Case 0:22-cv-00024 Document 1 Filed 02/07/22 Page 1 of 8
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`UNITED STATES DISTRICT COURT
`DISTRICT OF WYOMING
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`Case No.
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`NATHAN CHRISTIAN,
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`Plaintiff,
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`OneM COMMUNICATIONS LTD.,
`CHRISTOPHER RICHARDSON and
`MYHAO TIEN,
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`Defendants.
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`COMPLAINT
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`By and through undersigned counsel, Plaintiff Nathan Christian (“Plaintiff” or “Mr.
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`Christian”), files this Complaint Seeking Damages and sues Defendants OneM Communications
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`Ltd. (“OneM”) and MyHoa Tien (“Tien”) and Christopher Richardson (“Richardson”)
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`(collectively “Defendants” or the “OneM Group”), and alleges as follows.
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`PARTIES, JURISDICTION, AND VENUE
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`1.
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`This action involves, among other things, (i) breach of contract by Defendants, (ii)
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`covenants of good faith and fair dealing and (iii) unjust enrichment.
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`2.
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`Mr. Christian currently is a resident of the State of Wyoming. He is a heralded and
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`respected advisor in the blockchain technology sector. He is also an entrepreneur who has started
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`and currently manages several successful business ventures in the that sector. He has been
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`identified and lauded by numerous publications as an expert in his relevant field of work and is
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`routinely paid for his business advisory services to various blockchain assets and blockchain-based
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`business ventures.
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`1
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`3.
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`OneM is a corporation in the United Kingdom that operates in the blockchain
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`sector. In addition to the fiat assets under the control of OneM, they have also issued a crypto-
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`token that constitutes a significant portion of their collective holdings – a portion of this crypto-
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`token’s float was promised as payment to Plaintiff for his services and is referred to as mCoin.
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`Richardson is the CEO of OneM, while Tien serves as its Chief Compliance Officer in charge of
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`contract review under the supervision of Richardson.
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`4.
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`This Court has jurisdiction over the parties and is the proper venue for the dispute
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`as a result of the contract signed between the parties that states as much (the “Advisor Contract”)1.
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`(See Exhibit “1” at 4).
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`Facts Common to All Claims
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`5.
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`This action concerns Defendants’ breach of contractual duties and obligations in
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`regard to the Advisor Contract reached between Plaintiff and OneM in 2018. In Spring 2018,
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`Richardson and Tien contacted Mr. Christian seeking his guidance, advice and labor to help
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`develop and advance their blockchain-based business venture. OneM through Richardson and Tien
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`eventually agreed to a compensation package for Mr. Christian in exchange for his services. See
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`Exhibit “1” annexed hereto. As of the filing of this Complaint, OneM has failed to provide the
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`full and complete promised compensation to Mr. Christian despite his complete compliance with
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`the Advisor Contract.
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`1 This Court has personal jurisdiction over the Defendants because they either expressly or impliedly submitted to the
`State of Wyoming. OneM provided so in the contract agreement that was signed by Plaintiff by stating that, in sum
`and substance, that any legal action or proceeding may be brought only in the courts of the State of Wyoming. Venue
`is further proper in this forum as OneM expressly waived any claim of improper venue and any claim that [the courts
`of the State of Wyoming] are an inconvenient forum. Richardson and Tien as officers and directors controlling OneM
`thus submitted to Wyoming’s jurisdiction as well. The choice of Wyoming law by U.S. citizens to govern contracts
`with overseas parties involved in blockchain, such as the one at issue, is frequent given the state’s stature as a pioneer
`in blockchain legislation. Thus, the choice of law and venue by Plaintiff and OneM was commercially reasonable and
`intended to be enforceable by either of them.
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`2
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`6.
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`On or about April 19, 2018, Tien - the Chief Commercial Officer of OneM -
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`contacted Plaintiff regarding an offer (“the Offer”) for Mr. Christian to provide advisory,
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`marketing, and promotional services for OneM. This request was unsolicited, and was received by
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`Mr. Christian as an honest and legitimate request for services. (See Exhibit “2” annexed hereto).
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`7.
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`The Offer was later amended with additional details that included a clear and
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`mutually agreed to compensation package for Plaintiff’s time, services, and general expertise. This
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`package included:
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`I.
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`15 Ethereum (currently valued at approximately $58,758.00 USD) payable
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`upon Plaintiff’s acceptance of the Offer.
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`II. An additional 100 Ethereum (currently valued at approximately $382,570 USD)
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`or .5% from the total ICO sales of OneM’s coins, that being mCoin, whichever
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`was greater at the completion of the ICO to be payable after the Pre-ICO (Initial
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`Coin Offering).
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`III. Lastly, Plaintiff was also guaranteed 0.5% of the OneM digital token, that being
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`mCoin, which Plaintiff believes to have a liquidation value of at least
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`$250,000).
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`8.
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`On or about April 30, 2018, Plaintiff and OneM agreed to the offer. See Exhibit
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`“1” annexed hereto.
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`9.
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`Shortly thereafter, on or about May 2, 2018 Tien followed-up with Plaintiff over a
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`series of email Messages to (i) confirm the deal and (ii) to arrange for the transfer of the 15
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`Ethereum that were promised in the Advisor Contract. See Exhibit “3” annexed hereto.
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`10.
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`Thereafter, Plaintiff set about to fulfill his end of the Offer. He provided guidance
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`and advisement into the internal operations of OneM as well as its marketing efforts. Additionally,
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`Case 0:22-cv-00024 Document 1 Filed 02/07/22 Page 4 of 8
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`he provided Defendants with access to his tremendous cache of industry experts and insiders in
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`their efforts to grow OneM and its digital token, mCoin.
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`11.
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`Notably, Mr. Christian’s efforts went far above and beyond what was asked of him
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`in the contract.
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`12.
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`Defendants made it clear that they were essentially seeking nothing more than an
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`individual who was established and connected in the world of blockchain technology to provide
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`occasional advisory services. Furthermore, they requested the privilege of listing Mr. Christian on
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`their website and on their marketing materials as an advisor.
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`13.
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`Nonetheless, Mr. Christian acted as a confidant, advisor and deal-maker for
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`Defendants in a good-faith effort to promote their business venture.
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`Count I – Breach of Contract
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`Mr. Christian incorporates herein the allegations in Paragraphs 1 through 13 as if
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`14.
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`restated in full.
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`15.
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`Mr. Christian and OneM are parties to a lawfully enforceable contract, as evidenced
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`by the various documents and correspondences exchanged between the parties.
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`16.
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`This contract required Mr. Christian to provide business advisory services for
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`OneM and for OneM to compensate Mr. Christian for his time, labor and expertise.
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`a. Mr. Christian did so by, among other things:
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`i. Reviewing and recommending potential listings for OneM for getting
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`mCoin noticed and marketed quickly;
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`ii. Posting to his numerous social media accounts noting his engagement by
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`mCoin;
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`iii. Editing OneM’s social media posts regarding mCoin;
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`iv. Locating scam accounts posting on social media about mCoin to that would
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`damage the brand of the tokens;
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`v. Advising Defendants regarding website content;
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`vi. Permitting Defendants to use his name, picture, and likeness to add
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`credibility to their venture;
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`vii. Arranging and engaging in YouTube interviews with and reviews by other
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`social media influencers to be posted to social media wherein said
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`influencers promoted mCoin;
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`viii. Strategizing ways to optimize mCoin’s social media post recognition;
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`ix. Recommending to Defendants the extension of the ICO dates of mCoin for
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`maximum exposure; and
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`x. Sent out information about mCoin to various news outlets.
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`17.
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`By reason of OneM’s breaches facilitated by Richardson and Tien, Mr. Christian
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`has been damaged. He committed significant resources to Defendants and their business venture
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`without receiving the promised compensation. More specifically, Mr. Christian forwent other
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`opportunities to work with Defendants and now is without pay for the numerous hours he spent,
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`in good-faith, working to fix, redirect, develop, and promote Defendants’ business.
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`18. While the exact total of Mr. Christian’s outstanding damages cannot be specifically
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`defined as it depends, in part, on the fluctuating price of various digital assets, these damages at
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`present total at least $700,000 USD.
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`Case 0:22-cv-00024 Document 1 Filed 02/07/22 Page 6 of 8
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`Count II – Breach of Implied Duty of Good Faith and Fair Dealing
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`19. Mr. Christian incorporates herein the allegations in Paragraphs 1 through 13 as if
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`restated in full.
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`20. Mr. Christian and OneM are parties to a lawfully enforceable contract, as evidenced
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`by the various documents and correspondences exchanged between the parties. Richardson and
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`Tien negotiated the contract on behalf of OneM.
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`21.
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`Every contract in Wyoming contains an implied covenant of good faith and fair
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`dealing.
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`22.
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`Defendants and each of them breached the covenant of good faith and fair dealing,
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`both in the implied terms of the contract and also in the explicitly stated language of the parties in
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`their contract by failing to make the promised payments.
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`23. Mr. Christian has been damaged. He has committed significant resources to
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`Defendants and their business venture without receiving the promised compensation. More
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`specifically, Mr. Christian forwent other opportunities to work with Defendants and now is without
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`pay for the numerous hours he spent, in good-faith, working to fix, redirect, develop, and promote
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`Defendants’ business.
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`24.
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`During the ICO, Mr. Christian further advised OneM to partner with another
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`industry influencer in Asia to promote the venture. He further connected that influencer with
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`Defendants via email. However, OneM did not accept his guidance or respond to his emails until
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`weeks after the end of ICO.
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`25.
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`During the ICO, Mr. Christian advised Defendants of his recommended listings for
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`marketing exposure of OneM via email communications. Defendants refused to accept Mr.
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`Christian’s advice and therefore did not list OneM at the websites he recommended.
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`Case 0:22-cv-00024 Document 1 Filed 02/07/22 Page 7 of 8
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`26.
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`Defendants also delayed in starting the ICO due to their own need to improve
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`website security issues.
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`27.
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`Defendants further did not provide Mr. Christian with estimates for funding raised
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`to provide to potential investors.
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`28. Mr. Christian further offered to attend trade shows, but Defendants never scheduled
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`any for him to attend.
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`29.
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`Additionally, many of Mr. Christian’s efforts to work with Defendants to provide
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`business sadvisory services to OneM were ultimately rejected by the Defendants. As a result, Mr.
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`Christian has not only been denied payment for his work, but the underlying business venture in
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`which he has a stake has suffered as well.
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`Count III – Unjust Enrichment
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`30. Mr. Christian incorporates herein the allegations in Paragraphs 1 through 13 as if
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`restated in full. To the extent necessary, the following allegations are pled in the alternative.
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`31. While Mr. Christian completed performance of his portion of the contract,
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`Defendants have failed to adequately perform and complete their portion of the contract
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`32.
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`Consequently, Defendants benefited from the services of Mr. Christian while Mr.
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`Christian remains unpaid for his work.
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`33.
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`Additionally, given the nature of Defendants’ business venture, they continue to
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`benefit and be unjustly enriched by way of Mr. Christian’s time, labor and expertise, as their OneM
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`project retains and benefits from the work that Mr. Christian previously provided. Conversely, Mr.
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`Christian has yet to receive over $700,000 in promised compensation.
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`Case 0:22-cv-00024 Document 1 Filed 02/07/22 Page 8 of 8
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`PRAYER FOR RELIEF
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`WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully requests:
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`A. A judgment for compensatory and consequential damages in favor of Mr. Christian
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`and against Defendants;
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`B. An award of post-judgment interest;
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`C. An award of costs incurred by Mr. Christian in bringing this proceeding; and
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`D. Such other and further relief as the Court deems just and proper.
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`DEMAND FOR JURY TRIAL
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`Plaintiff demands a trial by jury on all issues so triable.
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`Dated: February 7, 2022
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`/s/ Robert V. Cornish, Jr.
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`Robert V. Cornish, Jr. (06-3898)
`LAW OFFICES OF ROBERT V. CORNISH,
`JR., PC
`680 South Cache Street, Suite 100
`Jackson, WY 83001
`Office: (307) 264-0535
`Email: rcornish@rcornishlaw.com
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`Counsel for Plaintiff
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`8
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