Playboy-v-Global-Blockchain Update On Shidan Gouran SCAM

Electronically FILED by Superior Court of California, County of Los Angeles on 07/17/2019 01:35 PM Sherri R.
Carter, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk
1 AKIN GUMP STRAUSS HAUER & FELD LLP

SUSAN K. LEADER (SBN 216743)
2 sleader@akingump.com
BRETT M. MANISCO (SBN 318351)
3 bmanisco@akingump.com
1999 Avenue of the Stars, Suite 600
4 Los Angeles, CA 90067-6022
Telephone: 310.229.1000
5 Facsimile: 310.229.1001
6 Attorneys for Plaintiff and Cross-Defendant
Playboy Enterprises, Inc.
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA

9 FOR THE COUNTY OF LOS ANGELES
10
PLAYBOY ENTERPRISES, INC., a Delaware Case No. BC716374
11 Corporation,
[Assigned To The Honorable Elaine Lu For
12 Plaintiff, All Purposes, Dept. 26]
13 v.
DECLARATION OF BRETT M.
14 GLOBAL BLOCKCHAIN TECHNOLOGIES MANISCO IN SUPPORT OF
CORPORATION, a Canadian corporation; SHIDAN PLAINTIFF’S PLAYBOY
15 GOURAN, an individual; TOKKEN MSB INC., a ENTERPRISES, INC., A DELAWARE
Canadian corporation; VICE INDUSTRY TOKEN, CORPORATION OPPOSITION TO
16 INC., a California corporation; STUART DUNCAN, DEFENDANT STUART DUNCAN’S
an individual; and DOES 1-10 inclusive, MOTION TO DISMISS FOR LACK OF
17 PERSONAL JURISDICTION OR IN
Defendants. THE ALTERNATIVE FORUM NON
18 CONVENIENS
19
20
GLOBAL BLOCKCHAIN TECHNOLOGIES
21 CORPORATION, a Canadian corporation
22 Cross-Complainant,
Date: July 30, 2019
23 vs. Time: 8:30 a.m.
Dept.: 26
24 PLAYBOY ENTERPRISES, INC., a Delaware
corporation; TOKKEN MSB INC., a Canadian
25 corporation; VICE INDUSTRY TOKEN, INC., a Reservation ID: 123339694809
California corporation; STUART DUNCAN, an
26 individual; and ROES 1-10 inclusive,
Date Action Filed: August 3, 2018
27 Cross-Defendants.
28
DECLARATION OF BRETT M. MANISCO IN SUPPORT OF PLAINTIFF’S PLAYBOY ENTERPRISES, INC., A
DELAWARE CORPORATION OPPOSITION TO DEFENDANT STUART DUNCAN’S MOTION TO DISMISS FOR
LACK OF PERSONAL JURISDICTION OR IN THE ALTERNATIVE FORUM NON CONVENIENS
1 DECLARATION OF BRETT M. MANISCO
2
I, Brett M. Manisco, declare as follows:
3
1. I am an attorney at Akin Gump Strauss Hauer & Feld LLP, counsel of record for
4
Plaintiff Playboy Enterprises, Inc. (“Playboy”), in Playboy Enterprises, Inc., et al v. Global Blockchain
5
Technologies Corporation, et al. I am an attorney admitted to practice before the Courts of the State of
6
California. I have personal knowledge of the matters set forth in this declaration, and, if called as a
7
witness, could and would testify competently thereto.
8
2. This Declaration is submitted in support of Plaintiff Playboy’s opposition to Defendant
9
Stuart Duncan’s motion to dismiss for lack of personal jurisdiction or in the alternative forum non
10
conveniens.
11
3. A true and correct copy of a Statement of Information filed by Vice Industry Token, Inc.
12
with the California Secretary of State, which I retrieved from the California Secretary of State’s
13
website, is attached hereto as Exhibit 1.
14
4. A true and correct copy of a printout of a Federal Corporation Information search from
15
the Government of Canada’s website corresponding to Tokken MSB, Inc is attached hereto as Exhibit
16
2.
17
5. A true and correct copy of the Whitepaper for Vice Industry Token is attached hereto as
18
Exhibit 3.
19
6. A true and correct copy of the draft MOU that Mr. Duncan sent to Mr. Gouran on
20
February 5, 2018 is attached hereto as Exhibit 4. Defendant Global Blockchain Technologies Corp.
21
(“GBT”) produced this document in response to Playboy’s Requests for Production of Documents and
22
Things, Set One.
23
7. A true and correct copy of Playboy’s First Amended Complaint is attached hereto as
24
Exhibit 5.
25
8. A true and correct copy of a March 8, 2018 email communication between Mr. Gouran
26
and Mr. Duncan is attached hereto as Exhibit 6. Defendant Global Blockchain Technologies Corp.
27
28 1
1 (“GBT”) produced this document in response to Playboy’s Requests for Production of Documents and
2 Things, Set One.
3 9. A true and correct copy of a March 14, 2018 email communication between Mr.
4 Duncan, his representatives, and Playboy, is attached hereto as Exhibit 7. Defendant Global
5 Blockchain Technologies Corp. (“GBT”) produced this document in response to Playboy’s Requests
6 for Production of Documents and Things, Set One.
7 10. A true and correct copy of the press release Playboy issued on March 14, 20189 is
8 attached hereto as Exhibit 8.
9 11. A true and correct copy of a March 16, 2018 email communication between Mr. Duncan
10 and Mr. Gouran is attached hereto as Exhibit 9. Defendant Global Blockchain Technologies Corp.
12 Things, Set One.
13 12. A true and correct copy of the Memorandum that Mr. Gouran emailed to Mr. Duncan on
14 March 16, 2018 is attached hereto as Exhibit 10. Defendant Global Blockchain Technologies Corp.
16 Things, Set One.
17 13. A true and correct copy of GBT’s responses to Playboy’s First set of Special
18 Interrogatories are attached hereto as Exhibit 11.
19 14. A true and correct copy of a printout from the United States Patent and Trademark
20 office regarding Mr. Duncan’s ownership of the trademark for the phrase, “Get Paid to Watch Porn” is
21 attached hereto as Exhibit 12.
22 15. A true and correct copy of Defendant Vice Industry Token, Inc.’s Special Interrogatories
23 to Playboy are attached hereto as Exhibit 13.
24 16. A true and correct copy of Defendant Vice Industry Token, Inc.’s Requests for
25 Production of Documents to Playboy are attached hereto as Exhibit 14.
26
27
28 2
1 17. A true and correct copy of the Certificate of Amendment of Articles of Incorporation
2 filed by Vice Industry Token, Inc. with the Secretary of State of California, which I retrieved from the
3 California Secretary of State’s website, is attached hereto as Exhibit 15.
4 I certify under penalty of perjury under the laws of California that the foregoing is true and
5 correct.
6 Executed on July 17, 2019 at Los Angeles, California.
7
9 Brett M. Manisco
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28 3
EXHIBIT 1
State of California S
Secretary of State
Statement of Information FW11138
(Domestic Stock and Agricultural Cooperative Corporations)
FEES (Filing and Disclosure): $25.00.
If this is an amendment, see instructions.
FILED
IMPORTANT – READ INSTRUCTIONS BEFORE COMPLETING THIS FORM In the office of the Secretary of State
1. CORPORATE NAME of the State of California
VICE INDUSTRY TOKEN, INC.
APR-19 2018
2. CALIFORNIA CORPORATE NUMBER

C4096615 This Space for Filing Use Only
No Change Statement (Not applicable if agent address of record is a P.O. Box address. See instructions.)
3. If there have been any changes to the information contained in the last Statement of Information filed with the California Secretary
of State, or no statement of information has been previously filed, this form must be completed in its entirety.
If there has been no change in any of the information contained in the last Statement of Information filed with the California Secretary
of State, check the box and proceed to Item 17.
Complete Addresses for the Following (Do not abbreviate the name of the city. Items 4 and 5 cannot be P.O. Boxes.)
4. STREET ADDRESS OF PRINCIPAL EXECUTIVE OFFICE CITY STATE ZIP CODE
9663 SANTA MONICA BLVD 450, BEVERLY HILLS, CA 90210
5. STREET ADDRESS OF PRINCIPAL BUSINESS OFFICE IN CALIFORNIA, IF ANY CITY STATE ZIP CODE
6. MAILING ADDRESS OF CORPORATION, IF DIFFERENT THAN ITEM 4 CITY STATE ZIP CODE
7. EMAIL ADDRESS FOR RECEIVING STATUTORY NOTIFICATIONS
Names and Complete Addresses of the Following Officers (The corporation must list these three officers. A comparable title for the specific
officer may be added; however, the preprinted titles on this form must not be altered.)
7. CHIEF EXECUTIVE OFFICER/ ADDRESS CITY STATE ZIP CODE
STUART KENNETH DUNCAN 9663 SANTA MONICA BLVD 450, BEVERLY HILLS, CA 90210
8. SECRETARY ADDRESS CITY STATE ZIP CODE
9. CHIEF FINANCIAL OFFICER/ ADDRESS CITY STATE ZIP CODE
LARRY PAGET 9663 SANTA MONICA BLVD 450, BEVERLY HILLS, CA 90210
Names and Complete Addresses of All Directors, Including Directors Who are Also Officers (The corporation must have at least one
director. Attach additional pages, if necessary.)
10. NAME ADDRESS CITY STATE ZIP CODE
13. NUMBER OF VACANCIES ON THE BOARD OF DIRECTORS, IF ANY: 0

Agent for Service of Process If the agent is an individual, the agent must reside in California and Item 15 must be completed with a California street
address, a P.O. Box address is not acceptable. If the agent is another corporation, the agent must have on file with the California Secretary of State a
certificate pursuant to California Corporations Code section 1505 and Item 15 must be left blank.
14. NAME OF AGENT FOR SERVICE OF PROCESS [Note: The person designated as the corporation's agent MUST have agreed to act in that capacity prior to the designation.]
STEPHEN MICHAEL KERNAN
15. STREET ADDRESS OF AGENT FOR SERVICE OF PROCESS IN CALIFORNIA, IF AN INDIVIDUAL CITY STATE ZIP CODE
Type of Business
16. DESCRIBE THE TYPE OF BUSINESS OF THE CORPORATION
CRYPTOCURRENCY PROPRIETOR
17. BY SUBMITTING THIS STATEMENT OF INFORMATION TO THE CALIFORNIA SECRETARY OF STATE, THE CORPORATION CERTIFIES THE INFORMATION
CONTAINED HEREIN, INCLUDING ANY ATTACHMENTS, IS TRUE AND CORRECT.
04/19/2018 STEPHEN MICHAEL KERNAN ATTORNEY
DATE TYPE/PRINT NAME OF PERSON COMPLETING FORM TITLE SIGNATURE
SI-200 (REV 01/2013) Page 1 of 1 APPROVED BY SECRETARY OF STATE
EXHIBIT 2
7/16/2019 Federal Corporation Information - 1038659-6 - Online Filing Centre - Corporations Canada - Corporations - Innovation, Science and Eco…
Home  Innovation, Science and Economic Development Canada  Corporations Canada

 Search for a Federal Corporation
Federal Corporation Information - 1038659-6
Buy copies of corporate documents
 Note
This information is available to the public in accordance with legislation (see
Public disclosure of corporate information).
Corporation Number
1038659-6
Business Number (BN)

796679884RC0001
Corporate Name
TOKKEN MSB INC.
Status
Active
Governing Legislation
Canada Business Corporations Act - 2017-08-30
Registered Office Address
5582 Manotick Main Street

Ottawa ON K4M 1E2
Canada
 Note
Active CBCA corporations are required to update this information within 15 days of
any change. A corporation key is required. If you are not authorized to update this
https://www.ic.gc.ca/app/scr/cc/CorporationsCanada/fdrlCrpDtls.html?corpId=10386596&V_TOKEN=1563297412178&crpNm=Tokken&crpNmbr=&bs… 1/3
information, you can either contact the corporation or contact Corporations

Canada. We will inform the corporation of its reporting obligations.
Directors
Minimum 1
Maximum 10
stuart kenneth duncan

741 Merlin Court
Ottawa ON K4M 0A1
Canada
 Note
Active CBCA corporations are required to update director information (names,
addresses, etc.) within 15 days of any change. A corporation key is required. If
you are not authorized to update this information, you can either contact the
corporation or contact Corporations Canada. We will inform the corporation of its
reporting obligations.
Annual Filings
Anniversary Date (MM-DD)

08-30
Date of Last Annual Meeting

Not available
Annual Filing Period (MM-DD)

08-30 to 10-29
Type of Corporation
Non-distributing corporation with 50 or fewer shareholders
Status of Annual Filings

2019 - Not due
2018 - Filed
Corporate History
Corporate Name History
2017-08-30 to Present TOKKEN MSB INC.
Certificates and Filings
Certificate of Incorporation
2017-08-30
Certificate of Amendment *
2018-10-16
Amendment details: Number of directors
* Amendment details are only available for amendments effected after 2010-03-
20. Some certificates issued prior to 2000 may not be listed. For more
information, contact Corporations Canada.
Buy copies of corporate documents
Start New Search Return to Search Results
Date Modified:
2019-05-22
EXHIBIT 3
W H I T E PA P E R
Vice Industry
Token
2
Table of Contents
The Adult Entertainment Industry is Ripe for Disruption…….3
1. Too many hands in the pot ……………………………………………………………………3
2. Its Not about the viewer.……………………………………………………………………….4
3. Limited user engagement……………….…………………………………………………….4
Rethinking Monetization for the Vice Industry - The Rise of the
“Attention Economy”..………………………………………………………………………………..5
Vice Industry Token..…………………………….………………………………………..6
Vice Industry Token Portals…..………….…………………………………………..7
Token Sale Distribution…………………………………………………………………..8
Proxy Token and Refund Contract Period………………………………..9
Timeline………………………………….………………………………….………………………10
Team………………………………….………………………………….…………………….………11
Stuart Duncan - CEO………..…………………………………………………………………………11
Kelly Holland - President …………………………………………………………………………..12
Bill Heilmann - CSO .……………………………………………………….…………………………..13
Eric Helsel - CMO .……………………………….……………………………….……………………..14
Andry Kostin - CTO .……………………………….……………………………….………………….15
FAQ………………………………….………………………………….………………………………16
3
The Adult Entertainment

Industry is Ripe for Disruption
The moving image has existed for over a century. While the technology to capture
and display moving images has rapidly evolved, the business model according to
which content is distributed, purchased and consumed has changed very little.
Today, viewers buy admission tickets to a movie, or purchase the rights to view a
pay-per-view event. Content producers and distributors, from cable and satellite
providers like DirecTV, Spectrum and Comcast to large communications enterprises
like Verizon and AT&T, all forecast revenues based on how many paying viewers they
can attract.
Even the advent of the internet did not alter this 100-year-old revenue model that
forms the basis for revenue generation across all video content categories, where
content producers pay advertisers to attract viewers, and viewers pay to watch it..
Through product placement, contextual advertising, and interstitial ads, Advertisers

today are willing to pay to place their advertising content in or as near to the point of
interest on websites as possible; including the video being offered. The proximity of
advertising to video content enables video providers to offer content for free.
Sponsors pay for screen space to display their advertisements. The advertisement
catches the attention of the viewer. This subsidizes the video provider’s operating
expenses. This permits viewers to watch without paying. These days people watch
videos for free, just for having to look at a few advertisements.
Today, the ad-supported free viewing model is the Internet industry standard.
However, there are three major problems with this model in its current state.
1. Too many hands in the pot

It isn’t as simple as the advertiser paying the content producer. More often, it
involves the advertiser paying an advertising network, and the advertising network
paying the agent of the content producer. Eventually revenue trickles down to the
content producer. Each of these parties along the way takes a cut. Because the
content producer often does not control or own the distribution network, very little
of the revenue is shared with the content producer.
4
Surprisingly, the bulk of revenue in the online adult pornographic industry is not
generated by content. The bulk of online adult revenues are generated by traffic.
62% of today’s online adult revenue is generated by traffic. Advertisers earn very
little of overall adult revenue, content producers earn even less, and viewers earn
nothing. Advertisers pay the traffic companies. Adult Content creators, and adult
content-affiliated websites and programs generate only 24% of total revenue. The
remainder of adult revenue is generated from webcam shows, and the sale of
merchandise such as lubes and toys.
Instead of improving the quality of content production, the current business

frustrates content producers and reduces the incentive to create quality content as
net revenues dwindle to nothing. This is a problem for content producers who
provide content to aggregators of free content (“Tube” sites) globally.
2. It’s not about the viewer

Since the viewer doesn’t pay for content on Tube sites, advertisers are able to
control which content gets sponsored. The advertisers control which content is
made available for free. The viewer can watch free content , but the curation
process does not capture the viewer’s specific taste and desires. Today, viewer
interests are a secondary concern at best.
3. Limited user engagement

When the supply of adult content on the internet was limited, it was easy to get
users to pay to watch. As more content became available, it was easy to provide
content for free with supporting ads and banners, pop ups and pop unders.
However, the “watch for free” system has led to saturation of the market with low-
quality content. While most video platforms show ads, this doesn’t necessarily mean
viewers watch ads. Viewers often switch windows or use ad blocking software.
Viewers even skip and may not even watch an ad. As a result, the value advertisers
get for their advertising dollars is questionable. As a direct consequence, ad costs
decrease, leading advertisers to place more and even lengthier ads to compete for
viewer’s attention. The lack of genuine engagement with ads by viewers is forcing
advertisers to rethink the monetization model.
5
Rethinking Monetization for the Vice Industry - The Rise of

the “Attention Economy”
“Free was good, it’s just not good enough anymore.”

- Stuart Duncan, CEO, Vice Industry Token and Blockchain
Authentic viewer attention is the most valuable resource in the adult industry. With
so many adult websites to choose from (over 150,000 worldwide according to AVN
and XBIZ), competition for viewer attention is fierce.
What does a new monetization model for the Vice Industry look like? ViceToken.com
is designed to re-center monetization of free adult content around the specific
desires of the viewer. We created a decentralized cryptographic token distribution
platform that rewards each stakeholder in the adult content industry by capturing
genuine viewer engagement with adult content. This ability to capture authentic
user engagement at the point of interaction forms the basis of the emerging
“Attention Economy”, in what has come to be called “proof of brain” technology. The
foundation of ViceToken.com is built on a “fork” of the code that powers the open-
source Steem blockchain, which generates and distributes Steem tokens as users
consume internet content, simultaneously recording proof of such interactions on
an immutable ledger. We modified (“forked”) the open-source code that powers the
Steem network to meet the specific needs of the adult content industry.
ViceToken.com awards tokens, called “VIT”, to each stakeholder in the adult content
distribution transaction chain. We trademarked the phrase “Get Paid To Watch Porn”
to emphasize the benefit of the VIT platform for adult content viewers. The process
of recording and authenticating viewer interaction on a ledger through generation
of VIT tokens also permits content producers to more accurately identify viewer
preferences, allowing them to refine and create better content for viewers.
To kickstart the VIT network, ViceToken.com has partnered with prominent adult
content brands to make their content available on the VIT network, and will also
offer a B2B implementation assistance program to other content producers to
integrate VIT into their web monetization strategy.
6
Vice Industry Token

Why use VIT instead of another cryptocurrency (or even fiat currency)? The VIT
protocol’s unique feature is the creation and distribution of tokens to all
stakeholders in the adult content industry that serve both as proof of engagement
with content (the data that matters most to adult website operators) and a
mechanism for payment.
The primary features of the VIT protocol are the VIT rewards pool and the VIT ledger.
The VIT rewards pool ensures instant and transparent allocation of VIT to
stakeholders according to a fixed set of rules. [The VIT protocol is capable of
recording more than 100,000 transactions per second.]
The VIT ledger records granular user behavior - such as social activity, likes, upvotes,
comments, and content preferences as valuable transaction metadata. Traditional
website traffic analysis systems passively record traditional engagement metrics,
such view counts and clicks, but do not permit content producers to provide
incentives to viewers to more deeply engage with their content in real time. The VIT
protocol also permits content producers to reward viewers for comments and votes,
providing much richer, insightful data. [The VIT protocol also includes web traffic
analysis tools to enable content producers to capitalize on such data, and to refine
the content they provide to more accurately represent the viewer preferences.] In
turn, viewers will spend more time engaging with content they are more likely to
buy, providing even more valuable information in an ongoing feedback loop. In
addition to these direct benefits, content producers will be able to aggregate and
sell engagement data” being useful to the website operator on a firsthand basis,
most forms of this data are saleable across many other verticals.
To support the VIT launch, ViceToken.com’s adult content partners and website
operators will embed support for VIT on their websites, and will honor VIT as a
means of payment for premium content. [Vice Industry Tokens will also be
supported by a growing number of Vice Industry Token decentralized video portals
in exactly same way].
VIT has an advantage over general-use cryptocurrencies such as Bitcoin because it

serves as both as a medium of exchange, and as a means of capturing viewer
engagement data in a single token. In addition, VIT’s engagement optimization tools
will allow content producers to customize their content to meet the needs of
individual porn fans.
7
Vice Industry Token Portals

Vicetoken.com will consist of a portal website (similar to the STEEMit.com site) that
consists of an interface familiar to users of existing Tube site. The portals will utilize
the ChainBase/Graphene database optimized for blockchain applications to capture
social interactions and text, as well as the Inter Planetary File System protocol
(“IPFS”) for hosting and delivering content. The portals will integrate the VIT protocol
to enable distribution of tokens to stakeholders.
Because the IPFS content storage and delivery platform is decentralized and
encrypted, it has numerous advantages over centralized platforms. Users with
sporadic or unreliable Internet service can access files in the same manner as users
with reliable Internet connectivity. This removes barriers for users in remote or
nonmetropolitan areas, in addition to enabling offline access.
As described above, participants in all aspects of the Vicetoken.com portal will be

eligible to earn VIT.
IPFS node operators will also be able to earn VIT by providing content storage
resources to portal operators.
The ViceToken.com portal will primarily operate as a channel for supporting the Vice
Industry Token blockchain and the websites and content of its adult industry
partners. The protocol that underlies the ViceToken.com portal is open source, and
will be available to independent content producers who want to take advantage of
the protocol to run their own branded VIT nodes, in any language – on the same
blockchain. In addition, the VIT protocol will allow others to modify the
ViceToken.com portal code at their discretion to add other off-chain functionality.
The re-branding option is offered to provide ample opportunity for enterprising
parties worldwide to create specialized versions of the Vicetoken.com portal with
their own unique flair, in the interest of enriching the overall network of users of
both the portal, and the VIT protocol. Those who operate VIT nodes will be able to
earn for transactions processed through each node.
The VIT protocol will also allocate 3% of the VIT earned by viewers and content
producers to ViceToken.com partner websites and brands as a reward for hosting
content.
8
Token Sale Distribution

ViceToken.com will generate four billion VIT in the genesis (initial) block. We will
allocate VIT as follows
ViceToken.com Inc: 1,000,000,000 Tokens
Content Providers, Strategic Partners,

Advisors: 600,000,000 Tokens
Crowdsale: 2,000,000,000 Tokens
STEEM Holders: 400,000,000 Tokens
ViceToken.com Inc will retain any VIT that remain unsold after the crowdsale.
After initial creation of VIT, The Vice Industry Token protocol will generate and
distribute additional VIT to stakeholders in an amount equal to no greater than 10%
of the amount created in the genesis block in the first year after launch. The rate of
generation will decrease by 1% in each additional year until the tenth year after
genesis, at which point the amount of VIT will remain constant.
Crowdsale purchasers will pay ~$0.05 of ETH per VIT, with a minimum purchase of
$50 of ETH.
Vice Industry Token Inc. will airdrop 400,000,000 (10%) of the genesis tokens to
STEEM token holders as of block number 18,500,000 on the STEEM Blockchain. The
airdrop to STEEM holders will be distributed by January 1, 2021, and possibly earlier,
in a manner and time period of Vice Industry Token Inc’s choosing.
9
Proxy Token and Refund

Contract Period
Vice Industry Token will use Ethereum to generate VIT Proxy Tokens in the VIT
crowdsale. The crowdsale is powered by a unique crowdsale smart contract which
includes refund capabilities. This refund functionality will allow any purchaser of a
proxy token, who purchased the tokens in the public crowdsale, to either call a claim
function or a refund function on any portion held for them in the contract after the
crowdsale ends. If the purchaser calls the claim function, the amount of tokens they
claim will be released to the purchaser's address and they will be ineligible on a
refund for those claimed tokens. On the other hand, if they call the refund function
for any portion of the tokens, the original amount they paid in ETH, for that portion,
will be refunded to their Ethereum account and the refunded VIT tokens will
become the property of Vice Industry Token Inc.. Upon expiration of the refund
contract, on June 28, 2018, the refund functionality will expire, and purchasers will
lose the right to call for a refund, however, the claim functionality will remain
available, indefinitely, whereby purchasers can have their held tokens sent to their
Ethereum accounts. In addition, after the refund contract expires, purchasers will
also be able to redeem their claimed proxy tokens for the native Vice Industry
Tokens from Vicetoken.com.
The purpose of the refund contract is to give the opportunity for purchasers who are
early supporters to use and experiment with the platform to ensure that the VIT
network provides the features and services that they were expecting.
The terms of sale, which will be made available on the website during the
crowdsale, will be the authoritative terms and description of the smart contract and
will supersede any previous terms and descriptions.
10
Timeline
1. January 11, 2018: Flash whitelist sale for a purchasing a guaranteed opportunity to
participate in crowdsale.
2. January 15, 2018: Flash whitelist sale for large orders with bonus.
3. February 5, 2018: Second flash whitelist sale.
4. February 20, 2018: Launch of the Vice Industry Token Crowdsale.

5. March 20, 2018: End of the Crowdsale and distribution of ERC20 proxy Tokens.
6. March 21, 2018: Launch of the VIT MainNet.
7. June 28, 2018: Expiration of the Refund Contract and launch of the VIT video
portal platform.
1. Flash whitelist sale for a 5. End of the Crowdsale 7. Expiration of the Refund
purchasing a guaranteed 3. Second flash and distribution of Contract and launch of the
opportunity to participate whitelist sale. ERC20 proxy Tokens. VIT video portal platform.
in crowdsale.
Jan. 11 Jan. 15 Feb. 5 Feb. 20 Mar 20. Mar 21 June 28
2. Flash whitelist sale for 4. Launch of the Vice 6. Launch of the

large orders with bonus. Industry Token VIT MainNet.
Crowdsale.
11
Team
Stuart Duncan - CEO
Stuart Duncan is an adult industry visionary, broadcast pioneer and
former C++ developer. Stuart started his career at Canadian Aviation
Electronics (CAE), moved to Mitel corporation and ended his software
development career at Telesat Canada before leaving to found 5D.com
(5D Communications), which owned the world’s first explicit adult TV
network, Exxxtasy.
By 1999, the TV and cable channels Stuart managed had become the
largest network of adult content TV producers in North America, when
it was sold to New Frontier Media and listed on NASDAQ. Stuart
continued technical operations for New Frontier and sat on the New
Frontier’s board until 2001. Stuart was the Chairman of the North
American Broadcasters Association Internet Committee from early 1999
to late 2001. During this time, Stuart successfully broadcasted MPEG1
and MPEG2 across the Internet using the 5D infrastructure to an
unbelieving audience of mainstream US broadcasters and cable
systems, proving that the Internet was capable of becoming the
broadcast medium it is today.
In 2000, Stuart was granted the first adult television broadcast license
in Canada. During the next 14 years, Stuart founded many of the top
adult brands in broadcast and cable today. These brands include
Exxxtasy TV (2000), Hustler TV (2003), Penthouse TV (2005), Red Hot TV
(2008), Skinemax TV (2009), and Playmen TV (2010). In 2015, Stuart
launched Media Vision Partners in the USA. MVP’s broadcast brands are
the fastest-growing adult broadcast networks in the USA. Stuart also
owns and operates successful adult film production studios.
For the past two years, Stuart has been working to modernize the adult
content industry by developing the Vice Token protocol and promoting
the “Get Paid to Watch Porn ®” brand.
12
Kelly Holland - President

A former mainstream award-winning documentary filmmaker, Kelly
Holland has been an adult film director and executive since 1994. In her
early adult career, Kelly directed for Vivid, and went on to direct for
numerous other companies including Adam and Eve.
In 2005, Kelly became the Executive Producer for Playgirl TV, where she
also served as the spokesperson for the brand, appearing in several
mainstream media outlets.
In 2006, she became the Executive Producer for Penthouse Broadcast.

Shortly thereafter, Kelly became the President of Penthouse TV, where
she built a global broadcast operation that is now the largest adult
broadcaster in the world.
In 2016, Kelly acquired Penthouse and all of its assets, including its
licensing, publishing, broadcast, and digital divisions.
In a process that has lasted eight years, Kelly has overhauled the
Penthouse brand. She has redesigned and refined its various properties
and licensees around the world, and reorganized the publishing division
to bring it to a profitable status. Kelly also pioneered the way for
Penthouse into over-the-top platforms worldwide.
Penthouse is now expanding its empire of satellite channels in over 100

countries around the world. In addition to its video and television
empire, Penthouse continues to grow product licensing and
international publications, in addition to developing location based
entertainment.
13
Bill Heilmann - CSO

Bill Heilmann recently served as a Managing Partner at MEC, one of the
largest media agencies in the world ($27 billion in billings), with a client
roster that includes the likes of Marriott, Paramount Pictures, and IKEA.
Prior to joining MEC, Bill was the Lead Global Strategist at BAV
Consulting where he oversaw the global repositioning of Lexus.
Bill has been the founder of two separate digital ventures, and has a
wealth of tech and marketing experience from working with brands
that include AOL, US Robotics, and MSNBC. His wide-reaching category
experience at various global advertising agencies includes luxury, retail,
spirits, sports, pharmaceuticals, financial services, health/beauty, and
home goods. A graduate of the University of Chicago, Bill has been the
strategic force behind a number of EFFIE and Cannes-award winning
campaigns, and was the recipient of the Ogilvy Award for advertising
excellence.
14
Eric Helsel - CMO

Eric Helsel joins Vice Industry Token as Chief Internet Media Officer
celebrating his 20th year in Internet marketing.
Eric’s career has involved creating online marketing and sales funnels
for international brands such as Red Bull, Snapple, Coors, and the NFL.
More recently, Eric was the Vice President of Online Sales and Internet
Marketing for Vivid Entertainment of Los Angeles for eight years. Eric
engineered the online release and traffic generation plan of the “Kim
Kardashian, Superstar” sex tape. Eric’s guidance and management at
Vivid resulted in a massive online success. Traffic generated by the
Kardashian video was in the multiple billions of impressions. Sales of
the “Kim Kardashian, Superstar” sex tape (viewed over 210 million times
online, and watched on average once every 1.5 seconds) earned over
$100 million since its release.
Eric has developed, managed, and overseen teams that have produced
over 200 products in the Internet marketing space since 1997. His
efforts have been responsible for PNL revenues in excess of $280
million throughout his career.
Before joining Victoken.com, Eric founded and managed the digital

media agency Community 32, where he developed some of the most
extreme product pursuits in digital marketing.
15
Andrey Kostin - CTO

Andrey Kostin is a Java Software Engineer and Java Architect with
10+ years of experience in Java development, and 5+ years
experience in architecture development in the big data, banking and
finance industries.
Andrey has specialized in the development of distributed, highly-

loaded, multi-threaded solutions, and was involved in the full
application lifecycle. This includes pre-sale activity, architecture
design, POC development, team construction, and development of
core application modules. He has also given lectures in Core Java,
GWT and Java EE.
Andrey has experience in P2P cryptography platforms, and was

involved as architect and senior developer for Deutsche Bank and
OTP Bank.
16
FAQ
When Will the Vice Industry Token Sale Start?
The Vice Industry Token Crowdsale is scheduled to begin on February 15, 2018. Stay
updated on times and dates by following social platforms and subscribing to the
newsletter.
Is there a Presale?
Yes, The presale will open on January 15, 2018 and is available only to accredited
investors.
What is the technology behind Vice Industry Token?
Vice Industry Token is powered by a fork of the Steem blockchain protocol.
How Much Is a Vice Industry Token?
Purchasers will pay the ETH equivalent to ~$0.05USD during the crowdsale, with a
minimum purchase of $50USD of ETH.
How Many Vice Industry Tokens Will Be Available in the Token Sale
and How Many Will Be Created in Total?
Four billion tokens will be created in the genesis (initial) block. These tokens will be allocated in
the following manner;
- Vice Industry Token Inc: 1,000,000,000 Tokens

- Strategic Content Provider Partners, Advisors & Presale Purchasers: 600,000,000
Tokens
-Crowdsale Purchasers: 2,000,000,000 Tokens
-STEEM Holders: 400,000,000 Tokens
All unsold tokens at end of the crowdsale will be retained by Vice Industry Token Inc..
17
Are There Any Discounts Available During the Crowdsale?
No. there is a very limited presale open to accredited investors with discounts
depending on quantity purchased. There is also a bounty campaign.
Can I Submit ETH from an Exchange Account?
No, please only send ETH from an Ethereum-compatible wallet whose private keys
you own and control.
How can I enter the Bounty Campaign?
Stay updated with the Newsletter, Telegram and other Social Platforms/ Follow the
links to the BitcoinTalk page and fully understand the bounty requirements before
committing to the campaign and participating.
What is the Steem Holder’s Airdrop?
Upon the token’s launch, 400,000,000 (10%) of the genesis tokens will be air
dropped to Steem holders as of block number 18,500,000 on the Steem Blockchain.
The airdrop to STEEM holders will happen over a time of Vice Industry Token Inc’s
choosing, but no later than January 1, 2021.
Proxy Token and Refund Contract Period
Vice Industry Token will use Ethereum to generate VIT Proxy Tokens in the VIT
crowdsale. The crowdsale is powered by a unique crowdsale smart contract which
includes refund capabilities. This refund functionality will allow any purchaser of a
proxy token, who purchased the tokens in the public crowdsale, to either call a claim
function or a refund function on any portion held for them in the contract after the
crowdsale ends. If the purchaser calls the claim function, the amount of tokens they
claim will be released to the purchaser's address and they will be ineligible on a
refund for those claimed tokens. On the other hand, if they call the refund function
for any portion of the tokens, the original amount they paid in ETH, for that portion,
will be refunded to their Ethereum account and the refunded VIT tokens will
become the property of Vice Industry Token Inc.. Upon expiration of the refund
contract, on June 28, 2018, the refund functionality will expire, and purchasers will
loose the right to call for a refund, however, the claim functionality will remain
available, indefinitely, whereby purchasers can have their held tokens sent to their
Ethereum accounts. In addition, after the refund contract expires, purchasers will
also be able to redeem their claimed proxy tokens for the native Vice Industry
Tokens from Vicetoken.com.
18
The purpose of the refund contract is to give the opportunity for purchasers who are
early supporters to use and experiment with the platform to ensure that the VIT
network provides the features and services that they were expecting.
The terms of sale, which will be made available on the website during the
crowdsale, will be the authoritative terms and description of the smart contract and
will supersede any previous terms and descriptions.
How is Vice Industry Token different from Spankchain and other

similar cryptocurrencies? What’s special about Vice Industry Token?
The only means a viewer has to receive SpankChain tokens to buy content from
adult content producers is to buy them on an exchange first. The only means for a
content producer to monetize SpankChain coins is to sell them on an exchange.
Further, SpankChain coins do not capture viewer engagement metadata, a crucial
element of the Attention Economy that drives is the real value behind VIT. In
comparison VIT is a multi-dimensional token that can be used to reward viewers for
their attention, to pay content producers for premium content, and for content
distributors to monetize the data they collect by selling it to other providers of
adult-related products and services.
Who are your adult content partners?
Vice Industry Token is partnered with Penthouse, Exxxtasy, Playmen, RedHot TV,
SkineMaxHD, to name just a few. More details are located on our website
https://vicetoken.com/
How does content tracking work?
If someone steals content and publishes it on the Vice Industry blockchain, only the
original content creator will receive VIT, which eliminates the incentive for content piracy.
How do I sign up for the CrowdSale Whitelist?
The whitelist began on January 11, 2018. Sign up to the newsletters and follow VIT
social media accounts for any updates.
Will Vice Industry Tokens be released on Ethos?
No. We have our own wallet and a built in exchange that allows similar tokens built
on graphene/chainbase/bitshares platform to be distributed, awarded, and
exchanged among participants as part of our application stack.
19
What is the ‘Proof of Brain’ concept?
The “Proof of Brain” concept is the foundation of the emerging Attention Economy
that allows content creators and distributors to capture richly detailed, authentic
viewer engagement information, encoded in a tamper-proof decentralized ledger.
With VIT, content creators know that each engagement is real, and not generated by
bots or by click farmers. VIT adds value to the entire adult content community by
rewarding interaction and incentivizing the creation of higher-quality content.
EXHIBIT 4
EXHIBIT 5
1 AKIN GUMP STRAUSS HAUER & FELD LLP
SUSAN K. LEADER (SBN 216743)
2 sleader@akingump.com
ANDREW S. JICK (SBN 278943)
3 ajick@akingump.com
BRETT M. MANISCO (SBN 318351)
4 bmanisco@akingump.com
5 Los Angeles, CA 90067-6022
Telephone: 310.229.1000
6 Facsimile: 310.229.1001
7 Attorneys for Playboy Enterprises, Inc.
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
FOR THE COUNTY OF LOS ANGELES
10
11 PLAYBOY ENTERPRISES, INC., a Case No. [BC716374]
Delaware corporation,
12 [THE HONORABLE ELAINE LU]
Plaintiff,
13 [CONDITIONALLY UNDER SEAL]
v.
14 FIRST AMENDED COMPLAINT FOR:
GLOBAL BLOCKCHAIN
15 TECHNOLOGIES CORPORATION, a 1. FRAUD AND INTENTIONAL
Canadian corporation; SHIDAN GOURAN, DECEIT;
16 an individual; TOKKEN MSB INC., a 2. NEGLIGENT
Canadian corporation; VICE INDUSTRY MISREPRESENTATION;
17 TOKEN, INC., a California corporation;
STUART DUNCAN, an individual; and 3. BREACH OF CONTRACT;
18 DOES 1-10 inclusive,
4. BREACH OF THE IMPLIED
19 Defendants. COVENANT OF GOOD FAITH
AND FAIR DEALING;
20 5. BREACH OF CONTRACT –
THIRD PARTY BENEFICIARY;
21
6. INTENTIONAL INTERFERENCE
22 WITH CONTRACT;
7. FALSE ENDORSEMENT AND
23 UNFAIR COMPETITION UNDER
15 U.S.C. § 1125(a); AND
24
8. UNFAIR COMPETITION UNDER
25 CAL. BUS. & PROF. CODE
§ 17200 ET SEQ.
26
JURY TRIAL DEMANDED
27
28
FIRST AMENDED COMPLAINT

1 Plaintiff Playboy Enterprises, Inc. (“Playboy”) alleges as follows:
2 SUMMARY OF THE ACTION
3 1. This case arises from the fraudulent and wrongful conduct of Global Blockchain
4 Technologies Corporation (“GBT”) and Shidan Gouran (“Gouran”), as well as the wrongful conduct of
5 Vice Industry Token (“VIT”) and Stuart Duncan (“Duncan”) (collectively, “Defendants”), which has
6 caused substantial and irreparable harm to Playboy.
7 2. Playboy is a media and lifestyle brand that publishes Playboy Magazine in the United
8 States, licenses foreign editions around the world, and creates content that is distributed through TV
9 networks, the internet, and other forms of media. Playboy’s brand is also licensed worldwide on
10 consumer products in more than 180 countries. The company owns and operates Playboy.com, which
11 features articles, videos, and experiences. Through Playboy’s extensive marketing efforts, media
12 projects, and product licensing initiatives, Playboy has become one of the world’s most well-
13 recognized and popular brands.
14 3. In February 2018, Duncan sent Gouran a draft agreement between Playboy and VIT, a
15 newly formed company that branded itself, in part, as a “porn” company. Under Duncan’s proposal,
16 VIT would agree to pay Playboy in exchange for granting VIT the right to use Playboy’s brand to
17 promote VIT.
18 4. In March 2018, Gouran pitched Playboy on a deal with VIT. Although Playboy was
19 conceptually interested, it declined for two reasons. First, Playboy’s current brand image was not
20 compatible with VIT’s identification as a porn company. Second, it lacked confidence that VIT would
21 be able to honor its payment obligations under the contract. Undeterred, Gouran came up with a new
22 proposal: Playboy could enter into a contract with GBT – a publicly traded blockchain company, of
23 which Gouran was the President and CEO.
24 5. GBT and Playboy proceeded to negotiate a deal, which was memorialized in the
25 Memorandum of Understanding between the parties (“MOU”). Under the proposed deal, GBT agreed
26 that it would make certain changes to the VIT website – in particular, GBT promised to remove
27 references to “porn” and to rebrand the VIT website as more generally video/entertainment oriented.
28 In turn, Playboy agreed to integrate GBT’s blockchain technologies onto its online media portal, under
1
1 the condition that GBT provide technical support to Playboy at no cost. Playboy further agreed to
2 make certain announcements regarding its partnership with GBT and the integration of the Vice token,
3 a digital token that users could earn by interacting with content on websites. In exchange, GBT agreed
4 to pay Playboy a total of $5 million in cash, along with additional consideration. Gouran signed the
5 MOU in his capacity as the President and CEO of GBT.
6 6. However, unbeknownst to Playboy, in the course of negotiating this deal, Gouran, on
7 behalf of GBT, made numerous false statements and omissions to Playboy which were material to
8 Playboy’s decision to enter into the deal with GBT.
9 7. Fundamentally, Gouran led Playboy to believe that GBT owned and/or controlled VIT
10 and therefore could ensure performance under the agreement, such as making changes to the VIT
11 website, providing technical support to Playboy, and making the payments to Playboy using the funds
12 raised by the Crowdsale. But GBT now claims that it has no relationship with VIT and therefore could
13 not control VIT. GBT admits that it could not make changes to VIT’s website, but it could only
14 “request” or “facilitate” changes to VIT’s website. If Playboy had known that GBT did not own or
15 control VIT, and therefore could not cause it as a non-party to the agreement to perform, Playboy
16 would never have entered into the agreement with GBT.
17 8. Gouran also promised that GBT would make payments to Playboy including a payment
18 of $4 million by July 16, 2018, which would be funded by the proceeds of a “crowdsale” involving the
19 Vice token (the “Crowdsale”). The goal of the Crowdsale, also known as an initial coin offering
20 (“ICO”), was to raise funds by selling the Vice Token. In reality, Gouran knew that GBT had no access
21 to the cash proceeds from the Crowdsale and therefore could not make this commitment. In fact, GBT
22 admits that it still does not know how much money the Crowdsale raised.
23 9. As an additional assurance to Playboy, Gouran also promised that if the Crowdsale did
24 not raise sufficient funds to cover the payment, GBT would make up any shortfall by providing
25 Playboy with shares of its common stock. But, in reality, Gouran had not received approval from
26 GBT’s board to make that promise.
27 10. Similarly, Gouran misled Playboy into believing that GBT would provide technical
28 support to Playboy, at no cost, to help Playboy integrate the blockchain technologies into the
2
1 designated site. But, in reality, GBT contracted with VIT to provide the technical support and has
2 disclaimed any responsibility for providing the promised technical support.
3 11. Finally, Gouran deceived Playboy by failing to disclose that while GBT did not have a
4 relationship with VIT, he did. As it turns out, Gouran is not only the President and CEO of GBT, but
5 he is also a “principle shareholder” of VIT. Playboy is informed and believes, and thereon alleges, that
6 Gouran only disclosed this conflict of interest to GBT’s board of directors after he had already agreed
7 to the deal on GBT’s behalf.
8 12. On March 13, 2018, in reliance on Gouran’s fraudulent misrepresentations and
9 omissions, Playboy entered into the MOU with GBT.
10 13. After the parties entered into the MOU, GBT made an initial payment to Playboy of $1
11 million under the MOU, which triggered Playboy’s obligation to make the agreed upon
12 announcements. Thereafter, Playboy honored its commitments under the agreement. In addition to
13 making the required announcements, Playboy designated a site for GBT to integrate the blockchain
14 technologies and attempted to work with GBT with regard to the integration. However, GBT did not
15 honor its promises, and GBT’s subsequent conduct has confirmed Gouran’s and GBT’s deception.
16 14. Contrary to its promise, GBT failed to provide the technical support to Playboy, which
17 made it impossible for Playboy to integrate GBT’s technologies into the designated site.
18 15. GBT also failed to cause VIT to remove the “porn” references from the VIT website.
19 Although the porn references were initially removed when the MOU was executed, VIT subsequently
20 reintroduced the words “Get Paid to Watch Porn” on the website, continued to refer to the service as
21 “adult” content, and displayed the Playboy name as an affiliate partner in the adult entertainment group
22 next to porn-related websites. These changes to the VIT website breached the MOU.
23 16. As the July 16 deadline neared for the $4 million payment to be made, Playboy began to
24 seek assurances from Gouran, on behalf of GBT, that GBT would honor its promise. Playboy also
25 asked Gouran, on behalf of GBT, to provide information relating to the cash proceeds for the
26 Crowdsale and information relating to GBT’s promise to provide stock in the case of any shortfall.
27 Gouran and GBT, however, refused to provide the requested assurances and refused to provide any of
28 the requested information. Instead, Gouran made up excuses and vaguely suggested that VIT could
3
1 provide Playboy with the proceeds of a secondary crowdsale, equity in VIT, and additional Vice
2 tokens. Playboy reiterated its request that GBT comply with its promises under the MOU and repeated
3 its requests for information, but Gouran and GBT simply stonewalled, delayed, and made up further
4 excuses.
5 17. To this day, GBT has failed to pay Playboy a single penny of the $4 million that it
6 promised, or provide any common stock to make up the cash shortfall. As it turns out, GBT never
7 intended to honor its obligations under the MOU and was instead (and unbeknownst to Playboy)
8 relying on VIT, a party that it now admits it has no control over, to fund the required payments to
9 Playboy.
10 18. GBT’s subsequent conduct further reinforces its deceptive tactics. On July 2, GBT
11 issued a press release to its investors seeking to reassure them regarding its financial health. In the
12 press release, GBT falsely represented to investors that “[a]ll” of its projects are “on schedule,” and
13 that there were no “significant roadblocks” to any of its “more notable projects.” Tellingly, GBT
14 neglected to disclose to its investors the significant delays and roadblocks with the Playboy project that
15 GBT caused. Thus, the press release further confirms GBT’s disregard for being truthful and for
16 keeping its promises.
17 19. The blame does not lie solely with GBT and Gouran, however. As Playboy later
18 discovered, VIT and Duncan also contributed to Playboy’s harm. Specifically, Playboy is informed
19 and believes, and on that basis alleges, that GBT and VIT entered into a side agreement, whereby VIT
20 agreed to pay GBT the $4 million, which both parties agreed would fund GBT’s payment to Playboy
21 under the MOU. That is, both GBT and VIT expressly agreed and intended that Playboy would receive
22 the benefit of the $4 million payment, thereby making Playboy an intended third-party beneficiary of
23 their side agreement. Playboy is informed and believes, and on that basis alleges, that VIT did not pay
24 GBT any cash proceeds from the Crowdsale, in breach of the side agreement. Moreover, Playboy is
25 informed and believes, and on that basis alleges, that GBT contracted with VIT with respect to
26 integrating the blockchain technologies into Playboy’s designed site, and that VIT did not provide the
27 agreed upon services. Accordingly, VIT’s and Duncan’s willful conduct disrupted GBT’s performance
28 of its obligations under the MOU and further contributed to Playboy’s harm.
4
1 20. On top of all this, even after GBT breached its obligations under the MOU – including
2 by failing to pay Playboy the $4 million by July 16, 2018 – Defendants continued to use Playboy’s
3 brand in violation of the MOU’s restrictions. Defendants’ unauthorized use of Playboy’s brand was
4 and is willful, oppressive, and malicious, and intended to cause confusion about Playboy’s affiliation,
5 endorsement, or approval of GBT and/or VIT, notwithstanding Defendants’ wrongful conduct. To halt
6 Defendants’ infringing acts and compensate Playboy for the ongoing harm that Defendants are
7 intentionally causing, Playboy is entitled to injunctive relief and actual and/or statutory damages, treble
8 damages, punitive damages and attorneys’ fees in this exceptional case.
9 21. Defendants’ deceptive, wrongful, and malicious conduct have caused substantial
10 economic and reputational harm to Playboy. Accordingly, Playboy is entitled to damages and other
11 relief as requested herein.
12 PARTIES, JURISDICTION, AND VENUE
13 22. Plaintiff Playboy is a Delaware corporation whose principal place of business is located
14 in Los Angeles, California.
15 23. Playboy is informed and believes, and on that basis alleges, that Defendant GBT is a
16 Canadian corporation whose principal place of business is located in Vancouver, Canada. On February
17 7, 2019, GBT announced that the company will change its name to Global Gaming Technologies Corp.
18 Therefore, the term “GBT,” as used herein, shall include Global Gaming Technologies Corp.
19 24. Playboy is informed and believes, and on that basis alleges, that Defendant Shidan
20 Gouran is an individual who resides in Ontario, Canada. Mr. Gouran is the President and CEO of
21 GBT.
22 25. Playboy is informed and believes, and on that basis alleges, that Defendant Tokken
23 MSB Inc. (“Tokken”) is a Canadian corporation whose principal place of business is located in
24 Ontario, Canada.
25 26. Playboy is informed and believes, and on that basis alleges, that Defendant Vice
26 Industry Token, Inc. (“VIT Inc.”) is a California corporation whose principal place of business is
27 located in Beverly Hills, California.
28
5
1 27. Tokken and VIT Inc. are referred to collectively herein as “Vice Industry Token” or
2 “VIT.” That is because, based on information provided by VIT and GBT, Playboy is informed and
3 believes that Tokken and VIT Inc. are, for all practical purposes, the same entity.
4 28. For example, on March 13, 2018, VIT’s Director of Public Relations, Tracy Bagatelle-
5 Black, asked Playboy to add the following “VIT boilerplate” to the end of a draft press release, which
6 defines “VIT” as referring to VIT Inc.:
7 About Vice Industry Token
8 Vice Industry Token Inc. (VIT) is a decentralized blockchain platform and
9 cryptographic token for the adult industry that allows producers to more efficiently
10 monetize their content by rewarding viewers just for watching content. Today’s ad-
11 based free viewing model is broken, dominated by tube sites and benefiting only web
12 traffic companies. By intelligently capturing genuine interactions, VIT will enable
13 producers to deliver high-quality content catered to the specific desires of their most
14 enthusiastic fans. Learn more and read the whitepaper at https://vicetoken.com/.
15 29. Moreover, a press release dated March 19, 2018, which cites VIT Inc. as its source,
16 similarly describes VIT as referring to VIT Inc., and further states that VIT Inc. is a “wholly owned
17 subsidiary” of Tokken:
18 About Vice Industry Token, Inc.
19 Vice Industry Token, Inc. is a decentralized blockchain platform and cryptographic token for
20 the vice industry that allows producers to more efficiently monetize their content by rewarding
21 viewers just for watching content. Today’s ad-based, free viewing model is broken, dominated
22 by tube sites and benefiting only web traffic companies. By intelligently capturing genuine
23 interactions, VIT will enable producers to deliver high-quality content catered to the specific
24 desires of their most enthusiastic fans. Vice Industry Token, Inc. is a wholly owned subsidiary
25 of Tokken MSB, Inc. For more information, please visit https://vicetoken.com/.
26
27
28
6
1 SOURCE Vice Industry Token Inc.1
2 30. There are also numerous references to Tokken as being interchangeable with VIT. For
3 example, an early draft of the proposed agreement with Playboy referred to Tokken as synonymous
4 with VIT and Vice Industry Token. Indeed, in its discovery responses, GBT has referred to “VIT
5 and/or Tokken MSB,” signifying that GBT views these entities as synonymous.
6 31. Playboy is informed and believes, and on that basis alleges, that Defendant Stuart
7 Duncan (“Duncan”) is an individual who resides in Ontario, Canada. Playboy is informed and
8 believes, and on that basis alleges, that Mr. Duncan is the CEO of Tokken and VIT Inc.
9 32. Collectively, GBT, Gouran, VIT, and Duncan are referred to herein as “Defendants.”
10 33. Jurisdiction and venue are proper in this Court because Los Angeles County is where
11 the agreement was entered into, where the agreement was to be performed, and/or where the breaches
12 occurred. Moreover, in the MOU, the parties expressly consented to the jurisdiction of the state courts
13 located in Los Angeles, California in connection with any action concerning the MOU.
14 34. Playboy is unaware of the true names or capacities, whether individual, corporate,
15 associate, or otherwise, of Defendants sued herein as DOES 1 through 10, inclusive, and therefore sues
16 these Defendants by such fictitious names. Playboy will seek leave of the Court to amend this
17 pleading to set forth the true names and capacities of said Doe Defendants when the same are
18 ascertained. Playboy is informed and believes, and on that basis alleges, that each of the fictitiously
19 named Defendants is responsible in some manner for the occurrences herein alleged, or was acting in
20 concert with, and with the permission, approval, and authorization of, the specifically named
21 Defendants.
22
23
24
25
26
27 1
https://www.prnewswire.com/news-releases/vice-industry-token-announces-mechbunnys-
integration-of-its-blockchain-technology-and-cryptocurrency-677268203.html.
28
7
1 FACTUAL ALLEGATIONS
2 A. General Background
3 35. In late 2017, as the price of Bitcoin and other cryptocurrencies climbed to historic highs
4 and the world’s attention was captured by the promises of blockchain technology,2 VIT was born.
5 According to a November 25, 2017 article, Penthouse and Exxxtasy joined forces to launch VIT,
6 described as “a blockchain-based content platform for the adult industry” that was designed to “enable
7 all sorts of producers to monetize their content as well as paying consumers to watch porn.”3
8 36. According to the same article, VIT planned to conduct a public crowdsale, also known
9 as an initial coin offering (ICO), for the Vice tokens beginning February 1, 2018.4 The crowdsale
10 aimed to raise between $25 million and $50 million. The article reported that “[t]he potential for Vice
11 websites video users ranges from 100s of millions of users including daily traffic to a potential user
12 base of over one billion users and viewers worldwide.” To achieve that goal, VIT would need not only
13 to raise funds, but to persuade adult content providers to integrate the Vice token so that it could reach
14 these viewers.
15 37. GBT is a publicly traded, Vancouver-based investment company that specializes in
16 projects and holdings in the blockchain and cryptocurrency industry.5
17 B. Gouran Pitches Playboy on a Deal with VIT
18 38. Playboy is informed and believes, and on that basis alleges, that on or about February 5,
19 2018 – more than a month before Gouran first pitched Playboy on the MOU – Gouran and Duncan
20 began communicating about the possibility of VIT entering into a deal with Playboy that would allow
21 VIT to use Playboy’s brand to promote its business.
22
23
24
25 2
https://www.nytimes.com/2018/01/13/style/bitcoin-millionaires.html.
3
26 https://www.cryptoninjas.net/2017/11/25/penthouse-exxxtasy-launch-vice-token-blockchain-
based-content-platform/.
4
27 Id.
5
https://investorintel.com/sectors/technology/technology-intel/the-nameless-broker-update-on-
28 global-blockchain-technologies/ (July 11, 2018).
8
1 39. Indeed, before Playboy met with Gouran for the first time, Gouran and Duncan had
2 already hatched a plan that would allow VIT to exploit and use Playboy’s brand. Gouran, as a
3 principle shareholder in VIT, stood to benefit personally from this deal.
4 40. Before meeting with Playboy, on February 5, 2018, Duncan emailed Gouran a copy of
5 a draft agreement, which Gouran forwarded to Maxwell Arnold, an analyst at GBT. The draft
6 agreement was titled, “Memorandum of Understanding Between: Tokken MSB Inc., (Vice Industry
7 Token (VIT) and Playboy Enterprises Inc. (Playboy),” and contained a signature block for Duncan to
8 sign on behalf of Token MSB. Under the terms of this draft agreement, among other things, VIT
9 would agree to pay Playboy 10% of the proceeds from the Crowdsale. In exchange, Playboy would
10 agree to grant VIT the right to use its brand.
11 41. Playboy was not introduced to the deal until several weeks later, on or about March 4,
12 2018, when Playboy was introduced to Barry Rotenberg, a lawyer who could “connect [Playboy] with
13 the vice token team” to discuss a potential business deal relating to the Vice token.
14 42. On or about March 6, 2018, Gouran, the President and CEO of GBT, sent Playboy a
15 draft Memorandum of Understanding, titled “VIT Playboy MOU.” Under this version of the draft
16 agreement, Playboy would be contracting with “Tokken MSB Inc. (Herein referred to as VIT or Vice
17 Industry Token).” The draft agreement provided, among other things, that Playboy would allow VIT to
18 integrate its technology onto Playboy’s platform, and VIT would pay Playboy with the proceeds from
19 its crowdsale.
20 43. Although Playboy was conceptually interested, it declined for two reasons.
21 44. First, Playboy did not want its valuable brand image and reputation to be tarnished by
22 association with a porn company, as its current image was incompatible with the “porn” label. VIT
23 branded itself as enabling content producers to pay consumers to watch porn, and its key personnel
24 were executives from the porn industry. Indeed, as VIT’s CEO, Stuart Duncan, reportedly stated in an
25 interview on April 11, 2018:
26 Before getting into cryptocurrency, I’ve [] been involved in the adult business
27 for over twenty years. I created Hustler TV, Penthouse TV and Exxxtasy TV,
28 among many others. I am friends with and know all the greats in the adult
9
1 industry. I am recognized as the guy that started the world’s first explicit
2 Exxxtasy adult channels back in the very early 1990s. Today I am one of the
3 largest providers of adult cable TV channels in the world.6
4 45. Given Playboy’s current brand image, it was not interested in doing business with a
5 company that was so closely affiliated with the porn industry, and Playboy communicated these
6 concerns to Gouran. On March 8, 2018, Playboy emphasized to Gouran that “We just need to make
7 sure we are protecting the brand,” and that “[t]he existing Mgmt and partners” are a “[PR] issue we are
8 trying to grasp.”
9 46. Second, Playboy lacked confidence that VIT, a newly formed company without a track
10 record, would be able to honor its payment obligations under the contract.
11 47. Thus, the deal that Duncan and Gouran had hatched a month earlier that would allow
12 VIT to use Playboy’s brand appeared to be dead in the water.
13 C. Gouran, on Behalf of GBT, Fraudulently Induces Playboy to Enter Into the MOU
14 With GBT.
15 48. Undeterred, Gouran came up with a new plan and proposed that instead of doing
16 business with VIT, Playboy could enter into an agreement with GBT, a publicly traded company, of
17 which Gouran was the President and CEO. Gouran falsely reassured Playboy that GBT owned and/or
18 controlled VIT and could ensure performance under the proposed contract, including by making
19 changes to the VIT website, providing technical support to Playboy, and making the payments to
20 Playboy using the funds raised by the Crowdsale – all promises that became part of the proposed
21 agreement.
22 49. These representations, however, were false and misleading, and were made with
23 fraudulent intent.
24
25
26
27
6
https://medium.com/authority-magazine/5-tips-from-a-cryptocurrency-expert-stuart-duncan-
28 of-vice-industry-token-f17348954aa5.
10
1 (a) Gouran, on Behalf of GBT, Falsely Represents that GBT Owns and/or
2 Controls VIT and Can Make Changes to VIT’s Website.
3 50. To assuage Playboy’s concerns about being associated with a porn company, Gouran
4 promised to make (and in fact caused to be made) a number of changes to VIT’s website. For
5 example, on March 8, 2018, Playboy stated in an email to Gouran that Playboy would likely want a
6 commitment that VIT would evolve its brand into a “more holistic VICE industry rather than purely
7 adult tie-in.” In response, Gouran stated by email, “That is not a problem at all, and most welcome.”
8 However, unbeknownst to Playboy, GBT had no ability to control VIT.
9 51. On March 13, 2018, Gouran emailed Mike Koroshun7 directing him to make specific
10 changes to VIT’s website on a specific time frame. In the email, Gouran directed Mr. Koroshun to
11 “Change everywhere that says ‘Get Paid to Watch Porn’ to ‘Get Paid to Watch Videos.’” In the email,
12 Gouran further stated, “We also have to change the partners section but I will let you know what to do
13 with it after you have completed these.” In the email, Gouran stated, “can we do this ASAP please,
14 priority over everything else, I want it finished by 9pm est.” Mr. Koroshun responded to Gouran’s
15 email stating, “On it.” Gouran knew that Playboy was copied on this email exchange, and intended
16 that Playboy would rely on Gouran’s statements in the email exchange. By including Playboy on this
17 email exchange, Gouran sought to demonstrate to Playboy that GBT controlled VIT and could make
18 changes to VIT’s website.
19 52. The same day, Gouran also emailed Playboy stating, “Hello, we updated the site:
20 https://vicetoken.com/.”
21 53. Based on these and other representations, Playboy believed that GBT owned and/ or
22 controlled VIT and thus GBT could ensure performance of its obligations under the MOU, including
23 that GBT could make changes to VIT’s website, that it could access the proceeds of the Crowdsale,
24 and that it could integrate the technologies onto Playboy’s designated site.
25
26
27 7
Mike Koroshun is listed on VIT’s website as a UI/UX Developer. See
https://vicetoken.com/team. Mr. Koroshun’s LinkedIn profile indicates that he is also a Developer for
28 GlobalBlockchain.io.
11
1 54. However, subsequent to the filing of this lawsuit, Playboy learned that GBT has no
2 ownership interest in, or control of, VIT. Indeed, GBT and VIT have each publicly stated in
3 connection with this litigation that the two companies are unaffiliated in any way.
4 55. In its demurrer to Playboy’s initial complaint, GBT stated that “GBT and VIT are
5 separate entities.” GBT argued that VIT is an “indispensable party” because GBT is not “affiliated
6 with any of VIT’s actions pertaining [to] VIT’s own website,” and VIT has an “interest in managing
7 the content on VIT’s own website.” GBT later modified its position in its responses to Playboy’s
8 interrogatories, admitting that GBT “requested” that VIT make certain changes to its website and that
9 “GBT cooperated with VIT” in making certain changes to VIT’s website, but continuing to state that
10 VIT’s website “is in the sole control of VIT and/or Tokken MSB.”
11 56. Similarly, in moving to quash service of the complaint on GBT, VIT argued that “VIT is
12 not affiliated with GBT in any shape or form.” In support of this motion, VIT attached the declaration
13 of its CEO, Stuart Duncan, in which Mr. Duncan stated, under penalty of perjury, that “GBT and VIT
14 are not affiliates or subsidiaries of one another in any shape or form. The two companies are entirely
15 separate entities, and I am unaware of any reason as to why Playboy would believe GBT and VIT are
16 related.”
17 57. Playboy never would have entered into the MOU with GBT if it knew that Gouran and
18 GBT did not control VIT, but instead were relying on VIT to make the requested changes to the
19 website, to provide GBT with access to the proceeds from the Crowdsale, and to coordinate with
20 Playboy to integrate the technologies onto Playboy’s designated site.
21 (b) Gouran, on Behalf of GBT, Falsely Represents that GBT Will Pay Playboy
22 the $4 Million Directly from the Crowdsale Proceeds.
23 58. In exchange for Playboy’s agreements in the MOU, GBT promised, among other things,
24 that it would make payments to Playboy including a payment of $4 million by July 16, 2018. Gouran,
25 on behalf of GBT, represented that GBT would pay Playboy up to $4 million from the proceeds of the
26 Crowdsale. Based on Gouran’s statements and/or omissions, Playboy reasonably believed that GBT
27 would have direct access to the proceeds from the Crowdsale.
28
12
1 59. In reality, GBT never intended to pay Playboy directly from the cash proceeds from the
2 Crowdsale. As it turns out, GBT entered into a secret side deal with VIT under which VIT agreed that
3 it would pay the $4 million to GBT out of the cash proceeds from the Crowdsale (the “Side Deal”),
4 which VIT and GBT intended would then be paid to Playboy.
5 60. On March 13, 2018 – after negotiations with Playboy had completed, and the MOU was
6 all but signed – Gouran sent an email to GBT’s CFO, Theo Van Der Linde, seeking board approval for
7 a deal between GBT and Playboy. In the email, Gouran states that the proposed agreement “involves
8 Global paying $1,000,000 USD to Playboy” – not $5 million, as it promised in the MOU – “and
9 offering stock in Global as collateral, in case of default by a third party” (i.e., VIT). Thus, the email
10 not only confirms Gouran’s understanding – unbeknownst to Playboy – that VIT, not GBT, would fund
11 the $4 million payment obligation, but it confirms that GBT never intended to pay the $4 million to
12 Playboy in the event that VIT did not pay GBT the $4 million from the proceeds of the Crowdsale.
13 61. On or about March 16, 2018, Barry Rotenberg sent a fax message to Gouran to
14 “confirm the details” of the deal between GBT and VIT. One of the deal terms was that, in addition to
15 the $1 million “advance Fee” that had been paid to Playboy by GBT, “[a] further $4,000,000 U.S. Fee
16 is due to Playboy from the Crowdsale.” Thus, the deal memorialized that “[o]n the Crowdsale you
17 [i.e., VIT] will pay . . . the first $4,000,000 U.S. to Playboy.” Gouran forwarded the fax message to
18 Duncan, who confirmed that VIT would pay $4 million to Playboy and $1 million to GBT.
19 62. In connection with this litigation, GBT now claims that it has no documents or
20 information whatsoever relating to the cash proceeds generated from the Crowdsale, or what became
21 of them. Accepting these representations as true, the only conclusion is that GBT never received any
22 portion of the cash proceeds from the Crowdsale from VIT.
23 63. Gouran’s false and misleading statements and omissions were material to Playboy’s
24 decision to enter into the MOU. If Playboy had known that GBT would not have access to the
25 proceeds from the Crowdsale; that GBT would not even know what the cash proceeds from the
26 Crowdsale were; and that GBT was relying entirely on VIT to fund the $4 million out of the Crowdsale
27 proceeds, Playboy never would have entered into the deal with GBT. Indeed, relying entirely on VIT
28
13
1 to fund the $4 million was precisely the deal Playboy sought to avoid by not agreeing to the original
2 deal Gouran proposed whereby Playboy would contract with VIT.
3 (c) Gouran, on Behalf of GBT, Falsely Represents that GBT Would Make Up
4 Any Cash Shortfall By Providing Common Stock.
5 64. In addition to the false statements and omissions regarding GBT’s access to the
6 Crowdsale proceeds, Gouran, on behalf of GBT, knowingly made false assurances to Playboy that any
7 shortfall in cash would be made up with GBT stock. Specifically, to assuage Playboy’s concerns that
8 the Crowdsale might not raise sufficient funds to cover GBT’s obligations under the agreement,
9 Gouran promised that if the Crowdsale raised cash proceeds of less than $4 million, GBT would satisfy
10 the $4 million obligation through a combination of cash and stock. The cash component would be the
11 actual amount raised through the Crowdsale. To make up the shortfall, GBT would issue shares of its
12 common stock to Playboy with an aggregate value equal to such shortfall. The number of shares
13 would be computed based on the VWAP per share as reported on the Canadian Stock Exchange over
14 the prior 20 trading days. The shares issuable to Playboy would be “of the same class listed on the
15 Canadian Stock Exchange” and “freely tradable without restriction.”
16 65. In actuality, Gouran had not received approval from GBT’s board to make this offer to
17 Playboy. Indeed, it was not until March 13, 2018 – after Gouran had already made the promise to
18 Playboy – that Gouran requested permission from GBT’s board to enter into the MOU with Playboy.
19 And Gouran was not able to obtain the board’s approval right away. In fact, Playboy is informed and
20 believes, and thereon alleges, that as late as March 27, 2018 – more than two weeks after the parties
21 had already executed and begun performing under the MOU, including Playboy’s issuance of press
22 releases – GBT’s chairman, Steve Nerayoff, still had not signed the board resolution approving the
23 MOU with Playboy.
24 66. At the time he made the promise, Gouran never intended that GBT would issue
25 common stock to Playboy in the event of a cash shortfall. At the time of the MOU, Gouran believed
26 that the Crowdsale had raised a sufficient amount of cash proceeds to fund the payments to Playboy,
27 and therefore believed that there would be no cash shortfall. In a draft board resolution dated March
28 14, 2018, GBT’s board stated, presumably in reliance on representations by Gouran, that “the
14
1 Crowdsale at this point is approximately $17,000,000 US and it would appear that there will be
2 sufficient funds available to repay the Corporation the $1,000,000 and the Corporation would not be
3 required to issue shares with respect to the subsequent $4,000,000 US.”
4 67. GBT’s promise that it would make up any cash shortfall by issuing common stock was
5 material to Playboy’s decision to enter into the MOU. Had Playboy known that Gouran had not
6 obtained the prior approval of GBT’s board to promise the payment of GBT stock to Playboy in the
7 event of a shortfall, Playboy would not have entered into the MOU with GBT. Moreover, had Playboy
8 known that Gouran never intended that GBT would pay Playboy the common stock in the event of a
9 cash shortfall, Playboy would not have entered into the MOU. The perceived financial stability of
10 GBT, and its promise to fulfill its obligations under the contract regardless of how the Crowdsale
11 performed, was a key reason that Playboy agreed to the deal.
12 (d) Gouran, on Behalf of GBT, Falsely Promises that GBT Will Provide
13 Technical Support to Playboy.
14 68. During negotiations with Playboy regarding the proposed agreement, Gouran, on behalf
15 of GBT, promised Playboy that GBT would provide technical support, at no cost to Playboy, to assist
16 Playboy in integrating the blockchain technology into Playboy’s designated site.
17 69. However, GBT has since claimed that, in actuality, Playboy needed to coordinate with
18 VIT to integrate the technology. In its responses to Playboy’s discovery requests, GBT attempted to
19 shift responsibility to VIT, stating that “VIT contracted with GBT” to integrate the blockchain
20 technology onto Playboy’s online media platform. Likewise, in a recent court filing, GBT claimed that
21 the MOU required Playboy “to cooperate with a third party, Vice Industry Token (‘VIT’), to integrate”
22 the technologies into Playboy’s platform.
23 70. Prior to execution of the MOU, Gouran did not disclose to Playboy that VIT, and not
24 GBT, would be responsible for integrating the blockchain technologies onto Playboy’s online platform.
25 Rather, Gouran and GBT, through their false and misleading statements and omissions, intentionally
26 led Playboy to believe that GBT would provide the required technical support – a promise that is
27 expressly memorialized in the MOU. Had Playboy known that GBT would attempt to shift
28
15
1 responsibility for integrating the technology onto VIT, an entity that GBT has no control over, Playboy
2 never would have entered into the MOU with GBT.
3 (e) Gouran Fails to Disclose to Playboy That, As a Principle Shareholder of
4 VIT, He Has a Conflict of Interest in the Playboy Deal.
5 71. Playboy is informed and believes, and on that basis alleges, that at the time Gouran
6 approached Playboy regarding the potential deal with VIT, and throughout the time that Gouran
7 negotiated the MOU with Playboy, Gouran was not only the President and CEO of GBT: he was also a
8 “principle shareholder” in VIT in his personal capacity.
9 72. On March 13, 2018 – after negotiations with Playboy had completed, and the MOU was
10 all but signed – Gouran sent an email to GBT’s CFO, Theo Van Der Linde, seeking board approval for
11 a deal between GBT and Playboy. In the email, Gouran described the proposed agreement between
12 GBT and Playboy, and explained that the reason he was seeking board approval was because “there is
13 a conflict of interest with this deal as I will potentially benefit from this partnership, outside of Global,
14 as one of the principle shareholders of the third party (Tokken MSB Inc.)[.]” (Emphasis added.)
15 73. During the negotiations leading up to the MOU, Gouran never disclosed to Playboy that
16 he was a principle shareholder in Tokken or VIT, and that he therefore stood to benefit personally from
17 the deal. This was a critically important fact and Gouran’s glaring failure to disclose this fact to
18 Playboy was material to Playboy’s decision to enter into the MOU with GBT.
19 D. In Reliance on Gouran’s and GBT’s Fraudulent Statements and Omissions,
20 Playboy Enters Into the MOU with GBT.
21 74. On March 13, 2018, in reliance on Gouran’s and GBT’s fraudulent statements and
22 omissions, Playboy entered into the MOU, a written and binding document that memorialized the
23 terms of Playboy’s and GBT’s agreement.
24 75. Under the MOU, Playboy agreed to integrate GBT’s blockchain technology into
25 Playboy’s online media platform “as selected and determined in PB’s sole discretion.” GBT agreed
26 that it would “provide technical services, at no cost to PB or its affiliates, to integrate into PB’s
27 selected online properties the VIT tokens.” GBT repeated this promise in another part of the MOU,
28
16
1 stating that it would “provide the technology resources and solutions” for Playboy to integrate GBT’s
2 blockchain technologies into the designated site “at no cost” to Playboy or its affiliates.
3 76. Playboy also agreed that, following receipt of GBT’s initial payment of $1 million,
4 Playboy would make certain announcements regarding its partnership with GBT and integration of the
5 Vice tokens.
6 77. Prior to Playboy making any announcements under the MOU, however, GBT agreed
7 that it would “remove the terminology referring to ‘porn’ from the VIT website”; that it would
8 “coordinate with [Playboy] to rebrand the VIT website as more generally video/entertainment-
9 oriented”; and that it would “evolve VIT from an adult only play to a broader draw.”
10 78. In the MOU, Playboy made very clear that all uses of Playboy’s brands – including,
11 without limitation, Playboy’s name and logo – in connection with the subject matter of the MOU
12 would be subject to strict limitations. Among other restrictions, the MOU provided that (i) all uses of
13 Playboy’s brands will be subject to Playboy’s prior written approval, which may be granted or
14 withheld in Playboy’s sole discretion; (ii) if notified in writing by Playboy, GBT will take immediate
15 action, or cause immediate action to be taken, to remove Playboy’s brands or to alter use as directed by
16 Playboy; (iii) GBT’s, VIT’s, and their respective affiliates’ use of Playboy’s brands will be limited to
17 those uses set forth in the MOU; and (iv) Playboy’s authorization to use its brands will terminate upon
18 the breach of GBT of any of its obligations under the MOU, including, without limitation, GBT’s
19 failure to timely pay any of the consideration described in the MOU.
20 79. In exchange for Playboy’s agreements to (i) make certain announcement and (ii) with
21 GBT’s technical assistance, to integrate GBT’s blockchain technologies onto the designated site, GBT
22 agreed to provide Playboy with compensation consisting of, among other things, an initial cash
23 payment of $1 million and a subsequent payment of $4 million which was due July 16, 2018. The
24 MOU reflects Gouran’s and GBT’s promise to Playboy that, if the cash proceeds from the Crowdsale
25 equaled or exceeded $4 million, then the $4 million payment would be made to Playboy in cash; and if
26 the cash proceeds from the Crowdsale were less than $4 million, then GBT would pay Playboy the
27 cash proceeds from the Crowdsale, and it would make up the shortfall by issuing shares of GBT’s
28
17
1 common stock with an aggregate value equal to the shortfall, according to a specific calculation that is
2 described in the MOU.
3 80. GBT’s promises, as memorialized in the MOU, further reflect and confirm Gouran’s
4 and GBT’s deception. For example, GBT’s promises that it would “remove” certain terminology from
5 the VIT website and that it would “rebrand” the VIT website further confirmed Gouran’s and GBT’s
6 deception regarding their ownership and/or control over the VIT website. In fact, GBT agreed to
7 indemnify Playboy for any actions or losses incurred by Playboy relating to or arising from “the
8 establishment and operation of the VIT site.” Through these statements, Gouran and GBT
9 intentionally and knowingly misled Playboy to believe that GBT had the power to control the content
10 on VIT’s website and to direct (not merely request or facilitate) that specific changes be made to the
11 VIT website. Nowhere in the MOU is it disclosed that Gouran and GBT, in fact, had no control over
12 the VIT website – in reality, they had only the power to “request” or “facilitate” that changes be made
13 to the VIT website.
14 81. Moreover, the MOU confirms Gouran’s and GBT’s deception regarding the $4 million
15 payment that was promised. In the MOU, GBT promises that the $4 million payment will be made to
16 Playboy, and GBT even “represents and warrants that it has sufficient and available funds to make the
17 USD payments set forth” therein. Thus, Playboy believed that GBT would have direct access to the
18 cash proceeds from the Crowdsale, and that GBT would be making the $4 million payment to Playboy.
19 Nowhere in the MOU is it disclosed that GBT would not have direct access to the cash proceeds from
20 the Crowdsale; that, in fact, GBT did not even know what the cash proceeds from the Crowdsale were;
21 and that GBT would be relying on VIT’s cooperation in order to fulfill its payment obligations to
22 Playboy. Nor is it disclosed anywhere in the MOU that Gouran had not obtained the approval of
23 GBT’s board of directors to promise a payment of stock to Playboy.
24 82. The MOU further confirms Gouran’s and GBT’s deception regarding Gouran’s
25 relationship with VIT and his financial interest in the transaction. Nowhere in the MOU is it disclosed
26 that Gouran was a principle shareholder of VIT; that he therefore stood to profit personally from the
27 transaction; and that he therefore had a conflict of interest in the transaction that was so serious that he
28
18
1 needed to seek permission from GBT’s board of directors to approve the transaction (though not, it
2 turns out, until after he had already agreed to the transaction on GBT’s behalf).
3 83. The MOU was not a mere agreement to agree. The MOU was intended by the parties
4 thereto to be binding upon execution of the agreement. This intention is clearly expressed in the
5 agreement itself. The MOU states: “This MOU will be legally binding on GBT upon its execution and
6 on PB once PB has given written confirmation of its receipt of the initial US $1,000,000 payment.”
7 The MOU was executed by GBT on March 13, 2018, and Playboy gave written confirmation of its
8 receipt of the initial $1 million payment to GBT. Accordingly, by its own terms, the MOU was at that
9 point legally binding on the parties.
10 84. The MOU also clearly states that it represents the entire agreement between the parties
11 thereto, and that neither party’s promises or obligations under the MOU would be conditional upon the
12 performance of agreements not expressly described therein. Specifically, the MOU states: “This MOU
13 supersedes and replaces all prior negotiations, understandings and proposed agreements between the
14 parties, written or oral.” GBT’s promises under the MOU, including its promises to provide technical
15 support and to make the $4 million to Playboy, were not conditional upon Playboy’s performance of
16 any alleged separate agreements or understandings that are not reflected in the MOU.
17 E. GBT and Gouran Confirm Their Fraudulent Intent By Failing to Honor Their
18 False Promises.
19 (a) In Reliance on GBT’s Initial Performance, Playboy Begins to Perform
20 Under the MOU.
21 85. After the MOU was finalized, GBT made the initial $1 million payment to Playboy
22 under the MOU for the purpose of inducing Playboy to issue a public announcement regarding the
23 partnership with Playboy. Playboy then performed its obligations under the contract by issuing an
24 agreed upon press release and by designating a specific site for integration of GBT’s blockchain
25 technologies pursuant to its discretion under the MOU. Specifically, Playboy announced that
26 “Playboy.TV will be the first of the company’s media platforms to feature the new digital wallet which
27 will enable the online platform to except Vice Industry Token (VIT), among other leading
28 cryptocurrency Tokens, for access to the brands exclusive content.”
19
1 86. Unfortunately, despite GBT’s initial performance, which induced Playboy to perform
2 under the MOU in good faith, GBT subsequently failed to honor its promises.
3 (b) GBT Failed to Provide the Promised Technical Support.
4 87. Contrary to Gouran’s and GBT’s promise, GBT failed to provide the promised technical
5 support to Playboy, which made it impossible for Playboy to integrate GBT’s technologies into the
6 designated site, despite Playboy’s good faith efforts to do so.
7 88. On May 20, 2018, Playboy reminded Gouran that the parties had “discussed that as a
8 next step we would complete any open conditions” related to integration of the technology on
9 Playboy’s designated site. On May 30, 2018, Gouran responded in the same email chain, agreeing that
10 GBT’s development team should speak with Playboy’s development team regarding next steps for the
11 integration, but without any further follow-up.
12 89. On June 15, 2018, Playboy emailed Gouran again to schedule a discussion between the
13 parties’ respective development teams regarding integration. On or about June 27, 2018, Playboy’s
14 and GBT’s respective development teams had a call to discuss integration.
15 90. Later the same day, Playboy sent Gouran an email copying members of Playboy’s
16 development team, including Roy Palondikar. The next day, Mr. Palondikar emailed Gouran asking
17 him to “send over any designs you have of the buttons and anything else that is user-facing.” Gouran
18 responded to Mr. Palondikar’s email by copying Mike Khoroshun and Simon Ditner, members of
19 GBT’s development team, and stating that they will have a Discord channel specific to this project.
20 However, neither Gouran nor any member of GBT’s development team provided any further follow-up
21 in response to Mr. Palondikar’s request.
22 91. On July 9, 2018, Mr. Palondikar sent another email to Gouran, copying John Mauser of
23 Too Much Media, and stating that “If you guys are still looking to integrate with them, this is the man
24 to talk to.” Gouran did not respond to this email either.
25 92. The same day, Mr. Mauser sent an email to Gouran regarding integration of the Vice
26 tokens. On July 18, Mr. Mauser sent Gouran another email stating that he “wanted to touch base again
27 since I didn’t see a reply come through my inbox and wanted to make sure the initial email was
28
20
1 received, so as not to create any delays.” To Playboy’s knowledge, Gouran never responded to either
2 one of Mr. Mauser’s emails.
3 93. In sum, although Gouran and GBT initially cooperated in setting up a discussion
4 between their respective teams regarding integration, after June 29, 2018, neither Gouran nor any
5 member of GBT’s development team provided any further response or engagement with respect to
6 integration of GBT’s blockchain technologies onto Playboy’s platform. Neither Gouran nor GBT ever
7 delivered the designs that Mr. Palondikar requested, nor provided the Discord channel that Gouran said
8 GBT would provide. Moreover, based on the lack of any such documents in GBT’s document
9 production, Playboy is informed and believes, and thereon alleges, that neither Gouran nor any
10 member of GBT’s development team so much as sent a single internal email about integrating GBT’s
11 technology into Playboy’s platform. Gouran’s and GBT’s willful refusal to cooperate with Playboy
12 with regard to integration made it impossible for Playboy to integrate GBT’s technologies into
13 Playboy’s designated site.
14 94. Additionally, based on GBT’s statement that it contracted with VIT to provide certain
15 unspecified services with respect to integration, Playboy is therefore informed and believes, and
16 thereon alleges, that VIT and Duncan were aware of GBT’s promise to Playboy under the MOU to
17 provide technical support, at no cost to Playboy, to integrate GBT’s blockchain technologies onto
18 Playboy’s designated site.
19 95. In fact, in his July 9, 2018 email to Gouran, Mr. Mauser stated that “I had just reached
20 out to Stuart about 2 weeks ago inquiring about the same thing, to see if there was an interest for the
21 integration. I see now there is.” Based on this statement by Mr. Mauser, Playboy is informed and
22 believes, and thereon alleges, that Duncan, on behalf of VIT, indicated to Mr. Mauser on or about June
23 25, 2018 (two weeks prior to July 9, 2018) that Duncan and/or VIT were not interested in the
24 integration of Vice token onto Playboy’s platform.
25 96. Accordingly, Playboy is informed and believes, and thereon alleges, that VIT and
26 Duncan willfully failed to provide the agreed upon services with regard to integration, either intending
27 or knowing that this conduct was substantially certain to disrupt GBT’s promise to Playboy under the
28 MOU to provide technical support with regard to integration.
21
1 (c) GBT Failed to Make the Promised Changes to the VIT Website.
2 97. As further evidence of Gouran’s and GBT’s deception, VIT, at Gouran’s request,
3 initially removed references to “porn” from the VIT website, which Playboy relied upon in agreeing to
4 enter into the MOU. However, after the MOU was executed, VIT subsequently made changes to the
5 VIT website, without Playboy’s knowledge or consent, that violated GBT’s promises under the MOU.
6 98. After the MOU was executed, but before this litigation was commenced, the VIT
7 website had reintroduced the words “Get Paid to Watch Porn” – indeed, those words were prominently
8 displayed on the website. Further, the VIT website continued to refer to “adult content” and the “adult
9 industry.” Moreover, the VIT website displayed Playboy’s name as an affiliate partner – on the same
10 page that contained the “porn” and “adult” language – under the adult entertainment group next to
11 porn-related websites. Playboy is informed and believes, and thereon alleges, that the following
12 images depict the content of VIT’s website, in part, as of June 21, 20188:
13 Image #1:
14
15
16
17
18
19
20
Image #2:
21
22
23
24
25
26
27
28 8
See https://web.archive.org/web/20180621144031/https://vicetoken.com/ (June 21, 2018).
22
1
2 99. Although Playboy is unaware of the exact date that these changes to the VIT website
3 were made, Playboy is informed and believes, and on that basis alleges, that these changes were made
4 on or before June 21, 2018. Had Playboy known that these changes would be made, Playboy never
5 would have entered into the MOU.
6 100. These changes to the VIT website breached GBT’s promises to Playboy under the
7 MOU. Nonetheless, in spite of this breach, both GBT and VIT continued to promote their partnership
8 with Playboy. For example, Gouran gave a GBT presentation to potential investors on June 6, 2018,
9 which included slides regarding the Playboy deal.
10 101. During roughly the same time period, VIT continued to regularly tweet about the
11 Playboy deal. For example, on June 14, 2018, VIT tweeted: “‘Playboy.tv will be able to pay people
12 just for watching videos by using Vice Industry Token, that will pull the platform way ahead of the
13 pack.’ -Global Blockchain.” (Depicted below.)
14
15
16
17
18
19
20
21
22
23
24
25 102. On July 5, 2018, VIT tweeted, “Playboy wants to Pay You to watch Adult
26 Entertainment!” (Depicted below.)
27
28
23
1
2
3
4
5
6
7
8
9
10
11 103. Playboy is also informed and believes, and on that basis alleges, that VIT and Duncan
12 were aware of GBT’s promise to Playboy under the MOU to remove the words “Get Paid to Watch
13 Porn” from the VIT website. According to GBT, VIT controls the content on its own website. On that
14 basis, Playboy is informed and believes, and thereon alleges, that VIT and Duncan willfully added the
15 word “Get Paid to Watch Porn” onto the VIT website, either intending or knowing that this conduct
16 was substantially certain to result in GBT breaching its promise to Playboy under the MOU to remove
17 those words from the VIT website.
18 (d) As the Deadline Approached, GBT Began to Indicate That It Would Not
19 Make the $4 Million Payment As Promised.
20 104. On July 6, 2018, Gouran told Playboy that the Crowdsale had occurred at an
21 “unfortunate time,” which negatively impacted the performance of the Crowdsale. Rather than
22 offering to pay Playboy either the cash or the stock that GBT owed under the MOU, Gouran instead
23 proposed that “VIT does a secondary crowdsale,” and that “Tokken MSB will pay you 10% of the
24 proceeds of the crowdsale plus they will give you 5% equity in the company and 500,000,000 more
25 tokens for the delay.”
26 105. On July 11, 2018, Gouran again insisted on having another crowdsale, because “the first
27 sale was at a very bad time.” Again, through these and other statements, Gouran misled Playboy into
28
24
1 believing that GBT owned and/or controlled VIT and that GBT had access to the proceeds from the
2 Crowdsale.
3 106. As the July 16 deadline neared for the $4 million payment to be made, Playboy began to
4 seek assurances from GBT, through Gouran, that GBT would honor its promise. Playboy also asked
5 Gouran, on behalf of GBT, to provide information relating to the cash proceeds for the Crowdsale and
6 information relating to GBT’s promise to provide stock in the case of any shortfall. Gouran and GBT,
7 however, refused to provide the requested assurances and refused to provide any of the requested
8 information. Instead, Gouran and GBT stonewalled, delayed, and made up excuses.
9 (e) GBT Never Paid Playboy a Single Penny of the Promised $4 Million.
10 107. In the end, GBT never paid Playboy a single penny of the $4 million that Gouran and
11 GBT promised. As it turns out, GBT never intended to honor its obligations under the MOU and was
12 instead (and unbeknownst to Playboy) relying on VIT, a party that it now admits it has no control over,
13 to fund the required payments to Playboy.
14 108. Playboy is also informed and believes, and on that basis alleges, that VIT’s failure to
15 provide GBT with the cash proceeds from the Crowdsale, in breach of the Side Deal, contributed to
16 GBT’s failure to pay Playboy any of the $4 million owed under the MOU.
17 F. GBT’s July 2018 Statement to Investors Confirms Its Deceptive Tactics
18 109. On July 2, 2018, GBT issued a statement seeking to assure its investors regarding its
19 financial health.9 In the press release, GBT acknowledged that investors may find the recent drop in
20 GBT’s share price to be alarming. GBT urged investors to “not lose confidence,” and assured
21 investors that there are “several other factors to take into account – which, when considered together,
22 provide an objectively positive short-term and long-term view of [GBT’s] shares as an investment.”
23 110. The first “factor” that GBT urged its investors to consider is that “All Projects [Are] on
24 Schedule.” That statement, however, is not accurate. GBT has failed to provide the technical services
25 to Playboy, and has failed to pay Playboy the $4 million that it promised to pay. Thus, the Playboy
26
27
9
https://ir.globalblockchain.io/press-releases/detail/45/global-blockchains-statement-to-
28 investors-regarding-q2.
25
1 project is not on schedule, and GBT’s statement to investors that “[a]ll” of GBT’s projects are on
2 schedule is false and misleading.
3 111. GBT’s press release further states:
4 [GBT] is presently undertaking several projects – a number of which remain under
5 confidentiality due to the involvement of major corporations as well as government
6 entities. An “at-a-glance” breakdown of some of the more notable projects is provided
7 below. There are not presently any significant roadblocks to any of these projects. There
8 will be considerable movement on each of the projects below prior to the end of 2018.
9 112. Conspicuously absent from the list of “more notable projects” is GBT’s partnership
10 with Playboy. In fact, GBT has created “significant roadblocks” to that project, including by failing to
11 provide the technical services to complete the project and by failing to pay Playboy the $4 million it
12 promised to pay. GBT’s omission of the Playboy deal from the list of notable projects confirms GBT’s
13 disregard for its partnership with Playboy and for the importance of honoring its promises. The
14 omission also misleads investors by failing to disclose the significant roadblocks GBT has caused
15 regarding the Playboy project, further evidencing GBT’s deceptive tactics and its lack of regard for the
16 truth.
17 113. The press release also states that “[t]he Company continues to be well financed for all
18 its major developments.” If indeed GBT is “well financed,” then its failure to pay Playboy must be
19 understood as willful and malicious, and a further reflection of GBT’s disregard for upholding its
20 promises to Playboy. If, on the other hand, GBT is unable to fulfill its promise to Playboy due to
21 financial constraints, then the statement that the company is “well financed for all its major
22 developments” is false and misleading.
23 G. Defendants Willfully Use Playboy’s Brand Without Authorization to Serve Their
24 Own Agendas, Causing Further Harm to Playboy.
25 114. Under the MOU, GBT’s authorization to use Playboy’s brands, including without
26 limitation the Playboy name and Rabbit Head logo, was expressly limited in scope and duration. In
27 particular, GBT’s, VIT’s, and their respective affiliate’s use of the Playboy brands was limited to the
28 uses set forth in the MOU. Moreover, GBT’s and VIT’s limited authorization to use Playboy’s brand
26
1 terminated upon GBT’s breaches of its obligations under the MOU, including, without limitation,
2 GBT’s failure to pay the $4 million; its failure to provide the promised technical support; and its
3 failure to make the required changes to the VIT website.
4 115. Nonetheless, Defendants continued to use Playboy’s brand even after GBT had
5 breached its obligations under the MOU, even though at that point they no longer had Playboy’s
6 authorization to do so.
7 116. As alleged previously, on or before June 21, 2018, the “Get Paid to Watch Porn”
8 language had already been reintroduced to the VIT website – which in itself was a breach of the MOU.
9 Nonetheless, after that date, the VIT website continued to include Playboy as an affiliate partner in the
10 adult entertainment group next to porn-related websites. The association that this created between
11 Playboy’s valuable brand and VIT’s slogan “Get Paid to Watch Porn” is exactly what Playboy was
12 trying to avoid when it insisted that GBT remove that language from VIT’s website before it entered
13 into the MOU.
14 117. Moreover, VIT issued numerous tweets after June 21, 2018 in which it used Playboy’s
15 name and/or logo in order to promote its business. For example, on July 6, 2018 – the same day that
16 Gouran proposed to Playboy that “VIT does a secondary crowdsale” instead of honoring its payment
17 obligations under the MOU – VIT tweeted: “Cable and satellite TV companies have a porn problem:
18
19
20
21
22
23
24
25
26
27
28
27
1 Their customers aren’t watching enough of it - No wonder industry leaders like Playboy and Exxxtasy
2 [are] teaming up with VIT to pay their viewers.” (Depicted below; emphasis added.)
3 118. On July 18, 2018 – two days after GBT had failed to pay the $4 million to Playboy,
4 which was due by July 16, 2018 – Gouran directed a PR representative to encourage a reporter to write
5 a story about GBT by telling the reporter that “what we are doing with Playboy ‘Get Paid to Watch’”
6 would make for a good story. The fact that Gouran was still attempting to use Playboy’s brand to
7 obtain favorable publicity for GBT, even after GBT had breached its obligation to pay Playboy the $4
8 million that it owed under the MOU, further confirms Gouran’s and GBT’s brazen disregard for
9 Playboy’s right to control the use of its brand.
10 119. VIT likewise continued to tweet about the Playboy deal even after GBT had failed to
11 pay Playboy the $4 million in breach of the MOU. For example, on July 26, 2018, VIT tweeted a
12 photo of Playboy Bunnies and stated, “Playboy will soon accept cryptocurrencies including Vice
13 Industry Token. This could change how porn is paid for online!” (Depicted below.)
14
15
16
17
18
19
20
21
22
23
24
25
26 120. The next day, on July 27, VIT tweeted, “Playboy to Soon Allow Bitcoin and Vice
27 Industry Token Across its Platform.” (Depicted below.)
28
28
1
2
3
4
5
6
7
8
9
10
11
12
121. Defendants’ continued use of Playboy’s brand, even after GBT had breached the MOU,
13
was done without Playboy’s consent and in violation of the express terms of the MOU.
14
122. Defendants’ unauthorized conduct was intended to deceive consumers and cause
15
consumer confusion and mistake as to the affiliation, connection, or association of Playboy with GBT
16
and/or VIT, and as to the sponsorship or approval by Playboy of GBT and/or VIT.
17
H. Defendants’ Wrongful Conduct Has Caused Substantial Harm to Playboy
18
123. As a direct and proximate result of Defendants’ wrongful conduct, Playboy has suffered
19
substantial harm.
20
124. Induced by Gouran’s and GBT’s false promises, Playboy agreed to publicize, and to
21
allow GBT and VIT to publicize, their partnership with Playboy and Playboy’s integration of the Vice
22
token. Playboy’s decision to allow its valuable brand to be associated with GBT and VIT hinged on
23
Gouran’s and GBT’s representations that, among other things, Playboy’s brand would not be
24
associated with “Get Paid to Watch Porn,” and that Playboy would receive $4 million from GBT,
25
whether in cash or stock.
26
125. However, as a direct and proximate result of Defendants’ wrongful conduct alleged
27
herein, these conditions were not met. Playboy’s brand was associated with “Get Paid to Watch Porn,”
28
29
1 and Playboy never received the $4 million that it was promised. Playboy’s consent to allow its
2 valuable brand to be associated with GBT and VIT was obtained by fraud. As a result of Defendants’
3 wrongful actions, Playboy has suffered substantial and irreparable harm to its brand value and
4 reputation.
5 126. Through this action, Playboy seeks to recover these and all other harms caused by
6 Defendants’ wrongful conduct alleged herein.
7 FIRST CAUSE OF ACTION
8 (Fraud and Intentional Deceit)
9 (Against GBT and Gouran)
10 127. Playboy incorporates by reference the allegations in the foregoing paragraphs as if fully
11 set forth herein.
12 128. In the course of negotiating the MOU with Playboy, Gouran, on behalf of GBT, made
13 numerous false statements and omissions to Playboy which were intended to induce, and which did
14 induce, Playboy to enter into the deal. Gouran’s and GBT’s false statements and omissions include the
15 following:
16 (a) Gouran and GBT led Playboy to believe that they owned and/or controlled VIT
17 and could make changes to VIT’s website. But GBT has since claimed that it had no control over
18 VIT’s website, and it only had the ability to “request” or “facilitate” changes to VIT’s website.
19 (b) Gouran and GBT promised that GBT would make payments to Playboy
20 including a payment of $4 million by July 16, 2018, which would be funded by the proceeds of the
21 Crowdsale. In reality, GBT had no access to the cash proceeds from the Crowdsale and was relying on
22 VIT to fund the $4 million payment.
23 (c) As an additional assurance to Playboy, Gouran and GBT also promised that if
24 the Crowdsale did not raise sufficient funds to cover the payment, GBT would make up any shortfall
25 by providing Playboy with shares of its common stock. But in reality, Gouran had not received
26 approval from GBT’s board to make that promise.
27 (d) Similarly, Gouran and GBT misled Playboy into believing that GBT would
28 provide technical support to Playboy, at no cost, to help Playboy integrate the blockchain technologies
30
1 into the designated site. But, in reality, GBT contracted with VIT to provide the technical support and
2 has disclaimed any responsibility for providing the promised technical support.
3 (e) Gouran and GBT also misled Playboy by failing to disclose that Gouran was not
4 only the President and CEO of GBT, but was also a “principle shareholder” of VIT, which created a
5 conflict of interest so serious that Gouran believed he had to disclose it to GBT’s board of directors
6 and seek approval for the transaction (though not until after he had already agreed to the deal on
7 GBT’s behalf).
8 129. Gouran and GBT knew that these representations were false at the time they were made,
9 or they made these representations recklessly and without regard for their truth. Likewise, Gouran and
10 GBT knew that the omitted facts were unknown to Playboy and could not have been discovered by
11 Playboy.
12 130. Gouran and GBT intended that Playboy would rely on the misrepresentations and
13 omissions in entering into the MOU and performing under the MOU.
14 131. Playboy actually relied on Gouran’s and GBT’s misrepresentations and omissions in
15 entering into the MOU and performing under the MOU, and Playboy’s reliance was justifiable. Had
16 Playboy known the truth, Playboy never would have entered into, nor performed under, the MOU.
17 132. As a direct and proximate result of Gouran and GBT’s fraud and intentional deceit,
18 Playboy has suffered substantial and irreparable harm, in an amount to be proven at trial.
19 133. GBT’s and Gouran’s conduct was willful and malicious. Accordingly, Playboy is
20 entitled to punitive damages in an amount to be proven at trial.
21 SECOND CAUSE OF ACTION
22 (Negligent Misrepresentation)
23 (Against GBT and Gouran)
26 135. In the course of negotiating the MOU with Playboy, Gouran, on behalf of GBT, made
27 numerous false statements and omissions to Playboy which were intended to induce, and which did
28
31
1 induce, Playboy to enter into the deal. Gouran’s and GBT’s false statements and omissions include the
2 following:
3 (a) Gouran and GBT led Playboy to believe that they owned and/or controlled VIT
4 and could make changes to VIT’s website. But GBT has since claimed that it had no control over
5 VIT’s website, and it only had the ability to “request” or “facilitate” changes to VIT’s website.
6 (b) Gouran and GBT promised that GBT would make payments to Playboy
7 including a payment of $4 million by July 16, 2018, which would be funded by the proceeds of the
8 Crowdsale. In reality, GBT had no access to the cash proceeds from the Crowdsale and was relying on
9 VIT to fund the $4 million payment.
10 (c) As an additional assurance to Playboy, Gouran and GBT also promised that if
11 the Crowdsale did not raise sufficient funds to cover the payment, GBT would make up any shortfall
12 by providing Playboy with shares of its common stock. But in reality, Gouran had not received
13 approval from GBT’s board to make that promise.
14 (d) Similarly, Gouran and GBT misled Playboy into believing that GBT would
15 provide technical support to Playboy, at no cost, to help Playboy integrate the blockchain technologies
16 into the designated site. But, in reality, GBT contracted with VIT to provide the technical support and
17 has disclaimed any responsibility for providing the promised technical support.
18 (e) Gouran and GBT also misled Playboy by failing to disclose that Gouran was not
19 only the President and CEO of GBT, but was also a “principle shareholder” of VIT, which created a
20 conflict of interest so serious that Gouran believed he had to disclose it to GBT’s board of directors
21 and seek approval for the transaction (though not until after he had already agreed to the deal on
22 GBT’s behalf).
23 136. Gouran and GBT had no reasonable grounds for believing that these representations
24 were true at the time they were made. Likewise, Gouran and GBT had no reasonable grounds for
25 believing that the omitted facts were known to Playboy or could have been discovered by Playboy.
26 137. Gouran and GBT intended that Playboy would rely on the misrepresentations and
27 omissions in entering into the MOU and performing under the MOU.
28
32
1 138. Playboy actually relied on Gouran’s and GBT’s misrepresentations and omissions in
2 entering into the MOU and performing under the MOU, and Playboy’s reliance was justifiable. Had
3 Playboy known the truth, Playboy never would have entered into, nor performed under, the MOU.
4 139. As a direct and proximate result of Gouran and GBT’s fraud and intentional deceit,
5 Playboy has suffered substantial and irreparable harm, in an amount to be proven at trial.
6 THIRD CAUSE OF ACTION
7 (Breach of Contract)
8 (Against GBT)
11 141. Playboy and GBT entered into the MOU, which is a valid and enforceable written
12 contract. Indeed, on or about May 20, 2018, Playboy emailed Gouran stating, “Our business affairs
13 team would like to confirm that we are aligned that a long form document is not required as the MOU
14 is comprehensive. As the long-form is a condition to the MOU, as we discussed when we met, we
15 would like to ensure this piece is completed.” Gouran responded, “yes, I confirm that we don’t require
16 the long form document either, we are aligned on this.”
17 142. Under the MOU, Playboy agreed to integrate GBT’s blockchain technologies into the
18 designated site and make certain announcements. In exchange, GBT agreed, among other things, to
19 make payments to Playboy including a payment of $4 million, to provide technical support, and to
20 make certain changes to the VIT website.
21 143. Playboy has satisfied its obligations under the MOU, or its performance is excused.
22 With respect to integration of GBT’s technologies, Playboy’s performance is excused because GBT’s
23 failure to provide the promised technical support made Playboy’s performance impossible.
24 144. GBT has breached the terms of the MOU by failing to make the required $4 million
25 payment, to provide the promised technical support, and to make the promised changes to the VIT
26 website.
27 145. As a direct and proximate result of GBT’s breaches of the MOU, Playboy has been
28 damaged in an amount to be proven at trial.
33
1 FOURTH CAUSE OF ACTION
2 (Breach of the Implied Covenant of Good Faith and Fair Dealing)
3 (Against GBT)
5 set forth herein.
6 147. Implicit in the MOU is a covenant of good faith and fair dealing that prohibits either
7 party from doing anything that would render performance of the agreement impossible or deny the
8 other party the benefits of the agreement. Additionally, the implied covenant of good faith and fair
9 dealing requires that GBT use its good faith efforts to give effect to the terms of the MOU.
10 148. GBT breached the implied covenant of good faith and fair dealing by engaging in the
11 conduct alleged herein, including, but not limited to, failing to make good faith efforts to fulfill its
12 payment obligations to Playboy, failing to provide the promised technical support to Playboy, and
13 failing to make the promised changes to the VIT website.
14 149. As a direct and proximate result of GBT’s breaches of the implied covenant of good
15 faith and fair dealing, Playboy has been damaged in an amount to be proven at trial.
16 FIFTH CAUSE OF ACTION
17 (Breach of Contract – Third Party Beneficiary)
18 (Against VIT)
19 150. Playboy is informed and believes, and on that basis alleges, that GBT and VIT entered
20 into the Side Deal, an agreement by which VIT agreed, among other things, to pay $4 million to GBT
21 out of the proceeds of the Crowdsale, which was intended to fund GBT’s payment obligation to
22 Playboy under the MOU. Playboy is informed and believes, and on that basis alleges, that the Side
23 Deal is a valid and enforceable contract.
24 151. Playboy is informed and believes, and on that basis alleges, that VIT was aware of
25 GBT’s payment obligations to Playboy under the MOU, namely, GBT’s obligation to pay Playboy up
26 to $4 million in cash proceeds from the Crowdsale, and to make up any shortfall with common stock.
27 Playboy is informed and believes, and on that basis alleges, that VIT understood that the purpose of the
28 Side Deal was to facilitate GBT’s performance of these payment obligations to Playboy under the
34
1 MOU. Indeed, in a March 16, 2018 email, Duncan wrote to Shidan, “If it’s 4 [million] to playboy and
2 1 [million] to global blockchain that’s acceptable[,]” thereby demonstrating his understanding that the
3 $4 million VIT agreed to pay to GBT under the Side Deal would ultimately be paid to Playboy.
4 152. Playboy is informed and believes, and on that basis alleges, that VIT understood that its
5 failure to pay GBT under the Side Deal could contribute to GBT’s failure to satisfy its payment
6 obligations to Playboy under the MOU. Playboy is informed and believes, and on that basis alleges,
7 that VIT understood and intended that Playboy was the beneficiary of its promise under the Side Deal
8 that it would pay $4 million to GBT out of the proceeds of the Crowdsale. Accordingly, Playboy is an
9 intended third-party beneficiary of VIT’s promises to GBT under the Side Deal.
10 153. Recognition of a right to performance in Playboy is appropriate to effectuate the
11 intention of GBT and VIT. In addition, the circumstances indicate that GBT, the promisee, intended to
12 give Playboy the benefit of the promised performance, i.e., payment. Consequently, Playboy may
13 enforce the Side Deal between VIT and GBT as an intended third-party beneficiary.
14 154. Playboy is informed and believes, and on that basis alleges, that VIT breached the terms
15 of the Side Deal by failing to make the required payment to GBT out of the cash proceeds of the
16 Crowdsale. As a direct result of VIT’s failure to pay GBT, GBT lacked the source of funds it intended
17 to use to pay Playboy. Because VIT understood that its payment to GBT would ultimately fund GBT’s
18 obligations to Playboy, VIT’s breach of the Side Deal was an actual and proximate cause of GBT’s
19 failure to satisfy its payment obligations to Playboy under the MOU.
20 155. As a direct and proximate result of VIT’s breach of the Side Deal, Playboy has been
21 damaged in an amount to be proven at trial.
22 SIXTH CAUSE OF ACTION
23 (Intentional Interference with Contract)
24 (Against VIT and Duncan)
25 156. A valid and enforceable contract – namely, the MOU – existed between Playboy and
26 GBT. Under the MOU, GBT promised Playboy that it would, among other things: (a) pay Playboy $4
27 million, whether through cash, stock, or a combination of both, by July 16, 2018; and (b) remove the
28 words “Get Paid to Watch Porn” from the VIT website.
35
1 157. VIT and Duncan were aware of the existence of the MOU between Playboy and GBT.
2 Playboy is informed and believes, and on that basis alleges, that Duncan sent Gouran a proposed deal
3 that would allow VIT to use Playboy’s brand. Indeed, Gouran initially proposed to Playboy that the
4 MOU be between Playboy and VIT, with Duncan as the signatory on VIT’s behalf.
5 158. When Playboy would not agree to enter into a contract with VIT, Gouran changed the
6 terms of the proposed deal to be between Playboy and GBT. Gouran informed Duncan of the changes
7 and the proposed terms of the MOU between Playboy and GBT. Playboy is informed and believes,
8 and on that basis alleges, that Duncan, on VIT’s behalf, approved the proposed deal between Playboy
9 and GBT.
10 159. Playboy is informed and believes, and on that basis alleges, that VIT willfully failed to
11 pay any portion of the cash proceeds from the Crowdsale to GBT, in breach of the Side Deal between
12 VIT and GBT. Based, in part, on GBT’s statement in its discovery responses that Duncan is a person
13 having knowledge regarding GBT’s dealings, discussions, or interactions with VIT relating to the
14 MOU, Playboy is informed and believes, and on that basis alleges, that Duncan personally directed,
15 approved, ratified, or otherwise participated in VIT’s failure to pay any portion of the cash proceeds
16 from the Crowdsale to GBT.
17 160. Playboy also is informed and believes, and on that basis alleges, that VIT added the
18 words “Get Paid to Watch Porn” on the VIT website after they were initially removed, which violated
19 GBT’s promises to Playboy under the MOU. Based on GBT’s statement in its discovery responses
20 that Duncan is a person having knowledge regarding the changes made to the VIT website relating to
21 Playboy – including removing all references to “Get Paid to Watch Porn” and making changes to the
22 affiliate partners section – Playboy is informed and believes, and on that basis alleges, that Duncan
23 personally directed, approved, ratified, or otherwise participated in VIT’s reintroduction of “Get Paid
24 to Watch Porn” onto the VIT website.
25 161. Additionally, based, in part, on GBT’s statement that it contracted with VIT to integrate
26 GBT’s blockchain technologies onto Playboy’s designated site, Playboy is further informed and
27 believes, and on that basis alleges, that VIT failed to provide the agreed upon services with regard to
28 integration. Based on GBT’s statement in its discovery responses that Duncan is a person having
36
1 knowledge regarding the technical support provided to Playboy, Playboy is informed and believes, and
2 on that basis alleges, that Duncan personally directed, approved, ratified, or otherwise participated in
3 VIT’s failure to provide the agreed upon services with regard to integration.
4 162. Playboy is informed and believes, and on that basis alleges, that Duncan and VIT
5 intended and/or knew with a substantial degree of certainty that VIT’s failure to pay any portion of the
6 cash proceeds from the Crowdsale to GBT, VIT’s reintroduction of the words “Get Paid to Watch
7 Porn” to the VIT website, and/or VIT’s failure to provide the agreed upon services with regard to
8 integration was substantially certain to disrupt GBT’s performance of its obligations under the MOU.
9 163. As a direct and proximate result of VIT’s and Duncan’s intentional acts, GBT’s
10 performance of its obligations under the MOU was disrupted. Specifically, as a direct and proximate
11 result of VIT’s intentional acts, (a) GBT failed to pay Playboy any portion of the $4 million that it
12 promised to pay to Playboy under the MOU, (b) GBT failed to satisfy its obligation to remove the
13 words “Get Paid to Watch Porn” from the VIT website, and (c) GBT failed to provide the promised
14 technical support to Playboy with regard to integration.
15 164. As a direct and proximate result of VIT’s and Duncan’s intentional interference with the
16 contract between Playboy and GBT, Playboy was harmed in an amount to be proven at trial.
17 165. VIT’s and Duncan’s conduct was willful and malicious. Accordingly, Playboy is
18 entitled to punitive damages in an amount to be proven at trial.
19 SEVENTH CAUSE OF ACTION
20 (False Endorsement and Unfair Competition under 15 U.S.C. § 1125(a))
21 (Against All Defendants)
24 167. Defendants each have deliberately and willfully used and continue to use, in commerce,
25 Playboy’s brand without Playboy’s consent.
26 168. Defendants’ use of Playboy’s brand constitutes a false designation of origin, false or
27 misleading description of fact, and/or false or misleading representation of fact, which is likely to
28 cause confusion, or to cause mistake, or to deceive as to the affiliation, connection, or association of
37
1 Playboy with VIT and/or with GBT, or as to the origin, sponsorship, or approval by Playboy of GBT’s
2 and/or VIT’s goods, services, or commercial activities.
3 169. As a direct and proximate result of Defendants’ acts alleged herein, Playboy has been
4 damaged and suffered harm.
5 170. Playboy’s remedy at law is not adequate to compensate it for the injuries inflicted by
6 Defendants. Accordingly, Playboy is entitled to a permanent injunction pursuant to 15 U.S.C. § 1116.
7 171. Playboy is informed and believes, and on that basis alleges, that Defendants’ acts are
8 willful and malicious, and intended to injure and cause harm to Playboy.
9 172. By reason of Defendants’ acts alleged herein, Playboy is entitled to recover actual
10 and/or statutory damages, treble damages, and the costs of the action under 15 U.S.C. § 1117.
11 173. This is an exceptional case making Playboy eligible for an award of attorneys’ fees
12 under 15 U.S.C. § 1117.
13 EIGHTH CAUSE OF ACTION
14 (Unfair Competition under Cal. Bus. & Prof. Code § 17200 et seq.)
15 (Against All Defendants)
18 175. Defendants have commercially exploited Playboy’s brand without Playboy’s consent.
19 Defendants’ conduct, as alleged above, constitutes unlawful and/or unfair business acts or practices
20 under Cal. Bus. & Prof. Code § 17200 et seq.
21 176. Defendants’ conduct has caused, and, if not enjoined, will continue to cause substantial
22 and irreparable damage to Playboy’s brand. Playboy is entitled to relief under Cal. Bus. & Prof. Code
23 § 17203, including enjoining GBT from engaging in the conduct described above.
24 177. As a consequence of Defendants’ violations, Playboy has suffered damages in an
25 amount to be established at trial.
26 PRAYER FOR RELIEF
27 WHEREFORE, Plaintiff Playboy respectfully requests that the Court issue relief as follows:
28 A. For compensatory and general damages, according to proof;
38
1 B. For punitive damages, according to proof;
2 C. For actual and/or statutory damages and treble damages under 15 U.S.C. § 1117;
3 D. For attorneys’ fees and costs of suit to the extent allowable by law, including under 15
4 U.S.C. § 1117 and/or Cal. Civ. Proc. Code § 1021.5;
5 E. For legal interest;
6 F. For injunctive relief, including a permanent injunction enjoining and restraining
7 Defendants and their agents from using Playboy’s brand without authorization; and
8 G. For such other and further relief as the Court deems just and proper.
9
10
Dated: February 21, 2019 AKIN GUMP STRAUSS HAUER & FELD LLP
11 SUSAN K. LEADER
ANDREW S. JICK
12 BRETT M. MANISCO
13
14 By
Susan K. Leader
15 Attorneys for Playboy Enterprises, Inc.
16
17
18
19
20
21
22
23
24
25
26
27
28
39
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
3 I am employed in the County of Los Angeles, State of California. I am over the age of 18 and
not a party to the within action; my business address is: 1999 Avenue of the Stars, Suite 600, Los
4 Angeles, CA 90067. On March 1, 2019, I served the foregoing document(s) described as: FIRST
AMENDED COMPLAINT [CONDITIONALLY UNDER SEAL] on the interested party(ies)
5 below, using the following means:
6
Miles J. Feldman
7 Laith D. Mosely
Lawrence J.H. Liu
8 Raines Feldman LLP
1800 Avenue of the Stars, 12th Floor
9 Los Angeles, California 90067
Telephone: (310) 440-4100
10 Facsimile: (310) 765-7643
11 Attorneys for Defendant Global Blockchain
Technologies Corporation
12
BY UNITED STATES MAIL I enclosed the documents in a sealed envelope or package addressed to the
13 respective address(es) of the party(ies) stated above and placed the envelope(s) for collection and
mailing, following our ordinary business practices. I am readily familiar with the firm’s practice of
14 collection and processing correspondence for mailing. On the same day that correspondence is placed
for collection and mailing, it is deposited in the ordinary course of business with the United States
15 Postal Service, in a sealed envelope with postage fully prepaid at Los Angeles, California.
16 BY OVERNIGHT DELIVERY I enclosed the document(s) in an envelope or package provided by an
overnight delivery carrier and addressed to the respective address(es) of the party(ies) stated above. I
17 placed the envelope or package for collection and overnight delivery at an office or a regularly utilized
drop box of the overnight delivery carrier.
18
BY ELECTRONIC MAIL OR ELECTRONIC TRANSMISSION. Based on a court order or an agreement of the parties
19 to accept service by e-mail or electronic transmission, I caused the document(s) to be sent to the
respective e-mail address(es) of the party(ies) as stated above. I did not receive, within a reasonable
20 time after the transmission, any electronic message or other indication that the transmission was
unsuccessful.
21
(STATE) I declare under penalty of perjury under the laws of the State of California that the foregoing
22 is true and correct.
23 Executed on March 1, 2019 at Los Angeles, California.
24
Hadiss Y. Calderon
25
26
27
28
1
PROOF OF SERVICE
EXHIBIT 6
EXHIBIT 7
EXHIBIT 8
7/16/2019 Playboy Press - The Latest Playboy News
MARCH 14, 2018

PLAYBOY ENTERPRISES TO INTRODUCE
CRYPTOCURRENCY WALLET FOR USE ON
ITS ONLINE PLATFORMS
Playboy.TV Expected to Enable Payments

Via Vice Industry Token and other Cryptocurrencies Later This Year
(LOS ANGELES, CA March 14, 2018) Playboy Enterprises, Inc. announced today that the company is
developing an online payment wallet that will support a number of cryptocurrencies across the
company’s online media, digital and casual gaming businesses.
Playboy.TV will be the first of the company’s media platforms to feature the new digital wallet which
will enable the online platform to accept Vice Industry Token (VIT), among other leading
cryptocurrency tokens, for access to the brand’s exclusive content. By integrating with VIT, visitors will
be able to pay and earn tokens to view Playboy.TV’s original content, as well as comment on and vote
for content.
“As the popularity of alternative payment methods continues to grow around the world, along with the
reach Playboy’s digital platforms, we felt it was important to give our 100 million monthly consumers
increased payment flexibility,” said Reena Patel, Chief Commercial Officer and Head of Operations for
Playboy Enterprises, Inc. “This innovation gives the millions of people who enjoy our content, as well
as those in the future who participate in our casual gaming, AR and VR platforms, more choices with
regard to payment and in the case of VIT, an opportunity to be rewarded for engaging with Playboy
offerings.”
Vice Industry Token, a decentralized blockchain platform and cryptographic token that rewards
viewers just for watching content, was launched earlier this year and is currently in the midst of a
crowd sale which ends on March 20th. Fans can find out more about VIT by visiting vicetoken.com.
www.playboyenterprises.com/playboy-news/ 1/2
7/16/2019 Playboy Press - The Latest Playboy News
The new digital wallet is expected to be available before the end of the year. The company also has
plans to integrate cryptocurrency to its casual gaming, AR and VR initiatives in the future.
###
ABOUT PLAYBOY ENTERPRISES, INC.:

Playboy is one of the most recognized and popular consumer brands in the world. Playboy
Enterprises, Inc. is a media and lifestyle company that markets the brand through a wide range of
media properties and licensing initiatives. The company publishes Playboy magazine in the United
States and licenses foreign editions of Playboy around the world; operates Playboy.com, a leading
lifestyle, and entertainment site; and creates content for distribution via television networks, websites,
mobile platforms, and radio. Through licensing agreements, the Playboy brand appears on a wide
range of consumer products in more than 180 countries, as well as retail stores and entertainment
venues. For more information about Playboy Enterprises, please visit www.PlayboyEnterprises.com.
About Vice Industry Token Inc

Vice Industry Token, Inc. is a decentralized blockchain platform and cryptographic token for the Vice
Industry that allows producers to more efficiently monetize their content by rewarding viewers just for
watching content. Today’s ad-based free viewing model is broken, dominated by tube sites and
benefiting only web traffic companies. By intelligently capturing genuine interactions, VIT will enable
producers to deliver high-quality content catered to the specific desires of their most enthusiastic fans.
Vice Industry Token, Inc. is a wholly owned subsidiary of Tokken MSB, Inc. For more information,
please visit https://vicetoken.com/
www.playboyenterprises.com/playboy-news/ 2/2
EXHIBIT 9
EXHIBIT 10
EXHIBIT 11
1 RAINES FELDMAN LLP
Laith D. Mosely (Bar No. 250832)
2 lmosely@raineslaw.com
Lawrence J.H. Liu (Bar No. 312115)
3 lliu@raineslaw.com
18401 Von Karman Ave., Suite 360
4 Irvine, California 92612
Telephone: (310) 440-4100
5 Facsimile: (310) 449-4877
6 Attorneys for Defendant, Global Blockchain Technologies Corporation, a Canadian

corporation
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA

9 COUNTY OF LOS ANGELES – CENTRAL DISTRICT
10
11 PLAYBOY ENTERPRISES, INC., a Case No. BC716374

Delaware Corporation,
12 Assigned to for All Purposes to:
13 Plaintiff, Hon. Susan Bryant-Deason, Dept. 52
14 vs.
15 DEFENDANT GLOBAL
GLOBAL BLOCKCHAIN BLOCKCHAIN TECHNOLOGIES
16 TECHNOLOGIES CORPORATION, a CORPORATION’S RESPONSES TO
Canadian corporation; and DOES 1-10, PLAINTIFF PLAYBOY
17 ENTERPRISES, INC.’S SPECIAL
INTERROGATORIES, SET ONE
18 Defendants.
19
20
Complaint filed: August 3, 2018
21
PROPOUNDING PARTY: Plaintiff Playboy Enterprises, Inc.
22
RESPONDING PARTY: Defendant Global Blockchain Technologies Corporation
23
SET NO.: ONE
24
25
Pursuant to California Code of Civil Procedure sections 2030.010 et seq., Defendant
26
Global Blockchain Technologies Corporation (“Defendant,” “GBT,” or “Responding
27
Party”), by its undersigned counsel, responds and objects to Plaintiff Playboy Enterprises,
28
-1-
DEFENDANT GBT’S RESPONSES TO PLAINTIFF’S SPECIAL
1 Inc.’s (“Plaintiff,” “Playboy,” or “Propounding Party”) First Set of Special Interrogatories
2 on Defendant GBT.
3 PRELIMINARY STATEMENT
4 These responses are made solely for the purpose of this action. Each answer is
5 subject to all objections as to competence, relevance, materiality, propriety and
6 admissibility, and any and all other objections and grounds which would require the
7 exclusion of any statement herein if the Interrogatories were asked of, or any statements
8 contained herein were made by, a witness present and testifying in Court, all of which
9 objections and grounds are reserved and may be interposed at the time of trial.
10 Responding Party has not completed its investigation of the facts relating to this
11 case and has not completed its preparation for trial. The following responses are based
12 upon information presently available and known to Responding Party and are made
13 without prejudice to Responding Party of the right to rely upon other or subsequently
14 discovered facts, documents, and witnesses.
15 Except for explicit facts admitted herein, no incidental or implied admissions are
16 intended hereby. The fact that Responding Party has answered any interrogatory should
17 not be taken as an admission that Responding Party accepts or admits the existence of any
18 facts set forth or assumed by such interrogatory, or that such response constitutes
19 admissible evidence. The fact that Responding Party has answered part or all of any
20 interrogatory is not intended and shall not be construed to be a waiver by Responding
21 Party of all or any part of any objection to any interrogatory made by Propounding Party.
22 The Preliminary Statement is incorporated into each of the responses set forth
23 below.
24 GENERAL OBJECTIONS
25
1. Responding Party objects to the Interrogatories to the extent they
26
purport to expand Responding Party's discovery obligations beyond those established
27
by the California Rules of Civil Procedure and the applicable rules of this Court.
28
-2-
1 2. Responding Party objects to the Interrogatories to the extent they seek
2 materials or information that are neither relevant to any claim or defense in this
3 case, nor reasonably calculated to lead to the discovery of admissible evidence.

5 materials or information that are not in Responding Party's possession, custody, or
6 control.

8 materials or information that are (l) already in Propounding Party's possession, custody,
9 or control; (2) equally or more readily available to Propounding Party; (3) publicly
10 available; or (4) obtainable from other sources or through other means of discovery
11 that are more convenient, more efficient, more practical, less burdensome, or less
12 expensive.

14 materials or information shielded from disclosure by the attorney-client privilege, the
15 work- product doctrine, or any other applicable privilege or protection. Responding
16 Party's responses to the Interrogatories do not waive, and may not be construed as
17 waiving, any applicable objection, privilege, or protection. Inadvertent disclosure of
18 information subject to a claim of privilege or protection is not, and may not be
19 deemed, a waiver of that privilege or protection. Unless otherwise stated, Responding
20 Party will neither log nor produce any materials generated subsequent to Propounding
21 Party's filing of this lawsuit against Responding Party (including in connection with these
22 objections and responses), even if they would otherwise be responsive to the literal terms of
23 a request, given the undue burdens and lack of relevance associated with any such
24 materials.
25 6. To the extent that any Interrogatory or response implicates Responding

26 Party's confidential business or customer information, Responding Party reserves the
27 right to designate such information as needed under a protective order.
28
-3-
1 7. Responding Party objects, to Interrogatories calling for information not
2 reasonably accessible without undue burden and/or cost. Responding Party reserves the
3 right to search and, if appropriate, produce responsive, non-privileged information from
4 such sources only if Propounding Party agrees to shift costs associated with such search
5 and response.
6 8. Responding Party's election to respond to an Interrogatory, notwithstanding

7 the objectionable nature of that Interrogatory, is not: (a) an acceptance of, or agreement
8 with, any of the characterizations or purported descriptions of the transactions or
9 events contained in the Interrogatory; (b) a concession or admission that the materials are
10 relevant to this proceeding; (c) a waiver of the general objections or the objections asserted
11 in response to that specific Interrogatory; (d) an admission that any such information
12 or documents exist; (e) an agreement that requests for similar information or documents
13 will be treated in a similar manner; or (f) an acceptance of, or agreement with, any of the
14 definitions in the Interrogatories to the extent that the definition or meaning of any
15 defined term is at issue in this action.
16 9. Responding Party reserves the right to amend, supplement, or alter these

17 objections and responses at any time if it becomes necessary or appropriate to do so.
18 These objections and responses are made without prejudice to, and are not a waiver of,
19 Responding Party's right to rely on other facts or documents.
20 The General Objections are incorporated into each of the responses set forth below.
21 SPECIAL INTERROGATORIES
22 SPECIAL INTERROGATORY NO. 1:
23 Describe, with particularity, any dealings, discussions, or interactions between VIT

24 and PLAYBOY relating to the MOU, including, without limitation, identifying all
25 PERSONS with knowledge regarding this topic.
26 (As used herein, the term “VIT” refers to Vice Industry Token, Inc., its parents,
27 subsidiaries, affiliates, attorneys, paralegals, agents, accountants, consultants,
28 representatives, directors, officers, employees, experts, independent contractors, and any
-4-
1 other person or entity associated with any of the above individuals or entities, and any
2 other person acting or purporting to act on its behalf.)
3 (As used herein, the term “PLAYBOY” shall refer to Playboy Enterprises, Inc., its
4 parents, subsidiaries, affiliates, attorneys, paralegals, agents, accountants, consultants,
5 representatives, directors, officers, employees, experts, independent contractors, and any
6 other person or entity associated with any of the above individuals or entities, and any
7 other person acting or purporting to act on its behalf.)
8 (As used herein, the term “MOU” refers to the Memorandum of Understanding
9 between PLAYBOY and YOU dated March 13, 2018.)
10 (As used herein, the words “YOU” and “YOUR” shall refer to Defendant Global
11 Blockchain Technologies Corporation, its parents, subsidiaries, affiliates, attorneys,
12 paralegals, agents, accountants, consultants, representatives, directors, officers, employees,
13 experts, independent contractors, and any other person or entity associated with any of the
14 above individuals or entities, and any other person acting or purporting to act on its
15 behalf.)
16 (As used herein, the term “PERSONS” means all natural persons. It does not refer
17 to corporations, partnerships, trusts, entities, or other associations.)
18 RESPONSE TO SPECIAL INTERROGATORY NO. 1:
19 Responding Party objects on the basis that the interrogatory is vague as to time,
20 overbroad, unduly burdensome, and harassing. (Code Civ. Proc., §§ 2017.020, 2019.030,
21 subd. (a).) Responding Party objects on the basis that the information requested is neither
22 relevant to the subject matter of the litigation nor reasonably calculated to lead to the
23 discovery of admissible evidence. (Code Civ. Proc., § 2017.010.) Responding Party
24 objects on the basis that the phrases and terms “any dealings, discussions, or interactions”
25 and “this topic” are vague and ambiguous to the extent that the interrogatory is
26 unintelligible. Responding Party also objects on the basis that the information sought is
27 obtainable from Propounding Party’s own records and files. (Code Civ. Proc., § 2019.030,
28 subd. (a)(1).) Responding Party further objects on the basis that the interrogatory as
-5-
1 phrased is compound. (Code Civ. Proc., § 2030.060, subd. (f).) Responding Party further
2 objects to the extent that the interrogatory calls for information protected under attorney-
3 client privilege and/or the work product doctrine. (Code Civ. Proc., §§ 2018.010 et seq.)
4 Subject to and without waiving the aforementioned objections, Responding Party

5 responds: VIT is a third-party to the MOU between GBT and Playboy. VIT contracted
6 with GBT to integrate VIT’s blockchain platform and cryptographic token with Playboy’s
7 online media platform by developing a digital wallet that could enable VIT cryptocurrency
8 payments through Playboy.tv’s web media portal. In discussions with GBT, Playboy
9 indicated that it would seek to obtain management positions in VIT and assist with the
10 technical aspects of the integration. Upon Playboy’s request, GBT cooperated with VIT in
11 rebranding VIT’s website and remove references to “porn.” Playboy, however, failed to
12 offer any meaningful support or cooperation with VIT to implement the technologies that
13 it promised. Playboy was also required to provide VIT with additional marketing support
14 and assist with the rebranding efforts. Persons with knowledge include: Shidan Gouran;
15 David DesLauriers; Aaron Rotenberg; Maxwell Arnold; Barry Rotenberg; Reena Patel;
16 Ben Kohn; Rachel Sagan; Jared Dougherty; John Vlautin; Stuart Duncan.
18 Describe, with particularity, the reason(s) why YOU did not make the payment to
19 PLAYBOY of $4,000,000, in cash or stock, by July 16, 2018, including, without
20 limitation, identifying all PERSONS with knowledge regarding this topic.
22 This interrogatory incorrectly assumes that the MOU is a binding agreement or

23 promise. Responding Party objects on the basis that the interrogatory is vague as to time,
25 subd. (a).) Responding Party objects on the basis that the phrase “the payment” is
26 undefined and so vague and ambiguous to the extent that the interrogatory is unintelligible.
27 Responding Party also objects on the basis that the interrogatory as phrased is compound.
28 (Code Civ. Proc., § 2030.060, subd. (f).) Responding Party further objects to the extent
-6-
1 that the interrogatory calls for information protected under attorney-client privilege and/or
2 the work product doctrine. (Code Civ. Proc., §§ 2018.010 et seq.)

4 responds: Following the execution of the MOU, GBT relied on Playboy to provide
5 backend technical support and to cooperate with Vice Industry Token in promoting the
6 business venture. Playboy provided no support or collaborative effort until the Crowdsale
7 was long over. Playboy made no contact with, nor any attempt to work with VIT on
8 integrating VIT’s platform on Playboy’s website. In addition, Playboy did not attempt to
9 meet and negotiate the long form agreement in a reasonable time as required under the
10 MOU. Ultimately, Playboy failed to engage with GBT and VIT to provide the support as
11 promised under the terms of the MOU until long after the Crowdsale had finished and
12 when such support had little to no impact on promoting the venture among the parties.
13 Instead, Playboy sought to obtain a windfall by demanding the $4,000,000 from the
14 Crowdsale, which it did not participate in, and based on the non-binding terms of the
15 MOU, which had not yet been finalized and were subject to various future conditions that
16 had not yet been met and further negotiations between the parties. GBT has acted in good
17 faith by seeking to continue discussions with Playboy regarding the live tv and
18 marketplace proposal options which was originally intended by the parties. Playboy,
19 however, has rebuffed such requests for further discussions.
21 Describe, with particularity, the technical support that YOU provided to

22 PLAYBOY, including, without limitation, identifying all PERSONS with knowledge
23 regarding this topic.
-7-
2 objects on the basis that the terms “technical support” and “this topic” are undefined and
3 so vague and ambiguous to the extent that the interrogatory is unintelligible. Responding
4 Party also objects on the basis that the information sought is obtainable from Propounding
5 Party’s own records and files. (Code Civ. Proc., § 2019.030, subd. (a)(1).) Responding
6 Party further objects on the basis that the interrogatory as phrased is compound. (Code Civ.
7 Proc., § 2030.060, subd. (f).) Responding Party further objects to the extent that the
8 interrogatory calls for information protected under attorney-client privilege and/or the
9 work product doctrine. (Code Civ. Proc., §§ 2018.010 et seq.)

11 responds: GBT was effectively prevented from providing any technical support to Playboy
12 based on Playboy’s refusal to coordinate with VIT and to provide backend access to
13 Playboy’s source code. Individuals with knowledge include: Shidan Gouran; David
14 DesLauriers; Aaron Rotenberg; Maxwell Arnold; Barry Rotenberg; Stuart Duncan.
16 Describe, with particularity, all changes YOU made to the VIT website relating to
17 PLAYBOY or the MOU, including, without limitation, identifying all PERSONS with
18 knowledge regarding this topic.
25 objects on the basis that the term “all changes,” “made,” and “this topic” are undefined and
27 Party further objects on the basis that the interrogatory as phrased is compound. (Code Civ.
28 Proc., § 2030.060, subd. (f).) Responding Party further objects to the extent that the
-8-
1 interrogatory calls for information protected under attorney-client privilege and/or the
2 work product doctrine. (Code Civ. Proc., §§ 2018.010 et seq.)
3 Without waiving the aforementioned objections, Responding Party responds: GBT

4 did not actually make any changes to third party, VIT’s website—which is in the sole
5 control of VIT and/or Tokken MSB. However, on March 13, 2018, GBT requested that
6 VIT make the following changes on its website:
7  change the phrase “The Revolutionary Adult Cryptocurrency Crowdsale is ON!”

8 to “The Revolutionary Vice Industry Token Sale is ON!”;
9
10  remove all references to “Get Paid to Watch Porn” to “Get Paid to Watch
11 Videos”;
12
13  change the language on VIT’s website to read: “The Vice Industry Token
14 represents a profound change in the broadcast and on-demand video
15 entertainment industry. It functions as two things; a video entertainment
16 platform where viewers can watch videos, and as a cryptocurrency where
17 anybody who participates (in viewing, adding, or curating content) will get paid
18 with VIT's proprietary cryptocurrency.
19
20 The original paradigm in mainstream and adult entertainment was that people
21 paid for the content they consumed; whether by subscription or pay-per-view.
22 With "tube" websites becoming popular, there was a shift toward free-viewing.
23 While free content was certainly desirable, wouldn't it be better if you could get
24 paid for it, too?
25
26 Vice Industry Token is creating a breakthrough in the online video

27 entertainment industry where everybody who accesses the platform will be
28 rewarded. This includes producers, distributors, and more importantly... you as
-9-
1 the viewer.
2
3 Backed by some of the top names in the entertainment world, Vice Industry
4 Token will deliver you the content that you want to see, while enabling you to
5 get paid just for watching it.
6
7 Online entertainment is a multi-billion dollar industry. Vice Industry Token is

8 your opportunity to get a piece of it, and all you have to do is watch videos. It's
9 that simple. Sit back and watch as we revolutionize mainstream and adult
10 entertainment. We look forward to you joining us!”;
11
12  make changes to the affiliate partners section.

13
14 Persons with knowledge include Shidan Gouran, Mike Koroshun, Jared Dougherty,
15 Reena Patel, and Stuart Duncan.
17 Describe, with particularity, the amount and nature of YOUR funds at the time
18 YOU entered into the MOU, including, without limitation, identifying all PERSONS with
19 knowledge regarding this topic.
21 Responding Party objects on the basis that the interrogatory is vague, overbroad,
22 unduly burdensome, and harassing. (Code Civ. Proc., §§ 2017.020, 2019.030, subd. (a).)
23 Responding Party objects on the basis that the information requested is neither relevant to
24 the subject matter of the litigation nor reasonably calculated to lead to the discovery of
25 admissible evidence. (Code Civ. Proc., § 2017.010.) Responding Party objects on the basis
26 that no pretrial discovery as to Responding Party’s finances are permitted without a court
27 order. (Civ. Code, § 3295; Kerr v. Rose (1990) 216 Cal.App.3d 1551, 1565; Jabro v.
28 Superior Court (2002) 95 Cal.App.4th 754, 758.) Responding Party objects on the basis
-10-
1 that the phrases “amount and nature of YOUR funds” and “this topic” are so vague and
2 ambiguous to the extent that the interrogatory is unintelligible. Responding Party further
3 objects on the basis that the interrogatory as phrased is compound. (Code Civ. Proc., §
4 2030.060, subd. (f).) Responding Party further objects to the extent that the interrogatory
5 calls for information protected under attorney-client privilege and/or the work product
6 doctrine. (Code Civ. Proc., §§ 2018.010 et seq.)
7 The interrogatory necessitates the preparation of a compilation, abstract, audit or

8 summary from documents in Propounding Party’s possession, and such preparation would
9 be similarly burdensome and/or expensive to both propounding and responding parties.
10 (Code Civ. Proc., § 2030.230; see also Brotsky v. State Bar of California (1962) 57 Cal.2d
11 287.) Subject to and without waiving the aforementioned objections, Responding Party
12 responds: The information requested may be found in GBT’s financial statements dated
13 January 2, 2018, and April 3, 2018, which will be produced in response to Playboy’s
14 Request for Production of Documents and Things, Set One.
16 Describe, with particularity, the cash proceeds that YOU received from the
17 CROWDSALE, including, without limitation, identifying all PERSONS with knowledge
18 regarding this topic.
19 (As used herein, the term “CROWDSALE” shall refer to the crowdsale referenced
20 in the MOU which was held from February 20, 2018 to March 20, 2018.)

27 objects on the basis that no pretrial discovery as to Responding Party’s finances are
28 permitted without a court order. (Civ. Code, § 3295; Kerr v. Rose, supra, 216 Cal.App.3d
-11-
1 at 1565; Jabro v. Superior Court, supra, 95 Cal.App.4th at 758.) Responding Party objects
2 on the basis that the terms “cash proceeds,” “CROWDSALE,” and “this topic” are so
3 vague and ambiguous to the extent that the interrogatory is unintelligible. Responding
4 Party further objects to the extent that the interrogatory calls for information protected
5 under attorney-client privilege and/or the work product doctrine. (Code Civ. Proc., §§
6 2018.010 et seq.) The interrogatory necessitates the preparation of a compilation, abstract,
7 audit or summary from documents in Propounding Party’s possession, and such
8 preparation would be similarly burdensome and/or expensive to both propounding and
9 responding parties. (Code Civ. Proc., § 2030.230; see also Brotsky v. State Bar of
10 California (1962) 57 Cal.2d 287.)
11 Based on these objections, Responding Party is unable to respond to this

12 interrogatory, however, invites Propounding Party to further meet and confer regarding the
13 information requested.
15 Describe, with particularity, what YOU did with the cash proceeds that YOU
16 received from the CROWDSALE, including, without limitation, identifying all PERSONS
17 with knowledge regarding this topic.
24 objects on the basis that no pretrial discovery as to Responding Party’s finances are
25 permitted without a court order. (Civ. Code, § 3295; Kerr v. Rose (1990) 216 Cal.App.3d
26 1551, 1565; Jabro v. Superior Court (2002) 95 Cal.App.4th 754, 758.) Responding Party
27 objects on the basis that the terms “cash proceeds,” “CROWDSALE,” and “this topic” are
-12-
1 Responding Party further objects to the extent that the interrogatory calls for information
2 protected under attorney-client privilege and/or the work product doctrine. (Code Civ.
3 Proc., §§ 2018.010 et seq.) The interrogatory necessitates the preparation of a compilation,
4 abstract, audit or summary from documents in Propounding Party’s possession, and such
5 preparation would be similarly burdensome and/or expensive to both propounding and
6 responding parties. (Code Civ. Proc., § 2030.230; see also Brotsky v. State Bar of
7 California (1962) 57 Cal.2d 287.)
8 Based on these objections, Responding Party is unable to respond to this

9 interrogatory, however, invites Propounding Party to further meet and confer regarding the
10 information requested.
12 DESCRIBE, with particularity, Shidan Gouran’s authority to promise, on YOUR

13 behalf, that YOU would provide stock to PLAYBOY in the event the CROWDSALE
14 raised less than $4,000,000, including, without limitation, identifying all PERSONS with
15 ·knowledge regarding this topic.
17 This interrogatory incorrectly assumes that the MOU is a binding agreement or

18 promise. Responding Party objects on the basis that the interrogatory is vague as to time,
19 overbroad, cumulative, unduly burdensome, and harassing. (Code Civ. Proc., §§ 2017.020,
20 2019.030, subd. (a).) Responding Party objects on the basis that the information requested
21 is neither relevant to the subject matter of the litigation nor reasonably calculated to lead to
22 the discovery of admissible evidence. (Code Civ. Proc., § 2017.010.) Responding Party
23 objects on the basis that “authority to promise,” “CROWDSALE,” and “this topic” are so
24 vague and ambiguous to the extent that the interrogatory is unintelligible. Responding
25 Party also objects on the basis that the interrogatory is not full and complete in and of
26 itself, and instead, Responding Party must resort to other materials in order to respond to
27 the interrogatory. (Code Civ. Proc., § 2030.060, subd. (d); Catanese v. Superior Court,
28 supra, 46 Cal.App.4th at 1164.) Responding Party further objects on the basis that the
-13-
1 interrogatory as phrased is compound. (Code Civ. Proc., § 2030.060, subd. (f).)
2 Responding Party further objects to the extent that the interrogatory calls for information
3 protected under attorney-client privilege and/or the work product doctrine. (Code Civ.
4 Proc., §§ 2018.010 et seq.)
5 Without waiving the aforementioned objections, Responding Party responds:

6 Shidan Gouran is the CEO of GBT. Persons with knowledge include: all employees,
7 directors, and officers of GBT.
9 Dated: November 7, 2018 RAINES FELDMAN LLP

10
11
By:
12 Laith D. Mosely
Lawrence J.H. Liu
13 Attorneys for Defendant, Global
Blockchain Technologies Corporation, a
14
Canadian corporation
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-14-
EXHIBIT 12
7/16/2019 Trademark Electronic Search System (TESS)
United States Patent and Trademark Office
Home|Site Index|Search|FAQ|Glossary|Guides|Contacts|eBusiness|eBiz alerts|News|Help
Trademarks > Trademark Electronic Search System (TESS)
TESS was last updated on Tue Jul 16 04:51:48 EDT 2019
Logout Please logout when you are done to release system resources allocated for you.
Record 1 out of 1
( Use the "Back" button of the Internet Browser to return to
TESS)
Word Mark GET PAID TO WATCH PORN

Goods and IC 041. US 100 101 107. G & S: Providing a website featuring non-downloadable videos in the field of adult
Services entertainment. FIRST USE: 20161227. FIRST USE IN COMMERCE: 20161227
Standard
Characters
Claimed
Mark Drawing Code (4) STANDARD CHARACTER MARK
Serial Number 87410641
Filing Date April 13, 2017
Current Basis 1A
Original Filing
1A
Basis
Date Amended to
July 11, 2017
Current Register
Registration
5278708
Number
Registration Date August 29, 2017
Owner (REGISTRANT) Duncan, Stuart INDIVIDUAL CANADA 741 Merlin court Ottawa CANADA K4m0a1
Type of Mark SERVICE MARK
Register SUPPLEMENTAL
Live/Dead Indicator LIVE
|.HOME | SITE INDEX| SEARCH | eBUSINESS | HELP | PRIVACY POLICY
tmsearch.uspto.gov/bin/showfield?f=doc&state=4802:8qwl0o.2.1 1/1
EXHIBIT 13
I S. Michael Kernan, State BarNo.181747
R. Paul Katrinak, State Bar No. 164057
2 THE KERNAN LAW FIRM
9663 Santa Monica Blvd Suite 450
3 Beverly Hills, California 90210
Telephone: (310) 490-9777
4 Facsimile: (310) 861-0503
5 Attorneys for Defendant and Cross-Defendant

Vice Industry Token, Inc.
6
7
8
9
10 PLAYBOY ENTERPRISES, INC., a Delaware ) Case No.: BC716374

Corporation, )
11 ) Assigned for all purposes to the Hon. Elaine
Plaintiff, ) Lu, Department 26
12 )
v. ) DEFENDANT VICE INDUSTRY TOKEN
13 ) INC.'S SPECIAL INTERROGATORIES
GLOBAL BLOCKCHAIN ) TO PLAINTIFF AND CROSS-
14 TECHNOLOGIES CORPORATION, a ) DEFENDANT PLAYBOY ENTERPRISES,
Canadian corporation, et al. ) INC. (SET ONE)
15 )
Defendants. )
16 )
)
17 GLOBAL BLOCKCHAIN TECHNOLOGIES )
CORPORATION, a Canadian corporation, )
18 )
Cross-Complainant, )
19 )
v. )
20 )
PLAYBOY ENTERPRISES, INC., a Delaware )
21 corporation, et al. )
22
23 PROPOUNDING PARTY: VICE INDUSTRY TOKEN, INC.
24 RESPONDING PARTY: PLAYBOY ENTERPRISES, INC.
25 SET NO.: ONE
26
27
28
DEFENDANT AND CROSS-DEFENDANT VICE INDUSTRY TOKEN, INC'S REQUEST FOR PRODUCTION OF
DOCUMENTS (SET ONE)
Pursuant to Section 2030.010 and Section 2017(b) of the California Code of Civil
2 Procedure, Defendant and Cross-Defendant Vice Industry Token, Inc. ("Propounding Party")
3 hereby propounds this First Set of Special Interrogatories on Defendant and Cross-
4 Complainant Global Blockchain Technologies Corporation ("Responding Party").
5 You are further notified that pursuant to Section 2030.010 and Section 2017(b) of the
6 California Code of Civil Procedure, you are required to respond, in writing, to each single
7 Interrogatory described below. Your response is to be subscribed under oath, within thirty (30)
8 days after service of this set oflnterrogatories. If you object to any particular Interrogatory, the
9 basis for such objection shall be stated in the written response.
10 INTERROGATORIES
11 SPECIAL INTERROGATORY NO. 1.

0 12 State all facts which support YOUR (for purposes of these Interrogatories "YOU"
"'"' -
0
"'"' -~" "' N

0
13 means Responding Party Playboy Enterprises, Inc. and all persons or entities acting on its
"' "':- ·c"' r-r--
~ ""> ~
"'- ·-..... "''

r-
-<
....,
0
14 behalf or under its direction and control, including, but not limited to attorneys, agents,
-;; 0
~ -~ u~
,,,.,R..-
z C
15 employees, accountants, investigators, insurance companies, its agents, its employees.
"'
µl
~
0
--
"'"'i~ -
>,
0
µl C
:r: "' 16 "YOUR" is the possessive form of YOU) contention that the alleged "Side Deal" between VIT
f-< "' ";';
M
"'"'"' "' 17 and GBT (for purposes of these Interrogatories "GBT" means Defendant and Cross-
18 Complainant Global Blockchain Technologies Corporation and all persons or entities acting on
19 its behalf or under its direction and control, including, but not limited to attorneys, agents,
20 employees, accountants, investigators, insurance companies, its agents, its employees) was an
21 enforceable contract.
23 IDENTIFY (for purposes of these Interrogatories "IDENTIFY" means and requires
24 YOU to state his or her name, address, telephone number, email address, employer and job
25 title) all witnesses which support YOUR contention that the alleged "Side Deal" between VIT
26 and GBT was an enforceable contract.
27 / / /
28 III
DEFENDANT AND CROSS-DEFENDANT VICE INDUSTRY TOKEN, INC'S SPECIAL INTERROGATORIES

{SET ONE)
SPECIAL INTERROGATORY NO. 3.
2 DESCRIBE (for purposes of these Interrogatories, "DESCRIBE" means to state a brief
3 description of the document and state the name, address, telephone number, and email address
4 of the person who has such documents in his or her possession, custody or control) all
5 DOCUMENTS (for purposes of these Interrogatories, "DOCUMENTS" means any and all
6 writings as defined in Evidence Code section 250) which support YOUR contention Complaint
7 that the alleged "Side Deal" between VIT and GBT was an enforceable contract.

9 State all facts which support YOUR contention that the alleged "Side Deal" between
10 TOKKEN MSB (for purposes of these Interrogatories "TOKKEN MSB" means Defendant and
11 Cross-Defendant Tokken MSB, Inc. and all persons or entities acting on its behalf or under its
:;; 12 direction and control, including, but not limited to attorneys, agents, employees, accountants,
... 0
13 investigators, insurance companies, its agents, its employees) and GBT was an enforceable
14 contract.

16 IDENTIFY all witnesses which support YOUR contention that the alleged "Side Deal"
17 between TOKKEN MSB and GBT was an enforceable contract.
19 DESCRIBE all DOCUMENTS which support YOUR contention Complaint that the
20 alleged "Side Deal" between TOKKEN MSB and GBT was an enforceable contract.
22 State all facts which support YOUR contention that the alleged "Side Deal" between
23 STUART DUNCAN (for purposes of these Interrogatories "STUART DUNCAN" means
24 Defendant and Cross-Defendant Stuart Duncan) and GBT was an enforceable contract.
26 IDENTIFY all witnesses which support YOUR contention that the alleged "Side Deal"
27 between STUART DUNCAN and GBT was an enforceable contract.
28 III
2
DEFENDANT AND CROSS-DEFENDANT VICE INDUSTRY TOKEN, INC.'S SPECIAL INTERROGATORIES
(SET ONE)
2 DESCRIBE all DOCUMENTS which support YOUR contention Complaint that the
3 alleged "Side Deal" between STUART DUNCAN and GBT was an enforceable contract.

5 State all facts which support YOUR contention that VIT knew about GBT's obligations
6 to YOU under the MOU (for purposes of these Interrogatories, "MOU" means the
7 Memorandum of Understanding as defined in Paragraph 5 of YOUR Complaint).
9 IDENTIFY all witnesses which support YOUR contention that VIT knew about GBT's
10 obligations to YOU under the MOU.
12 DESCRIBE all DOCUMENTS which support YOUR contention that VIT knew about
13 GBT' s obligations to YOU under the MOU.

15 State all facts which support YOUR contention that TOKKEN MSB knew about GBT's
16 obligations to YOU under the MOU.
18 IDENTIFY all witnesses which support YOUR contention that TOKKEN MSB knew
19 about GBT's obligations to YOU under the MOU.
21 DESCRIBE all DOCUMENTS which support YOUR contention that TOKKEN MSB
22 knew about GBT's obligations to YOU under the MOU.
24 State all facts which support YOUR contention that STUART DUNCAN knew about
25 GBT's obligations to YOU under the MOU.
26 SPECIAL INTERROGATORY N0.17.
27 IDENTIFY all witnesses which support YOUR contention that STUART DUNCAN
28 knew about GBT's obligations to YOU under the MOU.

3
(SET ONE)
2 DESCRIBE all DOCUMENTS which support YOUR contention that STUART
3 DUNCAN knew about GBT's obligations to YOU under the MOU.
5 State all facts which support YOUR contention that YOU were an intended third-party
6 beneficiary of the alleged "Side Deal" between VIT and GBT.
8 IDENTIFY all witnesses which supp01i YOUR contention that YOU were an intended
9 third-party beneficiary of the alleged "Side Deal" between VIT and GBT.

11 DESCRIBE all DOCUMENTS which support YOUR contention that YOU were an
12 intended third-party beneficiary of the alleged "Side Deal" between VIT and GBT.
15 beneficiary of the alleged "Side Deal" between TOKKEN MSB and GBT.

17 IDENTIFY all witnesses which support YOUR contention that YOU were an intended
18 third-party beneficiary of the alleged "Side Deal" between TOKKEN MSB and GBT.
21 intended third-party beneficiary of the alleged "Side Deal" between TOKKEN MSB and GBT.
24 beneficiary of the alleged "Side Deal" between STUART DUNCAN and GBT.
26 IDENTIFY all witnesses which support YOUR contention that YOU were an intended
27 third-party beneficiary of the alleged "Side Deal" between STUART DUNCAN and GBT.
28 / / /
4
(SET ONE)
3 intended third-party beneficiary of the alleged "Side Deal" between STUART DUNCAN and
4 GBT.
6 State all facts which support YOUR contention that VIT was supposed to do the Vice
7 Industry Token Crowdsale.
9 IDENTIFY all witnesses which support YOUR contention that VIT was supposed to do
10 the Vice Industry Token Crowdsale.

0
~
12 DESCRIBE all DOCUMENTS which support YOUR contention that VIT was
" 0
~ .~ :;:
~
~
~
Cl')
"'
(,:J
13 supposed to do the Vice Industry Token Crowdsale.
a: .; ·~ ~
<.:: ~~ 14 SPECIAL INTERROGATORY NO. 31.
.....l m :.='
z c3:;
«I
< .:'.
z "<j"
=::
i::
State all facts which support YOUR contention that TOKKEN MSB was supposed to
V°,R-
15
~ i"'::r:,2,
~
JJ.l ~ 2:-
:r: "'
!--< Cl')
~
~
16 do the Vice Industry Token Crowdsale.
M ~
"'"'
"'
"' 17 SPECIAL INTERROGATORY NO. 32.
18 IDENTIFY all witnesses which support YOUR contention that TOKKEN MSB was
19 supposed to do the Vice Industry Token Crowdsale.

22 was supposed to do the Vice Industry Token Crowdsale.
24 State all facts which support YOUR contention that STUART DUNCAN was supposed
25 to do the Vice Industry Token Crowdsale.
28 was supposed to do the Vice Industry Token Crowdsale.

5
(SET ONE)
3 DUNCAN was supposed to do the Vice Industry Token Crowdsale.

5 State all facts which support YOUR contention that VIT was required to pay GBT the
6 cash proceeds from the Vice Industry Token Crowdsale.
8 IDENTIFY all witnesses which support YOUR contention that VIT was required to pay
9 GBT the cash proceeds from the Vice Industry Token Crowdsale.
11 DESCRIBE all DOCUMENTS which support YOUR contention that VIT was
12 required to pay GBT the cash proceeds from the Vice Industry Token Crowdsale.
14 State all facts which support YOUR contention that TOKKEN MSB was required to
15 pay GBT the cash proceeds from the Vice Industry Token Crowdsale.
17 IDENTIFY all witnesses which support YOUR contention that TOKKEN MSB was
18 required to pay GBT the cash proceeds from the Vice Industry Token Crowdsale.
21 was required to pay GBT the cash proceeds from the Vice Industry Token Crowdsale.
23 State all facts which support YOUR contention that STUART DUNCAN was required
24 to pay GBT the cash proceeds from the Vice Industry Token Crowdsale.
27 was required to pay GBT the cash proceeds from the Vice Industry Token Crowdsale.
28 / / /
6
(SET ONE)
2 DESCRIBE all DOCUMENTS which.support YOUR contention that STUART
3 DUNCAN was required to pay GBT the cash proceeds from the Vice Industry Token
4 Crowdsale.

6 State all facts which support YOUR contention that VIT failed to pay GBT the cash
7 proceeds from the Vice Industry Token Crowdsale.

9 IDENTIFY all witnesses which support YOUR contention that VIT failed to pay GBT
10 the cash proceeds from the Vice Industry Token Crowdsale.
13 failed to pay GBT the cash proceeds from the Vice Industry Token Crowdsale.

15 State all facts which support YOUR contention that TOKKEN MSB failed to pay GBT
16 the cash proceeds from the Vice Industry Token Crowdsale.

18 IDENTIFY all witnesses which support YOUR contention that TOKKEN MSB failed
19 to pay GBT the cash proceeds from the Vice Industry Token Crowdsale.


24 State all facts which support YOUR contention that STUART DUNCAN failed to pay
25 GBT the cash proceeds from the Vice Industry Token Crowdsale.

7
(SET ONE)
3 DUNCAN failed to pay GBT the cash proceeds from the Vice Industry Token Crowdsale.
5 State all facts concerning VIT's alleged use of YOUR brand in commerce.
7 Identify any witnesses which supp01i YOUR contention that VIT allegedly used
8 YOUR brand in commerce.
10 DESCRIBE all DOCUMENTS which support YOUR contention that VIT allegedly
11 used YOUR brand in commerce.
13 State all facts concerning TOKKEN MSB's alleged use of YOUR brand in commerce.

15 Identify any witnesses which support YOUR contention that TOKKEN MSB allegedly
16 used YOUR brand in commerce.
19 allegedly used YOUR brand in commerce.

21 State all facts concerning STUART DUNCAN's alleged use of YOUR brand in
22 commerce.
24 Identify any witnesses which support YOUR contention that STUART DUNCAN
25 allegedly used YOUR brand in commerce.
28 DUNCAN allegedly used YOUR brand in commerce.

8
(SET ONE)
2 State all facts concerning VIT's alleged use of YOUR brand in violation of 15 U.S.C.
3 Section 1125(a).
5 IDENTIFY all witnesses which support YOUR contention that VIT allegedly used
6 YOUR brand in violation of 15 U.S.C. Section 1125(a).
9 used YOUR brand in violation of 15 U.S.C. Section 1125(a).
11 State all facts concerning TOKKEN MSB's alleged use of YOUR brand in violation of
12 15 U.S.C. Section 1125(a).
14 IDENTIFY all witnesses which support YOUR contention that TOKKEN MSB
15 allegedly used YOUR brand in violation of 15 U.S.C. Section 1125(a).
21 violation of 15 U.S.C. Section 1125(a).
27 DUNCAN allegedly used YOUR brand in violation of 15 U.S.C. Section 1125(a).
28 ///
9
(SET ONE)
2 State all facts concerning VIT's alleged use of YOUR brand in violation of Cal. Bus. &
3 Prof. Code Section 17200 et seq.
5 IDENTIFY all witnesses which support YOUR contention that VIT allegedly used
6 YOUR brand in violation of Cal. Bus. & Prof. Code Section 17200 et seq.
9 used YOUR brand in violation of Cal. Bus. & Prof. Code Section 17200 et seq.
11 State all facts concerning TOKKEN MSB's alleged use of YOUR brand in violation of
12 Cal. Bus. & Prof. Code Section 17200 et seq.
14 IDENTIFY all witnesses which support YOUR contention that TOKKEN MSB
15 allegedly used YOUR brand in violation of Cal. Bus. & Prof. Code Section 17200 et seq.
21 violation of Cal. Bus. & Prof. Code Section 17200 et seq.
27 DUNCAN allegedly used YOUR brand in violation of Cal. Bus. & Prof. Code Section 17200
28 et seq.
10
(SET ONE)
2 State all facts concerning any alleged damages suffered by YOU as a result of any
3 alleged actions taken by VIT.

5 IDENTIFY all witnesses which support YOUR contention that YOU have suffered
6 damages as a result of any alleged actions taken by VIT.
8 DESCRIBE all DOCUMENTS which support YOUR contention that YOU have
9 suffered damages as a result of any alleged actions taken by VIT.

12 alleged actions taken by TOKKEN MSB.
15 damages as a result of any alleged actions taken by TOKKEN MSB.
18 suffered damages as a result of any alleged actions taken by TOKKEN MSB.
21 alleged actions taken by STUART DUNCAN.
24 damages as a result of any alleged actions taken by STUART DUNCAN.
25 // /
26 // /
27 / / /
28 / / /
11
(SET ONE)
3 suffered damages as a result of any alleged actions taken by STUART DUNCAN.
4
DATED: May;?.)__, 2018
5
6
ernan
7 Attorneys for Defendant and Cross-
Defendant
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
12
(SET ONE)
DECLARATION FOR ADDITIONAL DISCOVERY
2 I, S. MICHAEL KERNAN, declare:
3 1. I am the attorney ofrecord for Defendant and Cross-Defendant Vice Industry
4 Token, Inc. ("VIT") in this action.
5 2. I am propounding to Plaintiff and Cross-Defendant Playboy Enterprises, Inc.
6 ("Plaintiff') the attached set of interrogatories.
7 3. This set of interrogatories will cause the total number of specially prepared
8 interrogatories propounded to the party to whom they are directed to exceed the number of
9 specially prepared interrogatories permitted by Section 2030.030 of the Code of Civil
10 Procedure.
11 4. I have previously propounded a total of zero (0) interrogatories, of which zero
12 (0) of those interrogatories were not official form interrogatories.
13 5. This set of interrogatories contains a total of 90 specially prepared
14 interrogatories.
15 6. I am familiar with the issues and the previous discovery conducted by all of the
16 parties in this action.
17 7. I have personally examined each of the questions in this set of interrogatories.
18 8. This number of requests is warranted under Section 2030.040(a) of the Code of
19 Civil Procedure because of the complexity and quantity of the existing and potential issues in
20 this paiiicular case. This case involves claims against VIT for interference with a contract
21 between Plaintiff and Defendant and Cross-Complainant Global Blockchain Technologies
22 Corporation. Almost all of this information is solely in Plaintiffs possession so this is the only
23 way to get this information and narrow the issues in this case.
24 9. None of the questions in this set of interrogatories is being propounded for any
25 improper purpose, such as to harass the party, or the attorney for the party, to whom it is
26 directed, or to cause unnecessary delay or needless increase in the cost of litigation.
27 II
28 II
1
I declare under penalty of perjury under the laws of the State of California that the
/l,
Ca~Hdl----
2 foregoing is true and correct. (/
3
Executed Mai;;~2019 in Los Angeles,
4
5 S. Michael Kernan
10
11
12
0
~
::1 .~ 13
~ ~
;:!" -0 ~
<.::
..l"'
~
~ 14
0
z< .::!" ~
Z 0
"'
"'::1
0
0
~
15
"'J.:.l-;:;"
.
:r ~"
~
16
~
17
18
19
20
21
22
23
24
25
26
27
28
2
PROOF OF SERVICE
2
STATE OF CALIFORNIA
3 COUNTY OF LOS ANGELES
4 I am employed in the County of Los Angeles, State of California; I am over the age of
18 and not a party to the within action; my business address is 9663 Santa Monica Boulevard,
5 Suite 450, Beverly Hills, California 90210.
6 On May 22, 2019, I served the foregoing document(s) described as:
7 DEFENDANT AND CROSS-DEFENDANT VICE INDUSTRY TOKEN'S
SPECIAL INTERROGATORIES TO PLAINTIFF AND CROSS-DEFENDANT
8 PLAYBOY ENTERPRISES, INC. (SET ONE)
9 on the interested parties to this action by placing a copy thereof enclosed in a sealed envelope
addressed as follows:
10
SEE ATTACHED SERVICE LIST
11
X (BY U.S. MAIL) I deposited such envelope in the mail at Los Angeles,
12 California. The envelope was mailed with postage thereon fully prepaid and addressed to the
0
~
person below.
:. .~ 13
...~ ~
~.,; ~ (BY PERSONAL SERVICE) by causing a true and correct copy of the above
"".::
_,"'
~
14 documents to be hand delivered in sealed envelope(s) with all fees fully paid to the person(s) at
z •
< .~
z "
~
the address(es) set forth below.
Ul:.
"' 0
0
15
"'
Ul;; . M
(BY FACSIMILIE) on the party by transmitting via facsimile the document(s)

"'
,-.
.
V,
16
~
listed above to the fax number(s) set forth above on this date. The facsimile machine I used
~
~
complied with California Rules of Court, Rule 2003(3) and the transmission was reported as
17 complete and without error by the machine. Pursuant to California Rules of Court, Rule
2009( c)(4), I caused the machine to print a transmission record of the transmission, a copy of
18 which is attached to this facsimile.
19 Executed May 22, 2019 at Los Angeles, California.
20 I declare under penalty of perjury under the laws of the State of California that the
above is true and correct.
21
22
23
24
25
26
27
28
PROOF OF SERVICE
Susan K. Leader Attorneys for Plaintiff-Cross-Defendant
2 Brett Manisco Playboy Enterprises, Inc.
Akin Gump Strauss Hauer & Feldd T,P
3 1999 A venue of the Stars, Suite 600
Los Angeles, CA 90067-6022
4 Attorneys for Defendant-Cross-Complainant
Laith Mosely Global Blockchain Technologies Corporation
1800 Avenue of the Stars, 121h Floor
6 Los Angeles, CA 90067
7 Cyrus S. N aim Attorneys for Defendant Shidan Gouran

Law Offices of Cyrus S. Nairn
8 9107 Wilshire Blvd., Suite 450
Beverly Hills, CA 90210
9
10
11
12
0
N
;;; 0
~
13
"'u.
C
a
"< e
14
..J
z
<
.
u
z
"'
Ul
15
" =;:
Ul ~
=
... > 16
"'
17
18
19
20
21
22
23
24
25
26
27
28
2
PROOF OF SERVICE
RECEIVED
MAY 1·s 2019

s. J'vfichdel Kernan, Esq. -·~~
The Kernan Law Firm
9663 Santa Monica Blvd.,
Suite 450
-·--•w----•- -• --
~~~"°'9~
~ ~
§~
~
'-' '~ --
~.-....
•...-,...-,.
- P I T N E Y BOWES
02 1P $ 007.35°
0000838980 MAY 22 2019
• MAILED FROM ZIP CODE 90028
AKIN GUMP
Strauss Hauer & Feld LLP
MAY 2 8 2019
~ MAILROOM
RECEIVED
ill
Susan K. Leader
Andrew S. Jick
AKIN GUMP STRAUSS HAUER & FELD LLP
Los Angeles, CA 90067
':!
EXHIBIT 14
1 S. Michael Kernan, State Bar No.181747
R. Paul Katrinak, State Bar No. 164057
2 THE KERNAN LAW FIRM
9663 Santa Monica Blvd Suite 450
3 Beverly Hills, California 90210
Telephone: (310) 490-9777
4 Facsimile: (310) 861-0503
5 Attorneys for Defendant and Cross-Defendant

6
7
8
9
10 PLAYBOY ENTERPRISES, INC., a Delaware ) Case No.: BC716374

C~m~nn, )
11 ) Assigned for all purposes to the Hon. Elaine
Plaintiff, ) Lu, Department 26
12 )
V. ) DEFENDANT VICE INDUSTRY TOKEN
13 ) INC.'S REQUESTS FOR PRODUCTION
GLOBAL BLOCKCHAIN ) OF DOCUMENTS TO PLAINTIFF AND
14 TECHNOLOGIES CORPORATION, a ) CROSS-DEFENDANT PLAYBOY
Canadian corporation, et al. ) ENTERPRISES, INC. (SET ONE)
15 )
Defendants. )
16 )
)
17 GLOBAL BLOCKCHAIN TECHNOLOGIES )
CORPORATION, a Canadian corporation, )
18 )
Cross-Complainant, )
19 )
V. )
20 )
PLAYBOY ENTERPRISES, INC., a Delaware )
21 corporation, et al. )
22
23 PROPOUNDING PARTY: VICE INDUSTRY TOKEN, INC.

24 RESPONDING PARTY: PLAYBOY ENTERPRISES, INC.
25 SET NO.: ONE
26
27
28
DOCUMENTS (SET ONE)
Pursuant to Section 2031.010, et seq. of the California Code of Civil Procedure,
2 Defendant and Cross-Defendant Vice Industry Token, Inc. ("VIT") hereby demands that
3 Plaintiff and Cross-Defendant Playboy Enterprises, Inc. ("Playboy") produce the following
4 responses to Requests for Production of Doc11mcnts, Set One, thirty days after you are served
5 with these requests to The Kernan Law Firm, 9663 Santa Monica Blvd., Suite 450, Beverly
6 Hills, CA 90210. For the demands to inspect the books and records, demand is hereby made
7 that they be made available at a reasonable time and place pursuant to that statute. Please note
8 that this discovery request requires two acts for compliance: (a) service of a written response
9 verified under oath upon counsel for Plaintiff, and (b) production of documents on or before
1o the date and time set forth above.
11 DEFINITIONS
12 Words in CAPITALS below are specifically defined as follows:
13 A. "AND," "AND/OR" and "OR" as used in these Document Requests shall be
14 construed disjunctively or conjunctively as necessary to bring within the scope of these
15 Document Requests any information which otherwise might be construed to be outside its
16 scope. The plural of any word used herein includes the singular and the singular includes the
17 plural. The masculine gender or any word used herein includes the feminine. The past tense
18 of a word used herein includes the present tense, and the present tense includes the past tense.
19 B. "YOU" or "YOUR" as used in these Document Requests shall mean Plainitff
20 and , its agents, representatives, employees, independent contractors, companies, law firms,
21 attorneys, members, managing members, affiliates and any others acting on its behalf.
22 C. "DOCUMENT" and "DOCUMENTS" as used in these Document Requests
23 shall mean any and all writings as defined in Section 250 of the California Evidence Code, all
24 forms of expression, photographs, pictures, electronic, video or sound recordings, however
25 produced or reproduced, and all originals, copies and drafts of all handwriting, typewriting,
26 printing, photostating, photographing and any other means of recording upon any tangible
27 thing any form of communication or representation, including without limitation letters, words,
28 notes, memoranda, ledgers, journals, minutes, books, telephone slips, expense accounts,
1
DEFENDANT AND CROSS-DEFENDANT VICE INDUSTRY TOKEN, INC.'S REQUEST FOR PRODUCTION OF
DOCUMENTS (SET ONE)
timesheets, telegrams, cables, photographs, microfilm, prints, publications, recordings,
2 videotapes, electronic recordings, computer disks, transcriptions, affidavits, bills, receipts,
3 prescriptions, diagnoses, checks and/or electronic mail. Without limiting the foregoing, the
4 terms "DOC1 JMENT" and "DOCUMENTS" include all writings, papers, agreements,
5 contracts, correspondence, letters, facsimile transmissions, memoranda, reports, notes,
6 telegrams, telex, envelopes, statements, studies, publications, records, messages, books,
7 pamphlets, leaflets, inter-office and intra-office communications, notebooks, instruments,
8 transcripts, minutes, agendas, indices, cards, diaries, drafts, revisions, photocopies, calendars,
9 appointment records, disclosures, questionnaires, histories, chronologies, time-lines, medical
10 records and reports, health care records and reports, mental health records and reports, notices,
11 investigation reports and materials, declarations, accountings, evaluations, summaries,

0
~
12 valuations, audits, verifications, inventories, appraisals, studies, endorsements, powers of
""'.:
~ -~ ~
"' 13 attorney, account statements, receipts, invoices, financial statements, balance sheets, ledgers,
.,.<>:
-
~
VJ ~
~ -OA •e ~
<
...:J
-co :=~"''
> 0 r--
14 books, income statements, expense reports, bills, billing records, checks, canceled checks,
Z ro ~~
< .!:! ~
zci::;
ui~=-
C
0 -
~..-...
0 15 check stubs, bank records, bank deposits and withdrawals, wire transfer and receipt records,
~ ~~ <'3
Ul ~ ~
:,:
E-o
~
U)
~
~
16 accounts receivable, accounts payable, tax records, safe deposit records, telephone bills and
'" ~
:g "'
"' 17 records, microfiches, computer indices, computer printouts, records stored by means of
18 computer or other electronic means, contents of computer hard disks, contents of computer
19 backup tapes and disks, photographs, videotapes, films, motion pictures, video discs, audio
20 recordings and cassettes, transcriptions, drawings, surveys, plans, blueprints, specifications,
21 charts, graphics, notes of oral or telephone communications, other written transfers of
22 information, and OTHER DATA COMPILATIONS.
23 D. "COMMUNICATION" or "COMMUNICATIONS" as used in these Document
24 Requests shall mean any oral or written exchange or transmission of words, numbers or ideas
25 to another person. Oral communications include, without limitation, conversations, meetings,
26 speech.es, statements and questions. Written communications include, without limitation, all
27 DOCUMENTS.
28
2
DOCUMENTS (SET ONE)
E. "PERSON" as used in these Document Requests shall mean any natural person,
2 firm, association, organization, partnership, trust, Limited Liability Company, corporation or
3 other entity of any type, nature or description.
4 F. The words "CONCERN," "CONCERNING," "RELATED TO," "RELATING
5 TO," "REFER TO", or "REFERING TO" shall mean mentioning or describing, pertaining to,
6 referring to, relating to, connected with, created in connection with or as a result of,
7 commenting on, referring to, embodying, memorializing, evaluating, describing, analyzing,
8 reflecting, constituting, or evidencing, whether directly or indirectly, explicitly or implicitly, or
9 in whole or in part, a stated subject matter.
10 G. "IDENTIFY" means: Please comply with the identification requirements or
11 Code of Civil Procedure § 2031, including stating the name, title, address, and telephone
~ 12 number of any PERSON identified and the location of any DOCUMENT identified .
.,. 0
13 SPECIAL DEFINITIONS
14 A. "COMPLAINT" means the operative Complaint in this matter.
15 B. "CROSS-COMPLAINT" means the operative Cross-Complaint in this matter.
16 C. "VIT" means Defendant and Cross-Defendant Vice Industry Token, Inc.
17 D. "TOKKEN MSB" means Defendant and Cross-Defendant Tokken MSB, Inc.
18 E. "STUART DUNCAN" means Defendant and Cross-Defendant Stuart Duncan.
19 INSTRUCTIONS
20 A. The response to each request shall be identified by request number and
21 segregated from responses to other requests. If a DOCUMENT is responsive to more than one
22 request, reference to the DOCUMENT may be noted in the response to the latter specification
23 in lieu of production of additional copies of the DOCUMENT.
24 B. If any DOCUMENT covered by this request is withheld by reason of a claim of
25 privilege, a list is to be furnished at the time the DOCUMENTS are produced, identifying any
26 such DOCUMENT for which the privilege is claimed, together with the following information,
27 with respect to any such DOCUMENT withheld: author; recipient; sender; indicated or blind
28 copies; date; general subject matters; basis upon which privilege is claimed; and the paragraph
3
DOCUMENTS (SET ONE)
of this request to which such document relates. For each DOCUMENT withheld under a claim
2 that it constitutes or contains attorney work product, also state whether plaintiff asserts that the
3 DOCUMENT was prepared in anticipation of litigation or for trial and, if so, identify the
4 anticipated litigation or trial upon whic.h the asse1iion is based.

5 C. In the event that any DOCUMENT called for by this request has been
6 destroyed, lost, discarded or otherwise disposed of, any such DOCUMENT is to be identified
7 as completely as possible, including without limitation, the following information: date of
8 disposal, manner of disposal, reason for disposal, and PERSON disposing of the
9 DOCUMENT.
10 D. This notice to produce calls for all items in the possession of the PERSON to
11 whom this request is directed, and any of its present or former agents, employees, attorneys,
0
~
.,. 0
12 consultants, fiduciaries and all other PERSON(s) acting on its behalf.
13 E. This request calls for production as a separate DOCUMENT any copy or copies
14 of a DOCUMENT which is or are no longer identical by reason of notation or modification of
15 any kind whatsoever.

16 REQUESTS FOR PRODUCTION OF DOCUMENTS
17 REQUEST FOR PRODUCTION NO. 1.
18 All DOCUMENTS CONCERNING COMMUNICATIONS between YOU and GBT.
20 All DOCUMENTS CONCERNING COMMUNICATIONS between YOU and VIT.
22 All DOCUMENTS CONCERNING COMMUNICATIONS between YOU and
23 TOKKEN MSB.

25 All DOCUMENTS CONCERNING COMMUNICATIONS between YOU and
26 STUART DUNCAN.
27 III
28 // /
4
DOCUMENTS (SET ONE)
2 All DOCUMENTS CONCERNING COMMUNICATIONS between YOU and anyone
3 RELATING TO the alleged agreement between YOU and GBT.
5 All DOCUMENTS CONCERNING any agreements between YOU and GBT.
7 All DOCUMENTS CONCERNING any agreements between YOU and VIT.

9 All DOCUMENTS CONCERNING any agreements between YOU and TOK.KEN
10 MSB.

12 All DOCUMENTS CONCERNING any agreements between YOU and STUART
13 DUNCAN.

15 All DOCUMENTS CONCERNING any payments made by YOU and GBT.

17 All DOCUMENTS CONCERNING any payments made by YOU and VIT.

19 All DOCUMENTS CONCERNING any payments made by YOU and TOKKEN MSB.

21 All DOCUMENTS CONCERNING any payments made by YOU and STUART
22 DUNCAN.
24 All DOCUMENTS CONCERNING the use of YOUR trademark by GBT.

26 All DOCUMENTS CONCERNING the use of YOUR trademark by VIT.

28 All DOCUMENTS CONCERNING the use of YOUR trademark by TOKKEN MSB.
5
DOCUMENTS (SET ONE)
2 All DOCUMENTS CONCERNING the use of YOUR trademark by STUART
3 DUNCAN.
4 RF,OTJRST FOR PRODUCTION NO. 18.

All DOCUMENTS CONCERNING any damages suffered by YOU as alleged in the
6 Fifth Cause of Action in the COMPLAINT as a result of any alleged actions taken by GBT.
8 All DOCUMENTS CONCERNING any damages suffered by YOU as alleged in the
9 Fifth Cause of Action in the COMPLAINT as a result of any alleged actions taken by VIT.

0
.,. 0
12 Fifth Cause of Action in the COMPLAINT as a result of any alleged actions taken by
;E -~ ~
~
~
~
V'.I
°'
,,;:
13 TOKKEN MSB.
:3: -0~ '§ ~
-< 2:
....::, CQ:.::
t!:::; 1 14 REQUEST FOR PRODUCTION NO. 21.
,,o
~ -~ u ~
z C ,,;.,-...
~ i ::::= 15 All DOCUMENTS CONCERNING any damages suffered by YOU as alleged in the
~ "'~8
f.l.l ~ ~
:r: "' ~ 16 Fifth Cause of Action in the COMPLAINT as a result of any alleged actions taken by
r- : ~
"'"'
"'
°' 17 STUART DUNCAN.
20 Sixth Cause of Action in the COMPLAINT as a result of any alleged actions taken by GBT.
23 Sixth Cause of Action in the COMPLAINT as a result of any alleged actions taken by VIT.
26 Sixth Cause of Action in the COMPLAINT as a result of any alleged actions taken by
27 TOKKEN MSB.
28
6
DOCUMENTS (SET ONE)
3 Sixth Cause of Action in the COMPLAINT as a result of any alleged actions taken by
4 STTTART DTTNCAN.

7 Seventh Cause of Action in the COMPLAINT as a result of any alleged actions taken by GBT.
10 Seventh Cause of Action in the COMPLAINT as a result of any alleged actions taken by VIT.

13 Seventh Cause of Action in the COMPLAINT as a result of any alleged actions taken by
14 TOK.KEN MSB.

17 Seventh Cause of Action in the COMPLAINT as a result of any alleged actions taken by
18 STUART DUNCAN.

21 Eighth Cause of Action in the COMPLAINT as a result of any alleged actions taken by GBT.

24 Eighth Cause of Action in the COMPLAINT as a result of any alleged actions taken by VIT.

27 Eighth Cause of Action in the COMPLAINT as a result of any alleged actions taken by
28 TOKKEN MSB.
7
DOCUMENTS (SET ONE)
3 Eighth Cause of Action in the COMPLAINT as a result of any alleged actions taken by
4 STUART DTTNC:AN.
6 All DOCUMENTS which support YOUR claims against VIT.
8 All DOCUMENTS which support YOUR claims against TOKKEN MSB.
10 All DOCUMENTS which support YOUR claims against STUART DUNCAN.
11 DATED: Ma~.).__, 2019
~
0
~
"
_;
-" "' ·§~
...'~; ~
"'
0
~
°'
12
13
By:S ran
< ;,, 0 t"-- Attorneys for Defendant and Cross-
,_J
-co ~ °'
:.= I
14
Z ro ~~ Defendant
< -~ ~
z t: .,;..-...
~
Ul
0 -0
::s ::: -
15
~ ro ~ C,
~ »
Ul C -
:i::
t"""
"'
ti}
~
~
16
~ "
:;; "'
"' 17
18
19
20
21
22
23
24
25
26
27
28
8
DOCUMENTS (SET ONE) .
PROOF OF SERVICE
2
STATE OF CALIFORNIA
3 COUNTY OF LOS ANGELES
4 I am employed in the County of Los Angeles, State of California; I am over the age of
18 and not a party to the within action; my business address is 9663 Santa Monica Boulevard,
5 Suite 450, Beverly Hills, California 90210.
6 On May 22, 2019, I served the foregoing document(s) described as:
7 DEFENDANT AND CROSS-DEFENDANT VICE INDUSTRY TOKEN'S
REQUESTS FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF AND
8 CROSS-DEFENDANT PLAYBOY ENTERPRISES INC. (SET ONE)
9 on the interested parties to this action by placing a copy thereof enclosed in a sealed envelope
addressed as follows:
10
SEE ATTACHED SERVICE LIST
11
X (BY U.S. MAIL) I deposited such envelope in the mail at Los Angeles,
12 California. The envelope was mailed with postage thereon fully prepaid and addressed to the
0
~
v
0
- person below.
~ .; ~ 13
- ·=.
"' 0
~
~
~
t.t.
9:- "O
r-
J.,t- (BY PERSONAL SERVICE) by causing a true and correct copy of the above
<
...l
-> 0 r-
~~
l'.O;: ~
14 documents to be hand delivered in sealed envelope(s) with all fees fully paid to the person(s) at
z ~ ,:,; a\
< .'.: U-.r
z_o::: i:::0 -.;;,-.. the address(es) set forth below.
0
15
~ !;; ~;
"':,:,-. . .:
~
~
16
(BY FACSIMILIE) on the party by transmitting via facsimile the document(s)
M
>
0 listed above to the fax number(s) set forth above on this date. The facsimile machine I used
~ " complied with California Rules of Court, Rule 2003(3) and the transmission was reported as
17 complete and without error by the machine. Pursuant to California Rules of Court, Rule
2009(c)(4), I caused the machine to print a transmission record of the transmission, a copy of
18 which is attached to this facsimile.
19 Executed May 22, 2019 at Los Angeles, California.
20 I declare under penalty of perjury under the laws of the State of California that the
above is true and correct.
21
22
23
24
25
26
27
28
PROOF OF SERVICE
Susan K. Leader Attorneys for Plaintiff-Cross-Defendant
2 Brett Manisco Playboy Enterprises, Inc.
Akin Gump Strauss Hauer & Feldd LP
3 1999 A venue of the Stars, Suite 600
Los Angeles, CA 9006 7-6022
4 Attorneys for Defendant-Cross-Complainant
Laith Mosely Global Blockchain Technologies Corporation
1800 A venue of the Stars, 12111 Floor
6 Los Angeles, CA 90067
7 Cyrus S. N aim Attorneys for Defendant Shidan Gouran

Law Offices of Cyrus S. Nairn
8 9107 Wilshire Blvd., Suite 450
9
10
11
12
-
0
~ 0
~
O N
~ ::: 0 13
-"' "'"
u.
~
.
~ ·;; r-
~ 1 ~~ 14
~ ro
z ('d
=~
~ 0\
< .::! u..,.
z0:: i:: ,.;-
0 -0
15
~
w
! ~; ~
.....
=:r:: ('d;:
,.. "'
M
0
~
16
~"'
~
17
18
19
20
21
22
23
24
25
26
27
28
2
PROOF OF SERVICE
RECEIVED
MAY 18 201g
.........
s. Michdet Kernan, Esq.
The Kernan Law Firm
9663 Santa Monica Blvd.,
Suite 450
..... --·--··--- . -
§e.r~~
~""
......
4-~'cSf>Os~
'-"""•~---
- P I T N E Y BOWES
• 02 1P
0000838980
$ 007.35°
MAY 22 2019
MAILED FROM ZIP CODE 90028
AKIN GUMP
Strauss Hauer & Feld LLP
MAY 2 8 2019
~ MAILROOM
RECEIVED
illl
Susan K. Leader
Andrew S. Jick
AKIN GUMP STRAUSS HAUER & FELD LLP
Los Angeles, CA 90067
;.._.
EXHIBIT 15

Playboy-v-Global-Blockchain Update On Shidan Gouran SCAM

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Playboy-v-Global-Blockchain Update On Shidan Gouran SCAM

Uploaded by

Copyright:

Available Formats

Electronically FILED by Superior Court of California, County of Los Angeles on 07/17/2019 01:35 PM Sherri R.

Carter, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk

1 AKIN GUMP STRAUSS HAUER & FELD LLP

8 SUPERIOR COURT OF THE STATE OF CALIFORNIA

2. CALIFORNIA CORPORATE NUMBER

7. EMAIL ADDRESS FOR RECEIVING STATUTORY NOTIFICATIONS

12. NAME ADDRESS CITY STATE ZIP CODE

13. NUMBER OF VACANCIES ON THE BOARD OF DIRECTORS, IF ANY: 0

Home  Innovation, Science and Economic Development Canada  Corporations Canada

Federal Corporation Information - 1038659-6

Buy copies of corporate documents

Business Number (BN)

Registered Office Address

5582 Manotick Main Street

information, you can either contact the corporation or contact Corporations

stuart kenneth duncan

Anniversary Date (MM-DD)

Date of Last Annual Meeting

Annual Filing Period (MM-DD)

Status of Annual Filings

Corporate Name History

2017-08-30 to Present TOKKEN MSB INC.

Certificates and Filings

Buy copies of corporate documents

Start New Search Return to Search Results

The Adult Entertainment Industry is Ripe for Disruption…….3

1. Too many hands in the pot ……………………………………………………………………3

2. Its Not about the viewer.……………………………………………………………………….4

3. Limited user engagement……………….…………………………………………………….4

Rethinking Monetization for the Vice Industry - The Rise of the

Vice Industry Token..…………………………….………………………………………..6

Vice Industry Token Portals…..………….…………………………………………..7

Token Sale Distribution…………………………………………………………………..8

Proxy Token and Refund Contract Period………………………………..9

Stuart Duncan - CEO………..…………………………………………………………………………11

Kelly Holland - President …………………………………………………………………………..12

Bill Heilmann - CSO .……………………………………………………….…………………………..13

Eric Helsel - CMO .……………………………….……………………………….……………………..14

Andry Kostin - CTO .……………………………….……………………………….………………….15

The Adult Entertainment

Through product placement, contextual advertising, and interstitial ads, Advertisers

1. Too many hands in the pot

Instead of improving the quality of content production, the current business

2. It’s not about the viewer

3. Limited user engagement

Rethinking Monetization for the Vice Industry - The Rise of

“Free was good, it’s just not good enough anymore.”

Vice Industry Token

VIT has an advantage over general-use cryptocurrencies such as Bitcoin because it

Vice Industry Token Portals

As described above, participants in all aspects of the Vicetoken.com portal will be

Token Sale Distribution

ViceToken.com Inc: 1,000,000,000 Tokens

Content Providers, Strategic Partners,

Proxy Token and Refund

3. February 5, 2018: Second flash whitelist sale.

4. February 20, 2018: Launch of the Vice Industry Token Crowdsale.

6. March 21, 2018: Launch of the VIT MainNet.

Jan. 11 Jan. 15 Feb. 5 Feb. 20 Mar 20. Mar 21 June 28

2. Flash whitelist sale for 4. Launch of the Vice 6. Launch of the

Kelly Holland - President

In 2006, she became the Executive Producer for Penthouse Broadcast.

Penthouse is now expanding its empire of satellite channels in over 100