BUSINESS LAW AND LITIGATION ATTORNEYS

November 14, 2018

International Markets Live
ATTN: CHRISTOPHER TERRY
45 Rockefeller Plaza
Suite 2000
New York, NY 10111-3193

Re:
Our Client:

TIME SENSITIVE CONFIDENTIAL LEGAL DEMAND

Dear Mr. Terry,

Please take note that the firm represents

(“ ” or “our client”) to redress the issue of your efforts to steal data, improperly redirect
payments, and generally sabotage our client’s business. The law firm herein, by and through
., hereby seeks all relevant damages on behalf of .

FACTS OF THE MATTER

In February of 2017, our client began offering a Forex education program under the name
. After experiencing a great deal of initial success, was contacted by you in
September of 2017 with an offer to merge operations with your company International Markets
Live (“IML”). When our client expressed that they were not interested in this merger, you made
overt threats which included stating that you could “pay to put us out of business” and that “we
wouldn’t even see it coming.”

Following this incident, continued to enroll clients and reached 60,000 clients by
June of 2018. At this point, you took a series of actions intended to undermine and destroy our
client’s business. There is clear evidence which demonstrates that between June and July of 2018
you and your company, IML, began hosting calls threatening to sue customers that joined ,
made false claims that was having merchant account issue and wasn’t properly
compensating representatives and trades, and sought to hire current and former support
staff. Additionally, you paid internet personality “Mack Mills” to defame and harass
registered clients with targeted spam advertisements.

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 These actions escalated with your attempts to hack ’s website, which resulted in
numerous website failures, page failures, and a change to the CVV codes for the website which
redirected customer payments to IML. Further, there is clear evidence that substantial sums of
money were siphoned from ’S via IML controlled servers.

In September 2018, our client was told by that you had informed him of
your subversive actions and that these included p gents to hack
and create back doors to facilitate sabotage and the theft of customer data. A
short time later, notified management that you had solicited
passwords and company date for IML. Further investigation revealed that our client’s
had been illegally integrated with servers operating fro , which
our control.

COMPUTER FRAUD AND ABUSE

As you may be aware, the Computer Fraud and Abuse Act (CFAA) provides for civil
actions arising out of various cyber infractions which include many of the actions you have taken
against . You are liable under this statute for (1) the unauthorized accessing (2) of a
“protected” computer (3) with the intent to either (a) obtain information, (b) further a fraud, or
(c) damage the computer or its data. It should be obvious that your actions in stealing data,
redirecting customers, accessing the , and attacking ’s website meet these
elements. Therefore, our client will be able to recover all of their losses in addition to potential
injunctive and equitable damages. If you do not comply with our demand, it is our intention to
seek this type of relief and have all businesses with which you are associated, closed.

DEFAMATION

In Nevada, one is liable for the damages caused by their defamation of another party
when (1) they made a false statement of fact about the other party, (2) that they made an
unprivileged publication of the statement(s) to a third party, (3) that the defendant acted
negligently, recklessly or intentionally, (4) that as a result of the statements, your reputation was
damaged. Lubin v. Kunin, 117 Nev. 107, 111, 17 P.3d 422, 425 (2001) (quoting PETA v. Boby
Berosini, Ltd., 111 Nev. 615, 619, 895 P.2d 1269, 1272 (1995).

Here, it is clear that you have defamed by recruiting “Mack Mills” to make false
and damaging statements about our client. The investigation our firm has conducted in this area
demonstrates that the statements made by Mr. Mills on your behalf were purposefully false and
designed to cause financial harm to our client. These statements were an unprivileged publication
about our client to third parties and has suffered significant damages as a result. In
particular, you are liable for the revenue our client has lost as a result of your defamation and
attempts to solicit customers.

CONVERSION

Finally, we would like to notify you of the tort of conversion. A party is liable for
Conversion when (1) there is a distinct and intentional act of dominion which is wrongfully

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exerted over the property of another; (2) the act is committed in denial of, or inconsistent with
the rightful owner’s use and enjoyment of the property, (3) the act committed in derogation,
exclusion, or defiance of the owner’s rights or titled in the property and (4) there is causation and
damages. M.C. Multi-Family Development, L.L.C. v. Crestdale Assoc., Ltd., 193 P.3d 536, 543
(Nev., 2008).

Here, by exerting control over our client’s data and forcing client payments to be
redirected to IML, you exerted control over ’s property. This is denying our client, who is
the rightful owner, the enjoyment of the property. This is in defiance of our client’s rights and
therefore, as has suffered damages as a result of these actions, you are liable to our client
for conversion.

DAMAGES & SETTLEMENT DEMANDS

As detailed above, you are liable for the damages your actions have caused our client. We
have calculated that your acts of sabotage and defamation has resulted in damages of
since you interfered with the launch of in July of 2018. This is in
addition to other substantial damages caused by your intentional interference with our client’s
business.

Despite the substantial liability your company bears in this matter, in the interest of
expediency, our client has authorized us to settle this issue for payment of $10,800,000.00.
However, if you are unwilling to do so we will pursue all possible claims against both you and
your company. Please note that if the matter is not concluded quickly it may be determined that
the actual damages has suffered are even higher. As I’m sure you’re aware, the expense of
these claims can be substantial, and you will likely be responsible for these additional expenses.

YOU HAVE 14 DAYS TO RESPOND TO THIS DEMAND. Please respond with your
intention as to how you would like to pursue the matter herein. The longer this case remains
open, the more significant the damages will be. Additionally, while we hope that the case will be
resolved soon, inaction on your part or a refusal to resolve the matter will likely result in
litigation, the cost of which you may be responsible for. Such costs include, but are not limited
to, court fees and attorney fees. We are prepared to file a Summons and Complaint should you
not respond within 14 days.

Thank you and I hope this matter can be resolved soon. Should you have any questions or
if you would like to discuss the case herein, please call our office at or email us at

Sincerely,

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