UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF NEW YORK 

COMMODITY FUTURES TRADING 

COMMISSION, 

Plaintiff, 

v. 

DWAYNE GOLDEN, JATIN PATEL, 

MARQUIS DEMARKING EGERTON a/k/a 

MARDY EGER a/k/a MARDY EGERTON, and 

GREGORY AGGESEN, 

Defendants. 

Case No. 22-cv-1252 

ECF Case 

COMPLAINT FOR INJUNCTIVE 

AND OTHER EQUITABLE RELIEF 

AND FOR CIVIL MONETARY 

PENALTIES UNDER THE 

COMMODITY EXCHANGE ACT 

AND COMMISSION REGULATIONS 

JURY TRIAL DEMANDED 

I. INTRODUCTION 

1. Between at least April 2017 and August 2017 (the “Relevant Period”), Defendants 

Dwayne Golden (“Golden”) and Jatin Patel (“Patel”), with the other Defendants and an 

Accomplice, operated manipulative and deceptive schemes in which they used websites to solicit 

investments of millions of dollars’ worth of Bitcoin whereby investors were promised guaranteed 

profits based on trading of Bitcoin, a virtual currency that is a commodity in interstate 

commerce, done by a team of professional traders or by recruiting additional customers into the 

purported investment opportunities. But the purported investment opportunities were in fact 

Ponzi schemes. Instead of trading customer investments, the operators of the schemes 

misappropriated many of the Bitcoin for themselves. 

2. Between at least April 2017 through at least July 2017, Golden and Patel operated 

the website www.empowercoin.com (“Empowercoin”), which became www.ecoinplus.com 

(“Ecoinplus”) in May 2017, with Defendant Marquis Demarking Egerton (“Egerton”) (Golden, 

Patel, and Egerton are collectively referred to as the “Ecoinplus Defendants”). Between at least 

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May 2017 and August 2017, Golden and Patel operated the website www.jet-coin.com 

(“JetCoin”) with Defendant Gregory Aggesen (“Aggesen”) and the Accomplice (Golden, Patel, 

and Aggesen are collectively referred to as the “JetCoin Defendants”; all Defendants are 

collectively referred to as “Defendants”). The schemes operated by the Ecoinplus Defendants 

and the JetCoin Defendants were substantially similar, using websites to make false and 

misleading claims about guaranteed returns on customer Bitcoin investments to solicit—and 

allow the websites’ operators to misappropriate—those Bitcoin. As in all Ponzi schemes, 

Defendants’ payouts of supposed profits to customers in actuality consisted of other customers’ 

misappropriated funds. 

3. The Ecoinplus Defendants fraudulently solicited potential customers by making 

false and misleading claims and omissions of material facts on the Empowercoin and Ecoinplus 

websites that customer Bitcoin would be invested by professional traders and would double in 

50-90 days while accruing daily payments of at least 2% of the customer’s investment. The 

Ecoinplus Defendants also falsely claimed that potential customers could earn up to an additional 

20 Bitcoin per day, for a daily distribution of up to 15-22% of the amount invested by new 

customer recruits, in what the Ecoinplus Defendants referred to as a “binary network.” These 

claims were false and misleading because the Ecoinplus Defendants did not employ traders and, 

in fact, did not trade Bitcoin; and because the guaranteed returns and commission payments were 

entirely fictitious because those amounts could only be paid to the extent that new customer 

investments were available to be redistributed to existing customers. Instead of having 

professional traders invest Bitcoin on their customers’ behalf, the Ecoinplus Defendants 

misappropriated to themselves more than 42% of the invested funds. The Empowercoin and 

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Ecoinplus websites have been offline since at least July 2017, and since that time the Ecoinplus 

Defendants have not returned any of their customers’ investments of Bitcoin. 

4. The JetCoin Defendants fraudulently solicited potential customers by making 

false and misleading claims and omissions of material facts on the JetCoin website that customer 

Bitcoin would be invested by experienced traders and would double in 40-50 days while 

accruing daily payments of up to 5% of the customer’s investment. The JetCoin Defendants also 

falsely claimed that potential customers could make additional earnings of 9-25% daily of the 

amount invested by new customer recruits as part of its “binary commission” schedule. The 

JetCoin Defendants claimed, “Instead of a 97% failure rate, JetCoin has a 100% success rate!” 

These claims were false and misleading because the JetCoin Defendants did not employ traders 

and, in fact, did not trade Bitcoin; and because the guaranteed returns and commission payments 

were entirely fictitious because those amounts could only be paid to the extent that new customer 

investments were available to be redistributed to existing customers. Instead of having traders 

trade Bitcoin on their customers’ behalf, the JetCoin Defendants and the Accomplice 

misappropriated to themselves more than 36% the invested Bitcoin. The JetCoin website has 

been offline since at least August 2017, and since that time the JetCoin Defendants have not have 

not returned any of their customers’ investments of Bitcoin. 

5. The Ecoinplus and JetCoin Defendants solicited and accepted virtual currencies in 

the form of Bitcoin from customers throughout the United States, including the Eastern District 

of New York, and foreign countries through their fraudulent solicitations. The Ecoinplus 

Defendants obtained approximately $23.2 million from investors via their solicitations, of which 

they misappropriated at least $9.865 million to themselves. The JetCoin Defendants obtained 

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approximately $21.7 million from investors via their solicitations, of which they and the 

Accomplice misappropriated at least $7.884 million to themselves. 

6. Through this conduct, Defendants were engaged, are engaging, or are about to 

engage in manipulative and deceptive acts with respect to contracts of sale of a commodity in 

interstate commerce, in violation of Section 6(c)(1) of the Commodity Exchange Act (the “Act”), 

as amended, 7 U.S.C. § 9(1) (2018), and Regulation 180.1(a), 17 C.F.R. § 180.1(a)(1)-(3) (2020). 

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

(2018), the Commission brings this action to enjoin such acts and practices and compel 

compliance with the Act. In addition, the Commission seeks civil monetary penalties and 

remedial ancillary relief, including, but not limited to, trading bans, restitution, disgorgement, 

rescission, pre- and post-judgment interest, and such other relief as the Court may deem 

necessary and appropriate. 

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

engage in the acts and practices alleged in this Complaint and similar acts and practices, as more 

fully described below. 

II. JURISDICTION AND VENUE 

9. Jurisdiction. This Court has jurisdiction of this action pursuant to Section 6c of 

the Act, as amended, 7 U.S.C. § 13a-1 (2018), which authorizes the Commission to seek 

injunctive and other 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 practice constituting a 

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

has jurisdiction pursuant to 28 U.S.C. § 1331 (2018) (federal question jurisdiction) and 28 U.S.C. 

§ 1345 (2018) (United States as plaintiff). 

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10. Venue. Venue properly lies with the Court pursuant to Section 6c(e) of the Act, 7 

U.S.C. § 13a-1(e) (2018), because Defendants are found in, inhabit, or transact business in this 

District, and because acts and practices in violation of the Act occurred, are occurring, or are 

about to occur, within this District. 

III. THE PARTIES 

11. Plaintiff Commodity Futures Trading Commission (“Commission” or 

“CFTC”) is an independent federal regulatory agency that is charged by Congress with the 

administration and enforcement of the Act and the Regulations. The Commission maintains its 

principal office at Three Lafayette Centre, 1155 21st Street, N.W. Washington, D.C. 20581. The 

Commission’s investigation of Defendants was conducted by staff of the Commission’s Division 

of Enforcement located in the Eastern Regional Office in New York, New York. 

12. Defendant Dwayne Golden is a citizen of the United States and during the 

Relevant Period resided primarily in Florida. With Patel and Egerton, Golden operated 

Empowercoin and Ecoinplus. With Patel, Aggesen, and the Accomplice, Golden operated 

JetCoin. Golden has never been registered with the Commission in any capacity. 

13. Defendant Jatin Patel is a citizen of India and during the Relevant Period resided 

primarily in the state of Maharashtra, India. With Golden and Egerton, Patel operated 

Empowercoin and Ecoinplus. With Golden, Aggesen, and the Accomplice, Patel operated 

JetCoin. Patel has never been registered with the Commission in any capacity. 

14. Defendant Marquis Demarking Egerton a/k/a Mardy Egerton a/k/a Mardy Eger 

is a citizen of the United States and during the Relevant Period resided primarily in North 

Carolina. With Golden and Patel, Egerton operated Empowercoin and Ecoinplus. Egerton has 

never been registered with the Commission in any capacity. 

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15. Defendant Gregory Aggesen is a citizen of the United States and during the 

Relevant Period resided primarily in New York. With Golden, Patel, and the Accomplice, 

Aggesen operated JetCoin. Aggesen has never been registered with the Commission in any 

capacity. 

IV. FACTS 

16. A virtual currency is defined here as a digital representation of value that 

functions as a medium of exchange, a unit of account, and/or a store of value, but does not have 

legal tender status in any jurisdiction. Bitcoin and other virtual currencies are distinct from 

“real” currencies, which are the coin and paper money of the United States or another country 

that are designated as legal tender, circulate, and are customarily used and accepted as a medium 

of exchange in the country of issuance. 

The Ecoinplus Scheme 

17. The Ecoinplus Defendants launched the Empowercoin website in or about April 

2017. Golden was primarily responsible for the purported Bitcoin investment concept and 

guaranteed compensation strategy offered by Empowercoin, based on his previous experience 

working with and helping to build multi-level-marketing companies. Egerton registered that 

website through a registration company located in Arizona and assisted Golden in drafting its 

content. For example, on April 24, 2017, Egerton sent to Golden a draft of the content for 

empowercoin.com containing substantially all of the misrepresentations described below, in 

paragraph 18. Patel was primarily responsible for the software and coding necessary to launch 

and maintain the Empowercoin website, which in May 2017 changed to the Ecoinplus website 

(which Patel registered, launched, and maintained). (In May 2017, Empowercoin members were 

informed that an expanded version of the platform, with better and more automated support, 

would be launching as ecoinplus.com. That communication—which was drafted by, among 

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others, Golden, Patel, and Egerton, including via voice messages sent by Egerton to the others on 

May 22, 2017—stated, “Remember empowercoin.com will soon become ecoinplus.com, also 

empowercoinplus.com.” The websites, and the purported investment opportunity offered on the 

websites, were substantially the same, other than the name change.) Egerton, along with Golden 

and Patel, controlled the websites and the purported investment opportunity presented by, and 

were principals of, the Empowercoin/Ecoinplus scheme. Golden, Patel, and Egerton aided and 

abetted each other’s conduct in connection with the Empowercoin/Ecoinplus scheme. 

18. The Ecoinplus Defendants, using the Empowercoin and Ecoinplus websites, and 

enlisting the help of promoters, made false and misleading representations to potential 

customers, including, among others, that: 

 Customers would double their Bitcoin investments in 50 to 90 days, depending on 

which investment package they chose (“E1” through “E8”), with the exception of 

the plan involving the smallest investment (“E1”). Customers were given a 

choice of packages that were guaranteed to double ranging from the “E2 package” 

requiring a 0.1 BTC investment that would double in 90 days, to the “E8 

package” requiring a 10 BTC investment that would double in 50 days.

 Daily Bitcoin payments of at least 2% of the invested amount would be deposited 

into customers’ registered wallets automatically. These guaranteed payouts were 

represented as a way to earn passive income through trading done by 

Empowercoin/Ecoinplus. Empowercoin/Ecoinplus was purportedly made up of 

“a worldwide team of high volume Bitcoin trading professionals” that needed “a 

larger amount of Bitcoin to achieve maximum profitability,” and that the entities 

wanted to divide the investing profits with customers who contributed to the 

entities’ ability to expand. The websites also explained that the purportedly 

profitable trading would exploit an arbitrage opportunity based on differing prices 

for Bitcoin on different exchanges.

 Customers could earn up to an additional 20 BTC, or an additional daily return of 

15-22%, by recruiting new customers in the Empowercoin/Ecoinplus “binary 

network.” Binary compensation plans are commonly used commission structures 

in multi-level marketing, whereby customers are paid commissions based on the 

amounts invested by recruits that they have referred into the program. Customers 

place new recruits on one of two “legs” and typically receive commissions on the 

leg with less volume, encouraging them to bring in more recruits to place on that 

side of the commission structure.

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19. These statements were false and misleading because Empowercoin and Ecoinplus 

were not made up of trading professionals and, in fact, the Ecoinplus Defendants did not trade 

Bitcoin; and because the guaranteed returns and commission payments were entirely fictitious 

(any daily or commission payments made to customers by the Ecoinplus Defendants were the 

product not of trading done by Empowercoin/Ecoinplus but instead Ponzi payments reflecting 

misappropriated Bitcoin from other customers). 

20. The Ecoinplus Defendants made these and other false and misleading statements 

and omissions of material facts intentionally or recklessly. The Ecoinplus Defendants made 

these and other false and misleading statements and omissions of material facts to prospective 

customers directly on the websites that they operated and through promoters in person, by 

telephone, and online. 

21. For example, on May 29, 2017, Golden sent a voice message, saying with respect 

to Empowercoin, that the scheme could not continue operating as it had because he had already 

“shifted a lot of the money into other programs” which meant that they could not continue to pay 

commissions as guaranteed. On the same date, Patel suggested in a voice message that the 

Ecoinplus Defendants only take money for themselves from newly invested Bitcoin as a way to 

keep the scheme going, noting that the Bitcoin in the system was the “lowest so far since we 

started” and that they had each made more than half a million dollars at that point. Also on May 

29, 2017, Patel suggested to Golden that they and Egerton begin “paying” themselves their 

misappropriated shares of customer Bitcoin investments on “profit” rather than on “gross”—that 

is, to take their shares after making Ponzi payments to other customers instead of before doing 

so—in an effort to keep the operation running longer. Patel noted, “We made a lot of money the 

last few days, we can wait to take more money.” On June 1, 2017, Patel said in a voice message, 

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regarding how long Empowercoin and Ecoinplus could continue operating, “as long as members 

keep joining, this company will keep running.” 

22. Via the foregoing false and misleading statements, including those identified in 

paragraph 18, the Ecoinplus Defendants solicited approximately $23.2 million in Bitcoin (valued 

at the time of investment) from customers throughout the United States, including the Eastern 

District of New York, and foreign countries. Those Bitcoin were not traded. Instead, the 

investments were put into a digital wallet, over which Golden and Patel had primary control. 

Golden, Patel, and Egerton typically misappropriated to themselves 12.5% each of daily 

customer investments. For a period of time, at least some customers of Empowercoin/Ecoinplus 

received Bitcoin daily and/or commission payments into their own digital wallets, representing 

not the proceeds of investments supposedly made by the entities, but instead the redistribution of 

Bitcoin solicited and misappropriated by the Ecoinplus Defendants from other customers. For 

example, on or about June 8, 2017, one customer deposited 4 Bitcoin to an Ecoinplus wallet 

address. The next day, those 4 Bitcoin were transferred out of the Ecoinplus wallet address to 

several different wallet addresses, all in smaller, round increments. Many of the of the transfers 

were for 0.16 Bitcoin. Those transfers from the Ecoinplus wallet address represented Ponzi 

payments that were purportedly daily or binary commission payments but were in fact Bitcoin 

deposited by another customer. Without new investments being made, the entities could not 

avoid running out of money to make the promised payments to customers. 

23. In order to provide purported customer service support for the Empowercoin and 

Ecoinplus websites, Egerton hired a firm operated and controlled by Golden. The Ecoinplus 

Defendants employed that firm—consisting of a group of individuals located in, among other 

places, Mexico—to respond on their behalf to certain customer complaints. None of the 

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communications in response to customer complaints corrected the misstatements that the 

Ecoinplus Defendants used to solicit their customers. Customer complaints grew more frequent 

after the Ecoinplus Defendants discontinued making the guaranteed daily investment and 

commission payments to customers. In addition, certain customer complaints and concerns were 

emailed directly to Egerton, who typically forwarded those complaints and concerns to Golden. 

24. The Ecoinplus Defendants took efforts not to be associated with the websites for 

fear of customer backlash. In a voice message to Patel on May 10, 2017, Golden complained 

that his name was associated with Empowercoin’s domain registration and that Empowercoin 

members were saying that he owned the company; he told Patel that the website was “supposed 

to be registered outside the country”; and he urged Patel to “undo” the registration, saying he 

hoped it was an accident that his name was associated with the registration. In a message to 

Egerton on May 16, 2017, an employee of Golden’s firm noted that she would be setting up “an 

anonymous Gmail” to handle customer emails through a virtual private network so that “it’ll be 

untraceable to us.” In a voice message to Golden on May 25, 2017, the same employee noted 

that the team responding to customer emails had been instructed not to communicate any 

information about the ownership of Ecoinplus and that all the individuals operating the company 

needed to maintain their anonymity. In a voice message on June 13, 2017, Golden encouraged 

Patel to make sure to “keep your distance” from being associated with Empowercoin/Ecoinplus. 

25. In a voice message to Golden on May 16, 2017, Egerton said that certain 

“leaders”—people responsible for bringing in large numbers of new customers—were not 

receiving the daily and commission payments promised to them. He urged that Golden and Patel 

fix the issue by paying those individuals what they were owed “so they can keep building,” i.e., 

bringing in new customer investments. 

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26. The Ecoinplus Defendants shut down the Ecoinplus website in or about July 2017 

and stopped responding to customer complaint inquiries. After that point, customers had no 

access to the accounts purportedly holding their investments, and no refunds were provided to 

customers. 

27. Of the Bitcoin received through the Empowercoin and Ecoinplus websites, 

approximately $9.865 million worth of Bitcoin was misappropriated by the Ecoinplus 

Defendants. Golden misappropriated approximately $1.279 million worth of Bitcoin. Patel 

misappropriated approximately $7.235 million worth of Bitcoin. Egerton misappropriated 

approximately $1.217 million worth of Bitcoin. 

The JetCoin Scheme 

28. The JetCoin Defendants, along with the Accomplice, launched the website 

JetCoin in or about May 2017. Golden was primarily responsible for the idea behind the JetCoin 

website. Patel was primarily responsible for the software and coding necessary to launch and 

maintain the website. The Accomplice registered the JetCoin website through a registration 

company located in Arizona, to an address in Arkansas. The Accomplice modeled the content of 

JetCoin on the Empowercoin website as well as another website offering a similar purported 

Bitcoin investment opportunity. For example, the Accomplice emailed a summary of the claims 

made on the Empowercoin website to Aggesen on May 28, 2017. (Golden and Patel, however, 

took efforts to keep Egerton unaware of their involvement in JetCoin and, vice versa, to keep 

Aggesen and the Accomplice unaware of their involvement in Empowercoin/Ecoinplus. Golden 

said in a voice message to Patel on May 24, 2017 that he did not want to create an “imbalance” 

between the two entities because “we’re making good money from both” and referred to the two 

entities as “rival enemies” in a voice message to Patel on May 26, 2017.) Aggesen advertised 

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the website to experienced multi-level marketing promoters, who in turn could recruit new 

customers into the program. Aggesen and the Accomplice, along with Golden and Patel, 

controlled the website and the purported investment opportunity presented by, and were 

principals of, the JetCoin scheme. Golden, Patel, and Aggesen, and aided and abetted each 

other’s conduct, and the conduct of the Accomplice, in connection with the JetCoin scheme. 

29. The JetCoin Defendants and the Accomplice, using the JetCoin website, and 

enlisting the help of promoters, made false and misleading representations to potential 

customers, including, among others, that: 

 “JetCoin has a 100% success rate!” 

 Customers would double their Bitcoin investments in 40 to 50 days, reflecting 

passive income, depending on which investment package they chose (“JC1” 

through “JC8”) and with the exception of the plan involving the smallest 

investment (“JC1”). 

 Customers would receive a daily payment of 4-5%, depending on which 

investment package they chose and with the exception of the plan involving the 

smallest investment (“JC1”). These guaranteed payouts were represented as a 

way to earn passive income through trading done by JetCoin. JetCoin purportedly 

used “the most robust system on the market,” had “the top trading team in the 

industry” and “the sharpest minds in the industry.” JetCoin solicited customers to 

“allow our professional traders do [sic] the work for you” by “tak[ing] advantage 

of the markets” and exploiting “the gap” or “the spread” in the price of Bitcoin. 

 Customers would qualify for “binary commissions” by making sales, or soliciting 

new customers to JetCoin, ranging from 9% for “JC1” to 25% for “JC8.” As with 

Empowercoin/Ecoinplus, those commissions were to be paid based on the volume 

of the customer’s recruit investments, depending on where the recruit was placed 

in the customer’s binary commission structure. 

30. These statements were false and misleading because the JetCoin Defendants and 

the Accomplice did not employ or otherwise use the services of any traders and, in fact, did not 

trade Bitcoin; and because the guaranteed returns and commission payments were entirely 

fictitious (any daily or commission payments made to customers by the JetCoin Defendants and 

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the Accomplice were the product not of trading done by JetCoin but instead Ponzi payments 

reflecting misappropriated Bitcoin from other customers). 

31. The JetCoin Defendants and the Accomplice made these and other false and 

misleading statements and omissions of material facts intentionally or recklessly. The JetCoin 

Defendants and the Accomplice made these and other false and misleading statements and 

omissions of material facts to prospective customers directly on the websites that they operated 

and through promoters who operated in person, by telephone, and online. 

32. For example, in a message on June 1, 2017, Golden said that he loved JetCoin but 

knew it had “a termination date,” that it would not work long term, and that it was built for 

“quick money.” In a voice message on June 30, 2017, Aggesen told the Accomplice that the 

biggest mistake in operating JetCoin was that they did not “stick with the story” that “there was 

trading going on.” He noted that both men knew the purported trading “wouldn’t support any 

system anyway over a long period of time” and compared it to a different, earlier scheme that he 

called a “Ponzi.” In a voice message to Aggesen on July 1, 2017, the Accomplice said, with 

respect to “people who want to sit by and earn money without doing anything,” that “no one 

believes in that crap,” meaning that the passive guaranteed payouts should have been obviously 

fictitious to potential customers. Likewise, in another voice message, Aggesen said to the 

Accomplice, “This whole thing about coming in and putting your money into something and 

making money for nothing, that’s such a joke. I didn’t have time to think about the whole 

concept here, the thing went so quick, with or without trading.” In a message on July 2, 2017, 

the Accomplice told Aggesen that JetCoin required new customer investments in order “to stay 

alive,” and that if the site did not receive 250 Bitcoin each day, it would collapse or require the 

operators to pay out of their own pockets. 

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33. Via the foregoing false and misleading statements, including those identified in 

paragraph 29, the JetCoin Defendants and the Accomplice solicited approximately $21.7 million 

in Bitcoin (valued at the time of investment) from customers throughout the United States, 

including the Eastern District of New York, and foreign countries. Those Bitcoin were not 

traded. Instead, the investments were put into a digital wallet, over which Golden and Patel had 

control. Golden and Patel typically misappropriated to themselves 25% of daily customer 

investments off the top, as compensation from Aggesen and the Accomplice for the software and 

support necessary to operate the JetCoin website. For a period of time, customers of JetCoin 

received payments into their own digital wallets, representing not the proceeds of investments 

supposedly made by JetCoin, but instead the redistribution of other purported investments 

solicited and misappropriated by the JetCoin Defendants. Aggesen and the Accomplice typically 

misappropriated to themselves the Bitcoin remaining after Golden and Patel took their cut and 

made daily Ponzi payments. Without new investments being made, the JetCoin could not avoid 

running out of money to make payments to customers. 

34. In order to provide purported customer service support for the JetCoin website, 

the JetCoin Defendants and the Accomplice engaged the same firm operated and controlled by 

Golden used by the Ecoinplus Defendants. The JetCoin Defendants and the Accomplice 

employed that firm—consisting of a group of individuals located in, among other places, 

Mexico— to respond on their behalf to customer complaints. 

35. Beginning in or about June 2017, the JetCoin Defendants and the Accomplice 

established a purported help desk for JetCoin customers, using two Gmail email addresses (the 

“JetCoin Emails”), one of which was also Patel’s personal email address. In June, July, and 

August 2017, JetCoin customers made hundreds of complaints to the JetCoin Defendants, 

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including certain customer emails that accused the JetCoin Defendants of running a Ponzi 

scheme. Responses to those complaints were sent from the JetCoin Emails. None of the 

communications in response to customer complaints corrected the misstatements that the JetCoin 

Defendants and the Accomplice used to solicit their customers. Instead, as described below, the 

emails promised fixes and changes that were never made, in an attempt to convince customers 

that JetCoin was not a Ponzi scheme. During this time period, Aggesen and the Accomplice 

exchanged dozens of voice messages discussing how best to communicate to customers and 

what, if any, changes could be made to salvage the JetCoin program, but they required Patel’s 

programming knowledge to make any fixes to the website. 

36. In early June 2017, the JetCoin website began experiencing issues. Specifically, 

customers noticed discrepancies in their accounts, including the fact that the daily investment 

payments and the commission payments that they had been promised had stopped. In response 

to dozens if not hundreds of such inquiries, the JetCoin Emails responded to inform customers 

that the entity was working to resolve certain IT issues and that the payments would be restarted 

in the very near future. Certain of the customer complaints were forwarded to the JetCoin 

Emails through Aggesen. For example, on June 3, 2017, one JetCoin promoter (“Promoter-1”) 

emailed Aggesen a complaint about a technical issue he received from a customer. Aggesen then 

forwarded the complaint to one of the JetCoin Emails. Another customer sent a complaint about 

a technical issue directly to Aggesen on June 5, 2017, and Aggesen again forwarded the 

complaint to one of the JetCoin Emails. In a voice message to Golden on June 13, 2017, Patel 

predicted that the next day or the day after would be the last day JetCoin would be able to make 

the guaranteed daily and commission payments to customers. 

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37. On June 16, 2017, Promoter-1 compiled three lists, each containing the usernames 

of dozens of JetCoin customers who were not receiving the guaranteed payments or were 

experiencing other issues with the website. Promoter-1 emailed those lists to both Aggesen and 

one of the JetCoin Emails. Separately, on the same day, the JetCoin Emails sent dozens of 

communications in response to customer complaints and concerns, stating, “We are aware of the 

percentage issue [i.e., regarding the timing of payments] in the Dashboard. We are working on 

them and it will all be resolved by Monday.” 

38. The promised payments were not restarted. Instead, the JetCoin Defendants and 

the Accomplice announced through the JetCoin Emails that they had made a series of purported 

changes to the payment structure that were supposedly designed to make the investment 

opportunity better able to survive for the long-term. 

39. In or about June 2017, the guaranteed daily payment was reduced from 4-5% to 

3.3%. Then, on or about June 23, 2017, the JetCoin Emails began to announce to customers that 

the daily guaranteed payments would be dropping again, from 3.3% to 1.1%, but that customers 

could qualify for the higher 3.3% return by recruiting 20 Bitcoin’ worth of new personal sales 

volume from new customers. The announcements assured customers that they would continue to 

earn daily payments of 1.1% as passive income, i.e., without the need to recruit any new or 

additional customers. Further, “binary” commission earnings were lowered to 5-18%. Those 

emails did not disclose to customers that the previous, higher guaranteed payments were 

fictitious and were the product not of trading done by JetCoin but instead Ponzi payments 

reflecting misappropriated Bitcoin from other customers. 

40. Even after this announcement, the JetCoin Defendants and the Accomplice did 

not resume making the promised payments. Many customers began to request that their initial 

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investments of Bitcoin be refunded to them, with or without the profits that they had been 

guaranteed. Via the JetCoin Emails, the JetCoin Defendants and the Accomplice consistently 

communicated to existing customers that no refunds would be issued. 

41. By approximately the end of June 2017, the JetCoin website was taken off line. 

In early July 2017, the JetCoin Defendants and the Accomplice informed customers via emails 

from the JetCoin Emails that “JetCoin 2.0” would be launching shortly thereafter. Among other 

changes, JetCoin 2.0 would pay “binary commissions” only on new investment volume brought 

in by customers after the launch of JetCoin 2.0. Accordingly, in order for customers to receive 

any “binary commissions,” they would need to recruit new investors into JetCoin. In response, a 

number of customer complaints accused JetCoin of being a Ponzi scheme. Emails to customers 

from the JetCoin Emails, however, continued to falsely claim that the reduced guaranteed 

payments would be resuming imminently. For example, on June 24, 2017, a customer asked 

when payments would resume, and one of the JetCoin Emails responded, “Payouts will begin on 

Sunday,” i.e., the next day. The customer responded two days later to complain that he still had 

not received any guaranteed payments. The JetCoin Email responded that “our programming 

team is still working on the updates to our system,” and promised, “We haven’t just disappeared 

like those before us.” In a voice message to the Accomplice on June 30, 2017, Aggesen 

proposed certain steps they could take to give customers “hope that their money wasn’t stolen 

and they weren’t scammed,” including making the smaller 1.1% payments. In a voice message 

to Aggesen the same day, the Accomplice said he thought paying the 1.1% was “throwing that 

money away.” In another message to Aggesen on July 2, 2017, the Accomplice discussed the 

fact that 90 Bitcoin were still “sitting there” in the JetCoin wallet and said that giving any of 

those funds back to customers would be “stupid” because it would not be sufficient to keep the 

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JetCoin scheme operational. The same day, in a message to Patel, the Accomplice said that 

JetCoin would need to take in 250 Bitcoin a day, without taking funds from the “pockets” of the 

JetCoin Defendants, “just to be able to stay alive.” 

42. The JetCoin Defendants and the Accomplice took efforts not to be associated with 

the websites for fear of customer backlash. For example, after a voice message on June 30, 

2017, in which Aggesen complained about “getting beat up” by JetCoin customers, the 

Accomplice proposed on July 1, 2017 that he and Aggesen tell customers that they were 

introduced to JetCoin by Patel and that they did not know who the owners were. Meanwhile, on 

June 30, 2017, Promoter-1 emailed to one of the JetCoin Emails and to Aggesen a request that he 

be removed “from the system effective immediately” and that any JetCoin records associated 

with him be deleted. 

43. The JetCoin Defendants and the Accomplice permanently shut down the JetCoin 

website in or about August 2017 and stopped responding to customer complaint inquiries. After 

that point, customers had no access to the accounts purportedly holding their investments, and no 

refunds were provided to customers. 

44. In late August 2017, the JetCoin Defendants and the Accomplice (using the 

JetCoin Emails) announced to customers that a purportedly new company (“My Digital BTC”) 

with purportedly new management would be taking over the JetCoin operations. My Digital 

BTC promised daily returns and commission payments similar to those promised by JetCoin. By 

mid-September, My Digital BTC had shut down as well. Although the JetCoin Defendants and 

the Accomplice promised, in emails sent from the JetCoin Emails, that customer Bitcoin would 

be returned (less any daily or commission payments already paid) on August 29, 2017, those 

refunds did not take place. 

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45. On or about June 5, 2018, Aggesen received a subpoena from the Federal Trade 

Commission (“FTC”) in connection with an investigation concerning at least one promoter of 

JetCoin. Golden advised Aggesen to delete his files related to JetCoin. To that end, Golden 

introduced Aggesen to a man that Golden represented would be able to clean Aggesen’s 

computer before Aggesen submitted the computer to the FTC. Aggesen spoke frequently with 

the Accomplice to solicit the Accomplice’s advice on how to respond to the subpoena. The 

Accomplice consistently advised Aggesen to delete any documents related to JetCoin, including 

communications that took place via Skype and WhatsApp, and provided Aggesen with 

instructions on how to do so, at one point explaining that Aggesen should search “jet” in his 

emails and delete all the results. The Accomplice also told Aggesen on several occasions that, in 

his view, Aggesen should either light his computer on fire or throw it in a lake. In the end, 

Aggesen worked with the man referred by Golden, deleted the contents of his computer, and 

submitted the cleaned computer to the FTC on or about June 27, 2018. 

46. Of the Bitcoin received through the JetCoin website, at least approximately 

$7.884 million worth of Bitcoin was misappropriated by the JetCoin Defendants and the 

Accomplice. Golden misappropriated approximately $1.128 million. Patel misappropriated 

approximately $4.896 million worth of Bitcoin. Aggesen misappropriated approximately $1.351 

million worth of Bitcoin. The Accomplice misappropriated approximately $509,000 worth of 

Bitcoin. 

V. VIOLATIONS OF THE COMMODITY EXCHANGE ACT AND REGULATIONS 

Count I—Use of a Manipulative or Deceptive Device or Contrivance 

Violations of Section 6(c)(1) of the Act and 

Regulation 180.1(a) by the Ecoinplus Defendants 

47. Paragraphs 1 through 46 are re-alleged and incorporated herein by reference. 

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48. 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 . . . contract of sale of any 

commodity in interstate commerce . . . any manipulative or deceptive device or contrivance, in 

contravention of such rules and regulations as the Commission shall promulgate.” 

49. 17 C.F.R. § 180.1(a) makes it “unlawful for any person, directly or indirectly, in 

connection with any . . . contract of sale of any commodity in interstate commerce . . . 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.” 

50. Bitcoin is a “commodity” under Section 1a(9) of the Act, 7 U.S.C. § 1a(9) (2018), 

and contracts for its sale are subject to the prohibitions of Section 6(c)(1) of the Act and 

Regulation 180.1(a). 

51. From at least April 2017 through July 2017, as described above, the Ecoinplus 

Defendants violated Section 6(c)(1) of the Act and Regulation 180.1(a) by, among other things, 

in connection with contracts of sale of commodities in interstate commerce, 

a. making or attempting to make untrue or misleading statements of material fact or 

omitting to state or attempting to omit material facts necessary in order to make 

statements made not untrue or misleading, such as representing on the 

Empowercoin and Ecoinplus websites that customer Bitcoin would be invested, 

that those investments would be made by professional traders, that customer 

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Bitcoin would double within 50-90 days, and that customers would receive 

guaranteed daily and commission payments, and sending emails to customers that 

did not correct or disclose those misstatements; and 

b. misappropriating customer Bitcoin that the Ecoinplus Defendants represented 

would be used to, and that customers deposited for the purpose of, trading that 

would exploit arbitrage opportunities based on differing prices for Bitcoin on 

different exchanges, whereas those Bitcoin were used for the benefit of others 

than the depositing customers and without the authorization of, or disclosure to, 

such customers, including by making Ponzi payments to other customers. 

52. By the foregoing conduct, the Ecoinplus Defendants directly or indirectly used or 

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

manipulative device, scheme, or artifice to defraud customers of Empowercoin and Ecoinplus, 

and the Ecoinplus Defendants engaged in such conduct intentionally or recklessly. 

53. By the foregoing conduct, the Ecoinplus Defendants, directly or indirectly used or 

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

omitted to state material facts necessary in order to make their statements to customers of 

Empowercoin and Ecoinplus not untrue or misleading, and the Ecoinplus Defendants engaged in 

such conduct intentionally or recklessly. 

54. By the foregoing conduct, the Ecoinplus 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 on customers of Empowercoin and Ecoinplus, and the 

Ecoinplus Defendants engaged in such conduct intentionally or recklessly. 

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55. Section 13(a) of the Act provides that “[a]ny person who commits, or who 

willfully aids, abets, counsels, commands, induces, or procures the commission of, a violation of 

any of the provisions of this [Act or Regulations] or who acts in combination or concert with any 

other person in any such violation, or who willfully causes an act to be done or omitted which if 

directly performed or omitted by him or another would be a violation of the provisions of this 

chapter or any of such rules, regulations, or orders may be held responsible for such violation as 

a principal.” 7 U.S.C. § 13c(a). 

56. Pursuant to Section 13(a) of the Act, each of the Ecoinplus Defendants is liable 

for the others’ violations, and the Accomplice’s violations, of 7 U.S.C. § 1 and 17 C.F.R. 

180.1(a). 

57. Each and every overt action in furtherance of the use or attempted use of a 

manipulative or deceptive device or contrivance is alleged herein as a separate and distinct 

violation of 7 U.S.C. § 9(1) and 17 C.F.R. § 180.1(a). 

Count II—Use of a Manipulative or Deceptive Device or Contrivance 

Violations of Section 6(c)(1) of the Act and 

Regulation 180.1(a) by the JetCoin Defendants 

58. Paragraphs 1 through 57 are re-alleged and incorporated herein by reference. 

59. From at least May 2017 through August 2017, as described above, the JetCoin 

Defendants violated Section 6(c)(1) of the Act and Regulation 180.1(a) by, among other things, 

in connection with contracts of sale of commodities in interstate commerce, 

a. making or attempting to make untrue or misleading statements of material fact or 

omitting to state or attempting to omit material facts necessary in order to make 

statements made not untrue or misleading, such as representing on the JetCoin 

website that customer investments of Bitcoin were guaranteed to succeed, that the 

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Bitcoin would be invested and would double in 40-50 days, that the Bitcoin would 

be invested by professional traders, and that customers would receive guaranteed 

daily and commission payments, and sending emails to customers that did not 

correct or disclose those misstatements; and 

b. misappropriating customer Bitcoin that the JetCoin Defendants represented would 

be used to, and that customers deposited for the purpose of, trading that would 

exploit market opportunities related to Bitcoin prices and the spread in the price 

of Bitcoin, whereas those Bitcoin were used for the benefit of others than the 

depositing customers and without the authorization of, or disclosure to, such 

customers, including by making Ponzi payments to other customers. 

60. By the foregoing conduct, the JetCoin Defendants directly or indirectly used or 

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

manipulative device, scheme, or artifice to defraud customers of JetCoin, and the JetCoin 

Defendants engaged in such conduct intentionally or recklessly. 

61. By the foregoing conduct, the JetCoin Defendants, directly or indirectly used or 

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

omitted to state material facts necessary in order to make their statements to customers of 

JetCoin not untrue or misleading, and the JetCoin Defendants engaged in such conduct 

intentionally or recklessly. 

62. By the foregoing conduct, the JetCoin 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 

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would operate as a fraud or deceit on customers of JetCoin, and the JetCoin Defendants engaged 

in such conduct intentionally or recklessly. 

63. Section 13(a) of the Act provides that “[a]ny person who commits, or who 

willfully aids, abets, counsels, commands, induces, or procures the commission of, a violation of 

any of the provisions of this [Act or Regulations] or who acts in combination or concert with any 

other person in any such violation, or who willfully causes an act to be done or omitted which if 

directly performed or omitted by him or another would be a violation of the provisions of this 

chapter or any of such rules, regulations, or orders may be held responsible for such violation as 

a principal.” 7 U.S.C. § 13c(a). 

64. Pursuant to Section 13(a) of the Act, each of the JetCoin Defendants is liable for 

the others’ violations of 7 U.S.C. § 1 and 17 C.F.R. 180.1(a). 

65. Each and every overt action in furtherance of the use or attempted use of a 

manipulative or deceptive device or contrivance is alleged herein as a separate and distinct 

violation of 7 U.S.C. § 9(1) and 17 C.F.R. § 180.1(a). 

VI. RELIEF REQUESTED 

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

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

a. An order finding that Defendants violated Section 6(c)(1) of the Act, 7 U.S.C. § 

9(1), and Regulation 180.1(a), 17 C.F.R. § 180.1(a) (2021); 

b. An order of permanent injunction enjoining each Defendant and any other person 

or entity associated with them, including but not limited to affiliates, agents, 

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

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

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from engaging in the conduct described above in conduct in violation of Section 

6(c)(1) of the Act, or Regulation 180.1(a); 

c. An order of permanent injunction restraining and enjoining each Defendant and 

their affiliates, agents, employees, successors, assigns, attorneys, and all persons 

in active concert with them, from directly or indirectly: 

i. 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));

ii. Entering into any transactions involving “commodity interests” (as that 

term is defined in Regulation 1.3, 17 C.F.R. § 1.3 (2021)), for their own 

personal account(s) or for any account in which Defendants have a direct 

or indirect interest; 

iii. Having any commodity interests traded on Defendants’ behalf; 

iv. 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; 

v. Soliciting, receiving, or accepting any funds from any person for the 

purpose of purchasing or selling any commodity interests; 

vi. Applying for registration or claiming exemption from registration with the 

Commission in any capacity, and engaging in any activity requiring such 

registration or exemption from registration with the Commission, except 

as provided for in Regulation 4.14(a)(9), 17 C.F.R. § 4.14(a)(9) (2021); 

and/or 

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

17 C.F.R. § 3.1(a) (2021)), agent, or any other officer or employee of any 

person (as that term is defined in 7 U.S.C. § 1a(38), registered, exempted 

from registration, or required to be registered with the Commission except 

as provided for in 17 C.F.R. § 4.14(a)(9)); 

d. An order requiring Defendants to pay civil monetary penalties, plus postjudgment interest thereon, in an amount not to exceed the penalty prescribed by 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, see 17 C.F.R. § 143.8 (2021), for each 

violation of the Act and Regulations described herein; 

e. An order directing Defendants, as well as any successors thereof, to disgorge, 

pursuant to such procedure as the Court may order, all benefits received 

including, but not limited to, trading profits, revenues, salaries, commissions, 

fees, or loans derived directly or indirectly from acts or practices which constitute 

violations of the Act and Regulations, as described herein, and pre- and postjudgment interest thereon from the date of such violations; 

f. An order directing Defendants, as well as any successors thereof, to make full 

restitution, pursuant to such procedure as the Court may order, to every customer 

and investor whose funds any Defendant received, or caused another person or 

entity to receive, as a result of the acts and practices constituting violations of the 

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

thereon from the date of such violations; 

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g. An order directing Defendants, as well as any successors thereof, to rescind, 

pursuant to such procedure as the Court may order, all contracts and agreements, 

whether express or implied, entered into between, with, or among Defendants and 

any customer or investor whose funds were received by Defendants as a result of 

the acts and practices which constituted violations of the Act and the Regulations, 

as described herein; 

h. An order directing that Defendants, and any successors thereof, make an 

accounting to the Court of all of their assets and liabilities, together with all funds 

they received from and paid to investors and other persons in connection with 

commodity transactions and all disbursements for any purpose whatsoever of 

funds received from commodity transactions, including salaries, commissions, 

interest, fees, loans, and other disbursement of money or property of any kind 

from at least January 2014 to the date of such accounting; 

i. An order requiring Defendants and any successors thereof to pay costs and fees as 

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

j. An order providing such other and further relief as the Court deems proper. 

* * * 

Dated: March 8, 2022 

COMMODITY FUTURES TRADING 

COMMISSION 

Manal M. Sultan 

Deputy Director 

Commodity Futures Trading Commission 

Division of Enforcement 

By: /s/ Devin Cain 

Devin Cain 

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Elizabeth C. Brennan 

Meredith Borner 

David Acevedo 

Commodity Futures Trading Commission 

Division of Enforcement 

140 Broadway, 19th Floor 

New York, NY 10005 

Phone: (646) 746-9887 

Fax: (646) 746-9939 

dcain@cftc.gov 

ebrennan@cftc.gov 

mborner@cftc.gov 

dacevedo@cftc.gov 

ATTORNEYS FOR PLAINTIFF 

COMMODITY FUTURES TRADING 

COMMISSION 

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