Complaint and Request for Injunction — Kengne v. ID.me, Inc.

Record facts

U.S. District Court for the Northern District of Georgia · No. 1:22-cv-02237-SEG · Doc. 6 · 2022-06-06 · Docket on CourtListener

Full text

Pro Se 2 (Rev. 12/16) Complaint and Request for Injunction 
RECEIVED IN CLERK'S OFFICE 
U.S.O.C •• Atlanta 
NITED STATES DISTRICT COURT 
JUN O 6 2022 
for the 
Northern District of Georgia 
Atlanta Division 
D put Clerk 
RAISSA DJUISSI KENGNE 
570 PIEDMONT AVE NE #55166 
ATLANTA, GA 30308 
Plaintiff(s) 
(Write the full name of each plaintiff who is filing this complaint. 
If the names of all the plaintifft cannot fit in the space above, 
please write "see attached" in the space and attach an additional 
page with the full list of names.) 
-v-
ID.ME, INC. 
COGENCY GLOBAL INC. 
250 Browns Hill Ct, 
Midlothian, VA, 23114 - 9510, USA 
Defendant(s) 
(Write the full name of each defendant who is being sued. If the 
names of all the defendants cannot fit in the space above, please 
write "see attached" in the space and attach an additional page 
with the full list of names.) 
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Case No. 
[3 
1 : 2 2-CV- 2 2 3 7 
(to be filled in by the Clerk's Office) 
COMPLAINT AND REQUEST FOR INJUNCTION 
I. 
The Parties to This Complaint 
A. 
The Plaintiff(s) 
Provide the information below for each plaintiff named in the complaint. Attach additional pages if 
needed. 
Name 
Street Address 
City and County 
State and Zip Code 
Telephone Number 
E-mail Address 
B. 
The Defendant(s) 
RAISSA DJUISSI KENGNE 
570 PIEDMONT AVE NE #55166 
ATLANTA, FULTON COUNTY 
GA30308 
404-932-1651 
CIANESEYA2022@GMAIL.COM 
Provide the information below for each defendant named in the complaint, whether the defendant is an 
individual, a government agency, an organization, or a corporation. For an individual defendant, 
include the person's job or title (if known). Attach additional pages if needed. 
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Pro Se 2 (Rev. 12/16) Complaint and Request for lnj1mction 
Defendant No. 1 
Name 
Job or Title (if known) 
Street Address 
City and County 
State and Zip Code 
Telephone Number 
E-mail Address (if known) 
Defendant No. 2 
Name 
Job or Title (if known) 
Street Address 
City and County 
State and Zip Code 
Telephone Number 
E-mail Address (if known) 
Defendant No. 3 
Name 
Job or Title (if known) 
Street Address 
City and County 
State and Zip Code 
Telephone Number 
E-mail Address (if known) 
Defendant No. 4 
Name 
Job or Title (if/mown) 
Street Address 
City and County 
State and Zip Code 
Telephone Number 
E-mail Address (if known) 
ID.ME, INC. (Registered Agent: COGENCY GLOBAL INC.) 
250 Browns Hill Ct. 
Midlothian, CHESTERFIELD COUNTY 
VA, 23114 - 9510 
Not Applicable 
Not Applicable 
Not Applicable , 
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Pro Se 2 (Rev. 12/16) Complaint and Request for Injunction 
II. 
Basis for Jurisdiction 
Federal courts are courts of limited jurisdiction (limited power). Generally, only two types of cases can be 
heard in federal court: cases involving a federal question and cases involving diversity of citizenship of the 
parties. Under 28 U.S.C. § 1331, a case arising under the United States Constitution or federal laws or treaties 
is a federal question case. Under 28 U.S.C. § 1332, a case in which a citizen of one State sues a citizen of 
another State or nation and the amount at stake is more than $75,000 is a diversity of citizenship case. In a 
diversity of citizenship case, no defendant may be a citizen of the same State as any plaintiff. 
What is the basis for federal court jurisdiction? (check all that apply) 
~Federal question 
~ 
Diversity of citizenship 
Fill out the paragraphs in this section that apply to this case. 
A. 
If the Basis for Jurisdiction Is a Federal Question 
List the specific federal statutes, federal treaties, and/or provisions of the United States Constitution that 
are at issue in this case. 
42 U.S.C. § 1104 Unemployment Trust Fund 
26 U.S.C. 3301 et seq. Federal Unemployment Tax Act 
O.C.G.A. § 34-8--45 Supplemental unemployment benefits 
B.· 
If the Basis for Jurisdiction Is Diversity of Citizenship 
1. 
The Plaintiff(s) 
a. 
b. 
If the plaintiff is an individual 
The plaintiff, (name) RAISSA DJUISSI KENGNE 
State of (name) GEORGIA 
If the plaintiff is a corporation 
, is a citizen of the 
The plaintiff, (name) Not Applicable 
, is incorporated 
------------------
under the laws of the State of (name) 
Not Applicable 
-------------------
and has its principal place of business in the State of (name) 
Not Applicable 
(ff more than one plaintiff is named in the complaint, attach an additional page providing the 
same information for each additional plaintiff.) 
2. 
The Defendant(s) 
a. 
If the defendant is an individual 
The defendant, (name) Not Applicable 
, is a citizen of 
-----------------
the State of (name) Not Applicable 
Or is a citizen of 
(foreign nation) Not Applicable 
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Pro Se 2 (Rev. 12/16) Complaint and Request for Injunction 
b. 
If the defendant is a corporation 
The defendant, (name) ID.ME, INC. 
, is incorporated under 
--~------------
the laws of the State of (name) 
VIRGINIA 
, and has its 
-"--'-'-'-'='"--'---'-"-'-------------
principal place of business in the State of (name) 
GEORGIA 
--=---==-=--~:__:c:_:____ ________ _ 
Or is incorporated under the laws of (foreign nation) 
.c..N.:..:o:...::t.c..A.:rP:..cP:..:.:lic:.c=a=-bl=--=e _______ _ 
and has its principal place of business in (name) 
Not Applicable 
-----'---'------------
(If more than one defendant is named in the complaint, attach an additional page providing the 
same information for each additional defendant.) 
3. 
The Amount in Controversy 
The amount in controversy-the amount the plafotiff claims the defendant owes or the amount at 
stake-is more than $75,000, not counting interest and costs of court, because (e.xplain): 
The amount in the controversy cannot be easily estimated. Defendant refuses to provide access 
to Plaintiff's account on ID.Me's website in order for Plaintiff to receive unemployment benefits 
causing Plaintiff to live without income. In addition, Plaintiff is experiencing foreclosure, which 
can be avoided by ID.ME providing access to Plaintiff's account. Plaintiff is unable to use her 
unemployment benefits to pay her mortgage. 
III. 
Statement of Claim 
Write a short and plain statement of the claim. Do not make legal arguments. State as briefly as possible the 
facts showing that each plaintiff is entitled to the injunction or other relief sought. State how each defendant 
was involved and what each defendant did that caused the plaintiff harm or violated the plaintiffs rights, 
including the dates and places of that involvement or conduct. If more than one claim is asserted, number each 
claim and write a short and plain statement of each claim in a separate paragraph. Attach additional pages if 
needed. 
A. 
Where did the events giving rise to your claim(s) occur? 
The events giving rise to Plaintiff's claim occurred in Atlanta, GA - Fulton County. 
B. 
What date and approximate time did the events giving rise to your claim(s) occur? 
Plaintiff signed up for an ID.me account on 04/22/2022 at Georgia DOL to receive unemployment 
benefits. Plaintiff was unable to create an ID.Me account and contacted ID.Me customer support on May 
16th, 2022. Plaintiff received an email from ID.Me stating that "A Member Support Representative will be 
reaching out as soon as possible with assistance. For your records, your ticket number is 10770653." 
Plaintiff received additional emails from Shamora (Member Support Associate) on May 17th, 2022 and 
nothing since then despite several emails from Plaintiff. Plaintiff received an email from John (Member 
Support Associate) on May 27th, 2022 and shortly thereafter, had a video conference call with John to 
validate Plaintiff's identity. Plaintiff is still not able to access her account on ID.Me in order to receive 
TTl11fflll"Un~ . 
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Pro Se 2 (Rev. 12/16) Complaint and Request for Injunction 
C. 
What are the facts underlying your claim(s)? (For example: What happened to you? Who did what? 
Was anyone else involved? Who else saw what happened?) 
Plaintiff signed up for an ID.me account on 04/22/2022 at Georgia DOL to receive unemployment 
benefits. 
Plaintiff was unable to create an ID.Me account and contacted ID.Me customer support on May 16th, 
2022. Plaintiff received an email from ID.Me stating that "A Member Support Representative will be 
reaching out as soon as possible with assistance. For your records, your ticket number is 10770653." 
Plaintiff received additional emails from Shamora (Member Support Associate) on May 17th, 2022 and 
nothing since then despite several emails from Plaintiff. 
Plaintiff received an email from John (Member Support Associate) on May 27th, 2022 and shortly 
thereafter, had a video conference call with John to validate Plaintiff's identity. 
Plaintiff is still not able to access her account on ID.Me in order to receive unemployment benefits. 
IV. 
Irreparable Injury 
Explain why monetary damages at a later time would not adequately compensate you for the injuries you 
sustained, are sustaining, or will sustain as a result of the events described above, or why such compensation 
could not be measured. 
Preventing Plaintiff's access to unemployment benefits will cause "irreparable harm" because Plaintiff will not be 
able to pay for housing or food. In addition, Plaintiff left BOO USA, her former employment, because of retaliation 
after notifying her supervisor, the SEC, and the PCAOB of unethical behaviors that are in violation of SEC 
regulations and PCAOB standards exhibited by Wesley Freeman, Scott Meier, Peter Poppo, Paul Davidson, 
Mark Davenport, and Johnson Wong at the following public companies and their affiliates: Interface, Atlanticus, 
BioHorizons (Henry Schein's subsidiary), Otelco, BlueLinx, NMS SPAR (subsidiary of SPAR). Since Plaintiff filed 
a complaint with the SEC and the PCAOB, her home has been broken into. Her phones and computers have 
been hacked. (Case No. 2022CV365268) Also, Plaintiff has been unable to access the limited amount of money 
she had invested on the Gemini platform. Furthermore, the economy has not yet fully recovered and Plaintiff is 
dealing with a complex set of issues such as non-existent income due to being blacklisted in the industry and 
ongoing concerns about the pandemic. 
A loss of housing or medical care and the inability to provide food, shelter and adequate childcare for a family constitute 
irreparable harm pending resolution of this cause of action and are not adequately compensable by an award of damages. 
V. 
Relief 
State briefly and precisely what damages or other relief the plaintiff asks the court to order. Do not make legal 
arguments. Include any basis for claiming that the wrongs alleged are continuing at the present time. Include 
the amounts of any actual damages claimed for the acts alleged and the basis for these amounts. Include any 
punitive or exemplary damages claimed, the amounts, and the reasons you claim you are entitled to actual or 
_ punitive money: dama_ges. 
WHEREFORE, Plaintiff respectfully requests this Court that Defendant be cited to appear and answer herein; 
that, on final hearing, the Court enters judgment against Defendant in Plaintiff's favor and grants relief to Plaintiff 
against the Defendant as follows: 
1. Declare that the Defendant violated the law as set forth above; 
2. Order Defendant, ID.Me, Inc, to give Plaintiff access to her account in order for Plaintiff to claim her 
unemployment benefits as stipulated under 2 U.S.C. § 1104 Unemployment Trust Fund, 26 U.S.C. 3301 et seq. 
Federal Unemployment Tax Act, and O.C.G.A. § 34-8-45 Supplemental unemployment benefits; 
3. Award the Plaintiff reasonable attorneys' fees and costs and/or pro se fees and costs for her investigation and 
prosecution of this action; and 
4. Grant any such additional relief to Plaintiff in law or equity as the Court deems just and proper under the 
circumstances. 
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Pro Se 2 (Rev. 12/16) Complaint and Request for Injunction 
VI. 
Certification and Closing 
Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best ofmy knowledge, information, 
and belief that this complaint: (1) is not being presented for an improper purpose, such as to harass, cause 
unnecessary delay, or needlessly increase the cost of litigation; (2) is supported by existing law or by a 
nonfrivolous argument for extending, modifying, or reversing existing law; (3) the factual contentions have 
evidentiary support or, if specifically so identified, will likely have evidentiary support after a reasonable 
opportunity for further investigation or discovery; and (4) the complaint otherwise complies with the 
requirements of Rule 11. 
A. 
For Parties Without an Attorney 
I agree to provide the Clerk's Office with any changes to my address where case-related papers may be 
served. I understand that my failure to keep a current address on file with the Clerk's Office may result 
in the dismissal of my case. 
Date of signing: 
Signature of Plaintiff 
Printed Name of Plaintiff 
B. 
For Attorneys 
Date of signing: 
Signature of Attorney 
Printed Name of Attorney 
Bar Number 
Name of Law Finn 
Street Address 
State and Zip Code 
Telephone Number 
E-mail Address 
06/03/2022 
RAISSA DJUISSI KENGNE 
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