Named Defendants

Alleged role in the enterprise

Personally promoted the fundraiser.com AI Hackathon, personally declared himself the sponsor of its $1M+ prize pool, and personally brokered the introduction of an enterprise contact (Issa, "Head of hackathon") to a hackathon participant's family member by direct message — Exhibits 26, 27, 30, 67. Publicly endorsed Plaintiff's "Bangchain" submission on X/Twitter, generating ~71,500 views and, the complaint alleges, driving inflated demand for a coordinated, unauthorized cryptocurrency token bearing the same name (¶49(f)). Caught on camera saying: "SEC, come for me. I'm in Romania… we're scammers… I'm gonna pump a coin up, make 10M, peel it off" — Exhibit 57, a first-person admission of pump-and-dump methodology and modus operandi (¶2a, predicate (aa)). Personally promoted the $DADDY cryptocurrency token through coordinated transmissions and publicly committed to artificially inflate its market capitalization "even if I have to buy it all myself" — Exhibit 56.

Alleged role in the enterprise

Operates the verified @TateTheTalisman X/Twitter account that, on June 13, 2024, introduced the $DADDY cryptocurrency token with an embedded Solana blockchain transaction screenshot and ran a "burn or take the cash and run" public poll — Exhibit 59. Together with Emory Andrew Tate III, alleged to have jointly exercised centralized operational authority, strategic direction, and economic control over the operator-defendant infrastructure, monetization vehicles, and enterprise components alleged in the FAC (¶5).

Alleged role in the enterprise

Self-identifies in the jointherealworld.com Privacy Policy as "Owned and Managed by New Era Learning LLC" — Exhibit 16. Publicly designated as a "Main Sponsor" of the fundraiser.com Hackathon under the on-page representation that Main Sponsors "support and fund this groundbreaking event," even though no actual sponsor commitment existed and the prize-fund wallet held under $17,000 at the time the representation was made (¶49(e); Exhibit 15). Does not appear in the Delaware Division of Corporations records, raising the question whether the LLC exists at all; the operations are conducted under the THE REAL WORLD federally registered trademark held by Defied Trust Digital Trading – FZCO LLC.

Alleged role in the enterprise

Acts as the domestic subscription-payment processor and "agent" of New Era — collecting $99/month subscription fees from Hackathon-driven applicants on continuous billing cycles that ran before, during, and after the contest window (¶49(d), ¶48(f)). Alleged to (i) conceal the identity of the underlying commercial enterprise actually collecting subscription revenue by serving as the consumer-facing payment processor of record, and (ii) transmit the collected subscription proceeds out of the United States, upstream to Thrift Technologies LLC and ultimately to Tate-controlled accounts and structures offshore. Formed February 6, 2023 — thirty-seven days after its parent Thrift Technologies — sharing the same registered agent and Dover, Delaware address.

Alleged role in the enterprise

Receives upstream remittances of subscription proceeds from Thrifty Consulting; Andrew Joslin, its sole Governor and managing principal, alleged to direct all subscription-infrastructure decisions including the custom integration of Thrifty's payment system with the fundraiser.com/apply lending-arm portal (¶48(c); Exhibit 35; ECF Nos. 25, 27). Formed December 31, 2022 — the coordinated thirty-seven-day formation sequence with Thrifty, shared registered agent, shared corporate-address infrastructure, and absence of independent capitalization are pleaded as consistent with a single enterprise design.

Alleged role in the enterprise

Alleged to exercise operational control over the subscription payment infrastructure of jointherealworld.com and fundraiser.com/apply, personally directing the custom integration of Thrifty's payment systems with the Hackathon application portal (¶48(c)). Personally liable as a managing agent of Thrifty Consulting LLC for the enterprise's deceptive trade practices under NRS 598.0979. Identified by sworn declaration of Thrifty's counsel (ECF No. 27) and by Joslin's own sworn declaration (ECF No. 25, Ex. 1).

Alleged role in the enterprise

Identified in the jointherealworld.com Privacy Policy as a distribution partner at 221 N. Broad Street, Middletown, Delaware 19709 — Exhibit 16. The complaint pleads that Plaintiff has been unable to confirm that Legendary Courses, Inc. exists as a currently registered Delaware corporation; named in the alternative, with the disclosed-entity designation alleged to lend apparent legitimacy to the scheme while obscuring beneficial ownership (¶48(a)(4)). The use of a non-existent or fictitious entity name in consumer-facing disclosures is itself pleaded as a deceptive trade practice under NRS 598.0923(3).

Alleged role in the enterprise

Holds the federally registered trademarks for THE REAL WORLD (Reg. No. 8238028), COBRATATE (Reg. No. 7568611), TOP G (Reg. No. 8037966), and twelve additional Tate-ecosystem marks deployed uniformly across fundraiser.com, cobratate.com, jointherealworld.com, topg.com, neweralearning.net, university.com, and thewarroom.ag — Exhibits 19, 20, 21, 22. Pleaded as the "brand-authorization and structural-concealment layer" of the RICO enterprise: the trademark holder whose authorization enabled every consumer-facing Tate-branded wire transmission while simultaneously concealing beneficial ownership behind a UAE free-zone shell (¶48(a)(4)). Operates a website with a placeholder Dubai address (conflicting with USPTO records), a placeholder phone number, and an @DefiedTrust X account that has publicly disclosed crypto/launchpad operations under the "Defied Bank" brand — Exhibits 62, 63, 64.

Alleged role in the enterprise

Alleged platform host, prize-representation publisher, submission recipient, and showcase maintainer for the Hackathon. Operates the contest platform that transmitted and continues to transmit a $1,000,000+ prize-pool display (Exhibits 8, 23), the free Hackathon submission form (Exhibit 24), the integrated /apply lending-arm portal requiring an active $99/month Real World subscription as a condition of any funding consideration, and the homepage representation "Access Up To $1M In Venture Capital Funding" (Exhibits 42, 77). Publicly replied "We encourage you!" to Tate's January 12, 2025 sponsorship video on the date of its transmission (Exhibit 41). Following the filing of this action, alleged to have deleted all originally authored posts on the @fundraiser_com X/Twitter account — pleaded as potential spoliation of electronically stored information warranting an adverse-inference instruction under Fed. R. Civ. P. 37(e) (¶48(e)).

Alleged role in the enterprise

Operates the "navigation bridge" between fundraiser.com and topg.com, and the Formspree-backed contact form reached from the only contact link available on fundraiser.com (¶48(b); Exhibits 17, 36, 37). Alleged to harvest participant contact data into the enterprise's commercial marketing distribution list — submissions purportedly seeking direct access to Tate are alleged to instead populate a commercial email list without disclosure (Exhibit 37). Operates a forensically mapped 21-field lead-qualification quiz at cobratate.com/form (redirect chain ending at form.typeform.com), with terminal outcomes including a redirect to thewarroom.ag — Exhibit 66. "Talisman Enterprises" appears in no publicly accessible corporate registry.

Alleged role in the enterprise

Operates the subscription portal designated as a "Main Sponsor" of the Hackathon, with shared Google Tag Manager backend integration to fundraiser.com (Exhibit 18) and subscription-verification API integration with fundraiser.com/apply (Exhibit 35). Operates the "UNFAIR ADVANTAGE" cryptocurrency landing page — "96% of people lose in crypto. You require an… UNFAIR ADVANTAGE" — Exhibit 71. The Real World identity-verification API integration with fundraiser.com is alleged to have been dismantled or to have broken after this lawsuit was filed, but is still recoverable from source code (Exhibit 35).

Alleged role in the enterprise

Brand-authority lender designated as Main Sponsor of the Hackathon and operator of the apparel-revenue outbound node from cobratate.com (¶48(b)). The TOP G federally registered trademark (Reg. No. 8037966) deployed on the site is held by Defied Trust Digital Trading – FZCO LLC.

Alleged role in the enterprise

On January 30, 2025, contacted Plaintiff's family member on Telegram within minutes of Defendant Tate's direct-message identifying Issa as the "Head of hackathon," opening the conversation with "andrew told me to text you" — Exhibits 30, 31. Communicated that locking 25% of the Bangchain cryptocurrency token supply was a condition of placement and promotion within the fundraiser.com ecosystem (Exhibit 31). Pleaded, on information and belief, as the token developer and price-manipulation coordinator who minted the Bangchain token bearing Plaintiff's AI project name and coordinated pump-and-dump trading activity (¶48(b)). On information and belief, also the developer of the $DADDY token (¶5k(2); Exhibit 60). Operates the @issasthoughts Telegram channel with 8,952 subscribers and channel bio "No crying in the casino" — Exhibit 69. Posted "thank you for submitting to the hackathon" on the Telegram channel on January 30, 2025 — Exhibit 73.

Alleged role in the enterprise

Operates the support hub publicly identifying jointherealworld.com and university.com as "our platforms" — Exhibit 46 — and operating the support@neweralearning.net consumer-support infrastructure for Hustlers University (predecessor) and Real World subscribers continuously from at least July 8, 2022 to the present (Exhibit 44). On information and belief, orchestrates the coordinated false "SOLD OUT" pricing display across both subscription portals — Exhibit 45. Operates a Formspree-backed contact-form backend at neweralearning.net/#contact with no entity-disclosed direct contact channel (Exhibit 61).

Alleged role in the enterprise

Operates a subscription pricing architecture — Conquer $99/mo / Vanguard $499/mo "SOLD OUT" — identical to jointherealworld.com, pleaded as demonstrating coordinated commercial operation across both portals under common enterprise control (Exhibit 45). Operates the "UNIVERSITY.COM CRYPTO CAMPUS" enrollment page presenting parallel "unfair advantage / robust strategy" cryptocurrency-instruction messaging to that displayed on jointherealworld.com — Exhibit 72.

Alleged role in the enterprise

Operates the thewarroom.ag live-chat-to-Telegram intake and payment infrastructure. War Room paid-membership pricing disclosed at $7,979 USD via bank transfer or cryptocurrency only, captured from the chat-agent on May 14, 2026 — Exhibit 66. The Telegram conversation step is conducted with the account "Alexander Cobratate" (registered February 2026, Trinidad and Tobago telephone number, labeled by Telegram as "Not an official account"), and the thewarroom.ag/pay page returned "Payment Successful" for a $1.00 War Room Membership charge after the charge-amount URL parameter was edited — Exhibit 68. Sent automated payment receipt from "The War Room" <billing@reachtwr.com> confirming the $1 charge — Exhibit 74.