Named Defendants

Alleged role in the enterprise

Promoted the Hackathon to a nationwide audience including Nevada through his @Cobratate account on X and the "Emergency Meeting" broadcast series on the enterprise's Rumble channel; directs the enterprise's Nevada-reaching operations; and, on information and belief, receives proceeds of the scheme, including its Nevada-originated revenue (¶13). Personally declared himself sponsor of the Hackathon's $1M+ prize pool and brokered the introduction of Issa as "Head of hackathon" to a participant's family member by direct message. Publicly endorsed Plaintiff's "Bangchain" submission on X. Caught on camera stating: "SEC, come for me. I'm in Romania… we're scammers… I'm gonna pump a coin up, make 10M, peel it off" — pleaded as a first-person admission of the pump-and-dump methodology. Also named on the registration of neweralearning.net.

Alleged role in the enterprise

Promoted the enterprise's subscription and merchandise platforms to a nationwide audience including Nevada through his @TateTheTalisman account on X and the "Emergency Meeting" broadcast series on the enterprise's Rumble channel, and, on information and belief, receives proceeds of the scheme including its Nevada-originated revenue (¶14). On June 13, 2024 the @TateTheTalisman account introduced the $DADDY cryptocurrency token with an embedded Solana transaction screenshot and ran a "burn or take the cash and run" public poll. Pleaded, with Andrew Tate, as an offshore recipient of the enterprise's U.S.-collected proceeds routed to the UAE via Defied Trust.

Alleged role in the enterprise

Built and maintains the payment infrastructure that charged Nevada residents' payment cards and takes a per-transaction fee on the enterprise's nationwide payments, including those originating from Nevada (¶15). The disclosed distribution partner and domestic subscription payment-processing layer on the jointherealworld.com and university.com privacy policies. Formed February 6, 2023 — thirty-seven days after its parent Thrift Technologies — sharing the same registered agent and Dover, Delaware address.

Alleged role in the enterprise

Together with Joslin, operates cobratate.com — which converts Nevada traffic into paying customers as a sales funnel linked to fundraiser.com — and derives revenue from that traffic (¶16). On information and belief, Thrift Technologies is also among the controllers of the Cloudflare account that operates the DNS and reverse-proxy for jointherealworld.com. Formed December 31, 2022; the coordinated thirty-seven-day formation sequence with Thrifty, shared registered agent, and shared corporate-address infrastructure are pleaded as consistent with a single enterprise design.

Alleged role in the enterprise

Helms Thrift Technologies and Thrifty, which operate the enterprise's payment layer that charged Nevada residents' payment cards; and, together with Thrift Technologies, operates cobratate.com, which converts Nevada traffic into paying customers — a sales funnel linked to fundraiser.com — and derives revenue from that traffic (¶17). On information and belief, Joslin also controls, in part through the address andrew@thrift.tech, the Cloudflare account that operates the DNS and reverse-proxy for jointherealworld.com, the enterprise's flagship subscription platform.

Alleged role in the enterprise

Operates fundraiser.com and the @bigmoneynick accounts on X, Instagram and TikTok; is, on information and belief, the registrant of record of thewarroom.ag and university.com; and controls Matador Learning and Courses Works (¶18). As operator of fundraiser.com he solicited and accepted Hackathon submissions from Nevada, maintains the showcase of those Nevada submissions, and made false prize and funding representations to a nationwide audience including Nevada. On information and belief he earned a commission on the traffic fundraiser.com passed to the merchandise- and subscription-selling domains owned by other Defendants, paid for by Nevada residents. Courses Works, which Thomas helms, advertises the same contract-drafting, company-formation and tax-registration services that Empire Legal Group supplies to the enterprise, and Eason is manager of record of both. Three core domains — fundraiser.com, thewarroom.ag and university.com — are, on information and belief, registered to Thomas through a single common registration account (¶36).

Alleged role in the enterprise

Distributed the enterprise's subscription platforms jointherealworld.com and university.com, sold nationwide including to Nevada consumers, and derives revenue from those sales (¶19). Identified as a "distribution partner" in the platforms' privacy policies alongside New Era and Thrifty. Valton Eason is the officer of record; the entity shares its Wyoming registered agent and common organizer with the "Wudan" entity sued as Roe Corporation 2.

Alleged role in the enterprise

Operates and controls topg.com within the enterprise's Nevada-directed conversion funnel and derives revenue from it (¶20) — the merch and brand storefront selling consumer goods under TOP G promotion. Valton Eason is the officer of record. The entity was incorporated as "TopG.com Inc," renamed "Caputra.com Inc." on May 12, 2026 and renamed again to "Caputra Brands Group Inc" on May 19, 2026 — two rebrands in seven days, bracketing the May 17, 2026 filing of the First Amended Complaint. Its counsel moved to quash the subpoena seeking to identify it; that motion was denied at ECF 102.

Alleged role in the enterprise

Holds the enterprise's United States federally registered wordmarks — COBRATATE (Reg. No. 7568611), THE REAL WORLD (Reg. No. 8238028) and TOP G (Reg. No. 8037966) — the brand names under which the enterprise markets and sells its products, and authorizes their use in the enterprise's Nevada-directed promotion, including on the @Cobratate account, the "The Real World" subscription platforms, and the display of both "THE REAL WORLD" and "TOP G" as "Main Sponsors" on the Hackathon site at fundraiser.com/hackathon (¶21). Defied Trust also operates the enterprise's offshore receive node in the United Arab Emirates, taking in the subscription proceeds the enterprise collects in the United States, including from Nevada.

Alleged role in the enterprise

Operates the enterprise's cryptocurrency layer; associated with the $DADDY pump method and the unauthorized "Bangchain" token. Directed token-promotion and solicitation at a nationwide audience including Nevada and communicated with participants in Nevada in furtherance of the scheme (¶22). On January 30, 2025 contacted Plaintiff's family member on Telegram within minutes of Tate's direct message identifying Issa as "Head of hackathon," opening with "andrew told me to text you," and communicated that locking a share of the Bangchain token supply was a condition of placement and promotion within the fundraiser.com ecosystem. Note: the SAC expressly pleads that the identification of the @issathecooker account holder as Abbasie is made on information and belief; that account holder's true identity is the subject of a court-authorized Rule 45 subpoena to non-party X Corp, which has not produced, and Plaintiff will confirm or amend the identification upon production.

Alleged role in the enterprise

On information and belief the entity behind the enterprise's paid "The Real World" subscription — sold through jointherealworld.com and university.com within the enterprise's Nevada-directed conversion funnel — receives the proceeds of that subscription, and, on information and belief, also manages both of those domains (¶23). Valton Eason is the officer of record. The subscription is sold at $99/month "Conquer" and $499/month "Vanguard," the latter displayed "SOLD OUT" as an alleged false-scarcity device across both portals.

Alleged role in the enterprise

On information and belief the entity behind the enterprise's paid "War Room" membership — sold through thewarroom.ag and reachtwr.com within the enterprise's Nevada-directed conversion funnel — receives the proceeds of that membership, and, on information and belief, also manages both of those domains (¶24). Valton Eason is the officer of record. War Room membership pricing was disclosed at $7,979 USD via bank transfer or cryptocurrency only, captured from the site chat agent; the thewarroom.ag/pay page returned "Payment Successful" for a $1.00 charge after the charge-amount URL parameter was edited.

Alleged role in the enterprise

Serves as the officer, director, or manager of record for University.com TRW Inc., War Room Inc., Caputra Brands, Matador Learning, Courses Works, New Era Comics, and Legendary Courses, Inc. — the enterprise's operating companies whose checkout and subscription systems reach Nevada — and is the manager and registered agent of record of Empire Legal Group LLC (¶25). This shared officer-and-agent structure, concentrated at a common Houston address, is the spine the complaint uses to tie otherwise-separate companies into a single association-in-fact enterprise.

Alleged role in the enterprise

On information and belief the Eason-controlled vehicle for the "Empire Global Partners" consultancy, supplying the enterprise's corporate-formation, tokenomics-support, and offshore banking and tax-structuring functions for its Nevada-reaching consumer platforms, including jointherealworld.com, university.com and fundraiser.com (¶26). Courses Works — helmed by Nicholas Thomas, with Eason as manager of record of both — advertises the same contract-drafting, company-formation and tax-registration services that Empire Legal supplies.

Alleged role in the enterprise

Built and operates the Value.io gateway whose code is served to Nevada consumers and charges their Nevada payment cards (¶27) — the multi-processor card-vault and routing gateway embedded in the enterprise's checkout that routes and transmits the subscription charges.

Alleged role in the enterprise

Directed the design and deployment of the Value.io gateway served to Nevada consumers and charging their payment cards (¶28).

Alleged role in the enterprise

Organizes the enterprise's legal, travel and corporate-structuring functions and, together with Matador Learning, coordinates the enterprise's social media and course content — functions that operate and sustain the scheme reaching Nevada (¶29). Helmed by Nicholas Thomas, with Valton Eason as manager of record. Advertises the same contract-drafting, company-formation and tax-registration services that Empire Legal Group supplies to the enterprise.

Alleged role in the enterprise

Built and maintains the course content sold on the enterprise's subscription platforms that reach Nevada (¶30). Publicly branded "Matador Interactive." Helmed by Nicholas Thomas, with Valton Eason as officer of record; together with Courses Works it coordinates the enterprise's social media and course content.

Alleged role in the enterprise

On information and belief sells merchandise or subscriptions into Nevada and receives proceeds of the scheme. Its role is pleaded in the alternative (¶31): (a) New Era Comics is the entity identified on the jointherealworld.com and university.com privacy policies under the name "New Era Learning LLC," no active United States-registered entity under that name having been identified for the period alleged; or (b) it is a separate Eason-helmed corporation that sells merchandise into Nevada and receives proceeds of the scheme. To the extent alternative (a) is true, the allegations pleaded against New Era (Roe Corporation 1) apply to New Era Comics. Plaintiff does not seek double recovery against both.