1

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF NEW YORK 

COMMODITY FUTURES 

TRADING COMMISSION 

 Plaintiff, 

v. 

ARMEN TEMURIAN and VISTA NETWORK 

TECHNOLOGIES 

 Defendants. 

 Civil Action No. [ ] 

 ECF Case 

 JURY TRIAL DEMANDED 

COMPLAINT FOR INJUNCTIVE RELIEF, CIVIL MONETARY 

PENALTIES, AND OTHER EQUITABLE RELIEF 

 Plaintiff Commodity Futures Trading Commission (the “CFTC” or “Commission”), by 

and through its undersigned attorneys, hereby alleges as follows: 

I. SUMMARY 

1. From at least September 2017 through January 2018 (the “Relevant Period”), 

Armen Temurian (“Temurian”) and his company, Vista Network Technologies (“Vista”) 

(Temurian and Vista together, “Defendants”), and others acting on their behalf or under their 

control, engaged in a scheme whereby they intentionally and/or recklessly made false or 

misleading material representations or disseminated false or misleading material information to 

the retail public in connection with the sale of digital assets that are commodities, such as Bitcoin 

and Ether. 

2. Specifically, Temurian and Vista fraudulently induced retail investors (the 

“Digital Asset Commodity Investors”) to transfer Bitcoin and Ether to Vista by falsely promising 

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that Vista would trade those digital assets and that the Investors would earn a 2.5% daily return 

on their investment and/or that their digital assets would double in value within 80 days. 

3. Defendants directed Digital Asset Commodity Investors to transfer their Bitcoin 

and Ether to certain digital wallets controlled by Vista. As a result, the Investors transferred over 

750 Bitcoin and 2,000 Ether—during the Relevant Period, worth over $6,000,000 and 

$1,000,000, respectively—to those digital wallets. 

4. Defendants acted intentionally or recklessly in falsely guaranteeing profits to their 

Digital Asset Commodity Investors because at the time such promises were made, Defendants 

did not have any reason to believe Temurian or Vista was capable of earning such profits. 

Further, neither Temurian, nor Vista, actually traded any digital assets on behalf of investors. 

5. Instead, Defendants’ course of conduct had characteristics of a Ponzi scheme. 

Specifically, according to Defendants’ own statements and records (viewed in conjunction with 

public blockchain information), while early Digital Asset Commodity Investors may have been 

paid back—or even paid profits—many later Digital Asset Commodity Investors did not receive 

any profits or even their entire original principal. At least some did not receive any assets back 

at all.

6. Indeed, consistent with a Ponzi scheme, Defendants’ own statements and records 

(reviewed in conjunction with public blockchain information) reflect that new investor funds 

were used to pay old investors.

7. Therefore, in addition to fraudulently soliciting investor funds, Defendants also 

misappropriated certain investors’ digital assets (together, the “Digital Asset Commodity 

Scheme”) by using these assets for purposes other than what Investors intended.

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8. Moreover, in early 2018, some Digital Asset Commodity Investors started to 

question why they were not seeing the promised return. Around this time, Temurian and Vista 

offered investors a different opportunity: to buy from Vista a “mini-miner.” Temurian and Vista 

claimed that the “mini-miner” could mine digital assets—including Bitcoin—from users’ home. 

This was also false. And Defendants knew it at the time and/or were reckless in not knowing it 

at the time.

9. Through the Digital Asset Commodity Scheme, Temurian and Vista engaged in 

acts and practices which violated the Commodity Exchange Act (“Act”), including Section 

6(c)(1) of the Act, 7 U.S.C. § 9(1), and Commission Regulation (“Regulation”) 180.1, 17 C.F.R. 

180.1.

10. Unless restrained and enjoined by this Court, Defendants are likely to continue to 

engage in the acts and practices alleged in this Complaint, or in similar acts and practices. 

Accordingly, the CFTC brings this action pursuant to Section 6c of the Act, 7 U.S.C. § 13a-1, to 

enjoin Defendants’ unlawful acts and practices and to compel their compliance with the Act and 

Regulations. In addition, the Commission seeks restitution, civil monetary penalties, permanent 

trading and registration bans, and such other statutory, injunctive, or equitable relief as this Court 

may deem necessary and appropriate.

II. JURISDICTION AND VENUE 

11. This Court has jurisdiction over this action under 28 U.S.C. § 1331 (federal 

question jurisdiction) and 28 U.S.C § 1345, which provides that district courts have original 

jurisdiction over civil actions commenced by the United States or by any agency expressly 

authorized to sue by Act of Congress. Section 6c(a) of the Act, 7 U.S.C. § 13a-1(a), authorizes 

the Commission to seek injunctive relief against any person whenever it shall appear to the 

Commission that such person has engaged, is engaging, or is about to engage in any act or 

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practice constituting a violation of any provision of the Act or any rule, regulation or order 

thereunder. 

12. Certain digital assets, including Bitcoin and Ether, are “commodities” in interstate 

commerce. 

13. Venue properly lies with this Court, pursuant to Section 6c(e) of the Act, 7 U.S.C. 

§ 13a-1(e) (2012), because Temurian and Vista transacted business in this District. 

III. THE PARTIES 

14. Plaintiff Commodity Futures Trading Commission is an independent federal 

regulatory agency charged by Congress with the administration and enforcement of the Act and 

the Regulations promulgated thereunder. The Commission maintains its principal office at 1155 

21st Street NW, Washington, DC 20581. 

15. Defendant Armen Temurian is a resident of Glendale, California and has never 

been registered with the Commission. 

16. Defendant Vista Network Technologies had its principal place of business in 

Glendale, California and it has never been registered with the Commission. 

IV. FACTS 

Defendants’ Digital Asset Commodity Scheme 

17. Temurian co-founded Vista in mid-2017. 

18. Since its inception, Temurian has been the CEO of Vista. 

19. By August of 2017, Defendants, or individuals they controlled, created and 

launched a website: http://vista.network (“the Website”). 

20. Defendants controlled the content of the Website. 

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21. The Website, in pertinent part, said: “Double Your Bitcoin and Your Ethereum 

Within 80 Days.” 

22. The Website further stated that “trading robots will trade every hour and will 

share their earnings with you as they deposit into your BTC and ETH WALLETS.” 

23. Under an “Opportunity” tab on the Website, Vista claimed “years of experience in 

the crypto mining and trading world.” 

24. Furthermore, in a list of benefits on the Website, it stated “Daily 2.5% -- Double 

in Just 80 days (ROI),” and that the goal was to double “as soon as possible.” 

25. In a “Vista PowerPoint” tab on the Website, a PowerPoint about Vista was 

available for download in multiple languages, including English (“Vista PowerPoint”). 

26. The Vista PowerPoint was created in July 2017. 

27. Specifically, the Vista PowerPoint repeated the false claim: “Double your Bitcoin 

and your Ethereum within 80 days or less through an automated Dual Coin Platform.” 

Defendants acted intentionally or recklessly in making this false claim because at the time such 

claim was made, Defendants did not have any reason to believe Temurian or Vista was capable 

of doubling Bitcoin or Ethereum within 80 days or less. 

28. The Vista PowerPoint claimed “Robot Traders” were part of Vista’s business 

model. 

29. The Vista PowerPoint reiterated the false claim: “Daily 2.5% - Double in Just 80 

days (ROI)” claim. 

30. It further claimed that Vista could “trade multiple times per hour even in minutes 

every single day.” 

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31. Furthermore, the Vista PowerPoint explained that investors could choose from a 

variety of investment “Packages,” depending on how much Bitcoin or Ether they chose to invest 

and additionally stated: “all packages 2.5% daily.” 

32. Both the Website and the Vista PowerPoint were designed to fraudulently induce 

Digital Asset Commodity Investors to believe that they would earn a 2.5% fixed daily return by 

having Defendants trade their digital assets. 

33. For example, a Digital Asset Commodity Investor residing in this District viewed 

the Website and, relying on its fraudulent guarantees of trading and daily profits, transferred 

digital asset commodities to wallets controlled by Vista. 

34. In addition to the content on the Website and in the Vista PowerPoint, Temurian 

personally marketed Vista to potential Digital Asset Commodity Investors located both in the 

United States and abroad in order to induce them to transfer their Bitcoin and Ether to Vista for 

purported trading. 

35. Specifically, in or about late 2017, Temurian invited potential Digital Asset 

Commodity Investors to Vista’s offices in Glendale, California. 

36. At Vista’s offices in Glendale, Temurian spoke directly to potential Digital Asset 

Commodity Investors and falsely represented to them that they would earn a fixed return on their 

digital assets by investing with Vista. 

37. Defendants acted intentionally or recklessly in making this false representation 

because at the time such representation was made, Defendants did not have any reason to believe 

Temurian or Vista was capable of guaranteeing a fixed return on their Digital Asset Commodity 

investment. 

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38. Temurian and Vista also relied on a network marketing model to further 

perpetrate the Digital Asset Commodity Scheme. 

39. Specifically, Defendants relied on a network of individual marketers to solicit 

investors (“Network Marketers”). Defendants purported to compensate these Network 

Marketers by offering them a fraction of the value of the Bitcoin or Ether transferred to Vista by 

the Digital Asset Commodity Investors that they recruited to invest with Vista. 

40. Defendants disseminated the Vista PowerPoint to the Network Marketers. In 

turn, the Network Marketers used the Vista PowerPoint and the false profit representations 

therein to induce Investors to transfer Bitcoin or Ether to wallets controlled by Temurian and 

Vista. 

41. Temurian was aware of, and sometimes monitored these efforts. 

42. At times he joined in them. For example, a Network Marketer (“Marketer A”) 

posted a video on YouTube on or about December 17, 2017, in which he used the Vista 

PowerPoint to market Vista to potential Digital Asset Commodity Investors. More specifically, 

Marketer A repeated the misrepresentations that Vista was trading all the time, utilizing bots, and 

that investors would earn 2.5% a day. Temurian appeared in this YouTube video via livestream 

after the PowerPoint presentation. 

43. A second marketer website, called “vistanetworkusa.com,” posted a video on or 

around November 2017, parroting language from the Website and PowerPoint regarding 

“doubling your bitcoin” and “daily 2.5%” payments, and showing potential investors how to 

transfer their Bitcoin or Ether to Vista. 

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44. On or about January 6, 2018, Temurian appeared in another video hosted by 

Marketer A—and posted on the “vistanetworkusa.com” website—which gave updates about 

Vista. In the video, Temurian reiterated the false claim that Vista does “trading.” 

45. In that video, Temurian also explained that Vista would no longer use the phrase 

“fixed return” or “fixed benefits of 2.5.” Instead, he said, Vista would make everything variable 

“from 1/4 percent up to 2.5 percent . . . that’s going to be how we run the daily benefits.” 

Investors Transfer Millions of Dollars’ Worth of Bitcoin and Ether to Plaintiffs 

46. From September 2017 through January 2018, Digital Asset Commodity Investors 

transferred Bitcoin or Ether to wallets controlled by Temurian and Vista. 

47. In total, during the Relevant Period, Temurian and Vista collected over 750 

Bitcoin (worth over $6,200,000 at the time such Bitcoin was deposited) and over 2,000 Ether 

(worth over $1,000,000 at the time such Ether was deposited) from their Digital Asset 

Commodity Investors. 

48. Of these totals, approximately 165 Bitcoin (worth over $1,300,000) and 800 Ether 

(worth approximately $350,000) came from Digital Asset Commodity Investors located in the 

United States. 

49. Indeed, hundreds of U.S.-based investors from around the country, including 

residents of this District, transferred Bitcoin or Ether to wallets controlled by Vista and 

Temurian. 

Defendants’ Representations Were False 

50. Contrary to the representations made by Temurian and Vista, neither Temurian 

nor Vista ever traded Bitcoin or Ether on behalf of Vista’s Digital Asset Commodity Investors. 

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51. Vista did not have a trading robot or other algorithm capable of generating a 2.5% 

daily return for Vista’s investors. 

52. At the time that Defendants represented to Digital Asset Commodity Investors 

that Vista would earn a “2.5% daily return” and “double” their money in 80 days, Defendants 

knew or were reckless in not knowing that these representations were false and that that neither 

he nor Vista had any trading program capable of achieving such fixed returns. 

53. In the January 6, 2018 video referenced above, Temurian claimed that Vista 

“do[es] trading,” knowing that Vista at that time was not trading—and had not traded—Digital 

Asset Commodities for Investors. 

54. In that same video, Temurian had no basis to represent that Vista would be able to 

generate any daily returns for investors. 

55. Indeed, on September 6, 2022, testifying under oath to Commission staff in this 

matter, entitled “In the Matter of Vista Network Technologies and Armen Temurian,” Temurian 

admitted that “Vista never traded for customers.” 

Misappropriation of Investor Assets 

56. In addition to Temurian’s September 6, 2022 admission that Vista never traded 

for Investors, Vista’s transaction records do not reflect any trading. Rather, Vista’s movement of 

digital assets has characteristics of a Ponzi scheme. 

57. Vista’s records and public information, taken together, reflect that many 

Investors’ digital assets sat in Vista-controlled wallets until they were bundled together and then 

split up into hundreds of small amounts—usually less than one hundredth of one Bitcoin. 

According to Vista’s records, most of these small amounts were deposited into wallets belonging 

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to other investors; other amounts, however, end up in wallets not identified by Vista as belonging 

to an investor. 

58. For example, Vista records (viewed in conjunction with public blockchain 

information) reflect that several U.S.-based investments made in late September 2017 sat in 

Vista-controlled wallets until November 21, 2017, when they were grouped together with other 

investors’ digital assets into a 33 Bitcoin1 transfer to another wallet. Ten of those Bitcoin were 

then used to make hundreds of small payments on November 21. And another 10 Bitcoin were 

used to make hundreds of small payments on November 23rd. According to Vista’s records, 

these hundreds of small payments went to earlier investors; but other portions of the original 33 

Bitcoin bundle were routed elsewhere. 

59. Other U.S.-based investors’ digital assets were turned around to repay other 

investors more quickly. 

60. For example, on December 12, 2017, Investor A, based in the U.S., transferred 

0.7 Bitcoin into a wallet controlled by Vista. At the time, 0.7 Bitcoin was worth nearly $12,000. 

61. The next day, December 13, 2017, that 0.7 Bitcoin, together with over a dozen 

other investors’ Bitcoin, was transferred through two different wallets, and then disseminated in 

small amounts to dozens, if not hundreds, of other wallets. According to Vista’s records, some 

of the wallets receiving these small amounts belonged to investors who had deposited bitcoin 

with Vista prior to December 2017. 

62. Investor A only ever received 0.1 BTC back. 

                                                             1

 At the time, 33 BTC was worth approximately $264,000. 

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63. On December 19, 2017, Investor B, based in the U.S., transferred 0.5 Bitcoin, 

worth over $9,000 at the time, into a wallet controlled by Vista. No Bitcoin was every returned 

to him. 

The MiniMiner 

64. By early 2018, certain Digital Asset Commodity Investors who were fraudulently 

induced to transfer their digital assets to Vista based on the false promise of profits complained 

to Vista that they had not received their promised gains. 

65. Around this time, Defendants urged Digital Asset Commodity Investors to 

continue investing with Vista in order to recoup their investment and more. As part of this 

effort, Defendants solicited Digital Asset Commodity Investors to purchase a new product, called 

a “mini-miner.” Defendants promised Investors that this “mini-miner” would generate consistent 

revenue by mining Bitcoin, among other digital assets. 

66. To market the mini-miner, Temurian and Vista created another website, 

“vistalive.com” in early 2018 (“VistaLive website”). 

67. The VistaLive website contained videos with representations about the miniminer. 

68. Specifically, one such video said that purchasers of the mini-miner could use it to 

“mine the cryptocurrency of your choice.” 

69. In the YouTube video described in paragraph 42, above, dated December 17, 

2017, Temurian said that Vista had started developing its own commercial mining machines. He 

said that these machines “will mine Bitcoin and some other coins like Etherium . . . .” 

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70. On the VistaLive website in 2018, another video featured an interview with the 

purported developer of the mini-miner, who also claimed that the mini-miner could mine 

Bitcoin. 

71. In fact, the mini-miner could not mine Bitcoin or Ether. And Temurian knew or 

was reckless in not knowing that it could not mine Bitcoin or Ether. 

72. Specifically, the developer of the mini-miner told Temurian in late 2017 that he 

was developing the mini-miner to mine only another digital asset called Monero. 

73. Temurian was also aware in late 2017 and early 2018 that the developer was 

having difficulty getting the mini-miner even to mine Monero. 

74. Nevertheless, Temurian and Vista marketed the mini-miner as a functional 

product that could mine multiple digital assets and sold hundreds of mini-miners anyway. 

COUNT I 

Violation of Section 6(c)(1) of the Act, 7 U.S.C. § 9(1), and Regulation 180.1, 17 C.F.R. § 

180.1(a) (2022) 

(Employment of Deceptive Devices; Misappropriation) 

75. The allegations set forth in paragraphs 1 to 63 are re-alleged and incorporated 

herein by reference.

76. 7 U.S.C. § 9(1) makes it unlawful “for any person, directly or indirectly, to use or 

employ, or attempt to use or employ, in connection with any swap, or a contract of sale of any 

commodity in interstate commerce, or for future delivery on or subject to the rules of any 

registered entity, any manipulative or deceptive device or contrivance, in contravention of such 

rules and regulations as the Commission shall promulgate . . . .” 

77. 17 C.F.R. § 180.1(a) makes it “unlawful for any person, directly or indirectly, in 

connection with any swap or contract of sale of any commodity in interstate commerce, or 

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contract for future delivery on or subject to the rules of any registered entity, to intentionally or 

recklessly: (1) use or employ, or attempt to use or employ, any manipulative device, scheme, or 

artifice to defraud; (2) make, or attempt to make, any untrue or misleading statement of a 

material fact or to omit to state a material fact necessary in order to make the statements made 

not untrue or misleading; [or] (3) engage, or attempt to engage, in any act, practice, or course of 

business, which operates or would operate as a fraud or deceit upon any person.” 

78. Digital assets such as Bitcoin and Ether are encompassed in the definition of a 

“commodity” under Section 1a(9) of the Act, 7 U.S.C. § 1a(9), and contracts for their sale are 

subject to the prohibitions of 7 U.S.C. § 9(1) and 17 C.F.R. § 180.1(a). 

79. From at least mid-2017 through mid-2018, as described above, Defendants 

violated 7 U.S.C. § 9(1) and 17 C.F.R. § 180.1(a) by, among other things, in connection with 

contracts of sale of commodities in interstate commerce, using or employing, or attempting to 

use or employ, a scheme or artifice to defraud, or making misrepresentations and omissions of 

material fact to current and prospective Digital Asset Commodity Investors, including, among 

other things, falsely promising that Vista would trade Bitcoin and Ether that had been deposited 

by investors, falsely guaranteeing profitable returns that they would receive from Defendants 

trading their Digital Asset Commodities, and misappropriating investors’ assets, including 

payments of investors’ funds to other investors consistent with a Ponzi scheme. 

80. The misleading statements alleged above were material, as they related directly to 

investment profit and risk of loss. 

81. By the foregoing conduct, Defendants directly or indirectly used or employed, or 

attempted to use or employ, a manipulative or deceptive device or contrivance or manipulative 

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device, scheme, or artifice to defraud customers and engaged in this conduct intentionally or 

recklessly. 

82. By the foregoing conduct, the Defendants directly or indirectly used or employed, 

or attempted to use or employ, a manipulative or deceptive device or contrivance which made or 

attempted to make untrue or misleading statements of material facts or omitted to state material 

facts necessary in order to make their statements to customers not untrue or misleading, and 

engaged in such conduct intentionally or recklessly. 

83. By the foregoing conduct, the Defendants directly or indirectly used or employed, 

or attempted to use or employ, a manipulative or deceptive device or contrivance or engaged or 

attempted to engage in an act, practice, or course of business which operated or would operate as 

a fraud or deceit, and engaged in such conduct intentionally or recklessly. 

84. Defendant Temurian is a controlling person of Vista and failed to act in good 

faith, or knowingly induced, directly or indirectly, Vista’s violations alleged in this Count. 

Accordingly, Defendant Temurian is liable for each and every violation of the Act committed by 

Vista, pursuant to 7 U.S.C. § 13(b). 

85. Section 2(a)(1)(B) of the Act, 7 U.S.C. § 2(a)(1)(B), provides that “the act, 

omission, or failure of any official, agent, or other person acting for any individual, association, 

partnership, corporation, or trust within the scope of his employment or office shall be deemed 

the act of such individual, association, partnership, corporation, or trust.” Because the acts, 

omissions and failures of Temurian, the CEO of Vista, the Network Marketers and others acting 

on the behalf or under their control of Vista, that violated Regulation 180.1 were within the 

scope of their employment or office, Vista is liable for those acts constituting violations pursuant 

to Section 2(a)(1)(B). 

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RELIEF REQUESTED 

WHEREFORE, the Commission respectfully requests that this Court, as authorized by 

Section 6c of the Act, 7 U.S.C. § 13a-1, and pursuant to its own equitable powers: 

A. Find that Defendants Temurian and Vista violated Section 6(c)(1) of the Act, 7 

U.S.C. § 9(1), and Commission Regulation (“Regulation”) 180.1, 17 C.F.R. 180.1; 

B. Enter an order of permanent injunction enjoining Defendants, and their affiliates, 

agents, servants, employees, successors, assigns, attorneys, and all persons in active concert with 

them, who receive actual notice of such order by personal service or otherwise, from engaging in 

the conduct described above—specifically, the use of any manipulative or deceptive device, in 

violation of Section 6(c)(1) of the Act, 7 U.S.C. § 9(1), and Commission Regulation 

(“Regulation”) 180.1, 17 C.F.R. 180.1.; 

C. Enter an order of permanent injunction restraining and enjoining Temurian and 

Vista, and their affiliates, agents, servants, employees, successors, assigns, attorneys, and all 

persons in active concert with them, from directly or indirectly: 

1) Trading on or subject to the rules of any registered entity (as that term is 

defined by Section 1a(40) of the Act, 7 U.S.C. § 1a(40)); 

2) Entering into any transactions involving “commodity interests” (as that term is 

defined in Regulation 1.3, 17 C.F.R. § 1.3 (2022)), or digital assets that are 

commodities, as that term is described herein, for their own personal 

accounts(s) or for any accounts in which any Defendant has a direct or 

indirect interest; 

3) Having any commodity interests or digital assets that are commodities, as that 

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term is described herein, traded on any Defendant’s behalf; 

4) Controlling or directing the trading for or on behalf of any other person or 

entity, whether by power of attorney or otherwise, in any account involving 

commodity interests or digital assets that are commodities, as that term is 

described herein; 

5) Soliciting, receiving, or accepting any funds from any person for the purpose 

of purchasing or selling of any commodity interests or digital assets that are 

commodities, as that term is described herein; 

6) Applying for registration or claiming exemption from registration with the 

CFTC in any capacity, and engaging in any activity requiring such registration 

or exemption from registration with the CFTC except as provided for in 

Regulation 4.14(a)(9), 17 C.F.R. § 4.14(a)(9) (2018); and 

7) Acting as a principal (as that term is defined in Regulation 3.1(a), 

17 C.F.R. § 3.1(a) (2018)), agent, or any other officer or employee of any 

person registered, exempted from registration, or required to be registered 

with the CFTC except as provided for in 17 C.F.R. § 4.14(a)(9). 

D. Enter an order directing Temurian and Vista, as well as any third-party transferee 

and/or successors thereof, to disgorge, pursuant to such procedure as the Court may order, all 

benefits received including, but not limited to, salaries, commissions, loans, fees, revenues, and 

trading profits derived, directly or indirectly, from acts or practices which constitute violations of 

the Act and Regulations as described herein, including pre-judgment and post-judgment interest; 

E. Enter an order requiring Temurian and Vista, as well as any successors thereof, to 

make full restitution to every person who has sustained losses proximately caused by the 

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violations described herein, including pre-judgment and post-judgment interest; 

F. Enter an order directing Temurian and Vista to pay a civil monetary penalty 

assessed by the Court, in an amount not to exceed the penalty prescribed by Section 6c(d)(1) of 

the Act, 7 U.S.C. § 13a-1(d)(1), as adjusted for inflation pursuant to the Federal Civil Penalties 

Inflation Adjustment Act Improvements Act of 2015, Pub. L. 114-74, tit. VII, § 701, 129 Stat. 

584, 599–600, see Regulation 143.8, 17 C.F.R. § 143.8 (2022), for each violation of the Act and 

Regulations, as described herein; 

G. Enter an order requiring Temurian and Vista to pay costs and fees as permitted by 

28 U.S.C. §§ 1920 and 2413(a)(2); and 

H. Enter an order providing such other and further relief as this Court may deem 

necessary and appropriate under the circumstances.

JURY TRIAL DEMAND 

Plaintiff hereby demands a trial by jury. 

Dated: February 15, 2023 

Respectfully submitted, 

COMMODITY FUTURES 

TRADING COMMISSION 

Manal M. Sultan 

Deputy Director 

By: /s/Samuel Wasserman___________________________ 

 Samuel Wasserman 

 Katherine Rasor 

Division of Enforcement 

290 Broadway, 6th Floor 

New York, New York 10007 

Phone: (646) 746-9700 

Fax: (646) 746-9939 

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JS 44 (Rev 4-29-2 1 Case 1:23-cv-01235 Document 1-1 Filed 02/15/23 Page 1 of 2 PageID #: 18 CIVIL COVER SHEET 

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as 

provided by local rules of court. This forn1, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the 

purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.) 

I. (a) PLAINTIFFS DEFENDANTS 

Commodity Futures Trading Commission 

(b) County of Residence of First Listed Plaintiff 

(EXCEPT IN US PLAINTIFF CASES) 

( C) Attorneys (Finn Name, Address, and Telephone Number) 

Samuel Wasserman 

Katherine Rasor a 

Armen Temurian and Vista Network Technologies 

County of Residence ofFirst Listed Defendant Los Angeles 

(IN US PLAINTIFF CASES ONLY) 

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED 

Attorneys (If Known) 

Michael Johnson 

Taylor English Duma LLP a 

II. BASIS OF JURISDICTION (Placean "X"inOne BoxOnly) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in One Box/or Plaintiff 

0 1 U S Government 

Plaintiff 

D 2 U S Government 

Defendant 

0 3 Federal Question 

(U.S. Government Not a Party) 

D 4 Diversity 

(Indicate Citizenship of Parties in Item Ill) 

Does this actio11 i11dude a 111otio11 for temporary restrai11i11g order or order 

to show cause? Yes0 No.lZ}' 

IV. NATURE OF SUIT (Place an "X" in One Box OnlJ~ 

CO:\'TRACT TORTS 

~ 110 Insurance 

120 Marine 

130MillerAct 

140 Negotiable Instrument 

D 150 Recovery of Overpayment 

& Enforcement of Judgment 

D 151 Medicare Act D 152 Recovery of Defaulted 

Student Loans 

(Excludes Veterans) 

PERSONAL INJURY 

310 Airplane 

31 S Airplane Product 

Liability 

320 Assault, Libel & 

Slander 

330 Federal Employers' 

Liability 

340 Marine 

PERSONAL INJURY 

D 365 Personal Injury -

Product Liability 

0 367 Health Care/ 

Pharmaceutical 

Personal Injury 

Product Liability D 368 Asbestos Personal 

Injury Product 

Liability 

(For Diversity Cases Only) and One Box/or Defendant) 

PTF DEF PTF DEF 

Citizen of This State D 1 D Incorporated or Principal Place D 4 D 4 

Citizen of Another State 

Citizen or Subject of a 

Foreign Country 

of Business In This State 

D 2 D 2 Incorporated and Principal Place 

of Business In Another State 

D 3 D 3 Foreign Nation 

D s O s 

FORFEITURE/PE:\'ALTY BA1'"KRUPTCY OTHER STATUTES 

625 Drug Related Seizure B 422 Appeal 28 USC 158 375 False Claims Act 

of Property 2 1 USC 881 423 Withdrawal 376Qui Tam (31 USC 

6900ther 28 USC 157 3729(a)) 

400 State Reapportionment 

PROPERTY RIGHTS 410 Antitrust 

820 Copyrights 4 30 Banks and Banking 

830 Patent 450 Commerce 

835 Patent - Abbreviated 460 Deportation 

New Drug Application 470 Racketeer Influenced and 

□ 840 Trademark Corrupt Organizations 

D 153 Recovery of Overpayment 

of Veteran's Benefits 

D 160 Stockholders' Suits 

D 190 Other Contract 

34 S Marine Product 

Liability 

350 Motor Vehicle 

PERSONALPROPERTY a,,,,,-----'"'-"'="---- □ 370 Other Fraud 

LABOR 

710 Fair Labor Standards □ 880 Defend Trade Secrets 480 Consumer Credit Actof 2016 (IS USC 1681 or 1692) 

D 195 Contract Product Liability 

D 196 Franchise 

REAL PROPERTY 

2 10 Land Condemnation 

D 220 Foreclosure 

§ 230 Rent Lease & Ejectment 

240 Torts to Land 

245 Tort Product Liability 

0 290 All Other Real Property 

3 S S Motor Vehicle 

Product Liability 

360 Other Personal 

Injury 

362 Personal Injury -

Medical Malpractice 

CMLRIGHTS 

440 Other Civil Rights 

441 Voting 

442 Employment 

44 3 Housing/ 

Accommodations 

445 Amer w/Disabilities -

Employment 

446 Amer w/Disabilities -

Other 

448 Education 

V. ORIGIN (Placean "X" inOneBoxOnlJ~ 

0 371 Truth in Lending 

D 380 Other Personal 

Property Damage 

D 385 Property Damage 

Product Liability 

PRISONER PETITIONS 

Habeas Corpus: 

463 Alien Detainee 

SI O Motions to Vacate 

Sentence 

530General 

535 Death Penalty 

Other: 

540 Mandamus & Other 

550 Civil Rights 

555 Prison Condition 

560 Civil Detainee -

Conditions of 

Confinement 

Act 

720 Labor/Management SOCUL SECURITY 

Relations 

~ 861 HIA (139Sff) 

740 Railway Labor Act 862 Black Lung (923) 

751 Family and Medical 863 DIWC/DIWW (40S(g)) 

Leave Act 864 SSID Title XVI 

790 Other Labor Litigation □ 865 RSI (40S(g)) 

79 I Employee Retirement 

Income Security Act FEDERAL TAX SUTS 

D 870 Taxes (U S Plaintiff 

□ 

or Defendant) 

871 IRS-Third Party 

Il\fl\fIGRATION 26USC7609 

462 Naturalization Application 

465 Other Immigration 

Actions 

0 I Original D 2 Removed from 

Proceeding State Court 

Remanded from 

Appellate Court 

D 4 Reinstated or D 5 Transferred from 

Reopened Another District 

(specify) 

D 6 Multidistrict 

Litigation -

Transfer 

Cite the U.S. Civil Statute under which you are filing (Do 1101 citejurisdiclio11al statutes u11less dfrersity): 

485 Telephone Conswner 

Protection Act 

490 Cable/Sat TV 

850 Securities/Commodities/ 

Exchange 

890 Other Statutory Actions 

891 Agricultural Acts 

893 Environmental Matters 

895 Freedom of Information 

Act 

896 Arbitration 

899 Administrative Procedure 

Act/Review or Appeal of 

Agency Decision 

950 Constitutionality of 

State Statutes 

D 8 Multidistrict 

Litigation -

Direct File 

VI. CAUSE OF ACTION 1-7-u_.s_.c_. ___ § __ 9( ..... 1> ________________________________ _ 

Brief description of cause: 

commO<lilies fraud 

VII. REQUESTED IN 

COMPLAINT: 

0 CHECK IF THIS IS A CLASS ACTION 

UNDER RULE 23, F.RCv.P. 

VIII. RELATED CASE(S) IF ANY (See insm,ctions): 

JUDGE 

DEMAND$ CHECK YES only if demanded in complaint: 

JURYDEMAND: G)Yes O No 

DOCKET NUMBER ----------------- ------------ DATE 

2/15/2023 

FOR OFFICE USE ONLY 

RECEIPT# AMOUNT 

SIGNAT~TZRNEY OF RECORD 

APPLYINGIFP JUDGE MAG JUDGE 
CERTIFICATION OF ARBITRATION ELIGIBILITY

Local Arbitration Rule 83. provides that with certain exceptions, actions seeking money damages only in an amount not in excess of $150,000,

exclusive of interest and costs, are eligible for compulsory arbitration. The amount of damages is presumed to be below the threshold amount unless a

certification to the contrary is filed.

&DVH LV (OLJLEOH IRU $UELWUDWLRQ

I, __________________________________________, counsel for____________________________, do hereby certify that the above captioned civil action is ineligible for

compulsory arbitration for the following reason(s): 

monetary damages sought are in excess of $150,000, exclusive of interest and costs,

the complaint seeks injunctive relief,

the matter is otherwise ineligible for the following reason

DISCLOSURE STATEMENT - FEDERAL RULES CIVIL PROCEDURE 7.1

Identify any parent corporation and any publicly held corporation that owns 10% or more or its stocks:

RELATED CASE STATEMENT (Section VIII on the Front of this Form)

Please list all cases that are arguably related pursuant to Division of Business Rule 50.3.1 in Sec ion VIII on the front of this form. Rule 50.3.1 (a) provides that “A civil case is “related” 

to another civil case for purposes of this guideline when, because of the similarity of facts and legal issues or because the cases arise from the same transactions or events, a 

substantial saving of judicial resources is likely to result from assigning both cases to the same judge and magistrate judge.” Rule 50.3.1 (b) provides that “ A civil case shall not be 

deemed “related” to another civil case merely because the civil case: (A) involves identical legal issues, or (B) involves he same parties.” Rule 50.3.1 (c) further provides that 

“Presumptively, and subject to the power of a judge to determine otherwise pursuant to paragraph (d), civil cases shall not be deemed to be “related” unless both cases are still 

pending before the court.”

1.) Is the civil action being filed in the Eastern District removed from a New York State Court located in Nassau or Suffolk

County? Yes No

2.) If you answered “no” above:

a) Did the events or omissions giving rise to the claim or claims, or a substantial part thereof, occur in Nassau or Suffolk

County? Yes No

b) Did the events or omissions giving rise to the claim or claims, or a substantial part thereof, occur in the Eastern

District? Yes No

c) If this is a Fair Debt Collection Practice Act case, specify the County in which the offending communication was

received: .

If your answer to question 2 (b) is “No,” does the defendant (or a majority of the defendants, if there is more than one) reside in Nassau or

Suffolk County, or, in an interpleader action, does the claimant (or a majority of the claimants, if there is more than one) reside in Nassau or 

Suffolk County?___________________________________

(Note: A corporation shall be considered a resident of the County in which it has the most significant contacts). 

BAR ADMISSION

I am currently admitted in the Eastern District of New York and currently a member in good standing of the bar of this court.

Yes No

Are you currently the subject of any disciplinary action (s) in this or any other state or federal court?

Yes (If yes, please explain No

I certify the accuracy of all information provided above.

Signature: ____________________________________________________

:FT /P

/DVW 0RGLILHG 

1<( ',9,6,21 2) %86,1(66 58/( F

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Case 1:23-cv-01235 Document 1-1 Filed 02/15/23 Page 2 of 2 PageID #: 19

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