Kiupelian

FACTS AND PROCEDURAL BACKGROUND

I. Facts

In January or March of 2015, Ara and Vardan Kiupelian (plaintiffs) bought stock in a company called Greenkraft, Inc. (Greenkraft) at a price of $.02 to $.28 per share. They bought $71,000’s worth. Plaintiffs bought this stock based on the representations of George Gemayel (Gemayel), who was Greenkraft’s founder, president, CEO, and sole director. Specifically, Gemayel told them that (1) Greenkraft was a “manufacturer of alternative fuel engine products,” (2) Greenkraft was a “viable, growing business,” (3) there was “lots of demand” for Greenkraft’s products, (4) “lots of people” had already invested in Greenkraft, and (5) Greenkraft’s stock would increase in value to $13 to $15

2 per share (that is, that the stock’s value would increase by somewhere between 4,642 and 75,000 percent). Gemayel’s representations to plaintiffs were not true: Greenkraft was never a “viable, growing business”; there was not “lots of demand” for its products; it had only 94 shareholders, which in plaintiffs’ view is not “lots of people”; and its stock price never exceeded $1 to $3 per share (and between 2016 and 2018, never exceeded $.50 per share).…