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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Miami Division

Case No.: 1:22-CV-23876

UNIQ BRANCH OFFICE MEXICO, 

S.A. DE C.V., a foreign corporation, 

and JACOBO HELFON DANIEL,

Plaintiffs,

v.

STEEL MEDIA GROUP, LLC, a 

Florida limited liability company, 

LUIS FERNANDO RODRIGUEZ 

MEJIA, an individual, and MATCH 

HOSPITALITY, WLL, a foreign 

corporation, MATCH HOSPITALITY 

AG, a foreign corporation,

Defendants.

/

COMPLAINT

COMES NOW, Plaintiffs, UNIQ BRANCH OFFICE MEXICO, S.A. DE 

C.V. (“Uniq”) and JACOBO HELFON DANIEL (“Helfon”) (collectively referred 

to as “Plaintiffs”), by and through undersigned counsel, and pursuant to the Federal

Rules of Civil Procedure, hereby sue Defendants, STEEL MEDIA GROUP, LLC 

(“Steel”), LUIS FERNANDO RODRIGUEZ MEJIA (“Rodriguez”), MATCH 

HOSPITALITY, WLL, (“Match WLL”), and MATCH HOSPITALITY AG 

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(“Match AG”) (collectively referred to as “Defendants”), and in support thereof 

allege as follows: 

INTRODUCTION

1. This is an action for damages. Plaintiffs suffered compensable losses 

when a Defendant, Steel, misappropriated funds intended to satisfy payment 

obligations due on luxury hospitality packages and/or tickets to the 2022 FIFA 

World Cup in Qatar. Rodriguez personally guaranteed all of Steel’s obligations. 

Defendant’s failures to make payments resulted in Defendants, Match WLL and 

Match AG, improperly retaining deposits belonging to Plaintiffs’ clients. These 

clients have validly assigned their right to collect to Plaintiffs. 

JURISDICTION, VENUE, AND PARTIES

2. This is an action for equitable relief and damages in excess of seventyfive thousand dollars ($75,000) exclusive of interest, costs, and fees. 

3. This Court has subject matter jurisdiction over Plaintiffs’ claims 

pursuant to 28 U.S.C. § 1332(a)(2). Complete diversity of citizenship exists between 

the Parties to this action. 

4. Plaintiff, Uniq, is a foreign corporation organized under the laws of 

Mexico, that conducts business in the State of Florida and Miami-Dade County, and 

otherwise consents to the jurisdiction of this Court. 

5. Plaintiff, Helfon, is a resident of Mexico and is otherwise sui juris.

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6. Defendant, Steel, is a Florida limited liability company, registered, 

authorized, and conducting business in Miami-Dade County, Florida with its 

principal place of business located at 1221 Brickell Avenue, Suite 900, Miami, FL 

33131. Upon information and belief, Steel has only one member, Rodriguez, who is 

a resident of Florida. 

7. Defendant, Rodriguez, is an individual residing in Florida and is 

otherwise sui juris. 

8. Defendant, Match WLL, is a foreign corporation organized under the 

laws of Qatar that conducts substantial and not isolated activity in Florida through 

brokers (including Steel) and holds property that was sent from Florida. 

9. Defendant, Match AG, is a foreign corporation organized under the 

laws of Switzerland that conducts substantial and not isolated activity in Florida

through brokers (including Steel) and holds property that was sent from Florida.

10. Venue is proper pursuant to 28 U.S.C. § 1391 because all causes of 

action accrued in Miami-Dade County, Florida. 

11. All conditions precedent to the filing of this action have been met,

waived, or excused. 

12. Plaintiff has retained the undersigned law firm and is obligated to pay 

reasonable attorneys’ fees as compensation for the costs and services. 

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GENERAL ALLEGATIONS

13. Plaintiff, Uniq, is in the business of providing clients with luxury travel 

experiences and accommodations. 

14. Plaintiff, Helfon, is an owner and officer of Uniq, and is generally in 

charge of managing the operations of Uniq. 

15. Defendant, Steel, is in the business of promoting and selling packages, 

services, and/or experiences at world class sporting and other events.

16. Defendant, Rodriguez, is the Authorized Member and principal of 

Steel.

17. Defendants, Match WLL and Match AG, are in the business of 

providing premium and exclusive sports hospitality services which include an 

“ongoing responsibility for the entire operation of the FIFA Hospitality Programme”

as stated on their website. 

18. Uniq and Steel entered into a commission agreement (the “Commission 

Agreement”) (attached hereto as Exhibit “A”) whereby Plaintiffs would promote 

events, in this case the 2022 FIFA World Cup in Qatar, to clients of Uniq (the 

“Clients”) who would then purchase tickets and hospitality packages (“World Cup 

Packages”) through Steel, from Match WLL.

19. Steel was obligated to pay Plaintiffs commissions as compensation for 

promoting the events once an agreement for the purchase of World Cup Packages 

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was reached between the Clients and Steel. Plaintiffs promoted the World Cup 

Packages and procured agreements to purchase the World Cup Packages by the 

Clients. The Clients sent payments directly to Steel to be applied towards the 

purchase price of the World Cup Packages from Match WLL. 

20. Steel thereafter was engaged as a broker to locate clients for the World 

Cup Packages, and as such agreed to purchase the World Cup Packages from Match 

WLL and received confirmation of purchase invoices (“Invoices”) outlining 

payment terms and accompanied by FIFA World Cup Qatar 2022 Hospitality Offline 

Sales Regulations (“Hospitality Regulations”) setting forth the terms and conditions 

that apply to the World Cup Packages. 

21. Steel made the required initial deposits to Match in accordance with the 

Invoices using the funds provided by the Clients. However, Steel misappropriated 

the funds in surplus of the initial deposits and failed to make payment in full resulting 

in Match WLL cancelling the Clients’ World Cup Packages and retaining the

deposits. Upon information and belief, Match AG, the parent company of Match 

WLL, now holds the total or a portion of these funds. Even if Match AG does not 

hold such funds, as parent company it has the authority to direct funds held by Match 

WLL.

22. In an undated letter that Steel sent to the Clients, Steel stated that the 

World Cup Packages were “100% confirmed” (translated from original) but were 

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delayed due to administrative and logistical difficulties. This letter promised that the 

Clients would receive their confirmations and tickets no later than November 7, 

2022.

23. On November 12, 2022, Steel and Rodriguez sent a second letter (“Nov. 

12 Letter”) (attached hereto as Exhibit “B”) to the Clients that was notarized and 

signed by Rodriguez. This letter states that Steel was defrauded and was unable to 

make the final payments due on the World Cup Packages. Additionally, the letter

claimsto have initiated legal action and additional steps had been taken to raise funds 

to make the necessary final payments. Furthermore, in the Nov. 12 Letter, Rodriguez

personally takes responsibility for all of the actions mentioned in the letter and 

personally guarantees refunds and compensation. 

24. Rodriguez then offered a lien on a residence that he owns personally to 

induce Plaintiffs and the Clients into delaying litigation and enforcing their rights. 

Upon a title search, it was determined that the residence was already encumbered 

with several liens and local violations, making the offered lien worthless. The several 

liens were not disclosed to the Plaintiffs and were concealed when Rodriguez made 

the initial lien offer on his residence. 

25. The Clients thereafter assigned collection rights to Plaintiffs for 

payment in full by Plaintiffs to the Clients of the amounts owed by Steel. As of the 

date of this filing, a total of one hundred six thousand one hundred seventy-six 

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dollars and thirty-one cents ($106,176.31) in claims have been assigned to Plaintiffs, 

which is attributed $10,800.00 to Helfon and $95,376.31 to Uniq. Plaintiffs reserve 

the right to amend this number as additional assignments are issued to Plaintiffs.

COUNT I

BREACH OF CONTRACT

(Plaintiffs Against Steel and Rodriguez)

26. Plaintiffs reallege and reincorporate by reference the allegations in 

paragraphs 1–25 as if fully set forth herein. 

27. The Clients and Steel entered into valid contracts to purchase World 

Cup Packages.

28. Steel committed a material breach of such contracts by, inter alia, 

misappropriating funds designated for a specific use, failing to make payment in full 

to Match with those funds, and failing to deliver the World Cup Packages to the 

Clients. 

29. The Clients suffered damages caused by Steel’s breaches. 

30. Rodriguez personally guaranteed Steel’s obligations under these 

contracts, as such he is jointly liable with Steel for compensation to Plaintiff. 

WHEREFORE, Plaintiffs pray that this Court issue judgment against 

Defendants, Steel and Rodriguez, for the value of the payments made by the Clients 

to Steel, less any refunds, plus interest thereon, costs, and fees, in favor of Plaintiffs,

along with any other relief this Court deems just and proper.

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COUNT II

FRAUDULENT INDUCEMENT

(Plaintiffs Against Steel and Rodriguez) 

31. Plaintiffs reallege and reincorporate by reference the allegations in 

paragraphs 1–25 as if fully set forth herein. 

32. Steel and Rodriguez made false statements regarding material facts by 

promising to use the Clients’ funds to purchase the World Cup Packages then 

misappropriating the funds so that the funds were not available to be used for their 

stated purpose. 

33. Furthermore, Rodriguez stated that the World Cup Packages had been 

“100% confirmed” when they had not yet been secured and the deadline to make 

payment in full had already passed. Rodriguez then offered a personal guarantee and 

lien on his residence that were false by virtue of having no value. 

34. Steel and Rodriguez knew or should have known that the 

representations were false. Steel and Rodriguez knew that the funds were 

misappropriated, that the deadline to make payment in full had passed, and that the 

World Cup Tickets were not confirmed. Rodriguez knew that he did not have 

sufficient assets to offer a guarantee and that his real estate was already encumbered 

by other senior liens. 

35. Steel and Rodriguez intended that the representation induce the Clients 

to act on it by agreeing to purchase the World Cup Packages and sending the funds 

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to Steel and Rodriguez. Steel and Rodriguez intended that the representations induce 

the Clients and Plaintiff to delay legal proceedings and enforcement of their rights. 

36. The Clients suffered damages in justifiable reliance on the 

representation. 

WHEREFORE, Plaintiffs pray that this Court rescind the contracts between 

the Clients and Steel, and Plaintiffs and Steel and issue judgment against Steel and 

Rodriguez in the amount of the value of the payments made by the Clients to Steel, 

less any refunds, plus interest thereon, costs, and fees, in favor of Plaintiffs along 

with any other relief this Court deems just and proper.

COUNT III

CONSTRUCTIVE TRUST

(Plaintiffs Against Steel)

37. Plaintiffs reallege and reincorporate by reference the allegations in 

paragraphs 1–25 as if fully set forth herein. 

38. The Clients and Steel shared a confidential relationship. 

39. Through this confidential relationship, Steel made a promise to the 

Clients.

40. Steel promised to transfer Clients’ funds to Match and transfer the

Word Cup Packages back to the Clients and caused reliance thereon.

41. Defendant has been unjustly enriched by failing to deliver the World 

Cup Packages or return the payments to the Clients.

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WHEREFORE, Plaintiffs pray that this Court issue judgment against 

Defendant, Steel, for the value of the payments made by the Clients to Steel, less 

any refunds, plus interest thereon, costs, and fees, in favor of Plaintiffs along with 

any other relief this Court deems just and proper.

COUNT IV

INDEMNIFICATION

(Uniq Against Steel and Rodriguez)

42. Uniq realleges and reincorporates by reference the allegations in 

paragraphs 1–25 as if fully set forth herein. 

43. Uniq discharged a duty owed to the Clients by providing refunds to the 

Clients as a result of vicarious, constructive, derivative, or technical liability due to 

the acts of Steel. 

44. The Commission Agreement at Clause Six, Subsection J and Clause

Eight obligates Steel to indemnify Uniq against all claims and lawsuits filed by the 

Clients or any other third party arising out of the World Cup Packages or any 

breaches by Steel.

45. Pursuant to the Commission Agreement at Clause Three, Subsection 6, 

Rodriguez is personally liable for all of Uniq’s obligations under the Commission 

Agreement.

46. Steel should have discharged the duty satisfied by Uniq. 

47. Uniq is without any fault.

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48. Uniq suffered damages by discharging the liability that should be borne 

by Defendant. 

WHEREFORE, Uniq prays that this Court issue judgment against 

Defendant, Steel, for the value of the payments made by the Clients to Steel, less 

any refunds, plus interest thereon, costs, and fees, in favor of Uniq, and hold Uniq 

harmless from all liability and fault, along with any other relief this Court deems just 

and proper.

COUNT V 

INDEMNIFICATION

(Helfon Against Steel and Rodriguez)

49. Helfon realleges and reincorporates by reference the allegations in 

paragraphs 1–25 as if fully set forth herein. 

50. Helfon discharged a duty owed to the Clients by providing refunds to 

the Clients as a result of vicarious, constructive, derivative, or technical liability due 

to the acts of Steel. 

51. Steel should have discharged the duty satisfied by Helfon.

52. Rodriguez personally guaranteed all of Steel’s obligations regarding the 

sale of World Cup Packages to the Clients.

53. Helfon is without any fault.

54. Helfon suffered damages by discharging the liability that should be 

borne by Steel and Rodriguez.

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WHEREFORE, Helfon pays that this Court issue judgment against 

Defendant, Steel, for the value of the payments made by the Clients to Steel, less 

any refunds, plus interest thereon, costs, and fees, in favor of Helfon, and hold 

Helfon harmless from all liability and fault, along with any other relief this Court 

deems just and proper.

COUNT VI

SUBROGATION

(Plaintiffs Against Steel)

55. Plaintiffs reallege and reincorporate by reference the allegations in 

paragraphs 1–25as if fully set forth herein. 

56. Plaintiffs are subrogated to the rights of the Clients. 

57. Plaintiffs made the payments to protect their own interest. 

58. Plaintiffs did not act as volunteers in making the payments because the 

Clients made claims against Plaintiffs due to Steel’s breaches.

59. Plaintiffs were not primarily liable for the amounts claimed by the 

Clients. 

60. Plaintiffs paid off the entire amount claimed by the Clients. 

61. Subrogation would not work any injustice to the rights of a third party. 

62. As a result, the Plaintiffs stand in the shoes of the Clients whose claims 

have been discharged and thus succeeds to the right and priorities of the original 

creditor. 

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WHEREFORE, Plaintiffs pray that this Court issue judgment against 

Defendant, Steel, for the value of the payments made by the Clients to Steel, less 

any refunds, plus interest thereon, costs, and fees, in favor of Plaintiffs, and 

subrogate the rights of Clients to Plaintiffs, along with any other relief this Court 

deems just and proper.

COUNT VII 

TEMPORARY INJUNCTION

(Plaintiffs Against Match WLL and Match AG)

63. Plaintiffs reallege and reincorporate by reference the allegations in 

paragraphs 1–25 as if fully set forth herein. 

64. Plaintiffs will suffer irreparable harm if Match WLL and Match AG are 

not enjoined from moving funds segregated for the World Cup Packages purchased 

by Steel for the Clients, because on information and belief Steel is undercapitalized 

and Rodriguez does not have sufficient assets to pay his debts.

65. Plaintiffs have no adequate remedy at law against Match WLL and 

Match AG. 

66. Plaintiffs have a substantial likelihood of success on the merits for their 

claims against Match WLL and Match AG for unjust enrichment. 

67. A temporary injunction would serve the public interest. 

WHEREFORE, Plaintiffs pray that this Court issue a temporary injunction

against Defendants, Match WLL and Match AG, enjoining Match WLL and Match 

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AG from distributing, disbursing, or otherwise disposing of the deposits paid by 

Steel on behalf of the Clients, along with any other relief this Court deems just and 

proper.

COUNT VIII

UNJUST ENRICHMENT

(Plaintiffs Against Match WLL and Match AG)

1. Plaintiffs reallege and reincorporate by reference the allegations in 

paragraphs 1–25 as if fully set forth herein. 

2. Plaintiffs, through the Clients and Steel, has conferred the benefit of the 

deposits for the World Cup Packages on Match WLL and Match AG. 

3. Match WLL and Match AG voluntarily accepted and retain the benefits

conferred.

4. The circumstances render Match WLL and Match AG’s retention of the 

benefits (i.e. the payments from the Clients) inequitable unless Match WLL and 

Match AG pays to the Plaintiffs the value of the benefits conferred by the Clients. 

WHEREFORE, Plaintiffs pray that this Court issue judgment against 

Defendants, Match WLL and Match AG, for the value of the deposits made by the 

Clients through Steel, plus interest, costs, and fees, in favor of Plaintiffs, along with 

any other relief this Court deems just and proper.

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DEMAND FOR JURY TRIAL

Plaintiffs hereby respectfully request a trial by jury on all appropriate issues 

so triable as raised in this Complaint. 

Date: November 28, 2022 AINSWORTH + CLANCY, PLLC

801 Brickell Avenue, 8th Floor 

Miami, Florida 33131

Telephone: (305) 600-3816

Facsimile: (305) 600-3817

Counsel for Plaintiff

By: /s/ Ryan Clancy

Ryan Clancy, Esq.

Florida Bar No.117650

Email: ryan@business-esq.com

Email: info@business-esq.com

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