REPORT: Uncontested Crypto.com Fraud; $TKO and $ROLR Exposed

Eight counts of documented fraud exposed in Case No. 25CU054346C threaten to dismantle $CRO with ripple effects on $TKO and $ROLR

The Seven Documented Counts

This is not a collection of inferences or contested allegations. The public docket in San Diego Superior Court (Jeremy Ryan v Foris Dax Inc, Case No. 25CU054346C) contains a catalogued record of eight specific misrepresentations made by Foris DAX's defense counsel and corporate declarants — including sworn statements in the Brandon Neff, Monika Klus, and Jennifer Zhong declarations, all high level employees of Foris Dax as well as sworn statements by its counsel.

At a hearing on April 17, 2026, defense counsel Charles Gulley was given repeated opportunities to rebut seven of the documented counts. He offered no rebuttal — not to a single one. That non-response is itself now part of the court record. The eighth documented count was filed on April 25, 2026 so unable to be addressed at that hearing.

The underlying facts require no interpretation: the California Secretary of State website, the Internet Archive (Wayback Machine), and the court docket itself provide independent, objective verification of the suspension record, timeline of concealment, and the falsehood of the declarations.

Under California Revenue and Taxation Code § 19719(a), transacting business or exercising corporate powers on behalf of a suspended corporation is a criminal misdemeanor punishable by fines and up to one year of imprisonment. This exposure applies to the corporation's officers and to attorneys who filed motions or appeared in court on its behalf during the suspension window. Whether the San Diego County District Attorneys office presses charges or not has yet to be seen.

The House Arrest Evidence Problem — and Why It's Bulletproof

Jeremy Ryan — federal defendant, blockchain developer, and known in crypto markets as "NFT Demon" — is currently confined to house arrest in San Diego as a condition of federal pretrial release in a case many believe to be government retaliation for his whistleblowing particularly as it relates to Epstein associates. He is restricted to a single monitored smartphone under 24/7 DOJ electronic surveillance.

That restriction is precisely what makes the evidentiary record unassailable.

Every search query, every document discovery, every timestamp in this investigation was automatically logged by federal monitoring software in real time. The government did not receive a tip. It did not subpoena records. It was the involuntary, contemporaneous witness to the discovery of the fraud as it happened — creating an objective, third-party-verified chain of custody for every finding in the record.

This is not a characterization from a filing. This is the operational reality of how house arrest with device monitoring works: the logs exist, they are held by the DOJ, and they cannot be altered or disputed by either party.

Prior Track Record

Ryan's ability to identify concealed systemic rot before institutional players has a documented history:

He identified and publicly exposed a $334 million crypto fraud months before the industry's largest firms acknowledged the collapse

He identified one of Jeffrey Epstein's closest associates from a single House Oversight Committee file — weeks before over 1,800 additional corroborating documents confirmed the connection — while the entire media apparatus missed it

The capacity being applied to Foris DAX is the same one that produced those prior disclosures.

The SEC Disclosure Clock: Monday Open

The regulatory urgency is real and time-bound. Two NYSE-listed companies have received actual notice — with verified read receipts — of the uncontested fraud record no later than Tuesday, April 21:

TKO Group Holdings (NYSE: $TKO) — executive board notified.

High Roller Technologies (NYSE: $ROLR) — including Brandon Eachus, reported 10% owner and several board members.

Under SEC Rule 10b-5, a material omission that renders existing disclosures misleading is a violation of securities law. The 4-business-day 8-K disclosure window is not discretionary. Directors and officers who had actual notice of a material partner-level regulatory risk and did not disclose it face personal liability and forfeiture of SEC Safe Harbor protections.

Both companies were contacted for comment on Friday, April 24. Neither responded before publication.

The binary choice before Monday's open is unambiguous:

File a distancing 8-K before the market opens, disclosing the material risk and separating from a partner with an uncontested fraud record

Remain silent — and face personal director liability once the record is formally certified at the next scheduled court hearing on Tuesday or shortly thereafter.

Regulatory Review Already Underway

The court record has reached two federal gatekeepers simultaneously:

OCC — Adam Cohen, Chief Counsel: Evaluating the "character and fitness" standard for Foris DAX's National Trust Bank Charter, which received conditional approval in February 2026. Seven uncontested fraud counts and a 420-day corporate suspension are direct disqualifying inputs under that standard

U.S. House — Shine Lee: Reviewing potential "Operational Integrity" disqualification under the PACE Act, introduced Tuesday, April 22, 2026 — which establishes new fitness thresholds for digital asset entities seeking federal licensing.

The Frauds Themselves

As stated Ryan has alleged eight different frauds, seven of which were known to the ROLR 0.00%↑ and TKO 0.00%↑ boards on Tuesday April 21st according to read receipts sent to me by Ryan. But couldn't they just be errors or oversights rather than deliberate fraud? When taken individually that makes sense but when taken as a whole and you understand how they benefited the defense and in fact were the only way to maintain a defense, the pattern becomes clear. Certainly something the OCC or any reasonable person won't find as coincidental. With the cooperation of Mr. Ryan we have compiled the seven instances below with supporting documentation. All of this can be found on the San Diego County Courts ROA which is their public court records system. You can search by case number or just search by name (Jeremy Ryan) under Civil cases in the drop down.

Alleged fraud #1: Neff Declaration

In order to try to move this case out of the public eye and into private arbitration the defense used a declaration from Brandon Neff who states he is the Compliance Manager for North America for crypto.com. His public profiles say hes the Consumer protection manager so that may even be a lie. But to prove Ryan accepted arbitration he stated that the only way to sign up for a crypto.com account when Ryan signed up in 2020 was through the phone app. He then detailed how the terms of service were accepted in that phone app.

So he hinged the entire enforceability of the arbitration (in a motion filed while they were suspended) on declaring only one way to sign up and detailing how Ryan would have had to have legally accepted the terms to do so. The only problem. As Ryan countered in another motion (on the court docket as ROA 20) with screenshots, there was also a web sign up at the time. His proof? The Wayback Machine. A month and a half before he signed up the Wayback Machine showed that there was a web sign up disproving entirely the grounds which make the arbitration enforceable.

Fraud #2 and #8: The Klus Declaration

Fast forward 11 days (more on that later) and Mr. Ryan has filed for default. Given as a corporation that is tax suspended cannot defend itself in court their time to file a response to Ryan's complaint had ended. Ryan filed for ex parte (emergency) relief to get the judge to order the clerk to enter default. This was the first time that Foris Dax doing business as crypto.com had even acknowledged the tax suspension. On November 24th, the same day as the hearing they filed a declaration from Monika Klus, Senior Tax Manager of North America. In this declaration, again to support a motion to stay, the only way to avoid a default judgment she stated:

and;

Judge Blaine Bowman ruled at that November 24th hearing that default was not appropriate for ex parte relief and that he would never even consider ruling on the merits of it using that mechanism. He pushed the ruling to the next scheduled hearing, April 17, 2026. This is important to note because Judge Bowman never ruled that default was inappropriate just not appropriate to hear via emergency relief. Crypto.com was revived by the state of California on 01/28/2026. But Ryan claims that even by November 24th it was fraudulent to imply diligence when your records state that you had already known about a tax suspension for 9 months and failed to cure. In California you can expedite a tax suspension revival in as little as two days. Even standard processing takes weeks not months.

But it gets worse. While suspended an unknown third party named John Ralstad took their corporate name on 10/27/2025. So the claim of diligence becomes even more shaky when combined with the fact they didn't even take 30 seconds to make sure they still owned their own name. Because of this the revivor was denied on 01/05/2026 (more on that later). Attached is an email from a supervisor from the Secretary of State office confirming the name was taken then changed prior to revival.

But wait that email is from April. How do we know this relates back to January. We also have the certified name change amendment and a certified certificate of good standing proving their name is now Foris Dax US Inc. But how do we know this was because of Ralstad. A few things. Taking a stroll to the Secretary of State Website Business Search and searching Foris Dax you will find evidence.

But while we are there let's roll in fraud #8. But starting with fraud #2. In California a person can reserve any available corporate name for 60 days. John Ralstad did that here on 10/27/2025 well before the claimed diligence. And then at the end of the 60 days, on Christmas, he incorporated it as a corporation stripping crypto.com of the ability to legally operate under it in California. The articles of organization for that are here (again you can find this all from the Secretary of State Website). Of note he incorporated the business with only 420 shares all owned by himself. In a statement of information Ralstad stated that the type of business was toy trolls. This is likely a clever way to “troll” the company particularly when combined with the 420 shares.

The secretary of state website still shows the original corporation as Foris Dax Inc as well as Ralstads but as Dragana stated only Ralstad owns that name. If you search by the original ones entity number 4566988 (like a social security number), the only name that pops up is Foris Dax US Inc which their history shows they changed to on 01/15/2026, 10 days after their tax revivor was denied because they didn't own their name.

So the diligence lie fails in both the 9 months and the name issue. It also makes them unfit for a bank charter if they can't complete a 2 day process in 9 months or keep their own name. But that brings us to fraud #8. The timing. Before the California FTB tax suspends a business they send multiple notices. But they weren't suspended on February 27th as Klus stated. They were suspended on December 2, 2024. As the history button shows you (also showing the revivor denial on 01/05/26 and name change on 01/15/2026.

So that means that they would have started receiving tax notices in October for 2024 at the latest. Which proves either Klus was lying that they only found out in February of 2025 or that they are so incompetent they missed all of the notices and missed the fact they were suspended (aka legally dead) for months. Neither looks good for a bank charter or even an internal governance in general. But compounding on this is the almost near certainty that they stated they were in good standing in every state during the multi month OCC bank charter application and review process when that was objectively false during most of the review and their own declarations prove they had knowledge of such.

But back to John Ralstad the man who hijacked Foris Dax Inc corporate name. On request for comment Ryan didn't provide an identity or elaborate on familiarity with him he simply stated “he seems to respect my work in early Anonymous movements” referring to the hacktivist collective. Ryan also gave us an email address for Ralstad and the format suggests it is a legacy address likely registered in the early 2000s despite no record of it online. But Ralstad didn't stop at just the name. In the days leading up to the April 17th hearing he created a series of podcasts using AI and published them to Spotify, Amazon Music, and iheartradio among others. These podcasts not only break down the case but also call for action particularly to “anons” including a blueprint for wave 1 of mass regulatory reporting. In a conversation with Ralstad he stated that he has an “army of anons ready to pounce” once the fraud record is certified. He stated the podcasts are for general public the real organizing happens in private groups across Signal, WhatsApp, Telegram, and Discord. Ralstad specifically asked to note that all plans are legally protected activities but in past actions have been highly effective especially when participation is at scale.

Fraud #3: Mahoney Misrepresentations

This one relates to lead counsel Matthew Mahoney name partner in law firm WITHAM MAHONEY & ABBOTT, LLP, surprisingly a well regarded boutique corporate law firm in San Diego. In a reply brief filed in April he stated several things:

He states numerous times that Ryan had not challenged arbitration or stay but the ROA shows probably at least a dozen filings that disprove that. But perhaps the most glaring falsehood is where Mahoney says that Ryan had not entered the Wayback Machine screenshots into evidence. This is a direct lie. Rather than flood you with over a dozen files I'll just attach ROA 20 in the San Diego court docket which proves both the contesting of the validity of arbitration as well as includes a screenshot of the Wayback Machine evidence. Remember counsel has a legal duty of candor to the court and even if not a sworn declaration they are legally required to verify things they state as fact. It is almost as bad as swearing under oath in the court system. Speaking of attorneys swearing falsehoods under oath in the court system.

Fraud #4: The Gulley Declaration

This alleged fraud involves a declaration from junior counsel Charles Gulley. In this declaration Gulley states under oath and penalty of perjurythat he personally reviewed the Secretary of State website (and even attaches screenshots from it) and that Foris Dax US Inc is not related to his client Foris Dax Inc and is in fact inactive. As you will remember the Secretary of State office supervisor refuted this.

Fraud #5: The Zhong Declaration

A few days later another tax manager for North America for Foris Dax filed a declaration. She stated that the information that Charles Gulley swore to was false. That Foris Dax US Inc was their new name in California. But even in such a short declaration she still couldn't keep from what Ryan describes as another instance of alleged fraud. She stated that the name change was strictly in the ordinary course of business. She failed to mention that 10 days prior their revivor request was denied due to not owning their name and logically that would be the reason which does not count as ordinary business.

Fraud #6: The 11 Day Gap

Ryan states that the sixth fraud is a material omission. As a matter of public record the complaint was served on crypto.com on October 13, 2025. They filed their motion to compel, while suspended and legally unable to defend in court on November 12, 2025. Ryan filed for default on November 13, 2025, the first day the clock had expired. Foris Dax and Ryan then exchanged various motions on November 13th. Not a single one of Foris Dax’s motions, however, acknowledged the tax suspension. The first motion to mention the tax suspension was on November 24th after Ryan filed an ex parte (emergency) motion to enter default. Ryan alleges, and numerous case law supports, that this concealment of suspension is, in itself sanctionable fraud. He even points to Palm Valley Homeowners Assn., Inc. v. Design MTC in which attorneys were sanctioned for this exact same concealment.

Fraud #7: The Navarro Declarations

We mentioned that there were a number of back and forth motions filed on November 12th and November 13th. On Foris Dax side those motions were served via email. This was strategic because by the 12th, any other form of service wouldn't have been served in time. In all of Foris Dax filings during this time, paralegal for their counsel Johnny Navarro, swore under oath that there was a court order or an agreement from Ryan for electronic service. By California law service on a party representing themselves needs one of those two things to be valid. The only problem is there was no court order or consent. Meaning the declaration was false on its face. In the reply brief from lead Counsel Matt Mahoney linked earlier he concedes this was false but asks the court to consider service accepted anyway.

What he fails to mention is why the law even exists to require written consent to electronic service if it can just be voided so long as its read.

Defense Response To All Eight Accusations:

In all eight instances of alleged fraud, defense counsel has refused to offer any response or explanation whatsoever. There is nothing on the ROA addressing this. On April 17th, 2026 there was even a hearing in front of a traveling judge as the normal judge was out on vacation. Both the traveling judge and defense counsel refused to address the Accusations of fraud on the court. But by staying silent defense counsel was admitting to fraud by adoptive admission under California Evidence Code § 1221. But the records show there was no reporter present at the hearing. So on Tuesday April 28th, Ryan is moving for a quick ruling on his proposed settled statement which is basically a process in which the court certifies what happened. But its not just his word, he had a witness at the hearing as well. Both his proposed statement and witness declaration can be found here. Given as Gulley was the only person in the courtroom for the defense and he is being accused of one of the frauds the judge will have to take into account one side not accused of fraud with a witness against another side accused of fraud. If the defense tries to counter at all.

What Happens Tuesday

Given as TKO and High Roller had all of this information on Tuesday, if no 8-K is filed before Monday's open, the next event on the timeline is the court hearing on Tuesday, at which the fraud record — already uncontested — moves toward formal certification. At that point, TKO 0.00%↑ and ROLR 0.00%↑ board members will have gone from having actual notice of an uncontested fraud record to having allowed a market open to pass without disclosure. Even more devastating they could face shareholder lawsuits for failing to disclose once the court certifies the fraud or the OCC pulls the bank charter. This would likely lead to a FTX like contagion which could bankrupt crypto.com almost instantaneously.

The evidence is already public. The court record is already filed. The monitoring logs already exist. The only remaining variable is whether the partners choose to get ahead of what the record will likely certify on Tuesday or shortly thereafter — or behind it.

Email Jack at: fintechinvestigations1@protonmail.com