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JAMES H. HOLL, III (CA Bar No. 177855) 

jholl@cftc.gov 

Attorney for Plaintiff

COMMODITY FUTURES

TRADING COMMISSION

1155 21st Street, N.W.

Washington, D.C. 20581

(202) 418-5311 / (202) 418-5523 (fax)

THE UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

WESTERN DIVISION

COMMODITY FUTURES

TRADING COMMISSION,

Plaintiff,

v.

DAVID CARMONA (a/k/a/ David 

Segundo Carmona a/k/a Wuilver 

Segundo), JUAN ARELLANO 

PARRA, MOSES VALDEZ, 

DAVID BREND, and MARCO A. 

RUIZ OCHOA, jointly d/b/a 

ICOMTECH,

Defendants.

Case No. 2:23-cv-04015

COMPLAINT FOR INJUNCTIVE

RELIEF, CIVIL MONETARY 

PENALITES, RESTITUTION,

AND OTHER EQUITABLE

RELIEF UNDER THE

COMMODITY EXCHANGE ACT

AND COMMISSION 

REGULATIONS

Plaintiff, Commodity Futures Trading Commission (“CFTC” or 

“Commission”), an independent federal agency, by its attorneys, alleges as follows:

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I. SUMMARY

1. This case involves a fraudulent solicitation scheme targeting Spanishspeaking communities in the United States and other countries. From at least August 

2018 through at least December 2019 (the “Relevant Period”), Defendants David 

Carmona (a/k/a/ David Segundo Carmona a/k/a Wuilver Segundo) (“Carmona”), Juan 

Arellano Parra (“Arellano”), Moses Valdez (“Valdez”), David Brend (“Brend”), and 

Marco A. Ruiz Ochoa (“Ruiz”), individually and jointly doing business as 

“Icomtech”, and each aiding and abetting each other, (collectively, “Defendants”), 

engaged in a multi-level marketing scheme involving the fraudulent solicitation of 

customer funds through false representations. 

2. To induce actual and prospective customers to give them money, 

Defendants and other Icomtech agents falsely represented: (1) that they would use 

customer money to trade Bitcoin and other digital asset commodities on the 

customers’ behalves; (2) that Icomtech would provide “daily returns” on the 

customers’ money from the trading of Bitcoin or other digital asset commodities of 

between 0.9% to 2.8%; (3) that Icomtech would double the customers’ money in 

approximately four to eight months from the trading; and (4) in exchange for a 

customer’s upfront payment of money to Icomtech (typically in cash), that Icomtech 

would create an online account for the customer where the customer purportedly 

could watch their money grow. 

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3. In actuality, Defendants did not trade Bitcoin or other digital asset

commodities on the customers’ behalves as they represented, and did not earn daily 

returns nor double the customers’ investments based on trading. Instead, Defendants 

misappropriated customer funds to further promote the scheme, and, on information 

and belief, to pay for personal expenditures and to pay themselves commissions and 

bonuses. In fact, some Icomtech customers lost all of their funds. 

4. As further inducement for customers to give them money, Defendants 

falsely promised existing customers that they would receive commissions and/or 

bonuses for referring family and friends to Icomtech. Based upon those 

representations, some customers accepted money from family and friends on behalf 

of Icomtech and then gave the money to Defendants or other Icomtech agents for 

Icomtech purportedly to trade Bitcoin and other digital asset commodities on the 

customers’ behalves. In actuality, despite referring family and friends to Icomtech, 

one or more Icomtech customers did not receive commissions and/or bonuses for 

those referrals as Defendants had promised.

5. Finally, the Icomtech written promotional materials that Defendants and 

other Icomtech agents provided to customers did not disclose, or did not fully 

disclose, that customer money would be used to, at least in part, pay for Icomtech 

expenses or Defendants’ and other Icomtech agents’ commissions and bonuses. 

6. As a result of Defendants’ fraudulent scheme, more than 170 individuals 

located in the United States and other countries transferred at least hundreds of 

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thousands of dollars to Defendants and other Icomtech agents. During and after the 

Relevant Period, numerous customers unsuccessfully attempted to withdraw money 

from their Icomtech accounts. Rather than return money to customers, certain 

Defendants made excuses and reassured customers that their money was safe. 

Despite the assurances, some customers lost all of their money.

7. By this conduct and the conduct further described herein, Defendants 

have engaged, are engaging, or are about to engage in fraudulent acts and practices in 

violation of Section 6(c)(1) of the Commodity Exchange Act (the “Act”), 7 U.S.C. 

§ 9(1), and Commission Regulation (“Regulations”) 180.1(a)(1)-(3), 17 C.F.R. 

§ 180.1(a)(1)-(3) (2022). 

8. Further, during the Relevant Period, each of the Defendants willfully 

aided and abetted each of the other Defendants’ fraudulent acts and practices and, 

therefore, are liable for that fraud pursuant to Section 13(a) of the Act, 7 U.S.C. 

§ 13c(a).

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

Commission brings this action to enjoin Defendants’ unlawful acts and practices and 

to compel their compliance with the Act and Regulations, and to further enjoin 

Defendants from engaging in any commodity interest or digital asset-related activity. 

Additionally, the Commission seeks civil monetary penalties, restitution, 

disgorgement of Defendants’ ill-gotten gains, and ancillary remedial relief, including, 

but not limited to, permanent trading and registration bans, rescission, fees and costs, 

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pre-judgment and post-judgment interest, and such equitable relief as this Court may 

deem necessary or appropriate.

10. Unless permanently 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.

II. JURISDICTION AND VENUE

11. This Court has jurisdiction pursuant to 28 U.S.C. § 1331(codifying 

federal question jurisdiction) and 28 U.S.C. § 1345 (providing 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). In addition, Section 

6c(a) of the Act, 7 U.S.C. § 13a-1, provides that United States district courts possess 

jurisdiction to hear actions brought by the CFTC for injunctive relief or to enforce 

compliance with the Act whenever it shall appear to the CFTC that such person has 

engaged, is engaging, or is about to engage in any act or practice constituting a 

violation of any provision of the Act or any rule, regulation, or order thereunder. 

12. Venue properly lies with this Court pursuant to Section 6c(e) of the Act, 

7 U.S.C. § 13a-1(e), because Defendants reside in this District, transact or transacted 

business in this District, and certain transactions, acts, practices and courses of 

business alleged in this Complaint occurred within this District, among other places.

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III. THE PARTIES

13. 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 CFTC 

maintains its principal office at Three Lafayette Centre, 1155 21st Street NW, 

Washington, D.C. 20581. 

14. Defendant David Carmona is an individual currently believed to be in 

federal custody (see Paragraph 27 below) who maintains a residence in Elmhurst, 

New York. Carmona is also known by the names David Segundo Carmona and 

Wuilver Segundo. Carmona has never been registered with the Commission. 

15. Defendant Juan Arellano Parra is an individual currently believed to 

be in federal custody (see Paragraph 27 below) who maintains a residence in Chino, 

California. Arellano has never been registered with the Commission. 

16. Defendant Moses Valdez is an individual believed to be residing in 

Hesperia, California. Valdez has never been registered with the Commission. 

17. Defendant David Brend is an individual believed to be residing in 

Tampa, Florida. Brend has never been registered with the Commission. 

18. Defendant Marco A. Ruiz Ochoa is an individual believed to be 

residing in Nashua, New Hampshire. Ruiz has never been registered with the 

Commission. 

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IV. FACTS

A. Background.

19. “Icomtech” was created by Carmona, Ruiz and other Icomtech 

“founders.” 

20. Icomtech is not and was not during the Relevant Period registered as a 

business entity in the United States. 

21. Throughout the Relevant Period, Defendants did business and operated 

and marketed Bitcoin and other digital asset commodity trading, among other things, 

to U.S. persons under the name Icomtech.

22. Certain digital assets, including Bitcoin, Ether and USDC, are 

“commodities” in interstate commerce.

23. Carmona, Valdez, Arellano, and Ruiz, among others, were Icomtech’s 

“Main Leaders”, and the website www.icomtech.org identified Valdez and Brend, 

along with their picture, as part of the Icomtech “TEAM”. 

24. Icomtech promotional material posted to the internet in 2019 claimed 

Icomtech was a company “with the mission to create the largest exchange in the 

world” for the purposes of buying and selling cryptocurrency, including Bitcoin. The 

promotional material claimed Icomtech’s goal was to become like other major 

cryptocurrency exchanges, including Coinbase, Binance and Bitmex, and touted 

Carmona as someone who had made a fortune trading cryptocurrency, including 

Bitcoin. 

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25. Other Icomtech promotional materials posted to the internet pitched 

Icomtech as “a technological institution based on Bitcoin,” and/or encouraged 

customers to “be part of this revolution of transactions in Bitcoin” through, at least in 

part, trading Bitcoin through Icomtech. 

26. As described below, throughout the Relevant Period, Carmona, 

Arellano, Valdez, Brend and Ruiz, individually as well as jointly doing business as 

Icomtech, all fraudulently solicited customers and prospective customers, including 

U.S. persons, to give them money for Icomtech to trade Bitcoin and other digital asset

commodities on the customers’ behalves. 

27. On October 13, 2022, Defendants Carmona, Arellano, Valdez, Brend 

and Ruiz were indicted for wire fraud in connection with the Icomtech scheme. 

Indictment, United States v. Carmona, 1:22-cr-00551-JLR (S.D.N.Y Oct. 13, 2022), 

ECF No. 2. 

B. Icomtech Websites.

28. During the Relevant Period, Icomtech had two websites associated with 

its business operations, “icomtech.io” and “icomtech.org.” The websites were 

identified in Icomtech written promotional materials. 

29. Once the customer paid the Icomtech agent who had solicited them cash 

or transferred money by other means, an Icomtech agent created an online account for 

the customer through the Icomtech websites, issued the customer a user ID and 

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temporary password, and emailed the customer a link with a user ID and temporary 

password. 

30. Thereafter, customers could access their account information by logging 

in through the Icomtech websites. Through the websites, customers could, among 

other things, access their account information, including account statements, and 

could check the supposed value of their accounts, including purported earnings from 

Defendants’ supposed trading on their behalves. 

31. Once logged into the “icomtech.io” website, the “my.icomtech.io” 

“Dashboard” page showed the customer his or her purported “Total Earning[s]” and 

provided the customer a link to his or her individual account(s) statement. During the 

Relevant Period, customers routinely accessed and used the account statements to 

track their purported earnings from Defendants’ supposed trading on their behalves.

32. The “icomtech.org” website also allowed customers to log into their 

account and perform multiple account-related functions through either the website or 

a Smartphone app. Under a section titled “Smartphone,” the website stated: 

Imagine the possibility of being able to generate earnings from 

your smartphone wherever you are, whenever you want. Our 

application will allow you to: •Edit your profile •Register new 

members •Review your earnings •Request withdrawal of your 

cryptocurrencies. 

33. Customers generally were told that they could withdraw their funds 

through the website or a Smartphone app beginning six months after deposit or after a 

minimum amount of $150 in earnings had accumulated. 

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C. Defendants’ Misrepresentations and Omissions Regarding Bitcoin 

and Other Digital Asset Commodity Trading.

34. During the Relevant Period, Carmona, Valdez, Arellano, Brend and 

Ruiz, individually as well as jointly doing business as Icomtech, fraudulently 

solicited actual and prospective customers, including U.S. persons, to give them 

money for Icomtech to trade Bitcoin and other digital asset commodities through 

Icomtech on customers’ behalves via one or more of the following: at in-person 

meetings – including in customers’ homes, at Icomtech promotional events, in 

Icomtech PowerPoint and other presentations and documents circulated at Icomtech 

promotional events, via YouTube and other presentations posted to the internet, 

Zoom meetings, and through word-of mouth. 

35. Defendants and other Icomtech agents represented in these in-person 

meetings, at Icomtech promotional events and/or in Icomtech promotional material, 

among other things, that Icomtech would: (1) trade bitcoin and other digital asset

commodities on the customer’s behalf; (2) provide daily returns from the trading of 

between 0.9% to 2.8%; (3) double the customer’s money in approximately four to 

eight months; and (4) customers could use one of Icomtech’s websites to create an 

online account where the customer could watch their money grow. 

36. Defendants and other Icomtech agents predominately directed their 

solicitations to Spanish-speaking individuals and targeted those communities. 

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Icomtech written promotional presentations and pitches were in both Spanish and 

English, although predominately in Spanish. 

i. Icomtech Promotional Events 

37. Icomtech flyers and/or advertisements listed the following dates and 

locations for Icomtech promotional events: January 6, 2019 at a restaurant called 

Luminarias in Monterey Park, California; February 5, 2019 at the DoubleTree Hotel 

in Commerce, California; March, 2019 at Planet Hollywood, Las Vegas; May 6, 2019 

at Luminarias Restaurant, Monterey Park, California; May 15, 2019 at the GrillSmith 

restaurant in Tampa, Florida; July 28, 2019 at the DoubleTree Hotel in Rosemead, 

California; September 17, 2019 at the DoubleTree Hotel, Rosemead California; 

September 18 and 19, 2019 at the Mariscos Puerto Escondido restaurant in Los 

Angles, California; and September 18, 2019 at the Quiet Cannon conference center in 

Montebello, California. 

38. In some instances, hundreds of people attended the Icomtech 

promotional events. 

39. Carmona, Valdez and Arellano, among other Icomtech agents, were 

specifically identified by name and/or pictured in advertisements for certain of these

Icomtech promotional events. For example:

a. Carmona was pictured using the name Wuilver Segundo and identified 

with the title “Co-Fundador Icomtech” (i.e., co-founder Icomtech) in an 

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advertisement for an Icomtech promotional event dated March 16 (no 

year specified) at the DoubleTree Hotel in Commerce, California; 

b. Valdez was pictured and identified by name in an advertisement for an 

Icomtech promotional event dated April 29, 2019 at the DoubleTree 

Hotel in Norwalk, California;

c. Valdez was pictured and identified by name in an advertisement for an 

Icomtech promotional event dated May 6, 2019 at the Luminarias 

restaurant in Monterey Park, California;

d. Carmona was pictured and identified by name with the title “CoFundador” (i.e., co-founder) in an advertisement for an Icomtech 

promotional event dated May 19, 2019 at the DoubleTree Hotel in 

Rosemead, California; 

e. Valdez and Arellano were pictured and identified by name in an 

advertisement for an Icomtech event dated July 28, 2019 at the 

DoubleTree Hotel in Rosemead, California; and

f. Valdez was pictured and identified by name, and Arellano was identified 

by name, in an advertisement for an Icomtech promotional event dated 

November 10, 2019 at the DoubleTree Hotel in Rosemead, California.

40. Upon information and belief, at each of these promotional events, one or 

more of the Defendants made fraudulent misrepresentations to customers and 

prospective customers as described in Paragraph 35 above.

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41. Valdez, Arellano, and Ruiz as well as other Icomtech agents organized 

the conference rooms, hotel rooms, and/or catering or other hotel services for the 

Icomtech promotional events. This included, among other things: (i) Ruiz signing a 

sales contract and service agreement on behalf of Icomtech with Planet Hollywood in 

Las Vegas for a March 2019 Icomtech promotional event; (ii) Valdez ordering and 

paying a deposit for a conference room and other services on behalf of Icomtech at 

the Quiet Cannon Montebello conference center in Montebello, California for a May 

2019 Icomtech promotional event; (iii) Arellano acting as Icomtech’s contact person 

in connection with an August 24, 2019 Icomtech event at the Quiet Cannon 

Montebello conference center in Montebello, California; and (iv) Arellano paying a 

deposit for a conference room at the Quite Cannon Montebello conference center in 

connection with a September 28, 2019 Icomtech event.

ii. Icomtech Solicitations and Promotional Materials

42. Carmona and Ruiz drafted or assisted in drafting Icomtech promotional 

material containing fraudulent misrepresentations that were posted on the Internet 

and/or circulated at Icomtech promotional events.

43. Valdez hosted a WhatsApp group chat titled “Bitlionaires LA.” The 

group chat contained links to Icomtech advertisements, meeting notices, presentations 

and videos. Some of those advertisements, presentations and videos contained 

fraudulent misrepresentations.

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44. A flyer posted in a Bitlionaires LA WhatsApp chat (Valdez was the 

administrator for the chatroom) advertising an Icomtech sponsored event to be held 

on April 2, 2019 at the Double Tree Hotel in Commerce, California, stated: 

Icomtech offers you the opportunity to have your own 

cryptocurrency business. You can generate thousands of dollars 

in digital gold, called Bitcoin, through e-commerce, trading, and 

mining, and thus grow your financial freedom.

45. At least one Icomtech presentation posted to the Bitlionaires LA 

WhatsApp group chat on June 15, 2019 also included the claim “Double by Trading” 

and that the money could be doubled in 140 days approximate. 

46. Another Icomtech advertisement posted to the Bitlionaires LA 

WhatsApp group chat also included the phrase “Double by Trading” and lists “140 

DAYS APPROXIMATE” next to the word “DOUBLE.” 

47. Brend used text messages and chats, and a YouTube video to solicit 

customers. Some of these text messages, chats, and YouTube videos contained 

fraudulent misrepresentations. 

48. Brend claimed in a YouTube video presentation entitled “Icomtech 

English Presentation 2019” that Icomtech used trading “algorithms.” He claimed the 

algorithms allowed Icomtech to “consistently” generate gains trading Bitcoin and 

thus “create a standard revenue for us.” 

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49. Brend also stated in his YouTube presentation entitled “Icomtech 

English Presentation 2019” that customers’ money would “double in roughly between 

six and eight months.” 

50. Carmona and Ruiz also claimed that Icomtech used “sophisticated 

algorithms” to do the trading. For example, during an Icomtech promotional event 

held in or about January 2019 at “Luminarias” restaurant in Monterey Park, 

California, they claimed that:

a. they were in the business of trading cryptocurrency, and had “robots 

doing the trading with sophisticated algorithms...." 

b. a person’s initial investment would be doubled within a six-month 

period; 

c. the customer would be paid a percentage between .9% to 3% of the 

original investment on a daily basis; 

d. the customer’s money could be withdrawn in Bitcoin through a 

bitcoin wallet on a weekly basis once a minimum amount of $150 in 

earnings was accumulated; and 

e. through the multi-level marketing referral program, a customer 

would receive a 20% commission on the investment of anyone 

referred. 

51. Arellano and other Icomtech agents solicited one California customer in 

the summer of 2019. The customer was told during the solicitation, among other 

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things, that it was easy to make money through Icomtech via daily trading and that 

the customer’s money could be doubled in 120 days. From the solicitation, the 

customer understood that Arellano would trade mostly in Bitcoin and other digital 

asset commodities and generate big profits.

52. Icomtech promotional presentations and materials also explained that 

Icomtech offered as many as eight (8) “Packages” that customers could choose to 

purchase for set amounts ranging from an upfront payment of $300 up to $20,000. 

Customers purchased packages predominately through cash payments to one or more 

Defendants or other Icomtech agents. 

53. The www.icomtech.org website contained a chart entitled “Packages” 

with a listing, by a Package number, of graduated “points” and a “global pool bonus” 

for higher dollar investment amounts and various percentage ranges associated with 

profitability. 

54. Brend gave an example of how one “package” worked in his YouTube 

video presentation entitled “Icomtech English Presentation 2019,” and how a 

customer could make even more money by referring friends and family:

You can invest here in a package, you can buy a $2,500 package --

I'll give you example, or a $300 package, and that will double in 

roughly between six and eight months. It depends on the package 

and what algorithm that you're locked into. The company chooses 

that when you sign up. But once you -- let's say you came in and 

you bought a $1,000 package. That'll make $2,000, but then, you 

know, a week later you, you had a little more money you got a tax 

return back. You're like ‘let me put in this $2,500 I got for tax 

return.’ So once, as soon as you do that you make 20 percent 

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from your own money, because that is your first level. And then 

if you decide to sign up your aunt or your mom or family 

member, and you do that, that person that you sign up below that

second package would be your second level and that would give 

you 3 percent, so you get a two-tier system but total you can 

make on your own money up to 23% or by bringing people 

in . . . . 

But all of this is based on trading mainly. We do have some mining 

values that are coming in here, but most of this is involved in the trading 

and you make about 0.9 to 2.8 percent every single day, Monday 

through Friday, and then also on Fridays, you can see that you'll actually 

get an opportunity to withdraw every Friday from between 3:00 to 9:00 

p.m. Pacific Standard Time.” (Emphasis added).

D. Defendants Communicated About Icomtech Operations and Coordinated Their Fraudulent Solicitation Activities.

55. Using instant messaging and voice-over-IP services and messenger 

applications, like WhatsApp Messenger, Defendants communicated amongst

themselves, and with other Icomtech agents, about Icomtech’s operations, customers 

and solicitations during the Relevant Period. For example, the Defendants 

communicated about rates of return, solicitation materials, and how to handle 

customer money. 

56. Defendants doing business as Icomtech coordinated their solicitation 

activities, i.e., they often attended and presented at the same Icomtech solicitation 

events, used the same or similar fraudulent solicitation pitches and materials at those 

events and in customer meetings, and used the same or similar fraudulent solicitation 

materials.

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E. Defendants Did Not Trade Bitcoin or Other Digital Asset

Commodities as They Represented and Did Not Earn Daily Returns nor Double the Money.

57. Notwithstanding the representations set forth in Paragraphs 32-33, 35, 

44-54 above, in actuality, Defendants: (i) did not trade Bitcoin or other digital asset 

commodities on the customers’ behalves as represented; (ii) did not earn daily returns 

of between .09% and 2.8% based upon the trading; and (iii) did not double the 

customers’ money based on trading. 

58. Instead, Defendants used customer funds to further promote the scheme, 

and, on information and belief, to pay for personal expenditures and to pay 

themselves and other Icomtech agents commissions and bonuses. 

59. Each of the Defendants aided and abetted each of the other Defendants’ 

fraudulent acts and practices set forth in Paragraphs 19 to 58 above.

F. Some Icomtech Customers Lost the Full Amount of the Funds They 

Deposited with Defendants for Trading.

60. During the Relevant Period, customers submitted their payments for an 

Icomtech package to an Icomtech agent via cash, wire transfer, check, money transfer 

services, and/or a digital asset commodity, specifically, Bitcoin. Some customers 

were told that they could only pay in cash. 

61. On information and belief, some of the cash payments by customers 

were deposited in bank accounts owned by Defendants, or in bank accounts in the 

name of companies associated with one or more of the Defendants, including True 

Credit Repair LLC, a company owned by the Brend’s wife. 

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62. During the Relevant Period, Carmona, Valdez, Arellano, and Brend 

received customer funds, either directly from customers, from companies associated 

with certain Defendants, or from other Defendants and Icomtech agents.

63. For the purpose of Icomtech trading Bitcoin or other digital asset

commodities on the customers’ behalves:

a. At least two Icomtech agents transferred customer funds to Carmona 

during the Relevant Period via cash, bitcoin transfer, payment 

processing services such as Zelle, and deposits into a bank account 

in Carmona’s name. 

b. At least two Icomtech customers gave funds to Arellano during the 

Relevant Period, including via cash and bitcoin transfer. 

c. At least one customer, and at least one Icomtech agent on behalf of 

numerous customers, transferred customer funds to Valdez during 

the Relevant Period. On information and belief, Valdez transferred 

some of those funds to Carmona.

d. A number of Icomtech customers and, on information and belief, an 

Icomtech agent on behalf of Icomtech customers, gave money to 

Brend, by making payment to him through PayPal, and/or by writing 

checks to his wife’s company, True Credit Repair LLC, a Florida 

limited liability company. Brend was a signatory on the True Credit 

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Repair LLC’s bank account into which some Icomtech customer 

money was deposited. 

64. Customers were generally told that, after six months or after a minimum 

amount of $150 in earnings accumulated, they could withdraw funds from their 

accounts on Fridays. Beginning in the late summer of 2019, some Icomtech 

customers attempted to withdraw their account balances in U.S. dollars and/or digital 

asset commodities in accordance with the instructions but found they were unable to 

do so, with limited exceptions. 

65. A number of customers confronted Carmona and Valdez, as well as 

other Icomtech agents, about their inability to withdraw their funds, and demanded 

the return of their money. 

66. Carmona and Valdez, as well as other Icomtech agents, provided 

purported explanations as to why customers’ money could not be immediately 

withdrawn. One explanation was that Icomtech was in the process of migrating to a 

new online system at a new web address. The transfer to the new website was in or 

about September 2019. Customers were told that the migration was progressing 

slowly and there were technical difficulties in the online transfer, but that the online 

system was being fixed. Nonetheless, customers were assured that their money was 

safe. 

67. Despite the assurances, Defendants misappropriated some, if not all of 

customer funds sent to Icomtech. 

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68. For example, when one customer accessed her account through the new 

on-line system in September 2019, the account did not reflect her investment. In fact, 

all of the earnings previously reflected in her account had disappeared, and her 

account balance was listed as zero. 

69. Each of the Defendants aided and abetted each of the other Defendants’ 

fraudulent acts and practices set forth in Paragraphs 60 to 68 above.

G. Defendants’ Misrepresentations and Omissions Concerning Commissions and Bonuses.

70. Icomtech customers also were told they could earn commissions and 

“bonus points” by recruiting others to invest in Icomtech. One Icomtech presentation 

stated: (i) “YOU EARN 20% for each package you sell” and “YOU EARN 3% for 

each package that your direct affiliate sells”; and (ii) “bonus points” earned for 

recruiting others to invest could be used to obtain prizes, including iPhones, Rolex 

watches, trips (to Las Vegas, Hawaii or Dubai), luxury cars (e.g., a Mercedes Benz), 

or exchange for as much as $20,000 in cash.

71. In furtherance of the Icomtech scheme, including through Icomtech 

solicitation materials posted on YouTube and in the Bitlionaires LA WhatsApp chat, 

Defendants and other Icomtech agents encouraged existing and prospective 

customers, including several California customers, to refer family and friends with 

promises of additional returns. Some of the existing customers accepted deposits 

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from family and friends on behalf of Icomtech and then gave the money to another 

Icomtech agent. 

72. In actuality, one or more Icomtech customers did not receive referral 

commissions and/or bonuses as promised in various verbal and/or written Icomtech 

solicitations.

73. However, on information and belief, some of the Defendants received 

commissions and/or bonuses for bringing new customers into the Icomtech scheme. 

For example, Brend claimed in a solicitation posted to the internet that he received a 

Mercedes Benz as an Icomtech bonus, but elected to exchange it for a $25,000 cash 

payment. 

74. The written promotional materials that Defendants and other Icomtech 

agents provided to customers and prospective customers did not disclose, and/or did 

not fully disclose, that customer money would be used to pay expenses for Icomtech 

and/or commissions and bonuses to Defendants and other Icomtech agents.

75. Each of the Defendants aided and abetted each of the other Defendants’ 

fraudulent acts and practices set forth in Paragraphs 70 to 74 above.

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V. VIOLATIONS OF THE COMMODITY EXCHANGE ACT AND 

COMMISISON REGULATIONS

COUNT ONE

FRAUD BY DECEPTIVE DEVICE OR CONTRIVANCE

Violation of Section 6(c)(1) of the Act, 7 U.S.C. § 9(1), and Regulation 180.1(a)(1)-(3), 17 C.F.R. § 180.1(a)(1)-(3) (2022) 

76. Paragraphs 1 through 75 of this Complaint are re-alleged and 

incorporated herein by reference.

77. 7 U.S.C. § 9(1), provides in relevant part:

It shall be unlawful for any person, directly or indirectly, to use or 

employ, or attempt to use or employ, in connection with any . . . 

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 . . . .

78. 17 C.F.R. § 180.1(a), provides in relevant part:

It shall be unlawful for any person, directly or indirectly, in connection with any swap, or contract of sale of any commodity in 

interstate commerce, or 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 . . . .

79. Digital assets such as Bitcoin are encompassed in the definition of 

“commodity” under Section 1a(9) of the Act, 7 U.S.C. § 1a(9).

80. During the Relevant Period, Defendants, individually and/or in concert 

with each other, intentionally or recklessly used or employed, or attempted to use and 

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employ, manipulative or deceptive devices or contrivances in connection with 

contracts of sale of any commodity in interstate commerce, in violation of 7 U.S.C. 

§ 9(1), and 17 C.F.R. § 180.1(a)(1)-(3), including by:

a. Misappropriating customer funds by using customer funds: (i) further 

promote the scheme; (ii) to pay for Icomtech expenses; and/or (iii) on 

information and belief, to pay themselves and other Icomtech agents 

commissions and bonuses, and/or

b. Misrepresenting in in-person meetings, Icomtech promotional events, in 

Icomtech promotional materials posted to the internet, and in electronic 

communications:

i. That Defendants and other Icomtech agents would use 

customer money to trade Bitcoin or other digital assets on the 

customers’ behalves;

ii. That Icomtech customers could achieve specific daily earnings; 

iii. That Icomtech customers’ money would be doubled in 

approximately four to eight months; and

iv. That existing customers who referred a family member or 

friend to give money to Icomtech for Icomtech to trade Bitcoin 

or other digital assets on behalf of that family member or 

friend would, in turn, receive commissions and/or bonuses for 

the referrals; and/or 

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c. Failing to disclose and/or failing to fully disclose in written 

solicitations and promotional materials that Defendants and other 

Icomtech agents provided to customers and prospective customers 

that customer money would be used to pay expenses for Icomtech 

and/or commissions and bonuses to Defendants and other Icomtech 

agents. 

81. Each act in furtherance of: (1) using or employing, or attempting to use 

or employ, a manipulative device, scheme, or artifice to defraud; (2) making, or 

attempting to make, untrue or misleading statements of material fact, or omitting to 

state material facts necessary to make the statements not untrue or misleading; or 

(3) engaging, or attempting to engage, in any act, practice, or course of business, 

which operated or would operate as a fraud or deceit upon any person, including but 

not limited to those specifically alleged herein, is alleged as a separate and distinct 

violation of Section 6(c)(1) and Regulation 180.1(a)(1)-(3). 

82. During the Relevant Period, each of the Defendants willfully aided and 

abetted each of the other Defendants’ fraudulent acts and practices described above 

and, therefore, are liable for that fraud pursuant to Section 13(a) of the Act, 7 U.S.C. 

§ 13c(a).

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VI. RELIEF REQUESTED

WHEREFORE, the CFTC respectfully requests that this Court, as authorized 

by Section 6c of the Act, 7 U.S.C. § 13a-1, and pursuant to the Court’s inherent 

equitable powers:

A. Find Defendants violated Sections 6(c)(1) of the Act, 7 U.S.C. §§ 9(1) 

and Regulation 180.1(a)(1)-(3), 17 C.F.R. § 180.1(a)(1)-(3) (2022);

B. Enter an order of permanent injunction restraining and enjoining 

Defendants and their affiliates, agents, servants, employees, successors, assigns, 

attorneys, and all persons or entities in active concert with any one of them, who 

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

conduct described above in violation of 7 U.S.C. §§ 9(1) and 17 C.F.R. § 180.1(a)(1)-

(3); 

C. Enter an order of permanent injunction restraining and enjoining 

Defendants, and any of their affiliates, agents, servants, employees, assigns, 

attorneys, and persons in active concert with any one of them, from directly or 

indirectly, in:

1. Trading on or subject to the rules of any registered entity (as that 

term is defined in 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 asset commodities, for accounts held in the name of 

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Defendants or for any account in which they have a direct or 

indirect interest; 

3. Having any commodity interest or digital asset commodity traded 

on Defendants’ 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 asset 

commodities; 

5. Soliciting, receiving or accepting any funds from any person for 

the purpose of purchasing or selling any commodity interests or 

digital asset commodities; 

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) (2022); and

7. Acting as a “principal” (as that term is defined in Regulation 

3.1(a), 17 C.F.R. § 3.1(a) (2022)), 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).

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D. Enter an order requiring Defendants, as well as any third-party transferee 

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

benefits received including, but not limited to, salaries, commissions, bonuses, loans, 

fees, revenues and trading profits derived, directly or indirectly, from acts or practices 

that constitute violations of the Act and Regulations as described herein, including 

pre-judgment and post-judgment interest;

E. Enter an order directing Defendants and any of their, to rescind, pursuant 

to such procedures as the Court may order, all contracts and agreements, whether 

implied or express, entered into between them and any of the customer whose funds 

were received by them as a result of the acts and practices that constitute violations of 

the Act and Regulations, as described herein;

F. Enter an order requiring Defendants and any of their successors, to make 

full restitution to every person or entity who has sustained losses proximately caused 

by the violations described herein, including pre-judgment interest;

G. Enter an order directing Defendants 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. 

No. 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; 

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H. Enter an order requiring Defendants to pay costs and fees as permitted 

by 28 U.S.C. §§ 1920 and 2412(a)(2); and 

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

deem necessary and appropriate under the circumstances.

Dated: May 24, 2023 Respectfully Submitted, 

 COMMODITY FUTURES TRADING

COMMISSION

 Attorney for Plaintiff

 

 By: /s/James H. Holl, III

JAMES H. HOLL, III (CA Bar No. 177885) 

 jholl@cftc.gov

 COMMODITY FUTURES TRADING

COMMISSION

 1155 21st NW

 Washington, DC 20581

(202) 418-5311 / (202) 418-5523 (fax)

 

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