December 2024 - cypherpunks - lists.cpunks.org

Re: SpaceX Interlocking Directors’ Intent to Manipulate Markets
by Gunnar Larson 03 Feb '25

03 Feb '25

On Thu, Nov 2, 2023, 12:52 PM Gunnar Larson <g(a)xny.io> wrote: > Dear Madam Attorney General James: > > xNY.io - Bank.org kindly seeks a response from your office concerning the > message below. > > Today in Manhattan, the FTX case will soon be sent for jury deliberation. > According to NPR, "... FTX founder Sam Bankman-Fried is accused of > orchestrating one of the largest financial frauds in history." > > Additionally, today Donald Trump's civil fraud trial continues in New York > City. > > Attorney General James, as you are aware xNY.io - Bank.org has an ongoing > dialog with your office concerning a 'RICO.' The New York State Department > of Financial Services records office has responded with a memo concerning > the "Las Vegas Museum of Organized Crime and Law Enforcement" here: > https://drive.google.com/file/d/1reLapm-6C0QJZhPKIPtN5HZGbYhTxZMh/view?usp=… > . > > This memo aims to execute N.Y. Executive Law, Article 15 § 297. Procedure > 1. Additionally, § 298-a. Application of article to certain acts committed > outside the state of New York, (Israel Crisis). > > Kind regards, > > 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 Sat, Jun 18, 2022, 4:44 PM Gunnar Larson <g(a)xny.io> wrote: > >> Dear Attorney General Letitia James: >> >> xNY.io - Bank.org, PBC seeks to earn your esteemed approval to engage the >> New York False Claims Act under urgent pretences. >> >> Today's correspondence marks the first time in history, a self-titled >> "mafia" (aka, the "PayPal Mafia '') is compelled to answer publicly the >> decision to manipulate both the New York False Claims Act and the Martin >> Act against one another. >> >> - Madam Attorney General, your leadership approach has historical >> context >> <https://www.nytimes.com/2019/12/10/climate/exxon-climate-lawsuit-new-york.h…> >> to logic and ultimate Exxon Mobil vs. New York State >> <https://drive.google.com/file/d/1nLp9RIYw8mAh1SRG8E9PMEK94SV-viUN/view?usp=…> case >> precedent. >> - xNY.io - Bank.org, PBC research and development notes our hawkish >> approach to ESG, D&O and LBO innovation. >> - xNY.io - Bank.org, PBC sees this not a democrat vs. republican >> concern as Mr. Elon Musk (CEO, SpaceX and Tesla) claims. False pretense to >> protect free speech are now being debated as party to a $200B pryamid >> scheme. >> >> Ms. James, on May 21, 2022 xNY.io - Bank.org, PBC >> <https://docs.google.com/document/d/1lv9Wt6y1ld4bNap0z3epIxttEGiP_oVpfxH0GTS…> >> contacted the SpaceX Corporation with reasonable concern of CEO Musk's >> intent behind the $44B Twitter LBO. The Orlando Police Pension Fund shared >> similar concerns to the intent behind Twitter's LBO as illegal. >> >> Since, market forces suggest that SpaceX and Tesla directors are part of >> interlocking directorate, self proclaimed the PayPal Mafia. The racket >> could waterfall to problem(s) at the New York State Department of Financial >> Services with Superintendent association to D&O insurance regulation. >> >> Ms. James, xNY.io - Bank.org, PBC seeks your office's urgent assessment >> of this matter. We aim to earn approval to explore the New York False >> Claims Act to confront SpaceX as a racket. >> >> *Like a house of cards, the PayPal Mafia racket could risk a waterfall >> of D&O interlocking directorate insolvencies. In summary: * >> >> 1. xNY.io - Bank.org's May 21, 2022 memo to SpaceX questioned intent >> behind baseless claims pioneered by SpaceX's CEO, branding ESG a scam via >> Exxon Mobil. Obviously, Exxon Mobil vs. New York State >> <https://drive.google.com/file/d/1nLp9RIYw8mAh1SRG8E9PMEK94SV-viUN/view?usp=…> alludes >> Mr. Musk party to a false claim. >> 2. SpaceX has failed to establish a preponderance of evidence and >> burden of proof not a racket. >> 3. SpaceX has failed to prove that Twitter's LBO is not false claim >> to free speech protection. >> 4. True social innovation cannot sponsor a fake news racket that >> could jeopardize space exploration and war. >> 5. Twitter's LBO dealmakers (Goldman Sachs and JP Morgan Chase) >> company balance sheets, financial statements and other corporate records do >> not impact xNY.io - Bank.org, PBC holding a racket accountable to false >> claims. >> >> The CEO of SpaceX and Tesla leveraging Exxon Mobil as an ESG >> securities scam does not preclude the PayPal Mafia's intent to engage false >> claims at the sacrifice of New York State's financial future. >> >> Madam Attorney General James, we hope to hear from your esteemed office >> and learn assessment of best next steps. >> >> Thank you, >> >> Gunnar >> >> -- >> *Gunnar Larson * >> *xNY.io <http://www.xny.io/> - Bank.org <http://bank.org/>, PBC* >> >> 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, May 22, 2022 at 9:34 AM Gunnar Larson <g(a)xny.io> wrote: >> >>> May 21, 2022 >>> >>> BY ELECTRONIC MAIL >>> >>> SpaceX Corporation >>> Board of Directors >>> One Rocket Road >>> Hawthorne, California >>> 90250 >>> Sales(a)SpaceX.com >>> >>> Re: Potential SpaceX Interlocking Directors’ Intent to Manipulate >>> Markets >>> >>> Dear SpaceX Board of Directors: >>> >>> From our New York headquarters, xNY.io - Bank.org, PBC embodies the >>> notion that rather than a merry-go-round, the process of change and >>> innovation is like a slide. >>> >>> Today’s memo aims to notify the SpaceX Corporation of concern of >>> potential market manipulation that could impact cross-border digital asset >>> innovation, free speech in the United States of America, the global ESG >>> economy and Moon exploration. >>> >>> Please find the attached memo >>> <https://docs.google.com/document/d/1lv9Wt6y1ld4bNap0z3epIxttEGiP_oVpfxH0GTS…> >>> addressed to SpaceX's board of directors. >>> >>> Respectfully, >>> >>> Gunnar Larson >>> >>

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HERE'S YOUR CHANCE TO FIGHT CITY HALL
by Gunnar Larson 01 Feb '25

01 Feb '25

Art Director/Designer: Sidney Myers Copywriter: Evan Stark Agency: Doyle Dane Bernbach, Inc. Client: Whirlpool HERE'S YOUR CHANCE TO FIGHT CITY HALL If you have a product you are not happy with, what do you do? Sit and sulk? Moan to your next-door neighbor? Promise yourself that you'll never buy another product from the manufacturer? A lot of good that will do. No, Mr. and Mrs. Consumer, that's not the answer. If you have a gripe, let the manufacturer know. Call him up. Write to him. Keep after him until he does something about it. Because nothing bothers a reputable manufacturer more than dissatisfied customers. We at Whirlpool believe in putting our money where our mouth is. We believe we make the best appliances you can buy. Automatic washers, dryers, refrigerators, air conditioners, dishwashers, etc. And we also believe our Tech-Care Service specialists provide the best service in our field. In addition, we were the first to do away with the complicated standard warranty and replace it with a fully binding, easy-to-understand warranty letter. We were first to provide a free, nation wide telephone number (800-253-1301) for service information. And we were the first to have consultants answer your calls, thereby solving many of your problems right over the phone. But still and all, we know that you can't please all of the people all of the time. That's the reason for the blank letter on the facing page. If you have a gripe about us, we want to know so we can do something about it. Just write your complaint, tear out the page and mail it to us. If you know anything at all about Whirlpool, you know it won't be ignored. By the way, if you have something nice to say about us, we'd like to hear that too. Steve Upton Vice President, Consumer Services Division Whirlpool Corporation

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Southern District of New York | SDNY Whistleblower Pilot Program
by Gunnar Larson 27 Jan '25

27 Jan '25

Dad: Please do not involve the Idaho FBI in anything to do with you or my mother. You should immediately consider contacting the link below for consideration of the SDNY Whistleblower Pilot Program. This is a new program launched June 24, 2024. I will call mom on Monday to see if she would like me to fill out the form for her, given Federal Dissability guidelines. It is my understanding that the Idaho FBI and the New York FBI could have been concerned that you or mom may have been a good target for entrapment, given my role at xNY.io - Bank.org. Dad, understand that the good people across the FBI expect that no one feels above the law. Even if you were indeed entraped, it is not the FBI's mandate to prevent anyone from malfeasance. All this said, because I am nearly certain my role in New York is part of all this, please waste no time in contacting the the SDNY Whistleblower Pilot Program. Given your being in Idaho, one might think Idahoans would not qualify. However, given my association you (AND MY MOTHER) would be covered cross border via New York Human Rights Law. Dad, I thank you in advance for perrserving a constructive relationship with the Idaho FBI. Like I said, I will call Mom on Monday to see if she would like to consider the idea separately. Love, Gunnar -- https://www.justice.gov/usao-sdny/sdny-whistleblower-pilot-pgram Skip to main content An official website of the United States government Here's how you know SDNY Whistleblower Pilot Program Share right caret (Individual Voluntary Self-Disclosure Program) SDNY Whistleblower Pilot Program: The Office has launched an SDNY Whistleblower Pilot Program designed to encourage early and voluntary self-disclosure of criminal conduct by individual participants in certain non-violent offenses. In exchange for such self-disclosure and cooperation, the Office will enter into a non-prosecution agreement where certain specified conditions are met, including, importantly, the condition that the Government was not previously aware of the criminal conduct that is the subject of the disclosure. By providing clarity on the requirements and the benefits of such self-disclosure, we seek to incentivize individuals (and their counsel) to provide actionable and timely information. That will, in turn, help us bring more misconduct to light and better protect the communities we serve. The Policy can be found here: Policy Effective 2-13-24. Our WBP Intake Form can be found here: WBP Intake Form Effective 2-13-24 Please email the WBP Intake Form to the following email address: USANYS.WBP(a)usdoj.gov The FAQs can be found here: SDNY Whistleblower Program Frequently Asked Questions (FAQs) Updated June 24, 2024 envelope icon Southern District of New York 26 Federal Plaza, 37th Floor New York, NY 10278

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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 26 Jan '25

26 Jan '25

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.

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Memo #4 - Goldman Sachs Deferred Prosecution Agreement
by Gunnar Larson 18 Jan '25

18 Jan '25

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

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xNY.io CRYPTOBANK White Paper
by Gunnar Larson 15 Jan '25

15 Jan '25

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. Bibliography Al-Naji, N., Chen, J. & Diao, L., 2018. Basis: A Price-Stable Cryptocurrency with an Algorithmic Central Bank. Basis.io, 0.99.7. Available at: http://www.basis.io/basis_whitepaper_en.pdf [Accessed April 24, 2021]. Association for Computing Machinery, 2020. On the Feasibility of Automating Stock Market Manipulation. ACSAC ’20: Annual Computer Security Applications Conference, p.962. 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Available at: https://prohashing.com/guides/earning-interest-on-cryptocurrencies [Accessed April 27, 2021]. Tarver, E. & James, M., 2021. Horizontal vs. Vertical Integration: What’s the Difference? Investopedia.com. Available at: https://www.investopedia.com/ask/answers/051315/what-difference-between-hor… [Accessed April 24, 2021]. Tierney, S., 2019. MoneyGram Money Transfer Review. NerdWallet.com. Available at: https://www.nerdwallet.com/article/banking/moneygram-review [Accessed April 26, 2021]. Torpey, K., 2018. Founding PayPal CEO Bill Harris Says Bitcoin Is A Scam, Here’s Why He’s Wrong. Forbes.com. Available at: https://www.forbes.com/sites/ktorpey/2018/04/24/founding-paypal-ceo-bill-ha… [Accessed April 25, 2021]. Trenchev, A., 2018. NEXO Token Utilities, London, United Kingdom: NEXO.io. Available at: https://nexo.io/token [Accessed April 27, 2021]. U.S. Congress, 2002. Fraud and related activity in connection with computer, Available at: https://uscode.house.gov/view.xhtml?req=(title:18%20section:1030%20edition:… [Accessed April 24, 2021]. U.S. Securities and Exchange Commission (SEC), Ponzi schemes Using virtual Currencies , SEC.gov. Available at: https://www.sec.gov/files/ia_virtualcurrencies.pdf [Accessed April 26, 2021]. u/zylstrar, 2019. Can someone share Nexo’s financial licenses? Reddit.com. Available at: https://www.reddit.com/r/Nexo/comments/eduft4/can_someone_share_nexos_finan… [Accessed April 27, 2021]. United Nations, 1948. Universal Declaration of Human Rights (UDHR), Available at: https://www.un.org/en/about-us/universal-declaration-of-human-rights [Accessed April 20, 2021]. Vostok Emerging Finance Ltd, 2020. YEAR-END REPORT 2019, Sweden: Vostok Emerging Finance. Available at: https://ml-eu.globenewswire.com/Resource/Download/3dd0f660-8cd7-4964-83d6-e… [Accessed April 26, 2021]. Wikipedia., 2021. IBM. Wikipedia.com. 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Meta Platforms, Inc. Board of Directors - USPTO, Digital Assets and Moscow Exchange
by Gunnar Larson 11 Jan '25

11 Jan '25

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

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Fwd: Memo #4 - Goldman Sachs Deferred Prosecution Agreement
by Gunnar Larson 10 Jan '25

10 Jan '25

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

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The Birth of Holiness | Marianne Williamson Video
by Gunnar Larson 10 Jan '25

10 Jan '25

Gunnar Donald Arthur Peter Larson: https://drive.google.com/file/d/1FMzGT_6VLXHwBxq94kQn7dZmf5OLg6Um/view?usp=… ----- Marianne Williamson once posted on Facebook that "today there is a burst of holiness due to all people who, if even for a moment, embrace the possibility of divine love on earth". Williamson is an author and speaker who teaches that divine love is the core of every human mind. She believes that this message can help people avoid misinterpretations of the Bible that can lead to harm. Williamson's teachings are a blend of Christianity, Buddhism, pop psychology, and 12-step recovery wisdom. She has written several books, including The Age of Miracles, Everyday Grace, and A Woman's Worth.

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Office of Public Affairs | Cholo Abdi Abdullah Convicted for Conspiring to Commit 9/11-Style Attack at the Direction of Al Shabaab | United States Department of Justice
by Gunnar Larson 06 Jan '25

06 Jan '25

https://www.justice.gov/opa/pr/cholo-abdi-abdullah-convicted-conspiring-com… A jury returned a guilty verdict today against Cholo Abdi Abdullah, 34, on all six counts in the indictment, which included conspiring to provide, and providing, material support to a foreign terrorist organization; and conspiring to murder U.S. nationals, commit aircraft piracy, destroy aircraft, and commit transnational acts of terrorism. Abdullah is scheduled to be sentenced on March 10, 2025. “The jury found that Cholo Abdi Abdullah, an operative of the terrorist organization al Shabaab, conspired to murder Americans in a terrorist attack reminiscent of the September 11 attack on our country,” said Attorney General Merrick B. Garland. “Today’s conviction ensures that Abdullah will spend decades in prison for his crimes. The Justice Department will never stop working to identify, investigate, and prosecute those who would use heinous acts of violence to harm the American people. It does not matter where terrorists hide, they will not evade the long arm of the law.” “Today, the jury returned a unanimous verdict holding Cholo Abdi Abdullah responsible for trying to replicate one of history’s most heinous acts of terrorism,” said U.S. Attorney Damian Williams for the Southern District of New York. “Abdullah trained with al Shabaab for months in Somalia to become a deadly terrorist, and then spent months at flight school preparing to hijack a commercial aircraft to crash it into a building in the United States. Abdullah relentlessly pursued his goals and was on the cusp of getting a commercial pilot license while conducting extensive attack planning, such as how to breach an airplane cockpit door. I commend the tireless work of our federal law enforcement partners and the career national security prosecutors of this office. This effort has been carried forward by generations of agents and prosecutors who never relented in their effort to bring Abdullah to justice and keep this nation safe. Thanks to their work and today’s verdict, Abdullah will now serve a lengthy sentence in federal prison.” According to the indictment and the evidence presented at trial, Abdullah was an operative for the foreign terrorist organization Harakat al-Shabaab al-Mijahideen, commonly known as “al Shabaab,” based in Somalia. After training with al Shabaab for months with AK-47 assault rifles and explosives at a series of safe houses in Somalia, Abdullah participated in a plot to hijack a commercial aircraft and crash it into a building in the U.S. He spent months at a flight school in the Philippines working toward a commercial pilot license, and researched how to obtain pilot jobs, targets such as the tallest buildings in a major American city, transit visas to the U.S., and how to open a cockpit door from the outside. Abdullah also sent encrypted messages reporting his progress to his al Shabaab handler, including his extensive research on post-September 11 hijackings. Abdullah conspired to commit this attack on behalf Al Shabaab, which has sworn allegiance to al Qaeda and is responsible for numerous deadly terrorist attacks, including attacks that have claimed American lives. Starting in or about 2019, al Shabaab embarked on a string of terrorist attacks as part of an operation in response to the U.S.’s decision to move its embassy in Israel to Jerusalem, which the group has dubbed “Operation Jerusalem Will Never be Judaized.” In particular, these terrorist attacks perpetrated by al Shabaab included an attack on Jan. 15, 2019, at a hotel in Nairobi, Kenya, which resulted in the deaths of approximately 21 people, including a U.S. national and survivor of al Qaeda’s September 11 attack on the World Trade Center in New York; a Sept. 30, 2019, attack on a U.S. military facility in Somalia; and a Jan. 5, 2020, attack on another U.S. facility in Kenya, in which three Americans were killed. Abdullah was convicted on six counts: conspiring to provide material support to a foreign terrorist organization, for which he faces a maximum penalty of 20 years in prison; providing material support to a foreign terrorist organization, for which he faces a maximum penalty of 20 years in prison; conspiring to murder U.S. nationals, for which he faces a maximum penalty of life in prison; conspiring to commit aircraft piracy, for which he faces a mandatory minimum penalty of 20 years in prison and a maximum penalty of life in prison; conspiring to destroy aircraft, for which he faces a maximum penalty of 20 years in prison; and conspiring to commit acts of terrorism transcending national boundaries, for which he faces a maximum penalty of life in prison. The FBI New York Field Office’s Joint Terrorism Task Force investigated the case. The Justice Department also thanks the FBI Legal Attaché Offices in Nairobi, Kenya, and Manila, Philippines; the FBI’s Hudson Valley Resident Agency; the Office of International Affairs of the Department of Justice’s Criminal Division; the U.S. Department of Defense; the Kenyan Directorate of Criminal Investigations, including the Anti-Terrorism Police Unit and the Joint Terrorism Task Force-Kenya; the Office of the Director of Public Prosecutions in Kenya; the Philippine National Police; the Philippine Department of Justice; the Joint Terrorism Financial Investigations Group-Philippines; and the Philippine Bureau of Immigration, for their assistance. Assistant U.S. Attorneys Nicholas S. Bradley and Jonathan L. Bodansky for the Southern District of New York and Trial Attorney John Cella of the National Security Division's Counterterrorism Section are prosecuting the case.

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