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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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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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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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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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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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JOSHUA S. LEVY
Acting U.S. Attorney
By: ________________________________
CHRISTOPHER J. MARKHAM
Assistant U.S. Attorney
December 21, 2023
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