IN THE UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
WESTERN DIVISION

Securities and Exchange Commission v. Titanium Blockchain Infrastructure Services, Inc.; EHI Internetwork and Systems Management, Inc. aka EHI-INSM, Inc.; and Michael Alan Stollery aka Michael Stollaire, Civil Action No. 18-cv-4315 DSF (JPRx)

NOTICE OF CLAIMS PROCESS AND CLAIMS BAR DATE

This notice may affect your legal rights. Please read it carefully. Among other things, failure to timely submit a claim pursuant to the DIRECTIONS below may result in your claim being barred from a distribution

To Potential Claimant:

On May 30, 2018, the above-captioned Court entered an Order appointing Josias Dewey as Receiver for the estate of Titanium Blockchain Infrastructure Services (“TBIS Estate”). On August 21, 2020, the Court entered an Order authorizing the Claims Process and Bar Date, as modified December 15, 2020. Copies of these orders and other information regarding this case are available on the TBIS Receivership website at https://tbis.io/.

You are receiving this Notice because our records indicate you may hold a claim against the TBIS Estate. Receiving this Notice does not mean that you hold a claim or that your claim will be eligible for a distribution from the TBIS Estate.

The TBIS Fraud

As alleged by the United States Securities and Exchange Commission, Titanium President Michael Alan Stollery, a/k/a Michael Stollaire, lied about business relationships with the Federal Reserve and dozens of well-known firms for purposes of promoting an Initial Coin Offering (“ICO”).  Titanium’s website contained fabricated testimonials from these supposed corporate customers. These fraudulent statements were used to promote the ICO, which Stollaire advertised through videos and social media. The SEC's complaint charged Stollaire and Titanium with violating Sections 5(a), 5(c), and 17(a) of the Securities Act of 1933 and Section 10(b) of the Securities Exchange Act of 1934 and Rules 10b-5(a) and 10b-5(c) thereunder. The complaint charged another Stollaire company, EHI Internetwork and Systems Management Inc., with violating Section 17(a) of the Securities Act and Section 10(b) of the Exchange Act and Rules 10b-5(a) and 10b-5(c) thereunder.

Eligible Claimants and Claims Process

You may be eligible to submit a claim if you:

(i) are a creditor of Titanium;

(ii) directly purchased Titanium Bar (“BAR”) or TBAR from Titanium;

(iii) purchased BAR from a third party (other than Titanium) prior to February 22, 2018, held such BAR through February 22, 2018, received TBAR from Titanium by virtue of your BAR holdings, and held such TBAR through May 29, 2018; or

(iv) purchased TBAR from a third party (other than Titanium) prior to May 29, 2018 and held such TBAR through May 29, 2018.

How Do I Submit a Claim?

The deadline for submitting a claim to the TBIS Estate was 11:59 p.m. (Pacific Time) on August 11, 2021. The online claim filing system is now closed. Individuals or entities with further questions should direct their correspondence to the Receiver at tbis@hklaw.com.

Deadline for Submitting Claims

Notice is hereby given that all people with potential claims for recovery from the TBIS Estate should file their claim with the Receiver so that it is actually submitted on the Receiver’s online claim system, by 11:59 p.m. (Pacific Time) on August 11, 2021 (the “Bar Date”).  Claims should be filed electronically through this online claim system.

Individuals or entities that believe they have good cause to either extend the Bar Date or to submit their claim by other means should request this from the Receiver at tbis@hklaw.com no later than the Bar Date. Unless a claim is subject to a Receiver-granted exception, all claims against TBIS Estate assets that are not received by the Bar Date are barred.

Frequently Asked Questions

A link to FAQ’s with respect to the Claim Process can be found here.

A link to step-by-step instructions for setting up MetaMask for the token validation process can be found here.

 

Receiver Contact Information:

Josias “Joe” Dewey

 

E-mail: tbis@hklaw.com

  

Direct: (305) 789-7746

 

Court Documents:

 

You may access here a copy of the Order Appointing Receiver that was entered on May 30, 2018 by the United States District Court for the Central District of California.

A link to the SEC’s latest press release regarding Titanium Blockchain Infrastructure Services, Inc. can be found here.

An update can be found in the Receiver’s Initial Status Report, here.

Lastly, links to the Receivership Court Filings can be found, here.

 

PLEASE NOTE, NEITHER THE RECEIVER, NOR ANY AFFILIATE OF THE RECEIVER, WILL EVER ASK YOU TO TRANSFER POSSESSION OF ANY CRYPTOCURRENCY (WITH THE EXCEPTION OF THE “CONTROL TOKEN” REFERENCED IN THE ONLINE CLAIMS SYSTEM) OR DISCLOSE ANY PASSWORD(S) OR PRIVATE KEY(S) FOR ANY REASON WHATSOEVER. PLEASE CONTACT THE RECEIVER IMMEDIATELY IF YOU ARE PROMPTED FOR SUCH INFORMATION IN CONNECTION WITH YOUR POTENTIAL CLAIM.