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Court filing — United States v. Thompson (Dkt. 1, D. Mass.)

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            Case 1:23-cr-10325-AK       Document 1       Filed 12/21/23     Page 1 of 8




                              UNITED STATES DISTRICT COURT
                               DISTRICT OF MASSACHUSETTS

                                                     )   Criminal No. 23cr10325
 UNITED STATES OF AMERICA                            )
                                                     )   Violation:
        v.                                           )
                                                     )   Count One:
 MICHAEL THOMPSON,                                   )   Conspiracy to Commit Market Manipulation
   a/k/a “VZZNBuilder1”,                             )   (18 U.S.C. § 371)
                                                     )
                 Defendant                           )   Forfeiture Allegation:
                                                     )   (18 U.S.C. § 981(a)(1)(C) and
                                                     )
                                                         28 U.S.C. § 2461)
                                                     )

                                         INFORMATION

       At all times relevant to this Information:

                                       General Allegations

       1.       Defendant    MICHAEL       THOMPSON         (“THOMPSON”),      also      known   as

“VZZNBuilder1”, lived in Virginia.

       2.       Co-conspirator 1 (“CC 1”) lived in Texas.

       3.       In or about 2023, THOMPSON and CC 1 created VZZN, a cryptocurrency

company. VZZN promoted a cryptocurrency token that operated on the Ethereum blockchain

(the “VZZN Token”). VZZN purported to create a video streaming service that could be used

with the VZZN Token.        The VZZN Token was a security that was not registered on a national

exchange.

                                    Overview of the Conspiracy

       4.       Beginning in or about January 2023 and continuing through at least in or about

December 2023, THOMPSON and CC 1 conspired with others known and unknown to the U.S.
            Case 1:23-cr-10325-AK       Document 1      Filed 12/21/23     Page 2 of 8




Attorney to artificially inflate the price of VZZN Tokens through manipulative trading and false

and misleading statements.

                                Object and Purpose of the Conspiracy

       5.       The object of the conspiracy was to commit market manipulation.     The purpose of

the conspiracy was for the defendant and his coconspirators to enrich themselves.

                                Manner and Means of the Conspiracy

       6.       Among the manner and means by which THOMPSON, CC 1 and others known and

unknown to the U.S. Attorney carried out the conspiracy were the following:

                a.     Soliciting investors to buy VZZN Tokens through the VZZN website and

social media platforms such as Twitter and YouTube;

                b.     Making false and misleading statements about VZZN and VZZN Tokens;

                c.     Engaging in manipulative trading of VZZN Tokens to create the appearance

of legitimate trading volume;

                d.     Inducing others to buy VZZN Tokens based on the false and misleading

statements and the manipulative trading, with the intent to inflate the price of VZZN Tokens

artificially so that THOMPSON, CC 1, and their co-conspirators could sell VZZN Tokens they

controlled at a profit; and

                e.     Coordinating their activities through encrypted messaging applications such

as WhatsApp and Telegram.




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            Case 1:23-cr-10325-AK       Document 1        Filed 12/21/23      Page 3 of 8




                           Overt Acts in Furtherance of the Conspiracy

       7.       Between in or about January 2023 and in or about December 2023, THOMPSON,

CC 1, and others known and unknown to the U.S. Attorney committed and caused to be committed

the following overt acts, among others, in furtherance of the conspiracy:

                a.     Beginning on or about February 8, 2023, THOMPSON and CC 1 advertised

VZZN as a cryptocurrency company on the VZZN website.

                b.     On or about May 4, 2023, THOMPSON sent CC 1 a WhatsApp message

stating, “In crypto I’m learning that yes it’s always about value, but in the meantime until you have

actual value, the optics of value can carry you a long way”.

                c.     On or about July 2, 2023, CC 1 published a promotion for “VZZNTOKEN”

claiming “Announcements INCOMING”.

                d.     On or about July 26, 2023, THOMPSON, using the Twitter account

VZZNBuilder1, published a promotion for an upcoming “Networking Event” for “VZZN”.

                e.     On or about October 13, 2023, THOMPSON and CC 1 solicited

investments for VZZN during a video conference call.

                f.     On or about October 24, 2023, THOMPSON and CC 1 solicited

investments for VZZN during a video conference call.

                g.     On or about November 2, 2023, THOMPSON and CC 1 traveled to

Massachusetts to solicit investments for VZZN.

                h.     On or about November 15, 2023, THOMPSON and CC 1 exchanged

WhatsApp messages in which they discussed their manipulative trades of VZZN Tokens. For

example:


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          Case 1:23-cr-10325-AK       Document 1      Filed 12/21/23        Page 4 of 8




                     i.      CC 1 stated, “Will do few buys now get some hype”.

                    ii.      THOMPSON responded, “Yeeesssiiirrr gooooooooo”.

                   iii.      CC 1 then stated, “Now organic buys coming in” and “Not my first

                             rodeo lol. I may know a thing or two about what I’m doing on

                             occasion. Now you’ll see narrative switch on social media”.

                   iv.       THOMPSON responded, “Maaaaaan you are the CRYPTO

                             MESSIAH for REEEAALLL”.

              i.      On or about November 28, 2023, CC 1 called an individual in

Massachusetts to request help correcting a technical issue with the VZZN Token.

              j.      On or about December 5, 2023, THOMPSON and CC 1 participated in a

Telegram conference call in which they discussed their plan to make manipulative trades of VZZN

Tokens.   For example:

                     i.      CC 1 stated, “I’m going to create a self-inflicted pump and create

                             FOMO [Fear of Missing Out] on my own[….] What that does is

                             create the appearance of a massive buy wall.    And that’s how you

                             generate FOMO.”

                    ii.      In response to a question about whether CC 1 had sufficient

                             manpower to create a self-inflicted pump and “FOMO”, CC 1 stated,

                             “It is a one-person thing. It takes me and my laptop. That’s it[….]

                             I got a hundred different wallets I can create and do all that shit

                             with.”




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                   iii.      In response to a question about whether THOMPSON was part of

                             the self-inflicted pump and creating “FOMO”, THOMPSON stated,

                             “I’m a part of everything. Literally anything that needs to happen

                             to make it happen, that’s where I am.”

              k.      On or about December 8, 2023, THOMPSON travelled to Massachusetts

with the intent to obtain a cash investment for VZZN.

              l.      On or about December 9, 2023, CC 1 traveled to Massachusetts with the

intent to obtain a cash investment for VZZN.




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            Case 1:23-cr-10325-AK       Document 1        Filed 12/21/23      Page 6 of 8




                                          COUNT ONE
                            Conspiracy To Commit Market Manipulation
                                        (18 U.S.C. § 371)
       The U.S. Attorney charges:

       8.       The U.S. Attorney re-alleges and incorporates by reference paragraphs 1 through

7(l) of this Information.

       9.       From at least in or about January 2023 to in or about December 2023, in the District

of Massachusetts and elsewhere, the defendant,

                MICHAEL THOMPSON, a/k/a “VZZNBuilder1”

conspired with CC 1 and others known and unknown to the U.S. Attorney to:

       a.       commit market manipulation, that is, knowingly and willfully, by the use of the

mails and any means and instrumentality of interstate commerce, directly and indirectly to effect

a series of transactions in a security not registered on a national exchange, to wit, the VZZN Token,

creating actual and apparent active trading in such security, and raising and depressing the price

of such security, for the purpose of inducing the purchase and sale of such security by others, in

violation of Title 15, United States Code, Sections 78i(a)(2) and 78ff(a).

       All in violation of Title 18, United States Code, Section 371.




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         Case 1:23-cr-10325-AK          Document 1       Filed 12/21/23      Page 7 of 8




                                  FORFEITURE ALLEGATION
                         (18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c))

       10.     Upon conviction of one of more of the offenses in violation of Title 18, United

States Code, Section 371, relating to conspiracy to commit market manipulation, as set forth in

Count One, the defendant,

               MICHAEL THOMPSON, a/k/a “VZZNBuilder1”

shall forfeit to the United States, pursuant to Title 18, United States Code, Section 981(a)(1)(C),

and Title 28, United States Code, Section 2461(c), any property, real or personal, which constitutes

or is derived from proceeds traceable to the offenses.

       11.     If any of the property described in Paragraph 10, above, as being forfeitable

pursuant to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United States Code,

Section 2461(c), as a result of any act or omission of the defendant –

               a. cannot be located upon the exercise of due diligence;

               b. has been transferred or sold to, or deposited with, a third party;

               c. has been placed beyond the jurisdiction of the Court;

               d. has been substantially diminished in value; or

               e. has been commingled with other property which cannot be divided without
                  difficulty;

It is the intention of the United States, pursuant to Title 28, United States Code, Section 2461(c),

incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any other property

of the defendant up to the value of the property described in Paragraph 10 above.


       All pursuant to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United

States Code, Section 2461(c).


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        Case 1:23-cr-10325-AK   Document 1   Filed 12/21/23      Page 8 of 8




                                          JOSHUA S. LEVY
                                          Acting U.S. Attorney


                                    By:   ________________________________
                                          CHRISTOPHER J. MARKHAM
                                          Assistant U.S. Attorney

December 21, 2023




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