Dorick
2 일 전
I allege that Dennis M. Danzik, Inductance Energy Corporation, Quantum Energy Inc, and FlooidCX Corporation have violated the Exchange Act and the Securities Act in that they have made use of deceptive and fraudulent contrivances, devices, schemes, and artifices, have made untrue statements, have omitted to reveal crucial material facts, and have engaged in practices which operated as a fraud, in connection with the sale of securities. The violations occurred in the course of their fraudulent efforts to deceive investors by blatantly misrepresenting the capabilities of a device which they have called the “Earth Engine,” or “Photon Engine.” While employing deceptive contrivances to cause investors to believe their false claims that the so-called “Photon Engine” is powered by “magnetic propulsion,” and could therefore make the electric grid unnecessary, they withheld from investors the crucial material fact that the so-called “Photon Engine” is actually powered entirely by electricity and not at all by magnets.
CLAIMS FOR RELIEF
1. Violations of Section 10(b) of the Exchange Act and Rule 10b-5 Thereunder by Dennis Danzik, Inductance Energy, Quantum Energy, And FlooidCX
Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] states:
“It shall be unlawful for any person, directly or indirectly, by the use of any means or instrumentality of interstate commerce or of the mails, or of any facility of any national securities exchange,
To use or employ, in connection with the purchase or sale of any security registered on a national securities exchange or any security not so registered, or any securities-based swap agreement, any manipulative or deceptive device or contrivance in contravention of such rules and regulations as the Commission may prescribe as necessary or appropriate in the public interest or for the protection of investors.”
Rule 10b-5 thereunder [17 C.F.R. §§ 240.10b-5] states:
“It shall be unlawful for any person, directly or indirectly, by the use of any means or instrumentality of interstate commerce, or of the mails or of any facility of any national securities exchange,
(a) To employ any device, scheme, or artifice to defraud,
(b) To make any untrue statement of a material fact or to omit to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading, or
(c) To engage in any act, practice, or course of business which operates or would operate as a fraud or deceit upon any person, in connection with the purchase or sale of any security.”
I now re-allege and incorporate by reference the paragraphs within the section entitled “FACTUAL ALLEGATIONS.”
By engaging in the conduct described above, Danzik, Inductance Energy, Quantum Energy and FlooidCX, directly or indirectly, in connection with the purchase or sale of securities, by the use of means or instrumentalities of interstate commerce, or of the mails, or of a facility of a national securities exchange, with scienter:
(a) Employed devices, schemes, and artifices to defraud;
(b) Made untrue statements of material facts or omitted to state material facts necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading; and
(c) Engaged in acts, practices, or courses of business which operated or would operate as a fraud or deceit upon other persons, including purchasers and sellers of securities.
By reason of the foregoing, Danzik, Inductance Energy, Quantum Energy, and FlooidCX violated, and unless restrained and enjoined will continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. §§ 240.10b-5].
2. Violations of Sections 17(a)(1), (2), and (3) of the Securities Act By Dennis Danzik, Inductance Energy, Quantum Energy, And FlooidCX
Section 17(a) of the Securities Act [15 U.S.C. §§ 77q(a)] states:
“It shall be unlawful for any person in the offer or sale of any securities (including security-based swaps) or any security-based swap agreement (as defined in section 78c (a) (78) of this title) by the use of any means or instruments of transportation or communication in interstate commerce or by use of the mails, directly or indirectly,
(1) to employ any device, scheme, or artifice to defraud, or
(2) to obtain money or property by means of any untrue statement of a material fact or any omission to state a material fact necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading; or
(3) to engage in any transaction, practice, or course of business which operates or would operate as a fraud or deceit upon the purchaser.”
I now re-allege and incorporate by reference the paragraphs within the section entitled “FACTUAL ALLEGATIONS.”
By engaging in the conduct described above, Danzik, Inductance Energy, Quantum Energy, and FlooidCX, directly or indirectly, in the offer or sale of securities, by use of the means or instruments of transportation or communication in interstate commerce or by use of the mails,
(1) with scienter, employed devices, schemes, or artifices to defraud;
(2) obtained money or property by means of untrue statements of material fact or by omitting to state a material fact necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading; and
(3) engaged in transactions, practices, or courses of business which operated or would operate as a fraud or deceit upon purchasers.
By reason of the foregoing, Dennis Danzik, Inductance Energy, Quantum Energy, and FlooidCX violated, and unless restrained and enjoined will continue to violate, Section 17(a) of the Securities Act [15 U.S.C. §§ 77q(a)].
Curious Bystander
4 일 전
Red engine, blue engine, yellow engine, green engine, purple engine, black engine, white engine, brown engine, burnt sienna engine, fuschia engine, yellowish-green engine, greenish-yellow engine, yellowish-green on top with greenish-yellow down below engine, purple engine with white polka dots, white engine with purple polka dots, rainbow-colored engine with gold LGBTQ+ lettering, edible engine with a flaky sugar-coated crust and rich apple pie filling…..