f2adca5637aea

53bdf1f

0x7ed96bd71dce30a8ab9ac70250fcf7e1e

660e2458d7002ec65a1e35e8dba3369

26. Plaintiff’s funds were then traced through multiple wallets (the “Defendant “1” 

Secondary Addresses”) prior to landing at Binance Exchange Pool Address 

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0x28c6c06298d514db089934071355e5743bf21d60 (the “Defendant “1” Binance Pool 

Address”). Binance is a legitimate online cryptocurrency exchange.

27. The final transactions that transferred the Plaintiff’s funds from the following 

Defendant “1” Secondary Wallet Addresses to the Defendant “1” Binance Pool Address as 

shown in the following transactions:

Date 

(EST) Amount Defendant “1” Secondary Wallet Address (Sender) Transaction ID

01/27/22 

at 

12:32pm

150,000.00 

USDT

0x03840901b5837b06e5ec4634dee0d5e7

6b7c1fd2

(Binance Wallet)

0xae58d2eaec89dc7fc583a5e740c23a6 

6973c90a9a0c062ef6766caee7cc0c522

01/27/22 

at 

2:37pm

350,000.00 

USDT

0xe5274c8fac9574518352f216c297194d

d40e49d0 (Binance Wallet)

0xcea6acedf054cc28225ad6c7712277c 

932ffb93526327d1dc3f0d0c84992bd11

01/28/22 

at 

12:31am

158,000.00 

USDT

0x1e8bd75ecbf283f7f5eaeb77b0e33dd3f

3d900bc (Binance Wallet)

0x93d9c3df688f9ec5f5bf3bfd84c8cae65 

76696b8344ce3d416a5ddba70058e3c

01/28/22 

at 

12:31pm

1,000,000.00 

USDT

0x6b663d77a2bfba6e8d16ef271ff0b17aa

4bbb643 (Binance Wallet)

0x091df3b50d10184177c5bb5f2ce3e885 

de7fa2c654ef8540ba771a02da3c287b

02/04/22 

at 

02:33pm

184,458.00 

USDT

0xe15ba3e0824f97f4b0f841cf030021097

eaf2108 (Binance Wallet)

0x5d4b82e3acd6dae62efdc6a4abff7c8b9b

98faf86c3263cf069734e6959d3c41

28. As set forth above, Defendants converted 958,648.41 USDT from Plaintiff 

valued at the time of the theft at approximately Nine Hundred Fifty-Eight Thousand Six 

Hundred Forty-Eight Dollars and Forty-One Cents ($958,648.41). Plaintiff tracked the USDT 

to the Binance Exchange Pool. 

29. Plaintiff suffered substantial damages.

30. If unchallenged, Defendant “1” and her cohorts JOHN DOES 1-20 will continue 

their fraudulent international criminal crypto theft scheme robbing unsuspecting persons and 

businesses in the U.S., in this district, and throughout the world. 

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FULFILLMENT OF CONDITIONS PRECEDENT,

ENTITLEMENT TO ATTORNEY’S FEES AND PUNITIVE DAMAGES

31. All conditions precedent to the maintenance of this action have been performed, 

have occurred, or have been waived or excused.

32. Plaintiff has retained the undersigned attorneys to bring this action and is

obligated to pay a reasonable attorney’s fee for their services. Plaintiff is entitled to an award 

of their attorney’s fees against Defendants, among other things, pursuant to 18 U.S.C. § 

1964(c).

COUNT I

RACKETEERING IN VIOLATION OF 18 U.S.C. § 1964

33. Plaintiff adopts and realleges the allegations set forth in paragraphs 1 through

32 above as if fully and expressly set forth herein and further alleges as follows.

34. The operation of Defendant “1” and JOHN DOES 1-20, individually and 

through their alleged business “DEFIEVIP,” and their mimicked business “Coinbase,” in their 

sophisticated global internet cryptocurrency fraud and conversion scheme constitutes a 

racketeering operation.

35. Defendant “1” directed and coordinated with JOHN DOES 1-20 as yet 

unidentified additional parties (collectively the “DEFIEVIP Enterprise,” “RICO Enterprise,” 

or "Enterprise") within the meaning of 18 U.S.C. § 1961(4), which Enterprise was engaged in, 

or the affairs of which affected, interstate and foreign commerce.

36. Defendant “1” and JOHN DOES 1-20 were each also a member of the RICO

Enterprise, as each was a distinct person, separate and apart, from each of the RICO Enterprise 

members together.

37. The RICO Enterprise engaged in a pattern of racketeering activity.

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38. Each person’s participation was effective partly because each mimicked an 

actual on-going business (Coinbase) with a presence in the marketplace: the United States and 

indeed worldwide.

39. As co-conspirators, the unlawful conduct of each member of the RICO

Enterprise is attributed to every member, i.e., Defendant “1” and JOHN DOES 1-20 as yet 

unidentified co-conspirators.

40. As set forth above, the RICO Enterprise engaged in the following predicate acts 

of racketeering within the meaning of 18 U.S.C. § 1961(1): Wire fraud in violation of 18 U.S.C. 

§ 1343.

41. The predicate acts set forth in this Complaint, include defrauding Plaintiff

beginning in December 2021, through domestic and international telephone calls, WhatsApp 

messaging, domestic and international texts, and e-mails with Plaintiff.

42. The predicate acts set forth in this Complaint are related, in that they have the 

same or similar purposes, results, participants, and methods of commission, and are otherwise 

interrelated by distinguishing characteristics and are not isolated events. The related criminal 

schemes set forth in this Complaint constitutes a “pattern or patterns of racketeering activity” 

as defined in 18 U.S.C. § 1961(5).

43. The Defendants engaged in two or more predicated acts of racketeering within 

a period of ten years and committed at least one such act after October 15, 1970.

44. The information that would establish further predicate acts and further acts of 

racketeering is solely within the control of Defendants. Due to the global nature of their 

criminal scheme, with the great distances between (a) the members of the DEFIEVIP 

Enterprise in China, and (b) their unsuspecting victims including Plaintiff (e.g., throughout the 

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United States, in this district, and throughout the world), practicality dictates that the Enterprise 

members communicated with each other, with Plaintiff, with victims similarly situated to 

Plaintiff, through use of mail and/or wire. Plaintiff requires discovery to ferret out the further 

extent of predicate acts and further acts of racketeering, including the identity of similarly 

situated defrauded victims and the scope of the systematic fraud.

45. Defendants have received income derived, directly or indirectly, from a pattern 

of racketeering activity and used or invested, directly or indirectly, part of such income, or the 

proceeds of such income, in acquisition of an interest in, or in the establishment or operation 

of, the RICO Enterprise, an enterprise which is engaged in, or the activities of which affect, 

interstate or foreign commerce in violation of 18 U.S.C. § 1962(a).

46. Defendants through a pattern of racketeering activity maintain, directly or 

indirectly, an interest in or control of the RICO Enterprise, an enterprise which is engaged in, 

or the activities of which affect, interstate or foreign commerce in violation of 18 U.S.C. § 

1962(b).

47. Defendant “1” was associated with the RICO Enterprise, and conducted or 

participated, directly or indirectly, in the conduct of the Enterprise's affairs through the pattern 

of racketeering activity described herein in violation of 18 U.S.C. § 1962(c).

48. Defendant “1” and/or JOHN DOES 1 - 20 as yet unidentified additional parties,

each entered into a conspiracy to conduct or participate, directly or indirectly, in the conduct 

of the RICO Enterprises' affairs through the pattern of racketeering activity described herein, 

in violation of 18 U.S.C. § 1962(d).

49. As a direct and proximate result of Defendants’ unlawful actions, Plaintiff has

suffered damages.

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WHEREFORE, Plaintiff RANGAN BANDYOPADHYAY demands that judgment 

be entered against Defendant “1” and JOHN DOES 1-20, jointly and severally, as follows:

(a) damages; 

(b) statutory trebled damages pursuant to 18 U.S.C. § 1964(c);

(c) punitive damages;

(d) costs, including reasonable attorney's fees, pursuant to 18 U.S.C. § 

1964(c);

(e) costs;

(f) interest; and

(g) such other and further relief as this Court deems just and proper.

COUNT II

CONVERSION

50. Plaintiff adopts and realleges the allegations set forth in paragraphs 1 through

32 above as if fully and expressly set forth herein and further alleges as follows.

51. As more fully alleged above, Defendants misappropriated Plaintiff’s funds.

52. Defendants have converted Plaintiff’s funds to their own use or to the use of 

others not entitled thereto, and have exercised dominion and control over the funds to 

Plaintiff’s exclusion and detriment.

53. Plaintiff has suffered damages as a direct and proximate result of Defendants' 

conversion.

WHEREFORE, Plaintiff RANGAN BANDYOPADHYAY demands that judgment 

be entered against Defendant “1,” and JOHN DOES 1-20, jointly and severally, for damages, 

interest, costs, and such other and further relief as this Court deems just and proper.

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COUNT III

UNJUST ENRICHMENT

54. Plaintiff adopts and realleges the allegations set forth in paragraphs 1 through

32 above as if fully and expressly set forth herein and further alleges as follows.

55. Plaintiff conferred a direct benefit upon Defendants by transferring the valuable 

cryptocurrency that Defendants converted from Plaintiff.

56. Defendants have knowledge of the benefit Plaintiff conferred upon them and 

have retained such benefit.

57. The circumstances under which Plaintiff conferred, and Defendants accepted, 

such benefit render Defendants’ retention of the benefits inequitable.

58. Equity requires that Defendants return to Plaintiff the benefits he conferred upon

Defendants.

WHEREFORE, Plaintiff RANGAN BANDYOPADHYAY demands that judgment 

be entered against Defendant “1” and JOHN DOES 1-20, jointly and severally, for damages, 

interest, costs, and such other and further relief as this Court deems just and proper.

COUNT IV

IMPOSITION OF A CONSTRUCTIVE TRUST

AND DISGORGEMENT OF FUNDS

59. Plaintiff adopts and realleges the allegations set forth in paragraphs 1 through

32 above as if fully and expressly set forth herein and further alleges as follows.

60. This is an action to impose a constructive trust upon the property taken from 

Plaintiff that is currently held by Defendants at the Binance Exchange Pool.

61. This action further calls for the restoration to Plaintiff of that wrongfully 

obtained property.

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62. As set forth above, Defendants -- through actual fraud, misappropriation, 

conversion, theft, or other questionable means -- obtained Plaintiff’s cryptocurrency, which in 

equity and good conscience Defendants should not be permitted to hold.

63. The cryptocurrency assets at issue are specific, identifiable property and have 

been traced to the Binance Exchange pool.

64. Any and all assets being held by Defendants at Binance must be held in trust for 

Plaintiff’s benefit, as Defendants are not entitled to the benefit of wrongfully misappropriated, 

converted, and stolen funds and cryptocurrency assets that were taken from Plaintiff.

65. The Tether identified herein which are being held by Defendants at Binance 

must be disgorged to Plaintiff’s benefit, as Defendants are not entitled to the benefit of 

wrongfully misappropriated, converted, and stolen funds and cryptocurrency assets that were 

taken from Plaintiff. 

WHEREFORE, Plaintiff RANGAN BANDYOPADHYAY demands the equitable 

imposition of a constructive trust over the property taken from Plaintiff that is currently under 

the control of Defendant “1” and/or JOHN DOES 1-20, in the identified cryptocurrency wallet 

addresses, and further demands that the wrongfully obtained property be restored to Plaintiff.

COUNT V

CONSPIRACY

66. Plaintiff adopts and realleges the allegations set forth in paragraphs 1 through

32 above as if fully and expressly set forth herein and further alleges as follows.

67. The Defendants conspired and confederated with each other to commit, and 

committed, (Count I) Racketeering in Violation of 18 U.S.C. § 1964; (Count II) Conversion; 

and (Count III) Unjust Enrichment.

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68. Plaintiff has suffered damages as a direct and proximate result of Defendants’ 

conspiracy.

WHEREFORE, Plaintiff RANGAN BANDYOPADHYAY demands that judgment be 

entered against Defendant “1” and JOHN DOES 1-20, jointly and severally, for damages, 

interest, costs, and such other and further relief as this Court deems just and proper. 

DEMAND FOR A JURY TRIAL

Plaintiff demands trial by jury on all issues so triable. 

Respectfully submitted,

September 13, 2022

THE BOBADILLA LAW FIRM

Attorneys for Plaintiff

20900 NE 30th Avenue, Suite 800

Aventura, FL 33180

Telephone: 786.446.8643

www.bobadillafirm.com

By: s/ D. Fernando Bobadilla

D. Fernando Bobadilla, Esq.

Fla. Bar No. 0136948

fernandob@bobadillafirm.com

Co-Counsel:

THE CRYPTO LAWYERS

Attorneys for Plaintiff

848 Brickell Avenue, Penthouse 5

Miami, Florida 33131

Telephone: (305) 423-3514

www.thecryptolawyers.com

By: s/ Agustin M. Barbara

Agustin M. Barbara, Esq.

Fla. Bar No. 1002677

agustin@thecryptolawyers.com

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