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November 2024
- 6 participants
- 595 discussions
Fwd: Launch of the One Million Black Women Initiative…John Waldron Interviews NATO Secretary-General…Institutions Sharpen Focus on Crypto Assets
by Gunnar Larson 11 Nov '24
by Gunnar Larson 11 Nov '24
11 Nov '24
Fri, Mar 12, 2021, 7:41 PM
We were just kids, Joshua.
Can you please clear this by your CEO and get back to me?
Thank you for everything.
Gunnar ✌️
---------- Forwarded message ---------
From: Gunnar Larson <g(a)xny.io>
Date: Fri, Mar 12, 2021, 7:41 PM
Subject: Fwd: Launch of the One Million Black Women Initiative…John Waldron
Interviews NATO Secretary-General…Institutions Sharpen Focus on Crypto
Assets
To: Joshua Plant <joshua(a)plantpr.com>
Black Women, NATO and Crypto. All the things Goldman is abusing, or has
abused historically.
After this Demo Day I feel a duty to not let up the gas on xNY.io and
Bank.org.
Will send you the memo to Linda... I really liked her chat today but I feel
bamboozled. And is billions.
---------- Forwarded message ---------
From: Gunnar Larson <g(a)vrnetworks.co>
Date: Fri, Mar 12, 2021 at 7:38 PM
Subject: Fwd: Launch of the One Million Black Women Initiative…John Waldron
Interviews NATO Secretary-General…Institutions Sharpen Focus on Crypto
Assets
To: <g(a)xny.io>
Sent from my iPhone
Begin forwarded message:
*From:* Briefings from Goldman Sachs <briefings(a)gs.com>
*Date:* March 12, 2021 at 12:53:52 PM EST
*To:* g(a)vrnetworks.co
*Subject:* *Launch of the One Million Black Women Initiative…John Waldron
Interviews NATO Secretary-General…Institutions Sharpen Focus on Crypto
Assets*
*Reply-To:* "Briefings from Goldman Sachs" <briefings(a)gs.com>
[image: Goldman Sachs]
<https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac1f>
[image: BRIEFINGS]
March 12, 2021
Goldman Sachs Launches One Million Black Women Initiative
[image:
https://www.goldmansachs.com/our-commitments/sustainability/one-million-bla…]
<https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac20>
“When we looked at the United States, it became clear that if you wanted to
make a long-term economic difference, you had to start by supporting Black
women,” said Goldman Sachs Chairman and CEO David Solomon, on the
launch of *One
Million Black Women*, the firm’s initiative to narrow opportunity gaps for
Black women by investing $10 billion and committing $100 million in
philanthropic capital for capacity-building grants over the next decade.
The effort will target investments to support Black women at key moments in
their lives and address the significant disadvantages they face across a
range of economic measures, including access to housing, healthcare,
education and capital. The firm will work with an advisory council of Black
leaders from leading corporations, nonprofit organizations and government,
who will play a critical role in driving the initiative forward.
*Learn more about the One Million Black Women
<https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac21> initiative.*
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email] <?subject=One%20Million%20Black%20Women&body=>
Black Womenomics: Investing in the Underinvested
<https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac25>
The *One Million Black Women* initiative draws on insights from Goldman
Sachs Research’s new *Black Womenomics* report, which delves into the 90%
wealth gap between Black and white households, its relationship with the
broader economic disadvantages Black women face, and the public and private
investment opportunities that can help close the divide. The report
contends that addressing structural economic disparities would make for not
only a fairer but also a richer society: The authors estimate that
confronting the wage gap alone (which accounts for two-thirds of the wealth
gap and widens throughout Black women’s working life) could add over one
million jobs to the U.S. economy, and increase annual GDP by $300-450
billion in current dollars.
Read report <https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac26> View
infographic <https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac27>
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email]
<?subject=Black%20Womenomics&body=https%3A%2F%2Fwww.goldmansachs.com%2Finsights%2Fpages%2Fblack-womenomics-f%2Fblack-womenomics-report.pdf>
Talks at GS With NATO’s Jens Stoltenberg
<https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac2b>
Above (L to R): John Waldron of Goldman Sachs and Jens Stoltenberg of NATO
As secretary-general of NATO, Jens Stoltenberg leads a political and
military alliance that was designed to maintain a delicate peace in the
shadow of World War II—a coalition that's since evolved to include climate
change as a key focus for its 30 member nations. “Climate change—global
warming—is what we call a crisis multiplier,” says Stoltenberg, who spoke
with Goldman Sachs President and COO John Waldron in a recent episode of *Talks
at GS*. “It will increase the competition for scarce resources, for water,
for land. It will force people to move,” he says. “I'm not saying that
climate change is the only reason for crisis and conflicts, but it may
exacerbate and fuel and multiply the consequences of different conflicts in
many places in the world.” The secretary-general envisions a three-part
approach to the threat. “The first thing NATO should do, and we are
starting to do that, is to have the best possible understanding of the link
between climate change, global warming, and security threats and
conflicts,” he says. “The second thing we should do is that we need to
adapt the way we conduct our [military] missions, operations—how we do our
work. Because we have to understand that the military, they operate, at
least mostly, out there in nature.” Last is the alliance’s own role in
contributing to climate change. “We could try to reduce emissions,” says
Stoltenberg, “because today’s military operations are normally extremely
energy consuming.”
Watch video <https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac2c>
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How Institutional Investors Are Thinking About Crypto Assets
Institutional investors are increasingly focused on investment
opportunities in crypto assets, says Goldman Sachs' Mathew McDermott, who
relayed how the assets are dominating client conversations—and at a more
technical level—on a recent *Exchanges at Goldman Sachs* podcast. “The
questions are not really, ‘What is it?’…It's more about ‘How can we get
exposure, what are the instruments we can transact?’” McDermott, who is
global head of Digital Assets for the firm, says the surge in trading
crypto can be seen across a diverse investor base, citing findings from a
recent Goldman Sachs survey of institutional clients. “40% of the clients
currently have exposure to cryptocurrencies,” he says, while “61% of
clients expect their digital asset holdings to increase over the next
year.” It’s a significant shift from where the cryptocurrency market was a
few years ago. “2017 was very much a retail-driven market,” McDermott says.
“This time around, we've just seen a huge volume of institutional demand
across the broad spectrum of different industry types. And as a function,
you're seeing incumbent banks now explore ways that they can develop
products to satisfy that client demand, enabling them to gain exposure to
the different cryptocurrencies.”
Listen to podcast
<https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac30>
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<?subject=How%20Institutional%20Investors%20Are%20Trading%20Cryptocurrency&body=https%3A%2F%2Fyoutu.be%2Fgk3hadD8YHM>
The Daily Check-In With Goldman Sachs
<https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac34>
Above (L to R): Mike Swell, Anna Skoglund and Katherine Tait of Goldman
Sachs
While mounting concerns over inflation spooked the bond markets and other
risk assets in recent weeks, such fears are likely overblown, says Goldman
Sachs’ Mike Swell
<https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac35>, who oversees a
team that manages $700 billion in fixed income assets. Investors are
“concerned [that] with the very significant recovery we’re seeing in the
economy—along with a lot of debt issued by the government—we’re going to
see a significant increase in inflation,” he says in a recent episode of *The
Daily Check-In*. But more broadly, Swell notes that labor market slack,
productivity gains and globalization will likely keep inflation in check
for longer than the market is currently expecting. “As we look into 2022,
you’re likely to see growth normalize, inflation normalize. And the Fed is
going to keep the money easy and, as a result, it’s going to be a good
environment for risk assets and it’s going to be a decent environment for
fixed income assets as well.”
In other episodes of *The Daily Check-In*, Anna Skoglund
<https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac36> of Goldman
Sachs’ Investment Banking Division discusses the increase in private equity
deal volumes in Europe this year and Goldman Sachs Research’s Katherine Tait
<https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac37> explains why
venture capital in the education sector had its best-ever year in 2020 as
the pandemic reshaped the future of learning.
*For more Daily Check-In videos, subscribe to our channel
<https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac38> on YouTube.*
Watch videos <https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac39>
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March QuickPoll: Moving to a ‘Post-Pandemic Regime’
After dealing with the recent volatility in interest rates, investors are
shifting their focus to central bank activity and economic data, according
to the latest Marquee QuickPoll survey of close to 700 Goldman Sachs
institutional investor clients. Here are highlights:
*Rate Moves Coming to an End?* Investor sentiment suggests that a jump in
interest rates is still expected but not for long: A majority of
respondents think interest rates will increase in March, but only 9% expect
10-year rates to end the month above 1.60%.
*Central Bank Policy in the Spotlight*. COVID-19 epidemic data and vaccine
developments were by far the primary (and only) variable investors were
watching in past QuickPoll surveys, but focus is now shifting to central
banks and macro indicators. COVID remains top of mind for 39% of
respondents this month, but 33% of investors are now keeping an eye out for
central bank statements and 16% are looking to U.S. economic data. “In our
view, this likely marks the end of the ‘pandemic regime’ for markets and
the beginning of a ‘post-pandemic’ one,” says Oscar Ostlund, head of
content for Marquee, the digital platform for the Global Markets Division.
*Portfolio Rotation to Inflation-Sensitive Assets*. Investors turned
bearish on gold, the price of which typically falls when real rates
rise—with about 35% of respondents expecting the price to be weakened
further by the end of the month. Meanwhile, investors continue to have a
bullish view on other commodities such as crude and copper. “We’ve seen
many investors shift their views on gold and significantly reduce their
enthusiasm on emerging market equities, which were the second-favorite
asset class last month but have significantly sold off,” Ostlund says.
*For more information about QuickPoll and Marquee, reach out to the team
<gs-marquee-sales@ny.email.gs.com?subject=BRIEFINGS%20Follow-Up%3A%20Interested%20in%20Learning%20More%20About%20Marquee&body=BRIEFINGS%20Follow-Up%3A%20Interested%20in%20Learning%20More%20About%20Marquee.>.
*
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<?subject=March%20QuickPoll%3A%20Moving%20to%20a%20%E2%80%98Post-Pandemic%20Regime%E2%80%99&body=>
Briefly…on the Path to Net-Zero Emissions and Inclusive Growth
<https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac40>
Just over a year into Goldman Sachs' 10-year plan to deploy $750 billion
toward accelerating the climate transition and advancing inclusive growth,
the firm has reached a fifth of its target. We sat down with *John
Goldstein*, head of the firm’s Sustainable Finance Group, to discuss
progress, client concerns and the impact of the pandemic on companies’
sustainability goals.
*John, soon after the firm announced its sustainability goal in late 2019,
the world went into lockdown. Can you describe how the pandemic affected
companies’ sustainability objectives in 2020? *
*John Goldstein*: Last year was undoubtedly a year of volatility and
complexity, but the one constant was the growing interest and focus in
sustainable finance and ESG as evidenced by the fact that in 2020 alone we
reached a fifth of our $750 billion 10-year target. The pandemic served as
a stress test for the industry—which it passed with flying colors. The
strong performance of ESG investments during the first-quarter downturn was
rewarded with greater focus and capital flows as the year progressed. In
addition, the pandemic reminded people of how quickly the world can change
and how important these emerging changes can be to portfolios. Factors that
may not have always been incorporated in traditional financial models can
have significant financial impacts. From our perspective, 2020 highlighted
the importance of both elements of our sustainability approach which
focuses on two interconnected themes: climate transition and inclusive
growth.
*Can you describe the firm’s approach to sustainability—how did you come to
decide on these two themes?*
*John Goldstein*: When we first announced our sustainability approach in
2019, people immediately understood the focus on climate transition, but
were less certain about the focus on inclusive growth. Well, 2020 was a
stark reminder that both pillars are essential. The pandemic gave us a
health and employment crisis while highlighting the deeply visible
manifestations of the ongoing racial inequalities, particularly in the U.S.
You could say that the social component of ESG has climbed into the front
seat with the environmental concerns.
*So let’s talk about how the first year of allocating capital went. How did
the firm approach making its targets a reality?*
*John Goldstein*: A big part of achieving our goal during the first year
stemmed from the fact that we were able to leverage the strengths across
the organization. Soon after we announced our 10-year target, we created a
new team, the Sustainable Finance Group, to coordinate our sustainability
efforts across the firm. Shortly thereafter, we launched dedicated
sustainability councils within all of our businesses, each led by a senior
leader within the firm, to integrate sustainability solutions into our work
with clients.
*What's an example? *
*John Goldstein*: One example I would highlight is the work that we did
with our Global Markets Division where we incorporated ESG data into the
division’s trading capabilities. That in turn helped clients achieve their
ESG goals either broadly or in specific areas, such as lowering their
carbon footprint in their portfolios. We essentially served as a product
incubator within divisions to understand the market need for new strategies
for their clients. The division, in turn, scaled the products and
strategies more broadly.
*What types of strategies resonated most with clients? *
*John Goldstein*: Climate solutions were a key focus for clients across the
firm. For example, we’ve worked with our colleagues in the Asset Management
Division to provide growth financing to Swedish manufacturer Northvolt AB
to support the construction of a lithium-ion battery factory that will
expand the market for electric vehicles in Europe. For our public market
investors, we’ve developed ESG strategies in our trading and asset
management businesses and are accelerating global power solutions through
our structuring services in the Global Markets Division. In the Investment
Banking Division, we were part of the largest corporate sustainability bond
for Alphabet; the largest IPO for a solar company, Shoals Technologies; and
helped clients issue more than $35 billion in COVID-19 relief bonds. What
we’ve learned is that there are multiple ways to help clients meet their
decarbonization goals across the firm. In fact, making sustainability a
core commercial focus for us has not only allowed us to scale ESG and
inclusive growth strategies across the breadth and depth of our
organization to meet our clients’ goals, but doing so has also enabled us
to tie it into our own funding strategy as we recently did with the
issuance of our $800 million green bond.
*Finally, what do you see as the key ESG and sustainability priorities for
companies this year? *
*John Goldstein*: Investors and corporates are all looking at moving
sustainability considerations from the periphery to the core of their
organizations. That means that for investors, it’s not just about ESG
products—it’s about all of their investing products. It’s not about their
sustainability report—it’s about their annual report. For us, our focus
will continue to remain on incubating and launching new product offerings
within our divisions in partnership with our clients and—in particular—to
accelerate our efforts to work as one firm to meet clients’ needs.
View infographic
<https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac41> Read
GS CEO David Solomon's statement
<https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac42>
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Goldman Sachs Media Highlights
*CBS This Morning* - March 10
Investing in Women: Goldman Sachs CEO on New Plan to Close the Wage Gap
<https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac46> (7:26)
*Essence* - March 10
Exclusive: Goldman Sachs Invests $10 Billion in New ‘One Million Black
Women’ Initiative
<https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac47>
*Bloomberg* - March 8
Goldman Open to Work With Financial Newcomers: Stephanie Cohen
<https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac48> (7:37)
*Bloomberg * - March 8
Goldman’s Abby Joseph Cohen Still Sees Potential in Equities
<https://tracking.gs.com/r/?id=h11421279,4ec274e4,4ec2ac49> (10:17)
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to buy, sell, or hold any particular security. Goldman Sachs believes the
data in this newsletter is accurate, but does not verify its accuracy
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To the extent this newsletter includes material from the Goldman Sachs
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relating to Securities Division material and your reliance on it.
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--
*Gunnar Larson - www.xNY.io <http://www.xNY.io> *
MSc
<https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…>
- Digital Currency
MBA
<https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…>
- Entrepreneurship and Innovation (ip)
G(a)xNY.io
+1-646-454-9107
New York, New York 10001
1
1
https://docs.google.com/document/d/1aeK8X8-2KDZ8tQPN5ksaUCXcxH9tbjexsUbW1ol…
xNY.io
CRYPTOBANK
Table of Contents
Introduction 2
Focus, Goals and Objective(s) 3
Strategic Intent 4
Innovation Strategy 5
Pioneering Human Resources (HR) Management in Banking 6
The Bitcoin Blockchain, Human/Civil Rights and Computer Crimes 7
Goldman Sachs’ Organization HR Management Analysis (MoneyGram and Ripple) 8
www.JUMO.World and Banking Africa 9
Earth_ID: Because Owning Your Identity is a Human Right 10
CryptoBank Environmental Analysis 11
The NEXO.io Conundrum 12
The Fireblocks Conundrum 13
Computer Software and the Blockchain Platform 14
Virtual Currency: Computer Software Protocols and Processes 15
Bank.org: Revolutionary Approaches to Agile Innovation 16
Conclusion 17
Bibliography 19
Introduction
Crypto and Blockchain are each a Human Right.
For all, everywhere.
How does New York based bank fraud happen from the inside? People who
commit crimes comprise departments and divisions of corporate
organizations, and some current Human Resources (HR) management cultures
lend well to the committing of crimes.
What organizational HR management design structures are at play to
architectect such fraud for bespoke juristical instances?
Is there a unique opportunity for a fresh and clean New York-based
international bank such as Bank.org?
xNY.io argues that modern and innovative Executive Suites pioneer
organizational HR management with the CEO and CFO leading the pack as the
most ethical example for members in their organization. This key
distinction calls for leaders to always adhere to a very strict, yet
progressive, standard of ethics, even when it’s inconvenient.
World renowned executive Jack McCullough suggests strict adherence is
necessary, especially when it’s inconvenient. McCullough says that if
you’re seen as a CEO and CFO “who will compromise when convenient, this
approach will cause colleagues to consider all the talk about ethics to be
lip service” (McCullough 2019).
The leadership at xNY.io is clear-eyed, recognizing the importance of an
extensive review program which seeks to explore all aspects of the
following criteria as part of Legal, Compliance, and Governance (Bloomberg
2021), which is our internal due diligence framework based on first class
industry standards and best practices (xNY.io | Bank.org n.d.).
In summary, this HR management innovation essay outlines and explores three
key concerns for modern Bank and CryptoBank organizations. These concerns
are signaled by our regulators who rightly suggest that it is critically
important that the organizers identify, at the beginning of the process, an
available management team and board of directors (NY-DFS 2008):
The theory of modern virtual currency cross-border regulation logic (Larson
2020a).
How to protect xNY.io’s strategic partnership with Bank.org and its mandate
to pioneer innovation(s) and noble advancement of modern international
banking?
Whereas, it is essential to safeguard virtual currency and its potential to
galvanize international, economic and social advancement of all peoples
(United Nations 1948).
Most importantly, what organizational HR management structures are
necessary to execute the proposed xNY.io and hybrid model framework, while
engaging agile innovation to explore the potential of growing Bank.org into
the World’s Best Bank and headquartered in New York (NY-DFS 2019)?
Focus, Goals and Objective(s)
Why would a New York bank build organizational HR strategies with the sole
purpose of taking advantage of the most vulnerable for exorbitant profit?
xNY.io’s focus is to fill a need in clarifying New York’s virtual currency
standards to achieve progressive innovation while constantly promoting
respect for human rights and personal freedoms by progressive measures,
national and international, to secure their universal and effective
recognition and observance across all global territories of business,
protecting all peoples and all nations (United Nations 1948).
Our simple strategy rests in the fact that virtual currency has
cross-border utilities (European Commission 2021). Our real world
experience has uncovered the strategy of a New York bank's misemployed
Manhattan Island as a walled garden for bad HR management camps while
wrongfully profiting off of the back of the most vulnerable across global
markets (Law 360 2021). Our goal is to profit off the pivot from the
textbook definition of marketplace manipulation, discussed herein related
to the feasibility of automating stock market manipulation (Association for
Computing Machinery 2020).
The Supreme Court placed emphasis on the central role of deception to the
concept of fraud.“ (T)he words ‘to defraud’ . . . primarily mean to cheat,
. . . usually signify the deprivation of something of value by trick,
deceit, chicane, or overreaching, and . . . do not extend to theft by
violence, or to robbery or burglary.” (Hammerschmidt v. United States
1924).
Bank.org feels confident in our knowledge and our direct dialogue with over
100 of the world’s leading scholars on the subject of international law:
(Morris 2008)
The International Criminal Court investigates and punishes people for
genocide, crimes against humanity, and war crimes (Wikipedia 2021a).
The International Court of Justice, sometimes referred to as the World
Court, has two major functions. Firstly, it settles disputes, which the
member countries may bring before it. Secondly, it may give its opinions on
legal matters (Wikipedia 2021b).
The objective of xNY.io’s research essay summarizes the discussion of New
York bank organizations and the corresponding HR management architectures
designed to target maximizing profits through conscious marketplace
manipulation structures. The best xNY.io CryptoBank must be concerned with
pioneering a business beyond leveraging computer crimes, a marketplace
manipulation matter associated with current New York BitLicense
architecture and subject to our attention related to
cross-border/international organized groups that are cyber-based in New
York (Federal Deposit Insurance Corporation 1989).
Strategic Intent
Imagine trying to open the best bank in the world and running up against
BitLicense regulatory arbitrage (Poster 2019) just a few Manhattan blocks
away.
Composing a richly robust innovation strategy calls for a clear and honest
appraisal of current marketplace conditions and identifying the firm’s
current status. This requires xNY.io to not only be ambitious but also
extremely articulate in outlining our strategic intent. We see our key
competitive advantage in cleverley leveraging our vision cohesively with
all available resources and modern ideals of Bank.org.
Bank.org is aware that our uniqueness is very difficult for competitors to
imitate. In her book Strategic Management for Technological Innovation,
Mellissa Schilling suggests that the New York banking sector may be
characterized as an oligopolistic industry in that there is a low degree of
rivalry. Schilling explains that sometimes competitors choose to avoid
head-to-head competition as a price collusion tactic (Schilling 2019).
Being extremely clear and transparent, xNY.io's business models emphasize
taking advantage of our competitors who have designed global regulatory
abtrigatre frameworks at the expense of our customers (Buchak et al. 2017).
Bank.org's stakeholder analysis highlights that many New York banks have
ignored the ethical and moral implications of designing HR management
structures with the sole purpose of training employees to act as
footmen/footwomen in defrauding a global customer base. Furthermore, these
bad actors revel in the naivety of potential rivals and government
regulators as an operative procedure of HR management.
Through an analysis of the best agile innovation strategy for execution,
xNY.io and Bank.org have partnered to engage both backward vertical
integration AND horizontal integration techniques (Tarver & James 2021):
xNY.io is vertically integrating backwards by producing our own advanced
blockchain technology for global payments.
Bank.org aims to actively engage leveraged buyouts of competitor banks, a
practice that is considered horizontal integration (Kenton & James 2021).
From the very beginning, xNY.io and Bank.org’s ethical and moral incentives
have been strategically integrated into a modern and innovative hybrid
infrastructure. Spanning key global functions including (but not limited
to) reserve management, international legal counsel, and public and
government affairs and relations, we consider ethics to be a quality
management concern. Honestly, the implications of our strategic intent are
derived from the morals of our founders who seek to efficiently secure the
smooth function of our cross-border operations.
Innovation Strategy
We recognize our competitors see modern innovation as merely improving
efficiency of obsolete legacy bank systems and processes to keep their
operations afloat. It is extremely troublesome that many New York bank HR
leaders’ modi operandi detail strategies of seeking new revenue channels
that target the most vulnerable across first to third world markets (Ripple
2013a).
As part of our ethical leadership agenda, articulating xNY.io’s strategic
intent enables the firm to incorporate our innovation practice into
Bank.org’s cross-border development and rollout. Capital investments are
required as part of a multidimensional performance architecture, along with
real-time systems and computational analyses.
Our honest deliberation and critical assessment of xNY.io’s strategic
intent and development of new computational technologies brought to light
the concern of competitors' engagement in computer crimes discussed in the
following section.
We recognize that true innovation goes beyond juvenile process
efficiencies. Our innovation strategy constantly anticipates the future by
recognizing where industry peers are failing today. This allows us to
identify and execute products and services that are better - extremely
better - than what the industry offers today.
Schilling notes that successful and innovative firms question existing
price performance assumptions. They attract customers by developing and
introducing products that extend well beyond current market requirements
and help mold the market’s expectations for the future (Schilling 2019).
This separates us from our competitors' desperate attempts to cut costs
rather than ethically addressing and improving their HR operations with
corresponding moral incentives.
Pioneering Human Resources (HR) Management in Banking
As international scholars (Mills 2006), our founders believe in the future
of virtual currencies and blockchain platform computer software. This
belief has been cultivated and nurtured by some of the most recognized
pioneers of the global blockchain industry (Bourne et al. 2018). We
consider virtual currency and blockchain technology to be precious,
appreciating assets with various growing benefits over the course of one’s
lifetime.
Rolling Stone profiles the New York bank JP Morgan Chase and the bank’s HR
management techniques, highlighting the conscious disregard of the ethical
and moral standards from Chase’s Executive Suite knowingly excited the
peddling of bad products stuffed with scratch-and-dent loans to investors
without disclosing the obvious defects of the underlying loans (Taibbi
2014).
Chase has repeated deal after deal with the same poor and fraudulent
organizational HR management methodology, as did many other banks. Rolling
Stone goes on to say, “It’s theft on a scale that blows the mind.”
New York banks and Silicon Valley technology firms have a long history of
not only challenging but actively attacking beliefs that virtual currency
and blockchain are innovative tools for means of payment and stores of
value, going so far as to launch an ever-popular campaign: “Bitcoin has no
value at all” (Torpey 2018).
It is safe to say that between New York and Silicon Valley, many
organizations, through their various HR management structures, have made
calculated efforts to kill the blockchain economy before it even got off
the ground (Al-Naji et al. 2018).
For example, New York, Europe and Africa are connected by a freeway of
cross-border arbitrage frameworks. Due to easily exploitable laws in
developing countries, some BitLicensees’ operations straddle New York,
Europe and Africa to evade detection and prosecution from law enforcement.
Through various HR management structures, New York banks have consciously
exacerbated regulatory loopholes resulting in virtual currency market
manipulation affecting international computer technology systems and
software such as the Bitcoin blockchain (Conway 2020).
Speaking generally, at least during the Bitlicense’s 2015-2020
implementation phase, New York banks likely leveraged the BitLicense
seeking to increase profits from cross-border virtual currency market
manipulation (Pettinger 2019).
The entire design for executing a loophole virtual currency standard only
comes into practice if a group of New York HR managers, at the direction of
the Executive Suite, puts together a scheme in secret to manipulate a bunch
of technical rules that laymen don’t understand to deprive people of their
money (Bagchi 2020).
From the position of absolute and essential need of becoming a leading
international bank, Bank.org has no other choice than to pioneer a
necessary HR culture that supports our primary activities of operation. It
is true that xNY.io came into existence as a tech-based response to the
stated problems that specifically addresses both the threats of future
damage and the current cross-border computer crime merry-go-round
responsible for extortionate damage already inflicted.
“We’ve got to change the cost-benefit calculus of criminals and
nation-states who believe they can compromise U.S. networks, steal U.S.
financial and intellectual property, and hold our critical infrastructure
at risk, all without incurring any risk themselves...” (Wray 2020).
The Bitcoin Blockchain, Human/Civil Rights and Computer Crimes
Bank.org is wise to objectively research and strategically organize its HR
leadership position as a pioneer, in comparison to current New York bank
management structures. Given that honest and fair dealing of virtual
currency is critical to blockchain technology, should admitted felons and
serial miscreants (Martens & Martens 2020) be allowed to further expand
their racket via global regulatory arbitrage and/or computer crimes?
Satoshi Nakamoto’s Bitcoin whitepaper states, “What is needed is an
electronic payment system based on cryptographic proof instead of trust,
allowing any two willing parties to transact directly with each other
without the need for a trusted third party” (Nakamoto 2008).
New York State Human/Civil rights laws are applicable internationally. “If
a resident person or domestic corporation violates any provision of this
article by virtue of the provisions of this section, this article shall
apply to such person or corporation in the same manner and to the same
extent as such provisions would have applied had such act been committed
within this state except that the penal provisions of such article shall
not be applicable” (N.Y. Executive Law 2019).
Congress amended the definition of “protected computer” to make clear that
this term includes computers outside of the United States so long as they
affect interstate or foreign commerce or communication of the United
States. This change addresses situations where an attacker within the
United States attacks a computer system located abroad. This change also
addresses situations in which individuals in foreign countries route
communications through the United States with intent to extort from any
person any money or other item of value, transmitted via interstate or
foreign commerce (U.S. Congress 2002).
Courts have interpreted expansively to define not only schemes to defraud
individuals of money or property, but also schemes to defraud individuals
of intangible interests and rights. Additionally, both mail and wire fraud
statutes have been expanded to include schemes to deprive individuals of
“honest services” (Eltringham 2015).
What organizational HR management techniques are required for an enterprise
to actively convince hundreds, if not thousands, of employees, clients and
customers to pursue their strategy while knowing it was fatally flawed?
Goldman Sachs’ Organization HR Management Analysis (MoneyGram and Ripple)
MoneyGram, which has about 227,000 global money transfer agent locations in
191 countries and territories, was recapitalized in 2008 (same year of
Bitcoin's whitepaper). Goldman Sachs acquired an equity interest of 63
percent in MoneyGram for about $710 million. Per the 2008 agreement,
MoneyGram also received $500 million in debt financing from Goldman Sachs
(Cordeiro 2011).
Walmart is the only MoneyGram agent, for both the Global Funds Transfer and
Financial Paper Products segments, that accounts for more than 10% of
revenue. In 2020, Walmart accounted for 13% of total MoneyGram’s revenue
and 16% in 2019 and 2018. Goldman Sachs (Investor) has a Participation
Agreement with Walmart Inc. (Walmart) under which the Investor is obligated
to pay Walmart certain percentages of any accumulated cash payments
received by the Investor in excess of the Investor's original investment in
the Company (MONEYGRAM INTERNATIONAL INC 2021).
In 2016, Ripple received New York’s First NY-DFS BitLicense for an
Institutional Use Case of Digital Assets (Larsen 2016). Shortly after being
NY-DFS accredited, Ripple announced it was teaming up with MoneyGram to
test payments using Ripple’s xRP virtual currency. During this time, Ripple
was making headlines as the xRP digital currency had surged — and fallen —
dramatically (Browne 2018). Soon after, Ripple announced a $50 million
investment in MoneyGram snagging a 10% equity stake in the firm. Brad
Garlinghouse, Ripple’s CEO, added that his firm would support MoneyGram’s
“further expansion” into the European and Australian payment corridors (De
2019).
Connecting the dots, MoneyGram is now one of the most expensive transfer
providers (Tierney 2019) on planet Earth. Customers incur fees for postal
mail, telephone calls, electronic mail, and other computerized messaging
services.
Computer crimes as a threat are no less of a threat because it is
contingent, because the speaker does not intend or is unable to carry it
out when the threat was not directly communicated to the MoneyGram customer
as a target, or because the language used might be considered cryptic or
ambiguously not part of the current New York BitLicense mandate.
Ripple simply made MoneyGram’s business more efficient, thus accruing more
profits for Goldman Sachs directed out of Manhattan. From 2019 - 2020,
MoneyGram received more than $40 million in market development fees from
Ripple Labs in return for providing liquidity to its On-Demand Liquidity
(ODL) network. It can be calculated that 10%-15% of the proceeds came from
Walmart customers, who are some of the most disenfranchised Americans
financially.
Over the last five years, through conscious organizational HR management,
Goldman Sachs created layer upon layer of New York BitLicense-related
disguises and cross-border systems under potential conspiracy and plausible
deniability to computer crimes and marketplace manipulation. Goldman Sachs'
various direct and/or indirect BitLicensee connections profit daily from
virtual currency market manipulation computer crimes with cross-border
reach, operating as a large syndicate group from lower Manhattan.
www.JUMO.World and Banking Africa
What is astonishing is that Ripple is powering some of JUMO’s bank
customers (Ripple 2020), in a troublesome manner similar to MoneyGram.
New York banks have a long and profitable history of exploiting regulatory
arbitrage. Similar to the MoneyGram instance, some evidence shows that
Goldman Sachs also seems to have entered Africa. Given that several
enforcement actions and lawsuits in the United States specifically targeted
banks’ treatment of minority borrowers (Taibbi 2014), it may not be
surprising to learn of www.Jumo.World or “JUMO” (Buchak et al. 2017).
A domain extension, in this case “.World” domain, is the targeted subject
area of a computer program. It is a term used in software engineering
(Wikipedia 2021):
During the fourth quarter of 2018, JUMO successfully finalized a $65
million capital raise that was led by Goldman Sachs in New York. JUMO is a
full technology software stack for building and running financial services,
targeted at the world’s most disadvantaged populations.
Today, JUMO operates across numerous African markets including Tanzania,
Ghana, Zambia, Kenya, Uganda, and most recently in Pakistan, with plans to
expand further across the sub-continent.
Since its launch in 2014, more than 15 million people have saved or
borrowed on the JUMO platform, with over $1.6 billion in funds disbursed to
customers. Nearly 70% of JUMO’s customers are micro and small business
owners.
JUMO targets the unbanked population across several emerging and developing
markets. A variety of JUMO’s partnerships with leading banks and mobile
network operators creates a marketplace where consumers can access
financial services and banks can access a new pool of mobile money
customers (Vostok Emerging Finance Ltd 2020).
Given the regulatory environment in Africa, it could be suggested that from
New York, Goldman Sachs and Ripple’s organizational HR management
structures once again aim to profit from some of the most vulnerable of the
human population.
Earth_ID: Because Owning Your Identity is a Human Right
The modus operandi of JUMO’s business is a type of malicious bank software
designed to encrypt or otherwise block access to valuable data (e.g.
Digital Identity) until the victim agrees to provide a specified payment.
The population of the African continent is approximately 1.2 billion
people. Imagine a whole continent of people with no proof of identity and
therefore no chance of having access to financial services, economic
opportunities, or formal employment. These are basic services that are
taken for granted and sadly are all too often denied to so many in our
world today. Many countries in Africa lack the necessary means to establish
and maintain basic systems of identity management, such as the registration
of births, especially for the rural poor and underprivileged (Plumer et al.
2020).
Earth_ID has plans to pilot the launch of it’s decentralized digital
identity platform in collaboration with University of Nicosia’s (UNIC) very
own African Partner, UNICAF. UNICAF has a physical presence on eleven
campuses throughout Sub-Saharan Africa. We welcome the students and staff
of UNICAF to be Earth_ID’s very first adopters, community leaders and
validators in trust to our decentralized identity solution. Goldman Sachs
from New York is a lead investor in UNICAF (Chege 2018).
According to the United Nations Digital Solutions Centre, the creation of a
unique personal United Nations ID (Earth_ID) using blockchain technology,
which is portable across organizations (Dumitriu 2020).
The proposal foresees that every United Nations organization could become a
trusted authority writing information onto the blockchain. The
organizations could run their own nodes separately, while the system will
ensure scalability and interoperability.
The Inspector recommends that the executive heads of the United Nations
organizations support the creation of a United Nations digital ID. This
will have multiple long term positive consequences in terms of saving time
and resources, facilitating staff mobility in allowing certification and
recognition of their knowledge and skills, reducing bureaucracy, and
enhancing system-wide coherence.
The descriptive definition of regulatory arbitrage suggests that New York
banks’ organizational HR management, with direction from the Executive
Suite, seeks to saturate lending to markets with more minorities and worse
socioeconomic conditions (Buchak et al. 2017).
CryptoBank Environmental Analysis
How can xNY.io innovate from underdogs to elite high performers, becoming
the best in the world?
xNY.io - CryptoBank wants to create the best World Crypto Bank known to
humanity, and we plan to do that expeditiously in 40+ countries and fiat
currencies. xNY.io has a problem: We are displeased with Ripple powering
customers like MoneyGram, Santander Bank and the other 300+ banking
customers. Our frustrations hinge on Ripple seeming to be propping up the
same bad banks that more or less rival Bitcoin's entire mission (Larson
2020b).
Furthermore, instead of putting the MoneyGram and other bad traditional
banks out of business, Ripple is looking to profit off of cross-border
payment startups similar to our best World Crypto Bank (Ripple 2013b).
Market segmentation determines groups of customers with common needs and
wants. All over the world, young people strive to make money. Those who are
at the beginning of the life road plan to grow financially. The
high-interest rate of xNY.io deposit accounts will help customers make
desirable choices for healthy and prosperous financial futures. Moreover,
geographically, xNY.io has a keen focus to improve banking in developing
countries on the African continent to help deprived people obtain the
rights of digital identity and interdependent modern bank accounts with
innovative products and services.
Digital asset trading platforms like NEXO.io in Europe powered by
Fireblocks in New York hop from more regulated jurisdictions to less
regulated or unregulated countries, leading to so-called regulatory
arbitrage or currency speculation (Pettinger 2019).
NY-DFS and FDIC regulators have more trouble detecting and blocking illicit
digital asset flows as virtual currency transactions are diverted away from
compliant regulated Fireblocks in New York to unregulated trading gateway
venues and peer-to-peer protocols that are directly against NY-DFS’
BitLicense mandate (FTI Consulting 2021).
The chain of financial service providers includes several intermediaries,
each drawing their own commission against the services provided. These
operating principles date several years back, and it is difficult to make a
paradigm shift from this existing operational hierarchy. This constraint is
being utilized by middlemen and the established market players. Financial
conglomerates use their supremacy, as well, to make sure their operations
continue unchallenged. The industry generally fails to serve a sizable part
of the community and this gap can only be bridged by new players. However,
the strong market hold of the established players makes it seemingly
difficult for innovators to contribute.
The NEXO.io Conundrum
Our role model for creating the best World Crypto Bank is NEXO.io. While
Ripple's business of leveraging digital currency and blockchain technology
is disheartening, the great success of NEXO's crypto bank and card is
impressive. Case in point, NEXO's token and overall business solution is a
better example (Trenchev 2018).
NEXO is a great example for our best World Crypto Bank' but is funded by
Goldman Sachs (Roony 2018), Which could be argued to be worse than Ripple.
Goldman's blockage of crypto/blockchain development in the United States
(U.S. Congress 2002) and Digital Identity in Africa (Plumer et al. 2020)
cannot be overlooked.
While Ripple is supporting the bad behavior of MoneyGram and other
traditional banks with cards, NEXO is just the best bad version of Ripple
funded by Sachs. Both are probably gaming the digital currency market and
global blockchain innovation, and possibly humanity as a whole.
Obviously, NEXO could get into trouble for operating an unregulated bank
fast (Jennings 2018):
Moreover, NEXO is, at various levels, illegal in the United States where
the federal government regulates most banks (NEXO 2019). For example, in
New York, some of the NEXO token benefits are forbidden by NY-DFS
(Sokolowski 2021) .
Nexo doesn't have a Bitlicense, but they still operate in New York
(u/zylstrar 2019). New York State Attorney General Letitia James has made
it clear that virtual currency firms must abide by the BItLicense or risk
being shut down (Sharma 2021).
Additionally, United States authorities could force NEXO to offer Federal
Deposit Insurance Corporation (FDIC) insurance on its accounts (Buchak et
al. 2017) .
It could be argued that Ripple (xRP) and NEXO.io (NEXO) built entire global
operations as direct/indirect BitLicensees with intent to profit from
various cross-border computer crimes such as market manipulation while
being partially funded and/or directed out of New York (U.S. Congress 2002).
However, NEXO operates like a bank. To explain, clients put cryptocurrency
in a wallet, borrow against it and receive funds through the NEXO wallet.
NEXO claims it can tap some huge markets that include crypto investors,
crypto miners, and hedge funds. Hence, NEXO looks like an investment bank.
Tellingly, NEXO looks a great deal like Goldman Sachs’ Marcus platform. For
example, both NEXO and Marcus offer loans and savings accounts.
The Fireblocks Conundrum
A few blocks south of Times Square in New York City, Fireblocks (Google
Maps 2021) powers the global operations of NEXO.io headquartered in Europe.
The CEO of Fireblocks has discussed his firm's $135 million investment led
by BNY Mellon and others: “‘While we have no plans to become a bank, we
believe our infrastructure will lend itself perfectly to power an entirely
new era of financial services,’ Shaulov added. ‘Developing products to
bridge digital and traditional assets is foundational to the future of
custody.’ Roman Regelman, BNY Mellon’s asset servicing CEO and digital head
said, ‘Following significant due diligence and market research, we
recognize Fireblocks as a market leader in providing secure technology to
support digital asset services’” (Shome 2021).
As previously noted, New York, Europe and Africa are connected by a freeway
of cross-border arbitrage frameworks. Due to easily exploitable laws in
developing countries, some BitLicensees’ daily operations straddle New
York, Europe and Africa to evade detection and prosecution from law
enforcement (Larsen 2016).
The Financial Action Task Force (FATF) identifies the “Travel Rule,” also
known as “Regulatory Arbitrage,” as a stand-out concern that is perhaps the
most glaring example of the lack of global harmonization of policies
designed to combat illicit financial flows in the crypto markets.
Fireblocks in New York powering the European based NEXO.io’s Global
CryptoBank (Metodiev 2020) operations at worst fueled a black-market
financial system and at best purposely and deliberately existed outside of
the NY-DFS BitLicense and bank industry regulations (Cyber Digital Task
Force 2020).
Fred Ehrsam, co-founder and managing partner at Paradigm (Ehrsam 2021), is
a lead investor in Fireblocks where he also serves as a board member.
Previously, Ehrsam co-founded Coinbase, the largest cryptocurrency company
in the US, and held the role of president from 2012 to 2017. Ehrsam
purchased his first Bitcoin in 2011 and has been an angel investor in some
of the space’s most formative companies. Prior to Coinbase, Ehrsam was a
foreign exchange trader at Goldman Sachs in New York. Ehrsam holds a B.S.
in Computer Science and Economics with honors and departmental distinction
from Duke University (Fireblocks 2020).
Computer Software and the Blockchain Platform
International Business Machines Corporation (IBM) is one of the world’s
largest computer firms and is headquartered in New York (Wikipedia. 2021).
IBM distinguishes the blockchain platform technology as computer software
(International Business Machines Corporation (IBM) 2021). Given IBM’s modus
operandi, it could be concluded that the Bitcoin blockchain is also
computer software.
Yet, New York banks can use those same innovations for their own
illegitimate ends, imposing great costs on the public. Today, few
technologies are more potentially transformative and disruptive—and more
potentially susceptible to abuse—than virtual currency (Cyber Digital Task
Force 2020).
Virtual currency fraud is a serious problem for such a developed country as
the United States, whose bank regulators have drawn attention to the
increase of these crimes. Having discovered that an unregulated virtual
currency sphere (such as in Africa, or other developing markets) is very
popular among virtual currency fraudsters (Prior 2020), the SEC has alluded
that this kind of regulatory arbitrage fraud was concerning (U.S.
Securities and Exchange Commission (SEC) n.d.).
An uncoordinated regulation can potentially have a stifling effect by way
of creating inconsistent regulatory requirements on top of increased
compliance costs to the industry.
Virtual Currency: Computer Software Protocols and Processes
The Internal Revenue Service (IRS) classifies virtual currency such as
Bitcoin as a computer software code. For example, Bitcoins counted at 21
million corresponds to a specific number of mining rewards that can be
given, and this is all written into a code (Yamalis 2018).
xNY.io’s key definition of virtual currency computer crimes is a consistent
message across markets. These crimes are relatively new, having been in
existence for only as long as Bitcoin has, which explains how unprepared
society, and the world in general, is towards combating these crimes
(Larson 2021a) .
Technological innovation and human flourishing are complementary concepts,
but the former does not guarantee the latter. Good public policy along with
ethical CEOs and CFOs at New York banks operating international HR
management organizations pioneer innovation of such policy (Eltringham
2015).
Marketplace manipulation and virtual currency regulatory arbitrage
undoubtedly stifles innovation and human flourishing. The absence of
protection under the law can endanger progress across both dimensions. It
takes careful consideration, and a deep and ongoing immersion in the facts,
to understand when and how law should intervene (FTI Consulting 2021).
Even in societies where transformative scientific and technological
advancements are achievable, ethical and moral CEOs and CFOs play a
critical mediating role. In the wrong hands, or without appropriate
safeguards and oversight, these advancements can facilitate great human
suffering.
Keeping all this in mind with a positive/optimistic attitude, a series of
smart and calculated leveraged buyouts can innovate beyond New York banks’
cross-border computer crime(s) such as (Prior 2020):
Conspiracy to Commit Fraud and Related Activity in Connection with Computers
Conspiracy to Commit Wire Fraud
Intentional Damage to a Protected Computer
Transmitting a Demand in Relation to Damaging a Protected Computer
The U.S. government could appropriately assert jurisdiction over such
offenses anywhere in the world, consistent with due process, under the
principle of protective jurisdiction. That principle holds that, “[F]or
non-citizens acting entirely abroad, a jurisdictional nexus exists when the
aim of that activity is to cause harm inside the United States or to U.S.
citizens or interests” (Cyber Digital Task Force 2020).
Bank.org: Revolutionary Approaches to Agile Innovation
A prerequisite to protecting our future customers' lifelong returns and
Bank.org’s profits calls for Bank.org’s engagement of agile innovation in
manufacturing new and revolutionary approaches to international banking
from our New York headquarters.
The key aim of the Bank.org endeavor, and our primary goal, is to attain
the legitimate financial inclusion and economic prosperity of all people,
including the excluded, under-privileged and under-served. Bank.org is
taking advantage of the New York banking industry at a crossroads. On the
one hand, digital banking services are rising to the forefront and drawing
increasing interest from customers. On the other, brick-and-mortar banking
remains an important way to connect with customers on a local and personal
level.
Bank.org intends to be a true borderless enterprise serving customers in
over 200 jurisdictions and 40+ fiat and virtual currencies.
Bank.org has the luxury of an opportunity to be fresh, clean and pure in
comparison to many of our legacy “multiple felon” bank peers directing
global operations out of New York.
Citibank has become the latest bank to be sued by a British currency
investment firm over allegations that its traders manipulated foreign
exchange markets for profit. Furthermore, expanding litigation accuses the
company of trade front-running.
Bank.org’s scope as an international bank engages xNY.io to lead our
virtual currency innovation practice. xNY.io is a pioneering instrument to
elegantly complement Bank.org’s international bank operations.
The best bank in the world has energy to pioneer relentless HR innovation
with passion to create those means, build those processes and those systems
that will facilitate inclusive solutions to those problems which rob so
many of a chance to realize their goals and achieve their full potential.
Bank.org’s barriers to global market penetration include government(s) that
sponsor our peers who historically do not factor in the social benefits of
bank competition or of effective natural monopoly regulation of global New
York firms like Goldman Sachs. That is, regulators may grant licenses to
firms that are operating at a high level as state firms and so appear
valuable to private markets. This experience is supported by Bank.org’s
analysis and vision of the best performing global online institutions
(versus money center banks), which shows the principle in practice.
Conclusion
2021 in New York now brings us to cooperation versus competition and
rationality versus altruism. As with many situations in real-life, the
games are often not zero-sum, but by cooperative efforts all players can be
better off (Larson 2021b).
In 1973, John Maynard Smith presented an idea explaining game theory and
how alpha culture exists in societies. Maynard’s hypothesis asked you to
imagine a world with doves and hawks. If there would be only hawks, their
fights would be devastating to their population. If there would be only
doves, they would be susceptible to any intruders, therefore such a
population would also not be stable. But the right combination of hawks and
doves would be evolutionarily stable (Smith & Corbin 1973).
We witness again and again that US American enterprises (aka New York
Banks), in particular, are being built by one or two supposedly shiny
figures (CEO or CFO) who have questable ethics and morals.
The qualitative effect on organizational HR Management is an Executive
Suite that assembles subpar teammates around him or her.
The firms focus on the growing experience and network of that single person
and are closely associated with the individual’s character. Business
relationships are being entered and trust being built with that individual
rather than the firm as an institution.
Startup companies like xNY.io and Bank.org that dare to explore more novel
approaches and non-hierarchical structures, though, show successes, as do
larger organizations formalizing and adopting respective strategies.
However, within the New York banking community with its various regulators,
there appears to be a window of opportunity for smart innovation.
Anecdotal observations yet again identify the root cause in the vast
multidisciplinary nature of the domain, and in the all-so-technical
backgrounds of its protagonists where Executive Suites and organizational
HR managers cling to their old habits while placing less importance on
innovation and executing modern organizational insights bank wide.
Behavioral and organizational research impressively underline a very simple
“game,” in which the conditions for survival (be nice, be provocable,
promote mutual interest) seem to be the essence of ethics and morality.
While this does not yet amount to a science of ethics or morality, the game
theory approach has clarified the conditions required for the evolution and
persistence of cooperation, and shows how Darwinian natural selection can
lead to complex behavior, including notions of morality, fairness, and
justice, beyond alpha culture.
In the 1980s, Professor of Political Science Robert Axelrod ran a
tournament inviting strategies from collaborators all over the world.
Axelrod found that the winning strategy that performed the best overall
(not in every game, but on average), was “Tit-for-Tat,” also called
look-back strategy or reciprocal altruism. It worked simply by starting the
first iteration with cooperation, then looking back at the opponent’s last
move and copying it in the next iteration (Axelrod 1980).
In summary, the best strategies were found to have these surprising
properties:
Be nice – don‘t be the first to defect.
Be provocable – return actions, both in retaliation and forgiveness.
Don‘t envy – don‘t focus on beating the opponent, but on maximizing your
own score.
Don‘t be tricky – anytime you try to exploit the opponent, you will
provoke revenge.
Bank.org is happy to make ethically sound risks to aggressively protect our
future customers' returns and our firm’s bottom line. The assumption our
competitors have is that historically New York banks’ CEOs and CFOs do not
engage the strategic roadmaps offered by a new aggressive market entrant
such as the xNY.io and Bank.org.
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1
3
Re: Meta Platforms, Inc. Board of Directors - USPTO, Digital Assets and Moscow Exchange
by Gunnar Larson 11 Nov '24
by Gunnar Larson 11 Nov '24
11 Nov '24
Nicki:
Thank you.
Gunnar
On Mon, Oct 21, 2024, 5:01 PM Chollet, Nicki <NChollet(a)ktslaw.com> wrote:
> Gunnar,
>
> I have opened a secure folder for you to put documents in. Please let me
> know if you have any problems accessing the folder.
>
> Best,
>
> Nicki
>
>
>
> Nicki
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…>
> Chollet
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…>
>
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…>
> NChollet(a)ktslaw.com
> Kilpatrick Townsend
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…>
> &
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…>Stockton
> LLP
>
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…>1100
> Peachtree Street NE
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…>
> |
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…> Suite
> 2800
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…>
> |
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…>
> Atlanta,
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…>
> GA
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…>
> 30309-4528
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%0D%0A+%7C+%0D%…>
> *T* 404 815 6010 | *M* 404 906 6948 | *F* 404 541 3387
> My Profile <http://www.ktslaw.com/en/People/C/CholletNicholeDavis> | vCard
> <http://www.ktslaw.com/vcard/NicholeDavisChollet.vcf>
>
>
>
> *From:* Gunnar Larson <g(a)xny.io>
> *Sent:* Wednesday, October 9, 2024 5:12 AM
> *To:* Chollet, Nicki <NChollet(a)ktslaw.com>
> *Cc:* investor(a)fb.com; Meta_Defensive_Disputes <
> Meta_Defensive_Disputes(a)kilpatricktownsend.com>; cypherpunks <
> cypherpunks(a)lists.cpunks.org>; Reader, Shaun <sreader(a)curtis.com>
> *Subject:* Re: Meta Platforms, Inc. Board of Directors - USPTO, Digital
> Assets and Moscow Exchange
>
>
>
> **CAUTION: External Email**
>
>
>
>
>
>
>
> Dear Ms. Chollet:
>
>
>
> We have the documents you are looking for concerning the Moscow Exchange.
>
>
>
> xNY.io - Bank.org would like to orgaize a secure channel to share this
> information with Meta.
>
>
>
> How would you like to proceed?
>
>
>
> Best,
>
>
>
> Gunnar
>
>
>
> --
>
> Gunnar Larson
>
> xNY.io - Bank.org
>
> 917-580-8053
>
>
>
> On Thu, Apr 7, 2022, 3:16 PM Chollet, Nicki <
> NChollet(a)kilpatricktownsend.com> wrote:
>
> Dear Mr. Larson,
>
> We have reviewed your correspondence and are still unable to determine the
> merits of your claim. Before we can properly evaluate or respond to your
> claim, you will need to provide additional details regarding the basis for
> your claim and documentation of your relationship with Moscow Exchange or
> ownership in the Moscow Exchange mark (for example, trademark registration
> certificates evidencing your ownership of the alleged marks in question).
>
> Meta Platforms reserves all rights.
>
>
> Sincerely,
>
>
>
>
>
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%7C+Atlanta,+GA…>
>
>
> *Nichole Davis Chollet **Kilpatrick Townsend & Stockton LLP*
> Suite 2800 | 1100 Peachtree Street NE | Atlanta, GA
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%7C+Atlanta,+GA…>
> 30309-4528
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%7C+Atlanta,+GA…>
>
> office 404
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%7C+Atlanta,+GA…>
> 815 6010 | cell 404 906 6948 | fax 404 541 3387
> nchollet(a)kilpatricktownsend.com | My Profile
> <http://www.kilpatricktownsend.com/en/People/C/CholletNicholeDavis> |
> VCard <http://www.kilpatricktownsend.com/vcard/NicholeDavisChollet.vcf>
>
> *From:* Gunnar Larson <g(a)xny.io>
> *Sent:* Thursday, April 7, 2022 2:45 PM
> *To:* Chollet, Nicki <NChollet(a)kilpatricktownsend.com>; investor(a)fb.com
> *Cc:* Meta_Defensive_Disputes <
> Meta_Defensive_Disputes(a)kilpatricktownsend.com>; cypherpunks <
> cypherpunks(a)lists.cpunks.org>
> *Subject:* Re: Meta Platforms, Inc. Board of Directors - USPTO, Digital
> Assets and Moscow Exchange
>
>
>
>
>
>
>
> Ms. Chollet:
>
> Should we fly with the Red Cross to Menlo Park?
>
> Gunnar
>
> --
>
> *Gunnar Larson - xNY.io <http://www.xny.io/> | Bank.org <http://bank.org/>*
>
> MSc
> <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…> -
> Digital Currency
>
> MBA
> <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…> - Entrepreneurship
> and Innovation (ip)
>
>
>
> G(a)xNY.io
>
> +1-646-454-9107
>
> New York, New York 10001
>
>
>
> On Wed, Apr 6, 2022 at 4:07 PM Gunnar Larson <g(a)xny.io> wrote:
>
> Ms. Chollet:
>
> Unfortunately, you receive this message with Meta's board of directors
> under delinquency.
>
>
>
> Meanwhile, xNY.io would like to learn Meta's approach to USPTO filing
> internationally in Jamaica.
>
>
>
> Ms. Chollet, Jamaica makes the story even so much more interesting and
> important.
>
>
>
> Thank you,
>
>
>
> Gunnar
>
> --
>
> *Gunnar Larson - xNY.io <http://www.xny.io/> | Bank.org <http://bank.org/>*
>
> MSc
> <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…> -
> Digital Currency
>
> MBA
> <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…> - Entrepreneurship
> and Innovation (ip)
>
>
>
> G(a)xNY.io
>
> +1-646-454-9107
>
> New York, New York 10001
>
>
>
> On Sun, Apr 3, 2022 at 8:33 PM Gunnar Larson <g(a)xny.io> wrote:
>
> Dear Ms. Chollet:
>
>
>
> Thank you again for your reply on Friday specific to Meta's USPTO mark
> application definition exactness to Moscow Exchange. Ms. Chollet, for
> reasons you may be aware of, xNY.io must kindly implore Meta's board of
> directors to recall all eight USPTO applications by 5:00pm Tuesday April 4,
> 2022 EST.
>
>
>
> Being very clear, to make sure there is no confusion to xNY.io's honest
> aim to protect digital asset innovation, Meta must understand that its
> USPTO mark filing is defined exactly to the Moscow Exchange mark. Ms.
> Chollet, laws in Russia and the United States often describe principles
> relating to integrity and ethical conduct. Anyone who is regulated
> (anywhere in the world) is subject to fit and proper requirements that can
> be interpreted at will.
>
> - Meta should understand that international peace and security is far
> more important than unnecessarily urging Meta's board of directors to do
> the right thing.
> - Furthermore, xNY.io submits Citigroup's Metaverse and Money
> whitepaper on regulation profiling Mr. Zuckerburg's idea that, "There are
> different types of integrity questions." With additional comment from
> Nadine Dorries, Member of the United Kingdom Parliament and Secretary of
> State for Digital, Culture, Media and Sport, who says "... Rebranding does
> not work. When harm is caused, we are coming after it."
> - xNY.io has collated 33 highlights to Citigroup's Metaverse and Money
> whitepaper for Meta's board as general reference
> https://drive.google.com/file/d/1REoa87GCmt2uhDp7ZYswbTRw4ygQgjsL/view?usp=…
>
> xNY.io asks not whether Meta's mark would damage the market for the Moscow
> Exchange (by, for example, devaluing it through parody or criticism), but
> whether it *usurps* the market by offering a competing substitute,
> potentially causing significant damage to digital asset purity and
> blockchain software technology innovation.
>
>
>
> Sending you the very best regards.
>
>
>
> Thank you,
>
>
>
> Gunnar Larson
>
> --
>
> *Gunnar Larson - xNY.io <http://www.xny.io/> | Bank.org <http://bank.org/>*
>
> MSc
> <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…> -
> Digital Currency
>
> MBA
> <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…> - Entrepreneurship
> and Innovation (ip)
>
>
>
> G(a)xNY.io
>
> +1-646-454-9107
>
> New York, New York 10001
>
>
>
> On Fri, Apr 1, 2022 at 6:18 PM Gunnar Larson <g(a)xny.io> wrote:
>
> Mr. Chollet:
>
>
>
> It would appear today's correspondence confirms that Meta is
> seemingly aware of xNY.io's general concern.
>
> - Meta has no real advantage questioning xNY.io's relationship with
> Moscow Exchange. Understand, xNY.io did not file USPTO application(s)
> seeking approval for a mark that is defined near exact to that of Moscow
> Exchange.
> - Furthermore, on March 17, 2022 Sber announced
> <https://www.sberbank.com/news-and-media/press-releases/article?newsID=cd44d…> digital
> asset issuance. This is one day before Meta's March 18, 2022 USPTO
> submission for mark approval relating to digital assets.
> - Meta's board of directors may understand xNY.io's general concern of
> coordination and/or lack of coordination that could risk global digital
> asset marketplace purity.
> - xNY.io asks not whether Meta's mark would damage the market for the
> Moscow Exchange (by, for example, devaluing it through parody or
> criticism), but whether it *usurps* the market by offering a competing
> substitute, potentially causing significant damage to digital asset purity
> and blockchain software technology innovation.
>
> Mr. Chollet, the last point is key to resolving any question of xNY.io's
> relationship with Moscow Exchange. xNY.io's March 24, 2022 memo to Meta is
> clear and honest. We expect that Meta will not aim to muddy the waters on
> this important concern forward.
>
>
>
> With all due respect, Meta’s board of directors may understand xNY.io
> cannot logically accept that the recent USPTO applications are not a
> marketplace manipulation exercise at xNY.io’s overall expense. Meta’s board
> of directors must ask itself, to the best of its knowledge, information,
> and belief, if further inquiry is reasonable under the circumstances?
>
>
>
> Respectfully,
>
>
>
> Gunnar Larson
>
> --
>
> *Gunnar Larson - xNY.io <http://www.xny.io/> | Bank.org <http://bank.org/>*
>
> MSc
> <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…> -
> Digital Currency
>
> MBA
> <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…> - Entrepreneurship
> and Innovation (ip)
>
>
>
> G(a)xNY.io
>
> +1-646-454-9107
>
> New York, New York 10001
>
>
>
> On Fri, Apr 1, 2022 at 4:21 PM Chollet, Nicki <
> NChollet(a)kilpatricktownsend.com> wrote:
>
> Dear Gunnar,
>
>
>
> We write to confirm we represent Meta Platforms, Inc. in connection with
> this matter. Please direct all further correspondence on this matter to our
> attention.
>
>
>
> We received your letter dated March 24, 2022 and your follow up from this
> morning. We reviewed your correspondence, however, we are unable to
> determine the merits of your claim. Specifically, your letter does not
> provide any information regarding a specific application or registration
> being asserted or any evidence of your relationship with any entity owning
> rights in the alleged Moscow Exchange mark. Before we can properly evaluate
> or respond to your claim, you will need to provide additional details
> regarding the basis for your claim and documentation of your relationship
> with Moscow Exchange or ownership in the Moscow Exchange mark.
>
>
>
> Meta Platforms reserves all rights.
>
>
>
> Sincerely,
>
>
>
>
> *Nichole Davis Chollet **Kilpatrick Townsend & Stockton LLP*
> Suite 2800 | 1100 Peachtree Street NE | Atlanta, GA
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%7C+Atlanta,+GA…>
> 30309-4528
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%7C+Atlanta,+GA…>
>
> office 404
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%7C+Atlanta,+GA…>
> 815 6010 | cell 404 906 6948 | fax 404 541 3387
> nchollet(a)kilpatricktownsend.com |
> <https://www.google.com/maps/search/1100+Peachtree+Street+NE+%7C+Atlanta,+GA…> My
> Profile
> <http://www.kilpatricktownsend.com/en/People/C/CholletNicholeDavis> |
> VCard <http://www.kilpatricktownsend.com/vcard/NicholeDavisChollet.vcf>
>
>
>
> *From:* Gunnar Larson <g(a)xny.io>
> *Sent:* Friday, April 1, 2022 7:23 AM
> *To:* investor(a)fb.com
> *Cc:* MetaProsecution <MetaProsecution(a)kilpatricktownsend.com>;
> cypherpunks <cypherpunks(a)lists.cpunks.org>
> *Subject:* Re: Meta Platforms, Inc. Board of Directors - USPTO, Digital
> Assets and Moscow Exchange
>
>
>
>
>
>
>
> Dear Meta Board of Directors:
>
> It has been eight days since our original correspondence, seeking clarity
> between Meta's logo and the Moscow Exchange logo.
>
>
>
> Offering Meta the benefit of the doubt, noting this could simply be some
> misunderstanding ... We seek Meta's clarification by 5:00pm today, Friday
> April 1, 2022.
>
>
>
> Respectfully yours,
>
>
>
> Gunnar Larson
>
> --
>
> *Gunnar Larson - xNY.io <http://www.xny.io/> | Bank.org <http://bank.org/>*
>
> MSc
> <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…> -
> Digital Currency
>
> MBA
> <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…> - Entrepreneurship
> and Innovation (ip)
>
>
>
> G(a)xNY.io
>
> +1-646-454-9107
>
> New York, New York 10001
>
>
>
> On Thu, Mar 24, 2022 at 5:20 PM Gunnar Larson <g(a)xny.io> wrote:
>
> Dear Meta Board of Directors:
>
>
>
> Please find the attached memo
> <https://docs.google.com/document/d/1f_fq1GaKNaAUGEyztdm-oMtIuEW2yXj4C5aoN0G…> addressed
> to your attention.
>
> - Today’s correspondence is to kindly submit xNY.io’s overall concern
> of Meta Platforms, Inc. and Moscow Exchange mark similarities,
> specifically, both marks seemingly resemble a geometric design consisting
> of two loops and/orovals touching or intersecting.
>
> xNY.io kindly asks Meta’s Board to respond by Friday, March 25, 2022 at
> 5:00pm EST.
>
>
>
> Respectfully yours,
>
>
>
> Gunnar Larson
>
> --
>
> *Gunnar Larson - xNY.io <http://www.xNY.io> | Bank.org <http://Bank.org>*
>
> MSc
> <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…>
> - Digital Currency
>
> MBA
> <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…>
> - Entrepreneurship and Innovation (ip)
>
>
>
> G(a)xNY.io
>
> +1-646-454-9107
>
> New York, New York 10001
>
>
>
>
>
>
>
>
>
> ------------------------------
>
>
> Confidentiality Notice:
> This communication constitutes an electronic communication within the
> meaning of the Electronic Communications Privacy Act, 18 U.S.C. Section
> 2510, and its disclosure is strictly limited to the recipient intended by
> the sender of this message. This transmission, and any attachments, may
> contain confidential attorney-client privileged information and attorney
> work product. If you are not the intended recipient, any disclosure,
> copying, distribution or use of any of the information contained in or
> attached to this transmission is STRICTLY PROHIBITED. Please contact us
> immediately by return e-mail or at 404 815 6500, and destroy the original
> transmission and its attachments without reading or saving in any manner.
> ------------------------------
>
>
> ***DISCLAIMER*** Per Treasury Department Circular 230: Any U.S. federal
> tax advice contained in this communication (including any attachments) is
> not intended or written to be used, and cannot be used, for the purpose of
> (i) avoiding penalties under the Internal Revenue Code or (ii) promoting,
> marketing or recommending to another party any transaction or matter
> addressed herein.
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
1
11
https://docs.google.com/document/d/1ajVVx6NGB9wd2GDXfLRftf0RVFpqjl8WWITvdNV…
March 10, 2022
BY ELECTRONIC MAIL
Mr. John Marzulli
United States Department of Justice
Eastern District of New York
271 Cadman Plaza East
Brooklyn New York, 11201
John.Marzulli(a)usdoj.gov
Re: Memo #4 - Goldman Sachs Deferred Prosecution Agreement
Dear Mr. Marzulli:
The Department of Justice has yet to respond to Memo #1, Memo #2 and Memo
#3 with our recent inquiry to the 1Malaysia Development Berhad Deferred
Agreement. Goldman Sachs' Deferred Prosecution Agreement
<https://www.justice.gov/usao-edny/pr/goldman-sachs-resolves-foreign-bribery…>
with the United States of America is in potential breach, with ethical
enforcement being concerned.
Memo #4 aims to associate the malfeasance in Malaysia with war crimes of
aggression (in the planning, initiation, or execution of a large-scale and
serious act of aggression), leveraging the world’s only military divided
capital city Nicosia, Cyprus.
1.
Additionally, Memo #4 aims to earn the DOJ’s assessment of New York
State’s regulatory marketplace manipulation deriving the war crime against
peace, related to the planning, preparation, initiation, waging or
participation in a common plan or conspiracy related to a war of
aggression, which can only apply in relation to international armed
conflict.
2.
In this case, the first challenge is to observe and consider the simple
idea that the DOJ’s Deferred Prosecution Agreement with Goldman Sachs
alone, through means of regulatory arbitrage naively fails to recognize the
‘cause and effect’ relationship at play at the inception of Memo #4’s
assertion of war crimes.
3.
Even with the best of intentions, perhaps unknowingly the DOJ may be
amplifying the effect of potential war crimes by indirectly supplementing
the root cause of the problem and financial model of the Deferred Agreement
being self-policing.
Mr. Marzulli, there has been an active United Nations peacekeeping mission
in Cyprus since the 1964 Turkish military invasion and occupation of the
northern third of Cyprus. Only Turkey recognises the Turkish Republic of
Northern Cyprus, while there is broad recognition that the ongoing military
presence constitutes occupation of territories that are under Turkish
military control.
-
The graduate education behind Memo #4 is a product of the University of
Nicosia’s (UNIC) main campus, located adjacent to the United Nations Buffer
Zone that separates the invaded Turkish Republic of North Cyprus and the
Republic of Cyprus, which joined the European Union in 2004.
-
Memo #4 is also a product of United Nations consultancy, based at its
Manhattan headquarters, where (today, what is now xNY.io - Bank.org)
was credited with increasing the breadth and accessibility of reference
content from the world’s most important multinational organization.
-
Memo #4’s subject of war crimes has preeminent association with such
projects as the Audio Visual Library of International Law.
Over the following sections, Memo #4 will provide a detailed timeline that
would constitute real concern of the war crime of aggression yielding the
war crime against peace in active war conflict in the world’s only military
divided capital, funded from Manhattan Island.
The Bank of Cyprus and Illegal Short Selling Irregularities of Turkey’s
Markets
Mr. Marzulli, turn this matter as we will, and look at it from any side
whatsoever, and it presents the appearance of a cross-border act of
aggression. Goldman Sachs’ potential disrespect to the Deferred Agreement’s
core values has cultivated new crimes that aim to manipulate cross-border
war crime regulatory frameworks.
-
On April 02, 2021 the Financial Times reported that Turkey fined Goldman
Sachs over alleged irregularities in short selling, just a week after
foreign investors pulled $1.9B from the country’s stock and bond markets.
Turkey’s Capital Markets Board said that Goldman Sachs was among 10
securities firms that had placed orders for short selling without proper
notification, violating rules enacted previously that temporarily
prohibited such transactions.
-
On April 20, 2021 the CyprusMail (Cyprus’ only English Language daily
newspaper) reported Goldman Sachs International acted as Global
Coordinators and Dealer Managers in a $330M bond issuance for the Bank of
Cyprus.
Given the active military conflict in Cyprus, Memo #4 notes that there is
one place on the planet you are not supposed to do this sort of thing.
Furthermore, the DOJ’s Deferred Agreement with Goldman Sachs may have been
tainted with the potential war crime of aggression, risking international
peace and the lives of United Nations peacekeepers, while jeopardizing the
United States of America’s financial security.
Concern of New York Prime Bank Instrument Fraud and Marketplace Manipulation
The United States Department of the Treasury warns that Prime Bank
Instrument Fraud schemes have attracted significant international
attention, since individuals and organizations have lost billions of
dollars worldwide. "Prime Bank Instrument Fraud" is the general term given
to prime bank fraud schemes that go by many different names.
During April 2021, Goldman Sachs could not in good faith (and, plausible
deniability) make any reasonable claim of holding a pristine relationship
with Turkey’s Central Bank or with Cyprus’ largest financial institutions,
given the 1Malaysia Development Berhad scandal and then pending Deferred
Prosecution Agreement with the United States of America.
-
Memo #4 suggests that Goldman Sachs developed a Prime Bank Instrument
Fraud program to level out yo-yo market dynamics caused by failed
marketplace manipulation exercises in Turkey and Cyprus.
-
Systematic bank fraud and/or marketplace manipulation of any kind
between Turkey and Cyprus could constitute the war crime of aggression.
-
Furthermore, Memo #4 argues that Goldman Sachs may have tried to
bambooze governments in New York, Cyprus and Turkey through regulatory
arbitrage loopholes, while Goldman seemingly may have not considered the
totality of such actions as war crimes.
Turkey has the highest inflation in Europe. It has the second-highest rate
of inflation among emerging markets, just behind Argentina. It has the 13th
highest inflation rate in the world, ranking it between South Sudan and
Nigeria. After Goldman Sachs was fined for illegal stock and bond market
short selling by the Turkish government, logic would argue further
malfeasance potentially could have been avoided by the DOJ’s 1Malaysia
Development Berhad investigation.
-
On April 15, 2021 CNBC reported that Goldman Sachs (note, the previous
section’s milestones of April 02, 2021 and April 20, 2021) crucially
removed its bias toward Turkey tightening interest rates. Goldman issued
guidance highlighting the fact that the bank thought that, “…the removal of
the tightening bias against rising inflation expectations suggests that the
TCMB (Turkish Central Bank) now has a more dovish reaction function.”
-
On August 14, 2021 the CyprusMail reported serious concern among
economists about data reporting from the Turkish Statistical Institute.
Ahmet Takan, a former official with the office of the Turkish prime
minister, acted as a whistle blower, warning that Turkey potentially was
manipulating inflation data.
-
On September 1, 2021 Reuters reported that Goldman Sachs hiked Turkish
growth forecasts. Goldman economists issued guidance stating, "Overall, the
Turkish economy has been able to grow faster than we thought without a
deterioration in its external balances, as the pickup in foreign demand has
been very supportive."
-
On November 30, 2021 Reuters reported that Goldman Sachs trimed Turkey’s
2022 growth forecast. Goldman Sachs' Murat Unur stated, "We think that the
GDP figures released today tell us little about the pace of economic
activity going forward as the recent sell-off in the Lira is likely to
impact economic activity significantly"
Mr. Marzulli, the DOJ’s Deferred Prosecution Agreement with Goldman Sachs
was signed on October 21, 2021. The timeline of events above do not
coincide with terms and conditions of the Deferred Agreement mandated by
the United States of America.
Furthermore, as an international graduate scholars of the world’s only
military divided capital on the planet, xNY.io - Bank.org should be
protected from any association of crimes against peace, related to the
planning, preparation, initiation, waging or participation in a common plan
or conspiracy related to a war of aggression, which can only apply in
relation to international armed conflict.
War Crimes Against Humanity
Mr. Marzulli, xNY.io - Bank.org is concerned that potential breaches to the
Deferred Agreement are impacting our global enterprise. Crimes against
humanity can be committed in peacetime as well as during an armed conflict.
Even a single act could fall under this exclusion ground provided it forms
part of a widespread or systematic attack against a civilian population and
the act is committed by any person (including a civilian) who had knowledge
of the attack and the link of the act to the attack.
1.
We are looking to learn more about the DOJ’s approach to assessing any
potential breaches to the Deferred Agreement’s mandates as we determine New
York State’s role in cross-border bank regulation and corresponding
innovation beyond war crimes against humanity.
2.
In order to establish whether a war crime or a crime against humanity
has been committed, the case officer should consult the relevant
international instruments and case law.
3.
Crimes against humanity are fundamentally inhumane acts, committed as
part of a systematic or widespread attack. Inhumane acts, which could reach
this threshold when committed pursuant to or in furtherance of a State or
organizational policy (potentially, New York State bank regulation).
4.
Persecution against any identifiable group or collectivity on political,
racial, national, ethnic, cultural, religious, gender, or other grounds
that are universally recognised as impermissible under international law.
5.
Furthermore, we have made 28 highlights to the Deferred Agreement
providing supporting reference to Memo #4’s overarching premise.
xNY.io - Bank.org submits Memo #4 for DOJ consideration of other inhumane
acts of a similar character intentionally causing great suffering, or
serious injury to body or to mental or physical health. Some crimes against
humanity would require an additional specific intent, such as Goldman Sachs
willfully disrespecting New York State and/or overall peace and security of
the United States of America.
Memo #1, Memo #2, Memo #3 and Memo #4 outline instances that correspond
with the associated definitions of the potential war crimes abroad and
jeopardize the future of bank innovation from New York, at great sacrifice
to the Homeland.
We hope to learn the DOJ’s approach to comment on Memo #4’s subject matter
or, without delay refer these concerns to the International Criminal Court
and/or International Court of Justice for comment.
Respectfully yours with anticipation,
Gunnar Larson - xNY.io <http://www.xny.io> | Bank.org
<http://bank.org>MSc
<https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…>
- Digital Currency
MBA
<https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…>
- Entrepreneurship and Innovation (ip)
G(a)xNY.io +1-646-454-9107
1
1
492 Highlights to UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. HILLARY R. CLINTON, et al., Defendants. ____________________
by Gunnar Larson 11 Nov '24
by Gunnar Larson 11 Nov '24
11 Nov '24
INTRODUCTION
March 24, 2022
158 Highlights:
https://drive.google.com/file/d/1zggK7lgptlZ6Qn11EndzbDloqqVxRifv/view?usp=…
1. In the run-up to the 2016 Presidential Election, Hillary Clinton and her
cohorts
orchestrated an unthinkable plot – one that shocks the conscience and is an
affront to this nation’s democracy. Acting in concert, the Defendants
maliciously conspired to weave a false narrative that their Republican
opponent, Donald J. Trump, was colluding with a hostile foreign
sovereignty.
The actions taken in furtherance of their scheme—falsifying evidence,
deceiving law enforcement, and exploiting access to highly-sensitive data
sources - are so outrageous, subversive and incendiary that even the events
of Watergate pale in comparison.
2. Under the guise of ‘opposition research,’ ‘data analytics,’ and other
political
stratagems, the Defendants nefariously sought to sway the public’s trust.
They worked together with a single, self-serving purpose: to vilify Donald
J. Trump. Indeed, their far-reaching conspiracy was designed to cripple
Trump’s bid for presidency by fabricating a scandal that would
be used to trigger an unfounded federal investigation and ignite a media
frenzy.
3. The scheme was conceived, coordinated and carried out by top-level
officials at the
Clinton Campaign and the DNC—including ‘the candidate’ herself—who
attempted to shield her involvement behind a wall of third parties.1 To
start, the Clinton Campaign and the DNC enlisted the assistance of their
shared counsel, Perkins Coie, a law firm with deep Democrat ties, in the
hopes of obscuring their actions under the veil of attorney-client
privilege. Perkins Coie was tasked with spearheading the scheme to find—or
fabricate—proof of a sinister link between Donald J. Trump and Russia.
To do so, Perkins Coie launched parallel operations: on one front, Perkins
Coie partner Marc Elias led an effort to produce spurious ‘opposition
research’ claiming
to reveal illicit ties between the Trump Campaign and Russian operatives;
on a separate front, Perkins Coie partner Michael Sussmann headed a
campaign to develop misleading evidence of a bogus ‘back channel’
connection between e-mail servers at Trump Tower and a Russian-owned
bank.
4. Marc Elias, in his mission to obtain derogatory anti-Trump ‘opposition
research,’ commissioned Fusion GPS, an investigative firm, and its
co-founders, Peter Fritsch and Glenn Simpson, and directed them to dredge
up evidence—actual or otherwise—of collusion between Trump and Russia.
Fritsch and Simpson, in turn, enlisted the assistance of Orbis Ltd. and its
owner, Christopher Steele, to produce a series of reports purporting to
contain proof of the
supposed collusion. Of course, the now fully debunked collection of
reports, known as the “Steele Dossier,” was riddled with misstatements,
misrepresentations and, most of all, flat out lies. In truth, the Steele
Dossier was largely based upon information provided to Steele by his
primary
sub-source, Igor Danchenko, who was subsequently indicted for falsifying
his claims. Even more damning, Danchenko had close ties to senior Clinton
Campaign official, Charles Halliday Dolan, Jr., who knowingly provided
false information to Danchenko, who relayed it to Steele, who
reported it in the Steele Dossier and eagerly fed the deceptions to both
the media and the FBI. This duplicitous arrangement existed for a singular
self-serving purpose – to discredit Donald J. Trump
and his campaign.
5. At the same time, Michael Sussmann, in his hunt for damaging intel
against the
Trump Campaign, turned to Neustar, Inc., an information technology company,
and one of its top executives, Rodney Joffe, a fervent anti-Trumper who had
recently been promised a high-ranking position with the Clinton
Administration, to exploit their access to non-public data in search of a
secret “back channel” connection between Trump Tower and Alfa Bank. When it
was discovered that no such channel existed, the Defendants resorted to
truly subversive measures – hacking servers at Trump Tower, Trump’s private
apartment, and, most alarmingly, the White House. This
ill-gotten data was then manipulated to create a misleading “inference” and
submitted to law enforcement in an effort to falsely implicate Donald J.
Trump and his campaign.2 All of these acts
were carried out in coordination with the Clinton Campaign and the DNC, at
the behest of certain Democratic “VIPs.”3
6. While their multi-pronged attack was underway, the Defendants seized on
the
opportunity to publicly malign Donald J. Trump by instigating a full-blown
media frenzy. Indeed, the Clinton Campaign and DNC—admittedly on a
“mission” to “raise the alarm” about their contrived Trump-Russia
link4—repeatedly fed disinformation to the media and shamelessly
promoted their false narratives. All the while, Hillary Clinton, Jake
Sullivan, Debbie Wasserman Schultz, and others did their best to
proliferate the spread of those dubious and false claims through
press releases, social media, and other public statements.
7. The fallout from the Defendants’ actions was not limited to the public
denigration
of Trump and his campaign. The Federal Bureau of Investigation
(FBI)—relying on the Defendants’ fraudulent evidence—commenced a
large-scale investigation and expended precious time, resources and
taxpayer dollars looking into the spurious allegation that the Trump
Campaign
had colluded with the Russian Government to interfere in the 2016
presidential election. The effects of this unfounded investigation were
prolonged and exacerbated by the presence of a small faction of Clinton
loyalists who were well-positioned within the Department of Justice and the
FBI
– James Comey, Andrew McCabe, Peter Strzok, Lisa Page, Kevin Clinesmith,
and Bruce Ohr. These government officials were willing to abuse their
positions of public trust to advance the baseless probe to new levels,
including obtaining an extrajudicial FISA warrant and instigating the
commencement of an oversight investigation headed by Special Counsel Robert
Mueller. As a result, Donald J. Trump and his campaign were forced to
expend tens of millions of dollars in legal
fees to defend against these contrived and unwarranted proceedings. Justice
would ultimately prevail – following a two-year investigation, Special
Counsel Mueller went on to exonerate Donald J. Trump and his campaign with
his finding that there was no evidence of collusion with Russia.
8. The full extent of the Defendants’ wrongdoing has been steadily and
gradually exposed by Special Counsel John Durham, who has been heading a
DOJ investigation into the origins of the Trump-Russia conspiracy. To date,
he has already issued indictments to Sussmann and Danchenko, among others,
for proffering false statements to law enforcement officials. As
outlined below, these ‘speaking’ indictments not only implicate many of the
Defendants named herein but also provide a great deal of insight into the
inner-workings of the Defendants’ conspiratorial enterprise. Based on
recent developments and the overall direction of Durham’s
investigation, it seems all but certain that additional indictments are
forthcoming.
9. In short, the Defendants, blinded by political ambition, orchestrated a
malicious
conspiracy to disseminate patently false and injurious information about
Donald J. Trump and his campaign, all in the hopes of destroying his life,
his political career and rigging the 2016 Presidential Election in favor of
Hillary Clinton. When their gambit failed, and Donald J. Trump
was elected, the Defendants’ efforts continued unabated, merely shifting
their focus to undermining his presidential administration. Worse still,
the Defendants continue to spread their vicious lies to this day as they
unabashedly publicize their thoroughly debunked falsehoods in an
effort to ensure that he will never be elected again. The deception,
malice, and treachery
perpetrated by the Defendants has caused significant harm to the American
people, and to the Plaintiff, Donald J. Trump, and they must be held
accountable for their heinous acts.
____________________
BACKGROUND
September 8, 2022
190 Highlights:
https://drive.google.com/file/d/1JUQtPF8f6ckSRHwLcu3S_joyF5xQoA-A/view?usp=…
Plaintiff initiated this lawsuit on March 24, 2022, alleging that “the
Defendants, blinded by political ambition, orchestrated a malicious
conspiracy to disseminate patently false and injurious
information about Donald J. Trump and his campaign, all in the hopes of
destroying his life, his political career and rigging the 2016 Presidential
Election in favor of Hillary Clinton.” (DE 177, Am. Compl. ¶ 9). On this
general premise, Plaintiff brings a claim for violations of the Racketeer
Influenced and Corrupt Organizations Act (“RICO”), predicated on the theft
of trade secrets, obstruction of justice, and wire fraud (Count I). He
additionally brings claims for: injurious falsehood (Count III); malicious
prosecution (Count V); violations of the Computer Fraud and Abuse Act
(“CFAA”) (Count VII); theft of trade secrets under the Defend Trade Secrets
Act of
2016 (“DTSA”) (Count VIII); and violations of the Stored Communications Act
(“SCA”) (Count IX). The Amended Complaint also contains counts for various
conspiracy charges and theories of agency and vicarious liability. (Counts
II, IV, VI, and X–XVI). Plaintiff’s theory of this case, set forth over 527
paragraphs in the first 118 pages of the Amended Complaint, is difficult to
summarize in a concise and cohesive manner.
It was certainly not presented that way. Nevertheless, I will attempt to
distill it here.
The short version: Plaintiff alleges that the Defendants “[a]cting in
concert . . . maliciously conspired to weave a false narrative that their
Republican opponent, Donald J. Trump, was colluding with a hostile foreign
sovereignty.” (Am. Compl. ¶ 1). The Defendants effectuated this
alleged conspiracy through two core efforts. “[O]n one front, Perkins Coie
partner Mark Elias led an effort to produce spurious ‘opposition research’
claiming to reveal illicit ties between the Trump
campaign and Russian operatives.” (Id. ¶ 3).
To that end, Defendant Hillary Clinton and her campaign, the Democratic
National Committee, and lawyers for the Campaign and the Committee
allegedly hired Defendant Fusion GPS to fabricate the Steele Dossier. (Id.
¶ 4). “[O]n a separate
front, Perkins Coie partner Michael Sussman headed a campaign to develop
misleading evidence of a bogus ‘back channel’ connection between e-mail
servers at Trump Tower and a Russian-
owned bank.” (Id.). Clinton and her operatives allegedly hired Defendant
Rodney Joffe to exploit his access to Domain Name Systems (“DNS”) data, via
Defendant Neustar, to investigate and
ultimately manufacture a suspicious pattern of activity between
Trump-related servers and a Russian bank with ties to Vladimir Putin, Alfa
Bank. (Id. ¶ 3). As a result of this “fraudulent evidence,” the Federal
Bureau of Investigations (“FBI”) commenced “several large-scale
investigations,” which were “prolonged and exacerbated by the presence of a
small faction of
Clinton loyalists who were well-positioned within the Department of
Justice”—Defendants James Comey, Andrew McCabe, Peter Strzok, Lisa Page,
Kevin Clinesmith, and Bruce Ohr. (Id. ¶ 7).
And while this was ongoing, the Defendants allegedly “seized on the
opportunity to publicly malign Donald J. Trump by instigating a full-blown
media frenzy.” (Id. ¶ 6). As a result of this “multi-pronged attack,”
Plaintiff claims to have amassed $24 million in damages.1(Id. ¶ 527).
Defendants now move to dismiss the Amended Complaint as “a series of
disconnected political disputes that Plaintiff has alchemized into a
sweeping conspiracy among the many individuals Plaintiff believes to have
aggrieved him.” (DE 226 at 1). They argue that dismissal is
warranted because Plaintiff’s claims are both “hopelessly stale”—that is,
foreclosed by the applicable statutes of limitations—and because they fail
on the merits “in multiple independent respects.” (Id. at 2). As they view
it, “[w]hatever the utilities of [the Amended Complaint] as a fundraising
tool, a press release, or a list of political grievances, it has no merit
as a lawsuit.” (Id.).
I agree. In the discussion that follows, I first address the Amended
Complaint’s structural deficiencies. I then turn to subject matter
jurisdiction and the personal jurisdiction arguments raised by certain
Defendants. Finally, I assess the sufficiency of the allegations as to each
of the
substantive counts.
____________________
BACKGROUND
October 31, 2022
25 Highlights:
https://drive.google.com/file/d/1QynNCV7iSPi-8b6dt605jmFTTNSaXtuD/view?usp=…
PlaintifP’s pleadings and theories were obviously and fatally defective
from the very
inceptionof this action. Plaintiff's initial Complaint spanned 108 pages
and S08 paragraphs. DE 1 (March 24, 2022). It named 28 individual
defendants, as well as 10 John Does and 10 ABC Corporations. /d.
Less than a month after the Complaint was filed, Hillary Clinton moved to
dismiss it with prejudice. DE 52 (Apr. 20,2022). Defendant Clinton’s motion
identified manyofthe fundamentalfactual deficiencies and legal flaws that
would ultimately lead this Court to dismiss the Amended
Complaint: namely, (1) that Plaintifs claims were untimely on their face,
DE 52 at 1-5; (2) that Plaintiff's own tweets confirmed his knowledge ofhis
supposed claimsno later than October 2017, DE 52 at 2-3; (3) that
Plaintiffs Complaint was replete with inadequate and conclusory
allegations, DE 52 at 6; (4) that Plaintiff failed to allege a RICO
enterprise, DE 52 at 7; (5) that
Plaintiff failed to allege the predicate act of theft of trade secrets
based on DNS information, DE 52 at 8-9; (6) thatPlaintifffailedtoallege the
predicate act ofobstructionofjustice in part because
he identified no “official proceeding,” DE 52 at 9-10; (7) that Plaintiff
failed to allege a patter of racketeering activity, DE 52 at 11-12; (8)
that Plaintiff failed to adequately allege RICO standing because his
supposed injuries were almostentirely undescribed, DE 52.at 12-14; (9) that
Plaintiffs injurious falsehood claim was barred by the First Amendment, DE
52 at 15-17; (10) that Plaintiff failed to allege almost every necessary
clementof injurious falsehood under Florida law, DE 52 at
17-18; (11) that Plaintiff failed to allege a malicious prosecution claim
as to any official proceeding and, in particular, as to the properly
predicated Crossfire Hurricane investigation, DE 52 at 19-20; and (12) that
Plaintiff failed to allege a claim for “agency” because it is not an
independent cause of action under Florida law.
In response, Plaintiff's counsel indicated that they planned to amend the
Complaint. DE 66 (Apr. 21, 2022). Defendant Clinton did not oppose
counsel's request for an extension of time in whichto amend. See, e.g., DE
102 (Apr. 27,2022). In the intervening period, other Defendants
joined Clinton's motion to dismiss and filed their own motions
alertingPlaintiff and his counsel to additional fatal defects in the
Complaint. See DE 124 (John Podesta), 139 (Peter Fritsch, Fusion GPS, Glenn
Simpson); 141 (DNC Services Corporation, Democratic National Committee,
Debbie Wasserman Schultz); 143 (Perkins Coie); 144 (Nellie Ohr); 145 (Robby
Mook): 146 (Michael
Sussmann); 147 (Mare Elias); 149 (HFACC); 157 (Rodney Joffe); 159 (Igor
Danchenko); 160 (Neustar, Inc.); 162 & 163 (Charles Halliday Dolan, Jr.);
165 (Jake Sullivan). With respect to each motion, Plaintiff's counsel
indicated that they planned to amend in response to the motions, and
Defendants did not oppose extensionsof time to allow them to do so. See DE
153 (May 17,2022). PlaintifP’s counsel filed the Amended Complaint
approximately two months after receiving Defendant Clinton’s motion to
dismiss and with the benefit of Defendants” additional motions in
the interim. DE 177 (June 21, 2022). “But despite this briefing, PlaintifPs
Amended Complaint failed to cureanyofthe deficiencies.”DE 267 at 63-64
(Sept. 8, 2022) (“0p.”). “Instead, Plaintiff added eighty new pages of
largely irrelevant allegations that did nothing to salvage the legal
sufficiency of his claims.” Op. at 64. The Amended Complaint is “193 pages
in length, with 819 numbered paragraphs,” and “contains 14 counts, names 31
defendants, 10 “John Does” described as fictitious and unknown persons, and
10 *ABC Corporations’ identified as fictitious and
unknown entities.” Op. at 4.
____________________
BACKGROUND
November 10, 2022
66 Highlights:
https://drive.google.com/file/d/1ppCsJe6sSJKIionWtII4rI4qRMbKzBn3/view?usp=…
The Complaint. In March 2022, Charles Dolan was among 29 defendants
initially sued by Mr. Trump. (DE 1). He was identified as a former chairman
of the DNC, a senior official in the Clinton Campaign, and a close
associate of and advisor to Hillary Clinton. The Complaint alleged
that in April 2016, Mr. Dolan participated in discussions about the
creation of a “dossier” to smear Mr. Trump and disseminate false
accusations to the media (Compl. ¶ 79), and at the direction of
Ms. Clinton assisted in preparation of the dossier (Compl. ¶ 81). According
to the Complaint, an allegation contained within the dossier that Mr. Trump
engaged in salacious sexual activity in a
Moscow hotel was derived from Mr. Dolan. (Compl. ¶ 91). Mr. Dolan was sued
for RICO
conspiracy (Count II), conspiracy to commit injurious falsehood (Count IV),
and conspiracy to
commit malicious prosecution (Count VI).
The Warning Letter. On May 31, 2022, counsel for Mr. Dolan wrote the
attorneys for Mr. Trump. They warned:
1. That Mr. Dolan had no role in any conspiracy related to the Steele
dossier.
2. That Mr. Dolan was not a source for the allegations of sexual activity.
3. That Mr. Dolan had not been in contact with any defendant other than
Igor Danchenko,
and that Mr. Dolan’s contacts with Mr. Danchenko involved business
interests and help for a conference in Moscow.
4. That Mr. Dolan had never been chairman of the DNC.
5. That Ms. Clinton was on record through a spokesperson as stating she had
no recollection of Mr. Dolan.
(DE 268-1).
The letter requested that Mr. Dolan not be named as a defendant in any
forthcoming
Amended Complaint. The letter further warned that if he were to be named,
or if he was not dropped from the original Complaint, Rule 11 sanctions
would be sought.
The Amended Complaint. On June 21, 2022, Plaintiff filed an Amended
Complaint, as
had been expected. It ballooned to 193 pages, 819 paragraphs and 31
defendants. With respect to Mr. Dolan, the allegations remained essentially
the same. But in the Amended Complaint, Mr. Dolan was identified somewhat
more vaguely as the former chairman of a “national Democratic
political organization.” (Am. Compl. ¶ 96). Elsewhere, he was described as
a “senior Clinton Campaign Official.” (Am. Compl. ¶ 4). Moreover, and
somewhat inexplicably, Mr. Dolan was identified in the Amended Complaint as
a citizen and resident of New York, despite a declaration that Mr. Dolan
had provided to Plaintiff’s lawyers explaining that Mr. Dolan was a
resident of
Virginia. (Am. Compl. ¶ 20; DE 268-2).
The Sanctions Motion and Memorandum. On July 15, 2022, Mr. Dolan served on
Mr.
Trump’s lawyers a motion seeking sanctions pursuant to Rule 11. The motion
pointed out that the change in Mr. Dolan’s purported title from “former
chairman of the DNC” in the original Complaint to “former chairman of a
national Democratic political organization,” in the Amended Complaint did
not solve the problems identified in the warning letter because Mr. Dolan
had never
been the chairman of any such organization. The motion further explained
that Mr. Dolan’s role in the Clinton Campaign was limited to knocking on
doors as a volunteer. The motion also stated
that Mr. Dolan had never been a resident of New York, that Mr. Dolan had
told Plaintiff’s lawyers so, and that the allegations of the Amended
Complaint to that effect demonstrated a lack of diligence over something
easily checked.
Mr. Dolan’s motion for sanctions went on to place the Trump lawyers on
notice of a critical failure in their claims, warning them that the
Danchenko Indictment referenced throughout the Amended Complaint not only
failed to support their allegations against Mr. Dolan but contradicted
them. That warning continues to be unheeded.
____________________
BACKGROUND
January 19, 2023
53 Highlights:
https://drive.google.com/file/d/1sf0y-bIBdwaa1PO0Y3hKWhhImoXXCfbR/view?usp=…
Plaintiff initiated this lawsuit on March 24, 2022, alleging that “the
Defendants, blinded by political ambition, orchestrated a malicious
conspiracy to disseminate patently false and injurious information about
Donald J. Trump and his campaign, all in the hope of destroying his life,
his
political career, and rigging the 2016 Presidential Election in favor of
Hillary Clinton.” (DE 1 ¶ 9).
The next day, Alina Habba, Mr. Trump’s lead counsel told Fox News’ Sean
Hannity:
You can’t make this up. You literally cannot make a story like this up . .
. and President Trump is just not going to take it anymore. If you are
going to make up lies, if you are going to try to take him down, he is
going to fight you back. And that is what this is, this is the beginning of
all that.1 She then explained on Newsmax: What the real goal [of the suit]
is, is democracy, is continuing to make sure that our elections, continuing
to make sure our justice system is not obstructed by political enemies.
That cannot happen. And that’s exactly what happened. They obstructed
justice. They
continued the false narrative . . . This grand scheme, that you could not
make up, to take down an opponent. That is un-American.2
On April 20, 2022, less than a month after the Complaint was filed, Hillary
Clinton moved for dismissal with prejudice. Her motion identified
substantial and fundamental factual and legal flaws. Each of the other
Defendants followed suit, pointing to specific problems with the claims
against them. The problems in the Complaint were obvious from the start.
They were identified by the Defendants not once but twice, and Mr. Trump
persisted anyway.
Despite this briefing and the promise “to cure any deficiencies,”
Plaintiff’s counsel filed the Amended Complaint on June 21, 2022. (DE 177).
The Amended Complaint failed to cure any of the defects. See DE 267, Order
of Dismissal (September 8, 2022). Instead, Plaintiff added
eighty new pages of largely irrelevant allegations that did nothing to
salvage the legal sufficiency of his claims. (DE 267 at 64). The Amended
Complaint is 193 pages in length, with 819 numbered paragraphs, and
contains 14 counts, names 31 defendants, 10 John Does described as
fictitious and unknown persons, and 10 ABC Corporations identified as
fictitious and unknown entities.
On July 14, 2022, the United States moved pursuant to the Westfall Act, 28
U.S.C. § 2679 (d)(i), to substitute itself as Defendant for James Comey,
Andrew McCabe, Peter Strzok, Lisa Page, and Kevin Clinesmith. (DE 224). On
July 21, 2022, I granted the motion to substitute. (DE 234).
On September 8, 2022, I dismissed the case with prejudice as to all
Defendants except for the United States.
3 I issued a detailed and lengthy Order, which I incorporate by reference
here.
(DE 267). I found that fatal substantive defects which had been clearly
laid out in the first round of briefing, precluded the Plaintiff from
proceeding under any of the theories presented. I found that the Amended
Complaint was a quintessential shotgun pleading, that its claims were
foreclosed by existing precedent, and its factual allegations were
undermined and contradicted by the public reports and filings upon which it
purported to rely. I reserved jurisdiction to adjudicate issues
pertaining to sanctions.
Undeterred by my Order and two rounds of briefing by multiple defendants,
Ms. Habba
continued to advance Plaintiff’s claims. In a September 10, 2022, interview
with Sean Hannity, the host asked her “Why isn’t [Hillary Clinton] being
held accountable for what she did?” Ms. Habba’s response reiterated
misrepresentations on which this lawsuit was based:
Because when you have a Clinton judge as we did here, Judge Middlebrooks
who I had asked to recuse himself but insisted that he didn’t need to, he
was going to be impartial, and then proceeds to write a 65-page scathing
order where he basically ignored every factual basis which was backed up by
indictments, by investigations, the Mueller report, et cetera, et cetera,
et cetera, not to mention Durham, and all the testimony we heard there, we
get dismissed.
Not only do we get dismissed, he says that this is not the proper place for
recourse for Donald Trump. He has no legal ramifications.
Where what [sic] is the proper place for him? Because the FBI won’t help
when you can do anything, obstruct justice, blatantly lie to the FBI,
Sussmann’s out, he gets acquitted, where do you go?
That’s the concern for me, where do you get that -- that recourse?4 She
also indicated that, while Mr. Trump doubted the suit would succeed, she
nevertheless “fought” to pursue it: You know, I have to share with you a
story, Sean, that I have not
shared with anybody. The recourse that I have at this point is obviously to
appeal this to the 11th Circuit as Gregg said. But when
I brought this case and we were assigned you know, this judge and we went
through the recusal process, we lost five magistrates, including Reinhart
[sic] who’s dealing with the boxes as we know.
The former president looked at me and he told me, you know what Alina.
You’re not going to win. You can’t win, just get rid of it,
don’t do the case. And I said, no, we have to fight. It’s not right what
happened. And you know, he was right, and it’s a sad day for
me personally because I fought him on [it] and I should have listened, but
I don’t want to lose hope in our system. I don’t. So,
you know I’m deciding whether we’re going to appeal it.5 Defendants now
move to recover attorneys’ fees and costs under Fed. R. Civ. P. 11, 28
U.S.C. § 1927, the Defend Trade Secrets Act, and/or this Court’s inherent
power. (DE 280 at 1).
In Part II, I find that a sanction under this Court’s inherent power is
appropriate. I do so by examining Plaintiff’s (and his lawyers’) conduct
throughout this litigation. In Part III, I look to Plaintiff’s conduct in
other cases. And in Part IV, I determine the reasonableness of Defendants’
attorneys’ fees and costs.
1
21
Elon:
Big in Idaho.
Gunnar ✌️
---------- Forwarded message ---------
From: Gunnar Larson <g(a)xny.io>
Date: Wed, May 15, 2024, 2:07 AM
Subject: Re: Plastic alternatives
To: Kevin Jacobsen <hammerman208(a)aol.com>
Morning Dad!
Thanks for sending!
Have a great day,
Gunnar
--
Gunnar Larson
xNY.io | Bank.org
MSc - Digital Currency
MBA - Entrepreneurship and Innovation (ip)
G(a)xNY.io
+1-917-580-8053
New York, New York 10001
On Tue, May 14, 2024, 7:02 PM Kevin Jacobsen <hammerman208(a)aol.com> wrote:
>
> Sent from my iPad
>
> Begin forwarded message:
>
> *From:* "Office of the VP for Research (vpresearch(a)uidaho.edu)" <
> vpresearch(a)uidaho.edu>
> *Date:* May 14, 2024 at 3:41:44 PM PDT
> *To:* Kevin Jacobsen <hammerman208(a)aol.com>, "Office of the VP for
> Research (vpresearch(a)uidaho.edu)" <vpresearch(a)uidaho.edu>
> *Subject:* *RE: Plastic alternatives*
>
>
>
> Kevin,
>
>
>
> Please reach out to Erik Coats and Armando MacDonald who are both cc’d on
> this email and they will speak with you about your project.
>
>
>
> Thank you,
>
>
>
> *LISA SNYDER*
> Executive Assistant to the Vice President
> Research and Economic Development
> Morrill Hall 105
> lsnyder(a)uidaho.edu
> 208-885-2258
>
>
>
> [image: image001.jpg]
>
>
>
>
>
>
>
>
>
> *From:* Kevin Jacobsen <hammerman208(a)aol.com>
> *Sent:* Friday, May 10, 2024 3:34 PM
> *To:* Office of the VP for Research (vpresearch(a)uidaho.edu) <
> vpresearch(a)uidaho.edu>
> *Subject:* Plastic alternatives
>
>
>
> I have looked for info on using soy protein to make replacement products
> that normally use fossil fuel for plastic. I find no info on lawn and
> garden string trimmer lines. Making from soy seems to be possible and would
> be a great product to
>
> I have looked for info on using soy protein to make replacement products that normally use fossil fuel for plastic. I find no info on lawn and garden string trimmer lines. Making from soy seems to be possible and would be a great product to sustain agriculture in our area. Hemp is another plant that could be used for the same product. Is there any research on these two?
>
> Sent from my iPad
>
>
1
1
Okay. Thank you for letting me know.
Gunnar
On Tue, Apr 23, 2024, 8:40 AM Roberta Kaplan <rkaplan(a)kaplanhecker.com>
wrote:
> I'm sorry, but I don't think we can help you on this.
> ------------------------------
> *From:* Gunnar Larson <g(a)xny.io>
> *Sent:* Tuesday, April 23, 2024 8:28:27 AM
> *To:* Roberta Kaplan <rkaplan(a)kaplanhecker.com>
> *Subject:* Re: Inquiry
>
> You don't often get email from g(a)xny.io. Learn why this is important
> <https://aka.ms/LearnAboutSenderIdentification>
> This email was sent from outside the Firm.
>
> Roberta:
>
> Thank you for your response.
>
> I wrote this LitigationFinanceJournal.com article back in 2022, now I am
> on the other side of it all.
>
> It is my understanding that the FBI is harassing my business, saying I am
> trying to use Donald Trump arguments against the Attorney General's office.
>
> That is simply not true. I am need to organize a personal attorney to
> protect myself from these attacks. I thought it could be beneficial if we
> worked together.
>
> Please let me know your thoughts.
>
> Thank you,
>
> Gunnar
> ---
>
>
> https://litigationfinancejournal.com/rnc-funding-of-trumps-legal-campaign-u…
>
>
> Litigation Finance Journal recently reported on a group of 14 state
> attorneys general that have called for action from the Department of
> Justice to review potential threats to U.S. national security from foreign
> adversaries’ engagement of litigation investment. Litigation funders and
> industry advocates have new ammo in response to the AGs’ claims, given
> recent news of the RNC funding former President Donald Trump’s various
> legal entanglements.
>
>
> According to ABC News, RNC leaders earmarked $1.6M in legal funding to
> support President Donald Trump’s defense over lawsuits brought by New York
> Attorney General Letitia James. Meanwhile, the United States Chamber of
> Commerce Institute for Legal Reform’s research has prompted 14 state
> attorneys general to ask for the Justice Department to assess national
> security risks of adversaries ‘undermining’ the United States by engaging
> litigation funding and third party investment vehicles.
>
> The group of 14 state attorneys general are concerned about foreign
> adversaries ‘weaponizing’ United States legal frameworks via litigation
> investment, to attack critical national industry and infrastructure, such
> as energy sectors. The group of 14 seeks the Department of Justice to
> detail how a network of federal agencies could engage a blueprint for
> defending United States independence from international litigation
> investors, hostile groups, agencies or governments such as Russia and China.
>
> This latest attack on the industry, prompted by the U.S. Chamber of
> Commerce, is simply another attempt to undermine the nascent and growing
> litigation funding sector. It is ironic, given that in the case of Consumer
> Legal Funding–which the Chamber specifically targets–the funding in
> question does not go to support legal fees, but rather to finance
> claimants’ livelihoods while they remain injured and unable to work.
>
> While the RNC’s funding of Trump’s legal battles does not constitute
> foreign investment, it illustrates the acceptance of third party legal
> funding across political lines, and should be noted by industry advocates
> looking to respond to the negative publicity put forth by the U.S. Chamber.
>
> On Tue, Apr 23, 2024, 7:02 AM Roberta Kaplan <rkaplan(a)kaplanhecker.com>
> wrote:
>
> Happy to talk. What is the matter?
> ------------------------------
> *From:* Gunnar Larson <g(a)xny.io>
> *Sent:* Tuesday, April 23, 2024 3:55:11 AM
> *To:* Roberta Kaplan <rkaplan(a)kaplanhecker.com>
> *Subject:* Inquiry
>
> You don't often get email from g(a)xny.io. Learn why this is important
> <https://aka.ms/LearnAboutSenderIdentification>
> This email was sent from outside the Firm.
>
> Ms. Kaplan:
>
> My name is Gunnar Larson and I am a co-founder at xNY.io - Bank.org.
>
> I was wondering if I could schedule a time to talk with your office
> concerning potentially working together on a developing matter.
>
> Thank you,
>
> Gunnar
> --
> Gunnar Larson
>
> xNY.io | Bank.org
>
> MSc - Digital Currency
> MBA - Entrepreneurship and Innovation (ip)
>
> G(a)xNY.io
>
> +1-917-580-8053
>
> New York, New York 10001
>
> ------------------------------
> This email and its attachments may contain information that is
> confidential and/or protected from disclosure by the attorney-client, work
> product or other applicable legal privilege. If you are not the intended
> recipient of the email, please be aware that any unauthorized review, use,
> disclosure, dissemination, distribution, or copying of this communication,
> or any of its contents, is strictly prohibited. If you have received this
> communication in error, please notify the sender immediately and destroy
> all copies of the message from your computer system. Thank you.
>
> ------------------------------
> This email and its attachments may contain information that is
> confidential and/or protected from disclosure by the attorney-client, work
> product or other applicable legal privilege. If you are not the intended
> recipient of the email, please be aware that any unauthorized review, use,
> disclosure, dissemination, distribution, or copying of this communication,
> or any of its contents, is strictly prohibited. If you have received this
> communication in error, please notify the sender immediately and destroy
> all copies of the message from your computer system. Thank you.
>
1
15
Gowling Taps Ashurst For 4 Real Estate Lawyers In Germany
<https://www.law360.co.uk/financial-services-uk/articles/2254982?nl_pk=a94fc…>
By Ashish Sareen
Gowling WLG announced Friday that it has recruited a four-lawyer real
estate team from Ashurst LLP to its new office in Frankfurt as it continues
to expand in Germany.
Read full article »
<https://www.law360.co.uk/financial-services-uk/articles/2254982?nl_pk=a94fc…>
| Save to favorites »
<https://www.law360.co.uk/financial-services-uk/articles/2254982?nl_pk=a94fc…>
1
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EU Sets Out Climate-Friendly Finance Targets For COP29
<https://www.law360.co.uk/financial-services-uk/articles/2258579?nl_pk=a94fc…>
By Sam Tabahriti
The European Union will later in November set out its climate finance and
investment targets at a climate change conference in Azerbaijan, pushing
for stronger global alignment with the goals of the Paris Agreement, it
said in a statement on Friday.
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<https://www.law360.co.uk/financial-services-uk/articles/2258579?nl_pk=a94fc…>
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<https://www.law360.co.uk/financial-services-uk/articles/2258579?nl_pk=a94fc…>
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FCA Confirms Rules For Commercial Pension Dashboards
<https://www.law360.co.uk/financial-services-uk/articles/2258553?nl_pk=a94fc…>
By Martin Croucher
The U.K.'s financial watchdog set out detailed rules for how commercial
pension dashboards will operate in the future, but experts say the lack of
a fixed launch date could hinder the emerging sector.
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<https://www.law360.co.uk/financial-services-uk/articles/2258553?nl_pk=a94fc…>
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