SEC v. Nova Tech Ltd; Cynthia Petion; Eddy Petion; Martin Zizi; James Corbett; Corrie Sampson, et al., No. 1:24-cv-23058, Southern District of Florida (Aug. 12, 2024) — Complaint

1

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
SECURITIES AND EXCHANGE COMMISSION,
   Plaintiff,
 v.
NOVA TECH LTD, CYNTHIA PETION,
EDDY PETION, MARTIN ZIZI, JAMES
CORBETT, CORRIE SAMPSON, DAPILINU
DUNBAR, JOHN GAROFANO, MARSHA
HADLEY,

 Defendants.

         Civ. Action No. 1:24-cv-23058
    JURY TRIAL DEMANDED

COMPLAINT
The Securities   and   Exchange   Commission   (“SEC”)   files   this   Complaint   against
Defendants Nova  Tech  Ltd. (“NovaTech”),  Cynthia  Petion,  Eddy  Petion, Martin  Zizi  (“Zizi”),
James  Corbett  (“Corbett”),  Corrie  Sampson  (“Sampson”), Dapilinu  Dunbar  (“Dunbar”),  John
Garofano  (“Garofano”),  and  Marsha  Hadley  (“Hadley”) (collectively,  “Defendants”),  and
alleges as follows:
I. SUMMARY
1. From  June  2019  to  approximately  May  2023,  Cynthia  Petion  and  Eddy  Petion
(together,  the  “Petions”)  operated  a  fraudulent crypto  trading  investment and  pyramid  scheme
primarily through NovaTech, a company registered in St. Vincent and the Grenadines. The Petions
used  a  multi-level  marketing  (“MLM”)  structure  to  raise  crypto  assets  worth  more  than  $650
million from  over  200,000  investors  in  the  United  States  and  abroad,  including  many  in  the
Haitian-American community.

2

2. In  solicitations  made  through  its  public  website,  social  media,  and  network  of
promoters, NovaTech claimed to pool investors’ crypto assets and trade them on the crypto asset
and  foreign  currency  markets.  NovaTech  promised  to  pay  profits  to  investors  from  this  trading
activity on a weekly basis. NovaTech purportedly never posted a weekly trading loss and, from
2019 to 2023, reported average returns of 2–3% per week.
3. In reality, NovaTech appears to have traded only a small fraction of investor assets,
it  suffered  significant  trading  losses,   and  it  had  no  other  known  sources  of  revenues  besides
investor  deposits.  In  other  words,  NovaTech  was  a  pyramid  scheme  that  depended  on  the
recruitment of new investors or new investments from existing investors to fund its enterprise.
4. The Petions misappropriated investor assets for unauthorized purposes, including
transferring millions of dollars of commingled investor assets to themselves.  On information and
belief,  they  also  used  investor  funds  to  make  payments  to  existing  investors  and  commission
payments to promoters.
5. In promoting NovaTech, the Petions also made a barrage of false and misleading
statements relating to NovaTech’s use of investors assets for trading, the profitability of its trading,
its  status  as  an  alleged  “registered  hedge  fund,” and  the  purported  safety  and  security  of  the
investment. The scheme collapsed in or around May 2023, after investors experienced withdrawal
delays and regulators in several U.S. states and Canadian provinces took action against,  or issued
fraud  warnings  about,  NovaTech  and  the  Petions. As  NovaTech  collapsed,  most  investors  were
unable to withdraw their investments, resulting in substantial losses.
6. Defendants  each  marketed  the  NovaTech  investment  to  investors  who  were
inexperienced  in  crypto  assets  and  who  wanted  to  participate  in  the  crypto  markets.  Certain

3

Defendants  targeted  affinity  groups,  in  particular  the  Haitian-American  community,  and used
religious overtones and appeals to financial freedom and independence to solicit investors.
7. Defendants Zizi, Corbett, Sampson, Dunbar, Garofano, and Hadley (collectively,
the  “Promoter  Defendants”)  were  instrumental  in  offering,  marketing,  and  distributing  the
NovaTech investment. The Promoter Defendants held themselves out as “leaders” and rose to the
highest  ranks  of  NovaTech’s  MLM  program.  They  did  so  by  recruiting,  developing,  and
maintaining a wide network of “downline” investors, many of whom became recruiters themselves
and  brought  in  additional  investors.  The  Promoter  Defendants  received  substantial  commission
payments from NovaTech for recruiting investors into their downlines.
8. Certain  Promoter  Defendants—Zizi,  Corbett,  Dunbar,  and  Sampson—became
aware  of  actions  against  NovaTech  by  regulators  in  the  United  States  and  Canada,  investors
experiencing withdrawal delays, NovaTech suspending withdrawals, and other red flags that raised
questions about the legitimacy of NovaTech and the legality of its offering and selling activities.
Nevertheless, these Promoter Defendants continued to promote NovaTech, recruit investors, and
operate their MLM networks in the face of these red flags. They also actively downplayed the red
flags to prospective investors and downline promoters.
9. By engaging in the acts and conduct alleged herein, Defendants NovaTech and the
Petitions violated the antifraud and securities-registration provisions of the federal securities laws,
Defendants Zizi, Corbett, Dunbar, and Sampson violated the antifraud, securities-registration, and
broker-registration provisions of the federal securities laws, and Defendants Garofano and Hadley
violated the securities-registration and broker
-registration provisions of the federal securities laws.
In the interest of protecting the public from further violations and enforcing the federal securities
laws, the SEC brings this action seeking permanent injunctive relief, disgorgement of ill-gotten

4

gains plus prejudgment interest, civil penalties, and all other equitable and ancillary relief the Court
deems necessary and proper.
II. JURISDICTION AND VENUE
10. The SEC brings this action pursuant to the authority conferred upon it by Sections
20(b) and 20(d) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77t(b) and 77t(d)]
and Sections 21(d) and 21(e) of the Securities Exchange Act of 1934 (“Exchange Act”)    [15 U.S.C.
§§ 78u(d) and 78u(e)].
11. This Court has jurisdiction over this action pursuant to Sections 20 and 22(a) of the
Securities Act [15 U.S.C. §§ 77t and 77v(a)] and Sections 21(d), 21(e), and 27 of the Exchange
Act [15 U.S.C. §§ 78u(d), (e), and 78aa].
12. Defendants,   directly   or   indirectly, made   use   of   the   mails   or means   or
instrumentalities of interstate commerce in connection with the acts, practices, transactions, and
courses of business alleged in this Complaint.
13. Venue is proper in this District pursuant to Section 22(a) of the Securities Act [15
U.S.C. § 77v(a)] and Section 27 of the Exchange Act [15 U.S.C. § 78aa]. At least one Defendant,
Defendant Dunbar, is found, is an inhabitant, and transacts business in this District. In addition,
certain acts, practices, transactions, and courses of business constituting violations of the securities
laws alleged herein occurred within this District, and the offer or sale of securities at issue in this
case took place in this District. Prior to approximately May 2022, the Petions are believed to have
resided  in  this  District,  wherefrom,  on  information  and  belief,  they  engaged  in  certain  acts,
practices, transactions, and courses of business constituting violations of the federal securities laws
alleged in this Complaint.

5

III. DEFENDANTS
14. Defendant Nova Tech Ltd. is a company registered and formed under the laws of
St. Vincent and the Grenadines in September 2019. According to its Disclosure Document dated
August 15, 2019 (the “Disclosure Document”) that was provided to investors, NovaTech is and/or
was responsible for “the management of Cryptocurrency trading accounts for qualified investors”
within the NovaTech organization.
15. Defendant Cynthia  Petion  is  a  U.S.  citizen.  On  information  and  belief,  she  is
currently residing in Panama, and prior to approximately May 2022, she resided in Wellington,
Florida.  Cynthia Petion  is  and/or  has  been  described  as  the  founder,  sole  shareholder,  Director,
Managing  Member,  and  CEO  of  NovaTech.  According  to  NovaTech’s  Disclosure  Document,
Cynthia Petion is “responsible for creating, planning, implementing, and integrating the strategic
direction of [NovaTech], managing and implementing [NovaTech’s] research and development of
cryptocurrency strategies, and overseeing and managing [NovaTech’s] overall operations.”
16. Defendant Eddy  Petion  is  a  U.S.  citizen  and  the  husband  of  Cynthia  Petion.  On
information and belief, he is currently residing in Panama, and prior to approximately May 2022,
he resided in Wellington, Florida. Eddy Petion is and/or has been described as a Managing Member
and  Chief  Operating  Officer  (“COO”)  of  NovaTech.  According  to  NovaTech’s  Disclosure
Document, Eddy Petion “oversees daily operations and trading for client accounts” at NovaTech,
and  purportedly  “conducted  independent  research  on  trading  strategies  using  his  proprietary
cryptocurrency trading account where he tested various trading strategies including value investor,
swing trading, short term trading and algorithmic and machine trading.”
17. Defendant Martin  Zizi  is  a  resident  of  Kennesaw,  Georgia.  He  was  the  first
NovaTech promoter to achieve the rank of Two Star Ambassador, the highest promoter rank within

6

NovaTech’s MLM program. He also founded one of the most successful NovaTech promotional
groups: Team Trinity of Success Club.
18. Defendant James Corbett is a resident of Mastic Beach, New York. Cynthia Petion
referred  to  him as a  “Founding  Leader”  of  NovaTech.  He  achieved  the  rank  of  Two  Star
Ambassador in NovaTech’s MLM program.
19. Defendant Corrie Sampson is a resident of Fairburn, Georgia. She was a Two Star
Ambassador in NovaTech’s MLM program. She cofounded one of the most successful NovaTech
promotional  groups:   Team  Diamond.  As  of  January  2023,  Team  Diamond  had  over  50,000
members who were investors in NovaTech.
20. Defendant  Dapilinu  Dunbar  is  a  resident  of  Miami,  Florida.  He  was  a One  Star
Ambassador   in   NovaTech’s   MLM   program,   the   second   highest   rank   behind   Two   Star
Ambassador. He was one of the most prolific promoters for NovaTech. He was a member of Team
Diamond,  where  he  often  collaborated  with  Sampson  and  Hadley  to  market  and  promote
NovaTech to investors and prospective investors.
21. Defendant John Garofano is a resident of Brooksville, Florida. He was a Two Star
Ambassador in NovaTech’s MLM program. Corbett originally recruited Garofano to invest and
participate in NovaTech and its MLM program, and the two often worked together to market and
promote NovaTech to investors and prospective investors.
22. Defendant Marsha Hadley is a resident of Murrietta, California. She was a One Star
Ambassador in NovaTech’s MLM program. Hadley and Sampson cofounded Team Diamond.
IV. FACTS
A. The Petions Founded NovaTech in June 2019.
23. Before  founding  NovaTech,  the  Petions  were  the  top  U.S.  promoters  for  another
alleged MLM crypto investment scheme:  AWS Mining PTY Ltd (“AWS”). Operating as “Team

7

Nova,”  the  Petions  were  the  highest  ranked  promoters  in  AWS’s  MLM  program,  commonly
referred to as the “founding presidents” of AWS’s operations in the United States. AWS offered
investments in cryptocurrency mining contracts to investors and paid bonuses and commissions to
an MLM network of sales agents who sold those investments for AWS and recruited additional
agents into its MLM program.
24. In  November  2018,  the  Texas  State  Securities  Board  (“TSSB”)  found  that  AWS
violated Texas securities laws and ordered AWS to cease and desist from offering its securities in
Texas. Among other things, the TSSB found that AWS violated Texas securities laws by making
false and misleading statements to investors about the profitability of the investments sold, offering
unregistered securities, and recruiting sales agents to offer and sell securities without a registration
or license to sell such securities. The AWS scheme collapsed soon thereafter.
25. At or around the  time  of  AWS’s  collapse,  court  records  indicate  that  the  Petions
were facing personal financial issues, including: (i) in April 2018, a credit card issuer sued Cynthia
Petion in state court in Palm Beach County, Florida, and subsequently obtained a judgment against
her for $11,776.55 in unpaid debt; (ii) in July 2018, a mortgage lender sued the Petions in state
court in Palm Beach County, Florida, in an action to foreclose a defaulted mortgage on a residential
real property held by the Petions; and (iii) in August 2019, a debt buyer sued Cynthia Petion in
state court in Palm Beach County, Florida, alleging that she had failed or refused to repay a loan.
26. The Petions began to publicly distance themselves from AWS as it collapsed. They
blamed AWS’s collapse on its principals and claimed that they, too, were victims of the alleged
scheme  (even  though  Cynthia  Petion  privately  acknowledged  that  she  made  over  $3  million  in
connection with AWS). The Petions then pivoted to creating and running their own MLM crypto
investment scheme—“NovaTech”—which Cynthia Petion told prospective investors was created

8

as a way for former AWS investors to recoup losses suffered when AWS collapsed. To help ensure
NovaTech’s success, the Petions lured other top AWS promoters to promote NovaTech to their
respective followings of investors.
27. Taking what they learned from AWS, the Petions founded and operated NovaTech
between approximately June 2019 and May 2023 (the “Relevant Period”). The Petions developed
and  implemented  an  MLM  structure  for  NovaTech—discussed  further  in  paragraphs  34–43
below—modeled after AWS’s MLM program. And in an attempt to avoid the TSSB’s scrutiny,
Cynthia Petion included Texas on NovaTech’s list of “Restricted Areas” and claimed not to offer
NovaTech to Texas residents.
28. Throughout the  Relevant  Period,  the  Petions  marketed  NovaTech—among  other
places, on its website, social media, through Telegram and WhatsApp, and in presentations made
available to  investors—as an  investment  program  that  promised  lucrative  profits  purportedly
earned from trading in crypto asset and foreign currency markets by NovaTech’s supposed “team
of experienced traders.” In addition to offering this “passive” investment opportunity, NovaTech
also  paid  commissions,  through  an  MLM  structure,  to  members  who  recruited  new  investors.
NovaTech’s marketing to investors heavily emphasized the MLM “business opportunity.”
29. Throughout the Relevant Period, the Petions held themselves out as the founders
and control persons of NovaTech, with Cynthia Petion serving as CEO and Eddy Petion as COO.
Cynthia Petion registered and maintained the novatechfx.com and novatechfx.io domains. Cynthia
Petion also registered and maintained the NovaTech website, novatechfx.com, that was marketed
to and used by investors. The website was hosted on a server provided by a U.S. company.
30. To  participate  in  the  NovaTech  investment  program,  investors  created  a  user
account on NovaTech’s website and funded their accounts with crypto assets worth a minimum of

9

$99. While creating their accounts, investors could identify their “sponsor” (i.e., the person who
recruited them) by, among other means, following a unique URL provided by the sponsor.
31. By creating an account on NovaTech’s website, investors could access marketing
and  training  materials,  access  NovaTech’s  official  Telegram  channel,  invest  crypto  assets  into
NovaTech’s  program,  track  their  account  balances  (including  purported  trading  profits  and
recruitment commissions credited to their account), re-invest purported profits and commissions,
and   submit   a   request   to   withdraw   purported   profits,   commissions,   and   invested   capital.
NovaTech’s  website  referred  to  this  suite  of  features  as  the  “back  office.” The  Petions  hired,
directed, and paid software development companies to develop and maintain the back office.
32. Throughout the  Relevant  Period,  NovaTech provided  investors  certain  written
disclosures  during online enrollment,  including  the  “Disclosure  Document”  (as  defined  in
paragraph  14  above).  When an investor  sought  to  invest  their  crypto  assets  in  NovaTech,  the
NovaTech website automatically directed the investor to a separate webpage featuring a unique,
single-use wallet address to which the investor was directed to send crypto assets for deposit into
an account controlled by NovaTech and the Petions.
33. The Petions established and controlled the methods by which NovaTech sent and
received crypto assets to and from investors. NovaTech used a crypto payment processor located
in  Lithuania  (and  in  Estonia  for  part  of  the  Relevant  Period)  (the  “Payment  Processor”).  The
Petions  controlled  NovaTech’s  account  with  the  Payment  Processor.  The  manner  in  which  the
Petions  elected  to  process  payments  using  the  Payment  Processor  obscured  both  incoming
transactions by investors to NovaTech and the onward transfer of investors’ assets from NovaTech.
B. The NovaTech Investment Offering.
34. Throughout  the  Relevant  Period,  the  Petions  promoted—among  other  places,  on
NovaTech’s  website and  in  presentations  to  investors  that  they  authored,  helped  author,  and/or

10

approved—the  NovaTech  investment  program  as offering a  participation  interest  in  a  pool  of
crypto assets that NovaTech purportedly traded on behalf of investors. On its website, NovaTech
referred to this participation interest as a “PAMM account,”  which its website described as a
product that allows investors to earn without having to trade. You
can invest your funds in NovaTech’s master accounts to be traded
by our experienced team of traders. We receive a percentage of the
profits  we  earn  from  trading  with  your  funds  as  a  reward. No
experience necessary.

NovaTech’s website further explained that the “PAMM system allows more money to be brought
into play while distributing the risk of one trader across (usually) multiple investors.”
35. In its  Disclosure  Document  provided  to  investors,  NovaTech  represented  that  its
investment objective was “to trade in and out of cryptocurrencies achieving gains in the Client’s
portfolio using proprietary buy and sell trading signals it has developed.” NovaTech represented
that it purportedly kept 30% of any purported trading profits and distributed 70% to investors.
36. Throughout the Relevant Period, NovaTech’s back office displayed two accounts
for each investor: a “Trading Account” and a “Bonus Account.” An investor’s “Trading Account”
reflected the investor’s capital contributions (whether initial or subsequent). NovaTech claimed to
be  actively  trading  all  crypto  assets  in  each  investor’s  Trading  Account.  The  “Bonus  Account”
purportedly reflected amounts that NovaTech credited, on a weekly basis, with the investor’s pro
rata share of alleged trading profits and any commissions the investor received from participating
in  the  MLM  program.  In  the  Disclosure  Document  and  other  back-office  materials,  NovaTech
represented to investors that assets in the Bonus Account were not traded, but at all times investors
had the option to “rollover” (i.e., reinvest) the purported profits and any commissions accumulated
in the Bonus Account by transferring any portion of them to the Trading Account. NovaTech also

11

represented that investors could withdraw crypto assets from the Trading Account and the Bonus
Account, subject to certain terms, as described, among other places, in paragraphs 40–42 below.
37. NovaTech’s fee structure incentivized investors to increase their Trading Account
balance  by  either  contributing additional assets  out  of  pocket  or  by  rolling  over  their  Bonus
Account balances to their Trading Account. For example, if an investor’s Trading Account balance
exceeded $25,000 for a full calendar month (“VIP” level), NovaTech waived its monthly service
fee for the investor and credited the investor a 1% “cash back reward” that was 1% of monthly
trading  profits  (expressed  as  a  percentage  that  NovaTech  called  the  “ROI”).  If  an  investor’s
Trading Account balance exceeded $100,000 for a full calendar month (“President’s Club” level),
NovaTech waived its monthly service fee for the investor and credited the investor a 2.5% cash
back reward and a $1,000 gift card bonus.
38. NovaTech’s promoters and the Petions also encouraged investors to rollover their
Bonus  Account  balances  into  their  Trading  Account,  purportedly  to  increase  the  weekly  profits
investors  received. For  example,  in  a  Zoom  presentation  given  near  the  end  of  2020  and  later
posted  to  YouTube  on  or  around  January  3,  2021,  Zizi—a  top-ranked  NovaTech  promoter—

advised that prospective investors should take at least 10% of their money
and have it work for you...by putting it in your trading account, and once you have
that done, the second -- the third step is for you to take the babies of the money that
is  making  for  you,  and  then  put  those  babies  back  to  work  where  we  get  to
compound  interest,  having  money  working  for  you,  making  babies  every  single
week.

Yes, you’re making money from your group volume. How much of that is going
back into your trading account? Ten percent of that must go back...

39. As another example, in a video posted to YouTube on May 4, 2022, Cynthia Petion
told investors, in relevant part: “[w]hen you earn your bonuses every week,...you have the option
of  redepositing  it  so  that  your  account  continues  to  grow,  and  that’s  the  best  way  to  grow  your

12

account without having to add any additional funds out of your own pocket.” In this same video,
Cynthia Petion also acknowledged that NovaTech incentivized its promoters to persuade investors
in  their  downlines  to  increase  their  Trading  Account  balances,  stating:  “I  know  as  affiliate
marketers we want people to put in as much as possible. Why? Because there’s check matching
and there’s all the other—there’s direct referral fees, and everything else. And as accounts grow,
our business grows, I get that.”
40. Throughout  the  Relevant  Period,  the  Petions  touted  investors’ supposed ready
access to capital and “weekly liquidity” that NovaTech provided, both in the Trading and Bonus
Accounts,  claiming  that  these  purported  features  differentiated  NovaTech  from  other  MLM
investment programs. For example, this selling point was described on the following slide from a
NovaTech  marketing  deck—authored  and  approved  by  the  Petions—that  NovaTech  made
available to all investors in the back office between approximately October 2021 and April 2023:

13

41. NovaTech  disclosed  to  investors  certain  investment  terms  in  writing  prior  to  the
investment. These  terms  were  located,  among  other  places,  in  NovaTech’s  Compensation  Plan
dated August 3, 2019 (“Compensation Plan”)—which, on information and belief, was published
to  NovaTech’s  back  office  between  approximately  August  3,  2019  and  October  2020—and  an
updated  Compensation  Plan  dated  October  2020  (“Updated  Compensation  Plan”),  which,  on
information and belief, was published to NovaTech’s back office between approximately October
2020 and January 2023. Cynthia Petion drafted both documents and Eddy Petion participated in
the drafting process and reviewed drafts. As further detailed in paragraph 53–56 below, the Petions
and NovaTech modified these terms in 2023.
42. The Updated  Compensation  Plan  provided,  among  other  things, that investor
requests to withdraw crypto assets from the Trading Account were to be processed within 7–14
business days and, if made within 90 days of registration, were subject to a 15% “processing fee.”
As  to  investor  requests  to  withdraw  from  the  Bonus  Account,  the  Updated  Compensation  Plan
provided that such requests were to be processed within 24–48 hours.
43. Neither NovaTech nor any of its affiliates have ever been registered with the SEC
as brokers, investment advisers, or in any other capacity. And the NovaTech securities offerings
and sales described herein have never been registered with the SEC. The Petions and the Promoter
Defendants  have  never  been  registered  with  the  SEC  as  brokers,  investment  advisers,  or  in  any
other capacity and have never been associated with a broker or dealer registered with the SEC.
C. The Petions Designed and Implemented NovaTech’s MLM Program to Promote and
Distribute NovaTech’s Investment Offering.
44. The  Petions  designed  and  implemented  NovaTech’s  MLM  program,  which
facilitated the distribution of NovaTech’s investment offering. Each of the Petions also personally
solicited investors. The Promoter Defendants were prominent participants in NovaTech’s MLM

14

program, through which they solicited investors to invest in the NovaTech investment offering.
During the Relevant Period, NovaTech raised crypto assets worth more than $650 million, valued
as of the time the crypto assets were deposited, using its MLM program to recruit over 200,000
investors.
45. Throughout the Relevant Period, the Petions solicited potential investors to invest
in  the  NovaTech  investment  offering  through,  among  other  means,  NovaTech’s  website,  social
media (including Instagram and Facebook), presentations led by the Petions that were broadcast
on  Zoom  to  potential  investors  (and some  of  which  were  recorded  and  distributed  publicly  on
YouTube or other sites), and Telegram channels and WhatsApp groups controlled by the Petions.
46. The  Petions  also  developed  an  MLM program  designed  to  solicit  prospective
investors to invest in NovaTech. This MLM program relied on and incentivized a wide network
of promoters to recruit new investors. Promoters stood to gain from recruiting new investors and
new  promoters  into  their  “downlines.”  A  promoter’s  downline  included  the  investors  that  the
promoter directly recruited to invest in NovaTech, plus all investors who were recruited to invest
in NovaTech by others in that promoter’s downline.
47. The Petions sought to cultivate and maintain relationships with top promoters. They
personally recruited at least two Promoter Defendants,  Zizi and Corbett, whom the Petions sought
out because of the large networks Zizi and Corbett had developed with other MLM programs, like
AWS. They also personally met with the top-performing promoters. In or around December 2021,
the Petions held a party for top promoters on a boat in Miami, which Zizi, Dunbar, and Garofano
attended.  In April 2023, Zizi and Dunbar attended Cynthia Petion’s birthday party in Panama, and
before that, in or around February 2023, Dunbar visited the Petions at their residence in Panama.

15

48. Throughout  the  Relevant  Period,  NovaTech’s  marketing  materials—which  the
Petions  authored  and approved—were  geared  primarily  toward  persuading  investors  to  recruit
others into their downlines (through the promise of generous commissions), while only describing
the trading program in brief and generic terms. NovaTech-branded marketing materials were made
available for all investors to download from NovaTech’s back office. These materials included a
slide deck that Cynthia Petion drafted and Eddy Petion reviewed and approved. Zizi, Corbett, and
Garofano, among others, used this slide deck in weekly Zoom meetings with prospective investors
throughout the Relevant Period.
49. When  the  Petions  and  certain  Promoter  Defendants  solicited  investors,  they
frequently  employed  religious  overtones,  appealed  to  the  financial  freedom  and  independence
purportedly attained by investing in crypto assets and participating in MLM programs, and targeted
certain affinity groups, in particular the Haitian-American community.
50. Throughout the Relevant Period, Cynthia Petion branded herself as “The Reverend
CEO” in NovaTech promotional materials and laced her investor pitches with religious appeals.
For example, in an interview posted to YouTube on October 6, 2022, Cynthia Petion described her
founding  of  NovaTech as  “God’s  vision.”  In  another  video  in  which  Cynthia  Petion trained
promoters on how to present NovaTech to prospective investors, which was posted to YouTube
on May 4, 2022, Cynthia Petion stated: “Jesus was the best affiliate marketer in the world.”
D. NovaTech Rapidly Collapsed and Halted Its U.S. Operations by May 2023.
51. By at least around October 2022, investors began to experience substantial delays
in withdrawing their crypto assets from NovaTech. In communications to investors, the Petions
attributed these delays to technical issues caused by NovaTech’s rapid growth. For example, in a
post to its official Telegram channel on October 28, 2022, NovaTech acknowledged “a growing

16

number of issues arising concerning USDT cash out requests,” and attributed these issues to “the
payment processor being unable to process” the requests.
52. Around  the  same  time,  NovaTech  came  under  scrutiny  from  regulators  in  U.S.
states and Canadian provinces. On October 11, 2022, the British Columbia Securities Commission
issued  a  fraud  warning  regarding  NovaTech,  and  on  October  12,  2022,  the  Alberta  Securities
Commission issued its own fraud warning. On November 22, 2022, the California Department of
Financial Protection and Innovation issued a desist and refrain order (the “California Order”).
The  California  Order  found  that NovaTech, certain  NovaTech  entities,  and  the  Petions  violated
California state securities-registration and anti-fraud statutes by: offering securities without being
permitted  or  qualified  to  do  so, making  material  misstatements  about,  among  other  things,
NovaTech’s purported registration status, and failing to provide any qualifications to substantiate
claims that investor funds were managed and traded by experienced traders. NovaTech could have
contested the California Order pursuant to California law, but it never did so.
53. On January 24, 2023, “NovaTech Admin”—which,  on information and belief, is an
account  controlled  by  Cynthia  Petion—posted  an  announcement  to  investors  through  the  back
office,  attributing  the  withdrawal  delays  to  “unusually  high  volumes  in  cashout  requests,  in
addition to the implementation of new payment processing systems and recent updates.”
54. On February 5, 2023, “NovaTech  Admin”  posted  an  announcement  to  investors
through the back office, announcing that NovaTech was instituting a 60-day “temporary freeze”
on all investor withdrawals from Trading Accounts. In the announcement, this pause was attributed
to “the forced closures of accounts” that were “due to regulatory changes in specific regions,” as
well as “the massive amounts of withdrawals we had to initiate.”

17

55. On or  around  March  31,  2023,  the  day  before  the  previously  announced  60-day
“temporary freeze” was due to be lifted, Cynthia Petion posted an announcement to the back office,
outlining NovaTech’s new compensation plan and new withdrawal terms applicable to all existing
and  new  investors  that  would  take  effect  the  following  day. These  terms  severely  restricted  the
frequency of withdrawals that investors could request from their Trading Accounts, as well as the
amount  of  crypto  assets  that investors  could  withdraw  from  their  Trading  Accounts,   while
continuing to permit, with fewer restrictions, withdrawals from Bonus Accounts.
56. On or around May 11, 2023, NovaTech announced it was halting U.S. operations,
and its website was disabled shortly thereafter, after which investors could no longer make any
withdrawals from their NovaTech accounts.  Ultimately, most investors were unable to withdraw
their investments from NovaTech, resulting in substantial losses.
E. The Petions Operated NovaTech as a Fraud on Investors.
57. The Petions did not provide the SEC access to NovaTech’s internal records during
the SEC’s  investigation  that preceded  the  filing  of  this  Complaint.   Instead,  the  Petions  and
NovaTech  ignored  the  SEC’s  investigative  subpoenas  and  failed  to  produce  any  documents  or
provide  testimony  in  response  to  those  subpoenas.   Nevertheless,  the  SEC  obtained substantial
evidence concerning NovaTech’s crypto asset transactions and trading, including but not limited
to public blockchain data, Payment Processor data, other data from various crypto asset exchanges,
and documents and information obtained from NovaTech’s former Chief Technology Officer.
58. NovaTech raised crypto assets during the Relevant Period worth more than $650
million, valued at the time of investor deposits, from more than 200,000 investors in multiple U.S.
states and foreign countries. These figures are primarily based on an analysis of cryptocurrency
transaction data pertaining to NovaTech, including relevant blockchain data, Payment Processor
data, and other relevant data from various crypto asset exchanges.

18

59. While  soliciting  these  investments,  NovaTech  represented  to  investors  that  the
returns it credited to investor accounts were derived from crypto asset and foreign currency trading
activity. During the Relevant Period, NovaTech reported to investors average returns of 2–3% per
week from its purported trading. Aside from the investor deposits and “profits” from its purported
trading activity, NovaTech had no other known profit-generating operations or inflow of assets.
Thus, to pay the returns that it reported and credited to investors, as well as the very significant
commission  payments  as  part  of  the  MLM  program,  while  also  keeping  30%  of  the  profits  for
itself,  NovaTech’s  trading  activities  had  to  generate  significant  profits  above  and  beyond  the
hundreds  of  millions  of  dollars’  worth  of  crypto  assets  that  NovaTech received  from  investors.
However, NovaTech used only a small fraction of crypto assets contributed by investors to trade
on trading platforms, and NovaTech’s limited trading was not profitable.
60. NovaTech failed to generate anywhere near the returns it represented to investors
through  the  small  percentage  of  crypto  assets  that  were  traded.  To  the  contrary,  records from
NovaTech’s known trading platforms show that traders and accounts associated with NovaTech
lost approximately $18 million in trading these assets during the Relevant Period.
61. NovaTech  had  an  automated  system  to  maintain  the  accounting  for  investors’
Trading and Bonus Accounts. On a weekly basis, this system calculated the amounts to be credited
to  investors’  accounts  based  on  the  trading  profits  purportedly  achieved  that  week.  During  the
Relevant Period, this system was not linked to any trading venue or trading system that NovaTech
used. Instead, the sole input into the accounting system for the reported trading profits/ROI was
provided manually  by  Cynthia  Petion  on  a  weekly  basis. Specifically,  Cynthia  Petion  manually
entered the weekly performance percentage in the back office and would then “run” the software

19

code that would use such manually entered percentage to generate each investor’s weekly profit
and commissions amounts and post those amounts to each investor’s back office account.
62. The Petions also caused NovaTech to transfer from wallets in which it aggregated
investor assets to accounts or wallets that the Petions owned and/or controlled. During the Relevant
Period,  at  least  $4.3  million  in  crypto  assets  were  transferred  from  NovaTech  into  accounts  or
wallets owned and/or controlled by Cynthia Petion, and at least $1.5 million in crypto assets were
transferred from NovaTech into accounts known to be owned and/or controlled by Eddy Petion.
63. In  addition,  NovaTech  transferred  an  additional  approximately $35.2  million  in
crypto  assets  from  wallets  in  which  it  aggregated  investor  assets  to  accounts  or  wallets  that,  on
information and belief, were owned and/or controlled by Eddy Petion. This is based on evidence
that  these  crypto  assets  were  initially  withdrawn  from  NovaTech’s  Payment  Processor  account
with the internal note “EP” (Eddy Petion’s initials), and evidence that at least some of the assets
withdrawn from the NovaTech Payment Processor account merged with crypto assets withdrawn
from Eddy Petion’s known crypto asset platform account before being simultaneously transferred,
in a single transaction, to Eddy Petion’s suspected deposit address.
64. NovaTech  failed  to  generate  returns  from  its  crypto  asset  and  foreign  exchange
trading, it used only a fraction of investor assets to trade, and it had no other known sources of
revenues  besides  investor  deposits  and  trading  activity. The  NovaTech  enterprise,  thus, was  a
pyramid  scheme  that  depended  on  the  recruitment  of  new  investors  or  new  investments  from
existing investors to fund the payouts of purported returns and commissions to existing investors.
Inevitably, the new  investments  NovaTech brought  in  could  not sustain  the  returns  and
commissions it  owed to existing  investors,  eventually leading  to  NovaTech’s collapse in  May
2023. Investors suffered pecuniary harm as a result of investing in NovaTech.

20

F. NovaTech  and  the  Petions  Made  False  and  Misleading  Statements  to  Investors  in
Furtherance of Their Fraudulent Scheme.
65. NovaTech  and  the  Petions  made  several false  and  misleading  statements  to
investors in furtherance of their fraudulent scheme. These misrepresentations created for investors
the false appearance that NovaTech and the Petions were operating a legitimate trading enterprise,
when in fact, NovaTech was a fraudulent and illegal pyramid scheme.  As alleged below, NovaTech
and the Petions made at least five categories of misstatements.
i. Misstatements regarding the use of assets invested by investors.

66. Throughout  the  Relevant  Period,  the  Petions  and  NovaTech  made  false  and
misleading statements to investors regarding how NovaTech used or would use the crypto assets
it received from investors. The following are examples of just some of these misrepresentations.
67. First, NovaTech’s Disclosure Document—which Cynthia Petion drafted and Eddy
Petion reviewed and participated in drafting, and which was made available to investors between
at least August 15, 2019 and May 2023—stated, in relevant part:
The investment objective of the Trading Advisor [NovaTech] is to achieve capital
appreciation  and  maximize  absolute  returns  for  ‘cryptocurrency’  trading  clients
using  the  Company’s  proprietary  trading  systems.  The  Trading  Advisor  seeks  to
trade in and out of cryptocurrencies achieving gains in the Client’s portfolio using
proprietary buy and sell trading signals it has developed.

68. Second, an affiliate PowerPoint  presentation  dated  January  2022  stated:  “LIVE
TRADING EXPERIENCE – We trade for you on the LIVE global Forex Market. Test your skills
on  our  Demo  Account  and  see  what  our  professional  traders  do  daily  to  ensure  your  financial
success!” Cynthia  Petion  drafted  this  presentation  and  Eddy  Petion participated  in  the  drafting
process.  NovaTech  posted  this  presentation  to  its  back  office  and  official  Telegram  channel
between January 2022 and May 2023, and NovaTech and/or its promoters gave the presentation
to investors and prospective investors at various times during this period.

21

69. Third, NovaTech’s  Compensation  Plan  dated  August  3,  2019  represented  to
investors  and  prospective  investors  that  trading  of  investors’  crypto  assets  deposited  with
NovaTech  commenced  “within  approximately  48–72  hours  of  initial  deposit.”  Cynthia  Petion
drafted this document and Eddy Petion participated in the drafting process. Between approximately
August  3,  2019  and  October  2020,  NovaTech  and  the  Petions  published  this  document  to
NovaTech’s  back  office,  where  investors  and  prospective  investors  accessed  and  reviewed  it.
NovaTech  updated  its  Compensation  Plan  in  October  2020.  In  the  Updated  Compensation  Plan
dated October 2020—described in paragraph 41 above—NovaTech represented to investors and
prospective investors that trading of investor crypto assets deposited with NovaTech commences
“within approximately 24–48 hours of initial deposit.” Cynthia Petion drafted this document and
Eddy Petion participated in the drafting process. Between approximately October 2020 and April
2023,  NovaTech  and  the  Petions  published  this  document  to  NovaTech’s  back  office,  where
investors and prospective investors accessed and reviewed it.
70. Fourth, in a March 25, 2020 WhatsApp message to prospective investors, Cynthia
Petion stated: “ We are trading your balances, anything we pay out is profit from those deposits.”
71. Fifth,  throughout  the  Relevant  Period,  NovaTech’s  website—which  the  Petions
controlled—stated: “What we pay out on Friday is a culmination of profits made from the trading
activity that took place during the week.”
72. Sixth, in a Zoom presentation on May 4, 2022 intended for prospective investors
and posted on YouTube, Cynthia Petion stated, “we’ve been able to return every penny to every
single user since we’ve started this program, and that’s because you give us the funds to trade, we
report only what we make, and the rest is still there trading.”

22

73. Seventh,  in  a  Zoom  presentation  on  June  23,  2022,  intended  for  prospective
investors and posted to YouTube, Eddy Petion stated: “ We don’t just hold your funds and hoping
for the market to do better. The funds are being actively traded. Up or down, we make money.”
74. Eighth, in almost-daily “opportunity calls” with prospective investors throughout
January–May 2023, two Promoter Defendants (Sampson and Hadley) presented a PowerPoint—
which Cynthia Petion approved—that stated “100% of your investment traded.”
75. As the Petions and NovaTech knew,  or were severely reckless in not knowing, these
statements were false, or at least misleading, at the time they were made. These statements created
the  false  and  misleading  impression  that  NovaTech:  traded  all  crypto  assets  received  from
investors,  did  so soon  after  those  assets  were  invested  (“within  approximately  24–48  hours  of
initial deposit”), and only reported and paid out the profits it generated from trading. As alleged in
paragraphs  57–64 above,  however,  NovaTech was  a  fraudulent  crypto  trading  investment  and
pyramid scheme, it traded only a fraction of the crypto assets that investors deposited, it reported
fabricated  returns  and  commissions,  and  it appears  to  have  paid  out  purported  returns  and
commissions to investors using new investments.
ii. Misstatements regarding NovaTech’s trading performance.

76. Throughout  the  Relevant  Period,  the  Petions  and  NovaTech  also made  false  and
misleading  statements  to  investors  regarding  the  supposed profitability  of  NovaTech’s  trading.
The following are examples of just some of these misrepresentations.
77. From at  least  October  2,  2020  through  November  22,  2022,  the  Petions  and
NovaTech posted to investors through the back office a “trading performance report” on a weekly
basis  reflecting  NovaTech’s  supposed  trading  performance  for  the  week.  During  this  period,
NovaTech reported weekly returns ranging from 0.65% to 4.20%, with an average weekly return

23

of 3.18%, and no week in which a loss was reported. During or around this period, NovaTech also
posted  the  same  information  on  its  official  Telegram  channel,  which  on  information  and  belief,
Cynthia Petion controlled.
78. Similarly,  in  a  March  26,  2020  WhatsApp  message  to  prospective  investors,
Cynthia  Petion  posted  a  chart  reflecting  NovaTech’s  purported  trading  performance  between
November 2019 and March 2020, which reflected average weekly profits of approximately 4.7%.
79. Throughout    the    Relevant    Period,    Cynthia    Petion    and NovaTech also
misrepresented investors’ account balances. As discussed in paragraph 61 above, these numbers
were manually generated by Cynthia Petion, who caused NovaTech to credit investors’ accounts
based on these fictitious returns.
80. As NovaTech and the Petions knew,  or were severely reckless in not knowing, these
statements were false and misleading at the time they were made.  Among other things—and as
alleged in detail, among other places, in paragraphs 57–64 above—the commissions and returns
reported to investors’ back-office accounts did not reflect NovaTech’s actual trading performance,
NovaTech’s trading was not profitable or at least not as profitable as represented to investors, and
the numbers reported to investors were fabricated. NovaTech was a fraudulent crypto investment
and  pyramid  scheme,  and  it  appears  to  have  paid  out  purported  returns  and  commissions  to
investors using new investments. NovaTech and the Petions knew or were severely reckless in not
knowing  these  facts,  among  other  reasons,  because  the  Petions  controlled  all  NovaTech
accounts/wallets,  controlled  the  commissions  and  returns  reported  to  investors’  back-office
accounts, and were aware of all of NovaTech’s trading activity, which was either reported to them
or conducted in accounts/wallets that they controlled.

24

iii. Misstatements regarding NovaTech’s legitimacy.

81. Throughout  the  Relevant  Period,  the  Petions  and  NovaTech  made  false  and
misleading  statements  to  investors  purporting  to  portray  NovaTech  as  a  legitimate  financial
services company. The following are examples of just some of these misrepresentations.
82. In  a  slide  deck  dated  October  2021 that  was  posted  to  the  back  office—which
Cynthia Petion drafted and Eddy Petion reviewed and participated in drafting—NovaTech stated
that it was a “[l]egally registered hedge fund.” On July 15, 2022, NovaTech repeated this statement
in a post published to investors on its Telegram channel, which the Petions controlled.
83. In a March 25, 2020 WhatsApp message to prospective investors, Cynthia Petion
stated that “[w]e are registered in USA as a hedge fund and money management company.” Eddy
Petion  sent  this  same  message  to  prospective  investors  via  WhatsApp  on  March  25,  2020.  In a
Zoom presentation on May 4, 2022, intended for prospective investors and posted on YouTube,
Cynthia Petion stated that, “ [i]n the United States, we’re registered as a hedge fund company.”
84. In a March 26, 2020 WhatsApp message to prospective investors, Cynthia Petion
represented that “[w]e are registered Brokers” at NovaTech.
85. As the Petions and NovaTech knew,  or were severely reckless in  not knowing, these
statements  were  false  at  the  time  they  were  made.  Neither  NovaTech  nor  the  Petions  were
registered with the SEC or with any regulatory authority in the United States as a “hedge fund,”
“money  management  company,”  investment  adviser,  broker,  or  dealer.   At a  minimum,  these
statements were highly misleading, because they created the false impression that NovaTech was
a legitimate financial services company that operated in compliance with U.S. laws and regulations
and under the oversight of U.S. regulators, when in fact, it operated as an unregistered entity and
a fraudulent crypto trading investment and pyramid scheme.

25

iv. Misstatements regarding the safety and security of the investment.

86. Throughout  the  Relevant  Period,  the  Petions  and  NovaTech  also  made  false  and
misleading  statements  to  investors  regarding  the  safety  and  security  of  their  investments  with
NovaTech. The following are examples of just some of these misrepresentations.
87. In the Updated  Compensation  Plan  dated  October  2020—described  in  paragraph
41 above—NovaTech and  the  Petions  claimed  that  investors  could  withdraw  their  assets  from
NovaTech at any time, and that such withdrawal requests would be processed within 24–48 hours
if  withdrawn  from  the  Trading  Account and  7–14  business  days  if  withdrawn  from  the  Bonus
Account.  Similarly, marketing decks made available to investors in the back office throughout the
Relevant  Period—including,  among  others,  a  January  2022  Affiliate  PowerPoint  presentation
further  described  in  paragraph  68 above  and  an  October  2021  slide  deck  further  described  in
paragraphs 40 and 82 above—contained the representation that there were “no withdrawal limits.”
88. In a Zoom presentation on May 5, 2022, which was posted to YouTube, Cynthia
Petion stated that, “[i]n this program, you’re in profit from day one, because again you have access
to that capital.”
89. As the Petions and NovaTech knew,  or were severely reckless in  not knowing, these
statements were false, or at least misleading, at the time they were made because they created for
investors  the  false  impression  that  NovaTech’s  disclosed  business  model  could  fund  investor
withdrawals  with  minimal  restrictions.  In  reality,  because  the  Petions  and  NovaTech  were  not
trading  enough  capital  and  were  not  generating  enough  profits  from  that  trading to  satisfy  the
weekly  returns  they  claimed  to  be  earning,  NovaTech’s  ability  to  satisfy  investor  withdrawal
requests   depended   on   its   continued   recruitment   of   new   investors   and   new   investments.
Consequently, NovaTech and the Petions did not have the capital to honor all withdrawal requests

26

as  promised  and  represented  to  investors.  Inevitably, their  representations  to  the  contrary  to
investors proved false when the new investments raised could not keep pace with the assets that
other investors sought to withdraw, eventually leading to the collapse of the scheme.
v. Misstatements in response to investor concerns.

90. In furtherance  of  the  fraudulent  scheme,  Cynthia  Petion  also  made  false  and
misleading  statements  to  assure  investors  that  the  withdrawal  issues  that  NovaTech  was
experiencing in late 2022 and early 2023 were not indicative of fraud. These misstatements helped
enable NovaTech  and  the  Petions  to  continue  operating  their  fraudulent  scheme  and  to bilk
investors of millions of dollars’ worth of additional crypto assets invested.
91. On February 28, 2023, a Promoter Defendant (Dunbar) posted to his Vimeo channel
a voice memo from Cynthia Petion intended for NovaTech investors and promoters. In the voice
memo, Cynthia Petion blamed delays in withdrawals on “everything going on in the market” and
system downtime due to the volume of investor deposits and withdrawals. She continued:
I wish I could give people the calmness that we ourselves feel internally knowing
that  things  are  under  control  and  improving  every  day.  .  .  .  No  business  allows
people to just withdraw huge sums of money at free will. It’s not our intention to
not give people their capital. However, people need to understand the nature of the
business. And if money is trading and everybody wants to panic and withdraw and
do everything else, it’s going to cause a backlog in doing so. Because we have to
forcibly close trades to release and that’s what we’ve been trying not to do. You
guys  have  seen  the  market  recently  whether  somebody’s  trading  or  not  trading,
whatever, there’s freezes going on all over the place. So we’re not doing anything
that’s not normal.

92. As Cynthia Petion knew or was severely reckless in not knowing, these statements
were false or misleading at the time they were made. Among other things, investors’ assets were
not tied up in trading as Cynthia Petion represented, because, as discussed, NovaTech deployed
only  a  small  percentage  of  investors’  assets  towards  trading.  As  Cynthia  Petion  knew  or  was
severely  reckless  in  not  knowing,  investors  experienced  issues  withdrawing  their  assets  from

27

NovaTech—not  because  assets  were  tied  up  in  trades  or  due  to  market  issues—but  primarily
because NovaTech was collapsing and lacked the assets to satisfy all investor withdrawal requests.
G. The Promoter Defendants Marketed NovaTech to Investors.
93. The Promoter Defendants—including Zizi, Corbett, Sampson, Dunbar, Garofano,
and  Hadley—played  a  critical  role  in  helping  the  Petions  distribute  the  NovaTech  investment
offering to investors. As further discussed below, the Promoter Defendants marketed and offered
the  NovaTech  investment  to  investors,  recruited  and  maintained  a  wide  network  of  “downline”
investors, many of whom became recruiters themselves and brought in additional investors, and
received substantial  commission  payments  and  bonuses  in  connection  with  their  efforts  to
distribute the NovaTech investment offering to investors.
i. The Promoter Defendants solicited investors to invest in NovaTech.

94. The Promoter Defendants rose to the highest ranks in the NovaTech MLM program,
including four “Two Star Ambassadors” (Zizi, Corbett, Garofano, and Sampson), and two “One
Star Ambassadors” (Dunbar and Hadley).
95. A  Two  Star  Ambassador  was  the  highest  of  nine  ranks  in  NovaTech’s  MLM
program  and  required,  among  other  things,  “group  volume”
1
  of  at  least  $100  million  in  crypto
assets invested by the promoter’s downline. A One Star Ambassador was the second highest rank
in NovaTech’s MLM program and required, among other things, “group volume” of at least $50
million in crypto assets. Aside from the commissions that promoters received from successfully
recruiting others to invest in NovaTech, promoters also stood to earn a “rank achievement bonus”

1
  As  used  by  NovaTech,  group  volume  referred  to  the  amount  of  crypto  assets  invested  by  a
promoter’s downline, including crypto assets that investors in the promoter’s downline contributed
or transferred to NovaTech and any purported trading profits or commissions that investors in the
promoter’s downline chose to “rollover” or reinvest.

28

for achieving the next highest promoter rank. For example, upon achieving the rank of Two Star
Ambassador,  a  promoter  earned  $100,000;  upon  achieving  the  rank  of  One  Star  Ambassador,  a
promoter earned $50,000.
96. As  further  described  below,  each  Promoter  Defendant:  (a)  received  commissions
and/or  other  transaction-based  compensation  from  NovaTech  for  successfully  recruiting  new
investors;  (b) regularly  participated  in  securities  transactions  for  NovaTech  at  key  points  in  the
chain  of  distribution;  (c)  provided  advice  to  NovaTech  investors  and  prospective  investors
regarding  the  merits  of  investing  and  reinvesting  in  NovaTech;  and  (d)  actively  marketed  and
promoted the NovaTech investment opportunity to investors and prospective investors.
a. Martin Zizi
97. Zizi was a Two Star Ambassador. He acted as a promoter for NovaTech between
approximately  October  2019  and  at  least  February  2023.  Before  NovaTech,  he  promoted  and
solicited  investors  for  at  least  two  other securities  issuers:  AWS  and  ZeekRewards.
2
  As  a
NovaTech  promoter,  Zizi  directly  recruited  at  least  30  investors  to  invest  in  NovaTech,  and  he
developed  and  maintained  a  downline  that  totaled  approximately  120,000  to  140,000  investors.
Though Zizi broadly promoted NovaTech, a significant number of investors whom he recruited
into NovaTech were from the Haitian-American community.
98. Zizi  promoted  NovaTech  through  email  and  his  personal  website  and  by,  among
other  means,  organizing  and  appearing  in  four  weekly  Zoom  sessions:  two  (in  English  and  in
Haitian Creole) aimed at recruiting new investors (“opportunity calls”) and two (one in English,
the other in Haitian Creole) aimed at training downline promoters to recruit investors (“training

2
 ZeekRewards was a fraudulent scheme that the SEC halted in 2012. See SEC v. Rex Venture
Grp., LLC d/b/a ZeekRewards.com, No. 3:12-cv-0519 (W.D.N.C. 2012).

29

calls”). Zizi also hosted multiple in-person events for his vast NovaTech downline to attend. For
example, in November 2022, Zizi hosted and was the keynote speaker at a NovaTech “Gratitude
Gala” in Orlando, and on January 21, 2023, he hosted another NovaTech gala in Atlanta. Through
these  efforts,  Zizi  solicited  existing  and  prospective  investors  to  invest  and/or  reinvest  in
NovaTech,  provided  advice  relating  to  investing  in  NovaTech,  made  statements  or  opinions
relating to the merits of investing and/or reinvesting in NovaTech, trained investors how to create
a NovaTech account, and answered investor questions.
99. Like  the  Petions,  Zizi  often  employed  religious  overtones  and  appealed  to  the
financial freedom and independence that investing in NovaTech purportedly offered investors. As
an  example,  in  a  video  presentation  posted  to  YouTube  and  dated  January  21,  2022,  Zizi  told
investors and prospective investors that the Petions are “the people that God g[a]ve the vision to
start this company.” During that presentation, he further advised:
And  it’s  very  difficult  to  make  a  decision  to  take  a  little  bit  of  your  hard-earned
money,  and  this  is  why  I  make  you  comfortable  in  a  sense  that  with  NovaTech,
there are different levels. And Pastor Bob just shows you that you could start as low
as $500 all the way down to a million bucks. It’s based on where you are at and
how  comfortable  you  are.  Now,  we  do  know  there  are  some  people  are  going
through  some  financial  struggle  that  probably  lost  their  job  during  the  pandemic
and are looking for a solid way to improve their financial wellbeing. Based on our
experience with the owners of the company and with the robots who’s been blessing
us for the past 28 going on 29 months, we feel comfortable presenting this project
as a way that will change our lives.

100. As another example, in a January 3, 2021 video presentation posted to YouTube,
Zizi told investors and prospective investors of NovaTech:
You need to take ten percent of your paycheck and get that ten percent to work for
you, and that’s the term, and I got it really right from the book when we talk about
having your money making babies for you. Find a vehicle that can grow that ten
percent  over  and  over.  Find  a  vehicle,  do  you—and  we  find  a  vehicle.  Now,  we
have to fund multiple vehicles, but we have one solid one which you are sitting on
right now which is NovaTech, and having that vehicle spilling out money for you.
One key thing is said in that lecture was that you have to make sure that the vehicle

30

that you are using, the person or the director of that vehicle know well about money.
They  know  how  to  have  money  work  for  you.  .  .  .  Now,  it’s  said  in  the  book  a
minimum of ten percent. So, you’ve got to take ten percent of your money and have
it work for you, and you already know how it’s going to work for you by putting it
in your trading account, and once you have that done, the second – the third step is
for you to take the babies of the money that is making for you, and then put those
babies back to work where we get compound interest, having money working for
you, making babies every single week.

b. James Corbett
101. Corbett  was  a  Two  Star  Ambassador.  He  acted  as  a  promoter  for  NovaTech
between approximately August 2020 and February 2023. Corbett was a top AWS promoter that
Cynthia Petion directly recruited to NovaTech. He has promoted and solicited investors for at least
one  other  dubious  securities  issuer  that  operated  an  MLM  program:  AWS.  As  a  NovaTech
promoter, Corbett directly solicited and sponsored at least 21 investors to invest in NovaTech, and
he developed and maintained a downline at NovaTech that totaled approximately 80,000 investors.
Corbett aggressively promoted NovaTech and recruited investors through weekly Zoom meetings,
which he promoted on social media, as well as through his personal website. Through these efforts,
Corbett  solicited  existing  and  prospective  investors  to  invest  and/or  reinvest  in  NovaTech,
provided advice relating to investing in NovaTech, and made statements or opinions relating to
the  merits  of  investing  and/or  reinvesting  in  NovaTech.  At  the  end  of  his  Zoom  meetings  with
investors  and  prospective  investors,  Corbett  would  typically  hold  a  Q&A  session  where  he
answered investor questions.
102. As  an  example,  in  a  May  12,  2022  video  presentation  that  Corbett  titled  “Why
NovaTech is the BEST Opportunity, by Global Ambassador James Corbett,” Corbett told investors
and  prospective  investors:  “NovaTech  was,  simply  put,  designed  for  the  common  man  to  be
successful  at.”  In a  video  presentation  to  NovaTech investors  and  prospective  investors  dated

31

February 19, 2022, Corbett opined: “A thousand dollars for one year, you can turn into $5,410.”
He further assured investors and prospective investors:
So look at this, and don’t be scared because you’ve finally found a place that not
only are you going to see it’s very easy, extremely easy to use, you don’t need to
go to college to learn how to do NovaTech. You sit down with a leader for an hour
and you’ll know -- not even an hour -- half-an-hour --    and you’ll know the basics
on how to be successful in this program. I mean it doesn’t take a big learning curve.
But try to give yourself a week or two to at least understand it, right?

c. John Garofano
103. Garofano  was  a  Two  Star  Ambassador.  He  acted  as  a  promoter  for  NovaTech
between  approximately  January  2021  and  February  2023.  As  a  NovaTech  promoter,  Garofano
directly solicited and sponsored at least 12 investors to invest in NovaTech, and he developed and
maintained  a  downline  of  investors  who  collectively  invested  and/or  reinvested  at  least  $100
million  in  crypto  assets  into  NovaTech.  Garofano  worked  closely  with  Corbett,  who  recruited
Garofano to  invest  in  and  join  NovaTech.  Like  Corbett,  Garofano  aggressively  promoted
NovaTech  and  recruited  investors  through  weekly  Zoom  meetings.  Through  these  efforts,
Garofano  solicited  existing  and  prospective  investors  to  invest  and/or  reinvest  in  NovaTech,
provided advice relating to investing in NovaTech, and made statements or opinions relating to
the merits of investing and/or reinvesting in NovaTech. At the end of his Zoom meetings, he (along
with Corbett) typically held a Q&A session where he answered investor questions.
104. As  an  example,  in  a  video  presentation  titled  “NovaTech  PAMM  Account
Presentation_Earn Passive Income” and uploaded to Vimeo on or about July 2, 2022, Garofano
advised investors and prospective investors, among other things:
There’s no skills required to trade unlike other platforms....

The  company  provides  customers  with  affordable  financial  solutions  including
trading the trading of cryptocurrencies and forex online and some of the using some
of the most sophisticated technologies like MetaTrader platform....

32

 [O]ne of the deepest liquidity pools in the industry....

They’re using professional software and professional management team....

Really like a mutual fund....

NovaTech has expert traders....

About 70-80% profit wins on their trades....

So it’s not tied up in any contract if I’ve done contracts before with other type of
investments, especially with mining cryptocurrency mining if you’re familiar with
that and that’s locked up, you can’t you don’t have access to it. Once you invest
with NovaTech, you have a hundred percent access at all times to your balances.
What I do recommend, this is what I do.  I teach this or explain this to my people I
get  in  is,  you  know,  add  a  little  bit  more  each  month  or  each  week  or  every  pay
period or when you can because you really want to get these balances up a little bit
more towards the bronze the silver area [referring to investment packages] to make
it really worthwhile....

d. Corrie Sampson
105. Sampson  was  a  Two  Star  Ambassador.  She  acted  as  a  promoter  for  NovaTech
between  approximately  July  2021  and  June  2023.  She  co-founded  “Team  Diamond,”  the  brand
under  which  she  promoted  NovaTech.  Sampson  directly  solicited  and  sponsored  approximately
35–40 investors and had over 50,000 investors in her downline. Sampson aggressively promoted
NovaTech primarily through weekly Zoom meetings, as well as through phone, text message, and
Telegram. Certain Team Diamond Zoom presentations were recorded and then posted to YouTube.
On  April  17,  2022,  Sampson  was  one  of  three  women  who  joined  Cynthia  Petion  in  a  “Boss
Ladies” Zoom webinar that was open to the public and during which Sampson described, among
other things, how she had been successful in building Team Diamond. Through these and other
efforts,  Sampson  solicited  existing  and  prospective  investors  to  invest  and/or  reinvest  in
NovaTech,  provided  advice  relating  to  investing  in  NovaTech,  made  statements  or  opinions

33

relating to the merits of investing and/or reinvesting in NovaTech, trained and assisted investors
on how to create an account, and answered investor questions.
106. As  an  example,  in  a  February  21,  2022  video  presentation,  Sampson  advised
investors and prospective investors of NovaTech: “This will change your lives, not just for you
but for generations to come. We are able to create generational wealth here, family. You want to
leave a legacy, get started. Get started right away.” Similarly, in her weekly Zoom presentations,
Sampson often used an online compound interest calculator to demonstrate how much investors
stood to earn based on NovaTech’s purported trading results.
e. Dapilinu (“Dap”) Dunbar
107. Dunbar was a One Star Ambassador. He acted as a promoter for NovaTech between
approximately September 2021 and May 2023. He has promoted and/or been involved in at least
30 other network marketing businesses that focus on crypto assets. As a NovaTech promoter, he
directly solicited and sponsored at least 110 investors to invest in NovaTech, and he developed
and  maintained  a  downline  of  at  least  10,000  investors.  Dunbar,  who  Hadley  recruited  into
NovaTech,  was  a  member  of  Team  Diamond,  and  frequently  appeared  as  a  presenter  in  Team
Diamond’s  weekly  Zoom  presentations  to  prospective  investors.  Dunbar  aggressively recruited
investors  through  Telegram,  Zoom  meetings,  and  videos  he  posted  on  a  Vimeo  channel  he
operated.  Dunbar  used  his Vimeo  channel  to  promote  NovaTech  and  provide  updates  to  his
downline. Through these and other efforts, Dunbar solicited existing and prospective investors to
invest  and/or  reinvest  in  NovaTech,  provided  advice  relating  to  investing  in  NovaTech,  made
statements or opinions relating to the merits of investing and/or reinvesting in NovaTech, trained
investors on how to create an account, and answered investor questions. On occasion, Dunbar also
represented to investors and prospective investors that he was assisting NovaTech with clearing

34

tech support tickets submitted by investors in order to minimize the delays in processing investors’
withdrawal requests.
108. In January 2023, Dunbar emceed NovaTech’s “New Year’s” live YouTube webinar
that featured Cynthia Petion and had over 4,000 viewers. As another example, in a YouTube video
posted on April 2, 2023, Dunbar advised investors and prospective investors about “seven ways
that  NovaTech  will  pay  you.”  He  further  advised  about  how  NovaTech  worked,  its  alleged
profitability, and how investors could make money by investing in NovaTech. And in the course
of  promoting  NovaTech,  Dunbar  further  advised  prospective  investors  about  the  merits  of
obtaining investment exposure to crypto asset markets through NovaTech:
[T]he crypto market is where you want to be, okay? Do not let the outside voices
distract you from the potential of what you can earn.... And with that being said,
guys, your future, freedom, and dreams start right now. Dream big.... Guys, I’m
telling  you,  build  your  future,  guys,  alright?  Use  Bitcoin.  Stack  your  Bitcoin....
Retirement  is  going  away.  If  you  are  in  the  U.S.,  Social  Security  is  going  away.
There are going to be other ways for you to secure your future. And I’m telling you
this just happens to be one of those ways.

f. Marsha Hadley
109. Hadley was  a  One  Star  Ambassador.  She  acted  as  a  promoter  for  NovaTech
between approximately 2021 and June 2023. On information and belief, she directly solicited and
sponsored  investors  to  invest  in  NovaTech,  including  Dunbar.  And  her  rank  as  a  One  Star
Ambassador implies that she developed and maintained a downline of investors at NovaTech who
collectively invested and/or reinvested at least $50 million in crypto assets into NovaTech.
3
 Hadley
also  co-founded  Team  Diamond  with  Sampson.  Like  Sampson,  Hadley  used  Zoom,  Telegram,
WhatsApp, and YouTube to aggressively promote NovaTech and recruit investors. Through these

3
 As explained in footnote 1 above, this $50 million could include investments of newly
contributed crypto assets, plus any purported trading profits or commissions that investors in
Hadley’s downline chose to “rollover.”

35

and other efforts, Hadley solicited existing and prospective investors to invest and/or reinvest in
NovaTech, provided advice relating to investing in NovaTech, and made statements or opinions
relating to the merits of investing and/or reinvesting in NovaTech.
110. As  an  example,  in  a  February  21,  2022  video  presentation  to  investors  and
prospective investors of NovaTech, Hadley stated:
Those of you that’s in the stock market, stocks were going down, down, down, like
crazy.  Cryptocurrency  was  going  down,  down,  down  like  crazy.  And  then  as  we
look at it, we still came out on top. NovaTech, we had a 1.85 percent profit? Okay.
Sign  me  up,  all  day,  every  day.  So  why  is  NovaTech  different,  ladies  and
gentlemen? ...

Number one, no expiration date and no earning caps. We can earn whatever you
want to earn for yourself and your family, the company says we don’t want to limit
anyone. Whatever your desires are that you need to come in every month in profits,
have at it. You can trade as long as you want, no repurchase requirements. And we
can  cancel  at  any  time.  So  I  was  talking  to  the  cofounder  of  our  team,  Corrie  J.,
right? Call her Corrie J. bad to the bone Sampson, I said, Corrie J., wait a second,
so  we’re  not  doing  any  trading  at  all;  we  don’t  have  to  have  any  knowledge  of
cryptocurrency  or  trading.  The  experts  is  doing  everything.  We  get  paid  every
Friday. Who would want to cancel?

ii. The Promoter Defendants were compensated for soliciting investors.

111. Each  Promoter  Defendant  received  commissions  from  NovaTech  for  recruiting
new  investors  and  for  raising  crypto  asset  investments  in  NovaTech.  The  Promoter  Defendants
received  these  commissions  pursuant  to  NovaTech’s  MLM  compensation  structure,  which  the
Petions designed, implemented, and operated.
112. NovaTech’s MLM compensation structure provided substantial incentives for the
Promoter Defendants and other promoters to recruit new investors. For example, by recruiting a
“direct  referral,”  i.e.,  a  person  directly  sponsored  by  a  promoter  and  thus  positioned  one  level
below that promoter in the downline, such a promoter stood to be paid: (i) 1% to 5% of the direct
referral’s investment (the “direct referral bonus”); (ii) 0.5% to 5% of the direct referral bonuses

36

earned by any recruits up to seven levels down in the promoter’s downline; (iii) 0.25% to 5% of
the trading “profit” paid to recruits up to nine levels down in the promoter’s downline; (iv) 0.25%
to 5% of the service fees paid by recruits up to nine levels down in the promoter’s downline; and
(v) additional “fast track” and “rank achievement” bonuses that incentivized quickly recruiting a
large downline.
113. NovaTech  referred  to  this  complicated  compensation  structure  as  “7  ways  to  get
paid.” NovaTech promoted this heavily, including in the marketing slide deck that Cynthia Petion
prepared (a slide from which is depicted below) and which was made available to investors in the
back office. Each of these “7 ways to get paid” resulted in transaction-based compensation being
paid to each Promoter Defendant and other promoters at NovaTech to incentivize them to bring
additional investors and/or investments into NovaTech.

114. Ultimately,   each   Promoter   Defendant   received   commissions   and/or   other
transaction-based  compensation  pursuant  to  NovaTech’s  Compensation  Plan  and/or  Updated
Compensation Plan (together, the “Compensation Plans”), which are further detailed in paragraph

37

84   above.   Given   the   significant   commissions   they   were   credited   through   NovaTech’s
Compensation  Plans,  the  Promoter  Defendants  were  able  to  withdraw  significant  compensation
from  NovaTech  in  comparison  to  the  amount  of  crypto  assets  they  invested.  Zizi,  Sampson,
Garofano, Dunbar, and Corbett each withdrew more than the amount each invested in NovaTech.
On information and belief, Hadley also withdrew more than she invested.
H. Four Promoter Defendants Engaged in Deceptive Acts in Furtherance of NovaTech’s
Fraudulent Scheme in the Face of Red Flags.
115. Four of the Promoter Defendants—Zizi, Corbett, Dunbar, and Sampson—became
aware of red flags putting them on notice that NovaTech was not a legitimate investment program.
These Promoter Defendants faced a choice: cease promoting NovaTech in light of the alarming
information  they  knew  or  follow  the  strong  financial  motivations  they  had  under  NovaTech’s
Compensation Plans to ignore the red flags and continue to promote NovaTech. Each of these four
Promoter Defendants chose the latter. In the face of the red flags, they continued to promote and
support  the  Petions  and  NovaTech’s  fraudulent  scheme  and  engaged  in  other  deceptive  acts  in
furtherance of the scheme. In doing so, they helped create the false impression that NovaTech was
a legitimate investment opportunity, when, in fact, it was on the brink of collapse. These Promoter
Defendants, thus, helped the Petions and NovaTech continue operating, recruiting promoters, and
raising new investments from unwitting investors.
i. Zizi engaged in conduct in furtherance of the fraudulent scheme.

116. Zizi became aware of the Canadian province fraud warnings at or around the time
they were issued in October 2022. He became aware of the California Order at or around the time
it was issued on November 22, 2022. And he became aware of the delays and pause in withdrawals
at or around the time they occurred in November 2022 and early 2023.

38

117. Zizi testified that Cynthia Petion told him that there were times when NovaTech
was not profitable, and that when reporting trading results, she used profits from other profitable
weeks to avoid reporting a loss or lower profit in the weekly ROI figures.
118. Despite serving in a role where he advised investors and prospective investors about
the  merits  of  the  NovaTech  investment,  Zizi  did  not  adequately  investigate  these  red  flags.  In
regard  to  the  Canadian  province  fraud  warnings  and  California  Order,  for  example,  Zizi  did
nothing more than take Cynthia Petion at her word that “legal is on top of it.”
119. In  the  face  of  these  red  flags,  Zizi  at  least  negligently  continued  to  promote  and
solicit investors for NovaTech. Indeed, Zizi continued to promote NovaTech and solicit investors
for  NovaTech  until  at  least  February  2023.  He  testified  that  he  continued  holding  NovaTech
opportunity  calls,  aimed  at  recruiting  new  prospective  investors  to  invest  in  NovaTech,  until
February 2023, and that he continued to use his personal marketing website to promote NovaTech
until February or March of 2023. He also testified that he continued doing training webinars with
NovaTech investors until April or May of 2023.
120. After becoming aware of the facts referenced in paragraph 117 above, Zizi failed
to disclose this material information about how Cynthia calculated and reported the weekly ROI
numbers to investors. Acting as an unregistered broker, Zizi provided advice to investors about the
merits  of  investing  in  NovaTech  and  held  himself  out  as  having  special  insight  and  knowledge
about  NovaTech  through  his  relationship  with  the  Petions.  He  used  this  position  to  market  and
promote NovaTech, encourage investors to invest, and advise investors about investing.
121. In addition, Zizi testified that he generally told investors, in presentations to and/or
communications with investors throughout the Relevant Period, that the ROI varied every week
based  on  how  NovaTech  performed.  On  information  and  belief,  Zizi  was  aware  of  the  facts

39

referenced in paragraph 117 above at the time of at least some of the instances in which he made
this representation to investors, but he failed to disclose this material information to investors at
that time or in subsequent communications with investors.
122. Zizi also actively sought to either discredit or undermine the California Order. For
example,  in  a  WhatsApp  chat  with  a  group  of  high-level  NovaTech  promoters  (who  also  were
investors),  Zizi  sent  a  message  on  or  about  November  27,  2022  that  discredited  the  California
Order  on  the  basis  that  it  was  unsigned.  Zizi  also  testified  that,  on  unspecified  dates,  he  told
California investors to circumvent the California Order by forming a Wyoming limited liability
company and opening an account in that entity’s name.
123. Zizi  had  financial  motivations  to  ignore  the  red  flags  and  continue  to  promote
NovaTech. Zizi continued to benefit from investors joining or reinvesting in NovaTech. Zizi’s last
known direct recruit that he solicited and sponsored invested in NovaTech on or about January 4,
2023. On information and belief, Zizi’s downline of investors continued to invest and/or reinvest
in  NovaTech,  as  well  as  solicit  and  sponsor  new  investors,  until  NovaTech  shut  down  its  U.S.
operations in May 2023. Zizi also continued to make withdrawals from NovaTech after becoming
aware of the red flags through at least the beginning of 2023.
ii. Corbett engaged in conduct in furtherance of the fraudulent scheme.

124. Through his experience with AWS, Corbett was aware of the signs of a fraudulent
MLM crypto  asset  investment  program.  For  example,  he  knew  that  investors  in  AWS  suffered
losses after AWS paused or delayed investor withdrawals and the TSSB issued a cease-and-desist
order finding that AWS violated Texas securities laws.
125. After signing  up  to  promote  NovaTech’s  program,  Corbett  became  aware  of
allegations made against NovaTech. As early as August 2020, for example, Corbett was aware of

40

social media posts in the MLM space accusing NovaTech of being a scam or Ponzi scheme, which
he affirmatively attempted to refute through his own comments and posts online.  For example, on
or  around  August  25,  2020,  Corbett  posted a  comment to  an  online  article  published on
BehindMLM.com,  a  website  that  purports  to  be  a  “resource  to  people  curious  about  the  MLM
industry and the companies that exist within it.”
4
 In response to other posts and comments to the
article that questioned the legitimacy of NovaTech, Corbett wrote:
Like the opinion editor and Not a real reporter you give us your opinion without
talking  to  whom  your  [sic] bashing.  I  know  for  a  fact  you  did  Bias  research  on
Nova.  Tell me what slim [sic] gave you your info? I was in AWS for 3 years and
can assure everyone Cynthia was NEVER a [sic] owner. All she ever did is try and
help  everyone.  Nova  tech  was  developed  to  clear  Cynthia’s  name.  I  can  tell  you
this she will stop at nothing to prove you wrong. As for the slime who paid you to
post this FALSE evaluation, I suspect he lost money (who hasn’t lost money?)....
Sincerely James Corbett Servant leader.

126. As another example, in January 2021, Corbett received an email from a prospective
investor asking: “[h]ow do we know that real trading takes place and this is not just a Ponzi using
new money to pay old?” Corbett testified that this was a question he heard “quite frequently” while
promoting NovaTech.
127. Corbett also became aware of the Canadian province fraud warnings at or around
the time they were issued in October 2022. He became aware of the California Order at or around
the time it was issued on November 22, 2022. And he became aware of the delays and pause in
withdrawals at or around the time they occurred in November 2022 and early 2023. These were
the same or similar red flags as were present at AWS before its collapse.
128. Corbett  was  also  aware  that  the  crypto  asset  markets  fluctuated  throughout  the
Relevant Period, with various times where crypto assets that NovaTech purported to trade dropped

4
 “About BehindMLM,” https://behindmlm.com/about/ (last visited Aug. 7, 2024).

41

in value. Yet, as Corbett knew, NovaTech purported to report weekly trading profits throughout
the Relevant Period.
129. The  red  flags  discussed  in  paragraphs  124–128  above  put  Corbett on  notice  that
NovaTech was not a legitimate investment program, was defrauding investors, and/or was making
false or misleading statements or omissions to investors. Despite serving in a role where he advised
investors  and  prospective  investors  about  the  merits  of  the  NovaTech  investment  and  holding
himself  out  as  having  special  knowledge  and  insight  into  NovaTech,  Corbett  did  nothing  to
independently  investigate  these  red  flags  or  allegations  levied  against  NovaTech.  For  example,
Corbett  testified  that  he  regularly  asked  Cynthia  Petion  for  additional  information  about
NovaTech’s  trading,  including  as  early  as  January  2021,  but  she  refused  to  provide  it.  He  also
testified that he did nothing to investigate the California Order aside from asking Cynthia Petion
about it, who merely told him the Order was not final and had not been served on NovaTech yet.
He did not even bother to search online for the Order.
130. Well  after  learning  of  these  red  flags,  Corbett continued  to  promote  and  solicit
investors for NovaTech through at least May 2023.  He also continued to support NovaTech in the
face of red flags indicating that it was not operating as a legitimate investment program.
131. For example, Corbett continued to promote NovaTech on his personal website until
at  least  June  2023.  Corbett  also  continued  to  advise  and  support  his  downline  of  NovaTech
investors until at least May 2023. In December 2022, for instance, he sent a WhatsApp message
to other NovaTech leaders discussing how his “group” in the Canadian provinces where the fraud
warnings were issued “has about 1700 members and was hoping to leave [their investments] in
unless they are told to withdraw.” He further wrote: “[t]he way Im [sic] reading this is if they are
not asked to withdraw and close account then they can still trade.” On information and belief, he

42

subsequently  advised  at  least  some  of  these  investors  about  keeping  their  investments  in
NovaTech.
132. As  another  example,  in  early  January  2023,  Corbett  participated  in  a  recorded
interview with a YouTuber who runs the channel “Ponzi Patrol.” The interview was conducted via
Zoom and was posted to the Ponzi Patrol YouTube channel on or about January 11, 2023. Corbett
knew that the interview was recorded,  would be posted online to the general public, and would
address allegations that NovaTech was a Ponzi scheme.
133. In the interview, Corbett held himself out as having a close relationship with the
Petions and denied that NovaTech was a Ponzi scheme. He also addressed allegations and investor
concerns  relating  to  NovaTech,  including  concerns  over  delayed  withdrawals,  the  Canadian
province  fraud  warnings,  and  the  California  Order.  The  following  are  examples  of  some  of  the
statements that Corbett made during the interview:
I’ve been defending NovaTech for four years. I traveled the world with these people
the three prior years. I know the development and what happened, and what they
did to develop NovaTech. I know the trading and the board meetings and how they
go --    went about, and the story of how they opened up, and why they even opened
up a trading certificate....
...
First  of  all,  California,  they  can  still  trade  on  this  platform.  They  haven’t  been
stopped from trading. They’re still running their things....Canada is shutting down
there, but – but think about what you’re saying. They’re paying back everybody in
Canada that was trading on their platforms, and it’s going on right now.
....
They’re  not  a  Ponzi  scheme,  because  I  know  that  they’re  not  running  a  Ponzi
scheme.  I  know  these  people.  I  know  they’re  trading  with  the  funds  that
they’re...receiving....

134. Corbett did not “know that they’re not running a Ponzi scheme.”  He did not know
what,  if  any,  trading  NovaTech  actually  did.  His  statements  further  sought  to  refute  or  quell
investor  concerns  about the  regulatory  scrutiny and  withdrawal  issues  that  NovaTech  was
experiencing at the time, even though he lacked direct knowledge or evidence to say, for example,

43

that  NovaTech  was  “paying  back  everybody  in  Canada.”   His  statements  created  the  false  and
misleading impression that NovaTech was a legitimate investment program and that the issues it
faced  would  pass  and/or  not  prevent  investors  from  recouping  their  investments.  And  he  made
these statements despite being aware of the red flags, acting as an unregistered broker to investors,
and holding himself out to investors as having a special relationship and access to NovaTech and
its founders and special insight into and knowledge of NovaTech’s operations.
135. Individuals  continued  to  invest  and/or  reinvest  in  NovaTech following Corbett’s
deceptive acts and his awareness of the red flags. On information and belief, Corbett’s downline
of investors continued to invest and/or reinvest in NovaTech, as well as solicit and sponsor new
investors, until NovaTech shut down its U.S. operations in May 2023.
iii. Dunbar and Sampson engaged in conduct in furtherance of the fraudulent
scheme.

136. Sampson and Dunbar, who together promoted NovaTech as part of Team Diamond,
became aware of the Canadian province fraud warnings at or around the time they were issued in
October 2022. They also became aware of the California Order at or around the time it was issued
on  November  22,  2022.  And  they  became  aware  of  the  delays  and  pause  in  withdrawals  at  or
around the time they occurred in November 2022 and early 2023. These red flags put Sampson
and  Dunbar  on  notice  that  NovaTech  was  not  a  legitimate  investment  program,  was  defrauding
investors,  and/or  was  making  false  or  misleading  statements  or  omissions  to  investors.  Indeed,
Dunbar  testified  that  he  knew,  based  on  his  experience  with  other  failed  crypto  and  MLM
programs, that one sign that an MLM and/or crypto company is on the verge of collapse is when
the company stops paying out as often as it previously did.
137. Despite  serving  in  a  role  where  they advised  investors  and  prospective  investors
about the merits of the NovaTech investment, Sampson and Dunbar did nothing to independently

44

investigate these red flags. Sampson even testified that she took no steps to determine whether the
California Order was legitimate.
138. Dunbar and Sampson continued to promote and solicit investors for NovaTech well
after becoming aware of the red flags. Specifically, they both continued to promote NovaTech and
appear on NovaTech promotional Zoom meetings until at least May 2023.
139. Sampson and Dunbar also sought to discredit or undermine the California Order.
For  example,  in  a  video  presentation  hosted  by  Sampson  and  posted  to  the  Team  Diamond
Telegram channel on or about May 20, 2023, Dunbar stated:
[W]e allowed a person, not a state . . . a person who filed a cease and refrain that
meant  diddlysquat  to  scare  hundreds  of  thousands  of  people  into  thinking
NovaTech  was  going  away  because  they  got  a  cease  and  refrain  in  California.
Never  got  signed  by  anyone  in  California.
5
  It  was  like  you  going  and  putting  a
restraining order on someone by filing documentation and paying $89.

140. At  the  end  of  Dunbar’s  rant  seeking  to  discredit  the  California  Order,  Sampson
stated her agreement with Dunbar’s description of the California Order. She did so in her trusted
position as the cofounder and leader of Team Diamond, to whom Dunbar directed his comments.
141. Dunbar and Sampson also sought to undermine and quell investor concerns about
withdrawal  issues  and  encourage  and  advise  investors  and  prospective  investors  to  invest  in
NovaTech in spite of the red flags.
142. For example, in or around March or April 2023, Dunbar posted a video “short” to
his BTGi
6
 Telegram chat, which was subsequently posted to YouTube on or about May 29, 2023,

5
 The version of the California Order that was posted to the website of the California Department
of Financial Protection and Innovation (“DFPI”) was/is unsigned, like other orders posted to
DFPI’s website, consistent with DFPI’s policy of not publicly posting signed orders to avoid
issues with forged/copied signatures.
6
 “BTGi” is shorthand for “Bridging the Gap Internationally,” an acronym that Dunbar used on
social media and online.

45

titled  “Novatechfx.  Dap  [Dunbar]  and  the  CEO  working  on  efficiency  of  the  payouts.  Listen”,
where he appears with Cynthia Petion in  what appears to be Panama. In this video, Dunbar claimed
to  be  helping  resolve  support  tickets  so  that  NovaTech  could  resume  processing  investors’
withdrawal requests. On February 28, 2023, he posted to his Vimeo account a voice memo from
Cynthia Petion, in which she blamed   withdrawal delays on assets tied up in trades, technical issues,
and market factors. Dunbar’s statements and actions created the false and misleading impression
that the investors’ withdrawal issues would soon be resolved and were not cause for alarm.
143. Likewise, Sampson sought to allay investor concerns over NovaTech’s withdrawal
issues.  In  her May  20,  2023  video  posted  to  the  Team  Diamond  Telegram  channel,  Sampson
advised investors to “just hang in there as long as we possibly need to.” She also advised: “[w]e’re
gonna get paid again, y’all, and it won’t be long. I don’t know. No one told me that. That’s my
thought, and it’s also my prayer.”
144. In  that  same  May  20,  2023  video,  Dunbar  and  Sampson  continued  to  promote
NovaTech and advise investors and prospective investors to believe and invest in NovaTech:
MR. DUNBAR: NovaTech is who we all believe in, and NovaTech is who we’re
all going to continue to believe in until we have no reason to, and at this point we
have every reason –

MS. SAMPSON: Every reason

MR. DUNBAR: -- to believe. All right? So --

MS. SAMPSON: Praise the lord.

MR. DUNBAR: Queen, I’m going to go ahead and let you go for now, and then
we’ll continue and dive and unpack a little more for that. So --

MS. SAMPSON: All right, young king. Well, I sure appreciate you letting me do
that. You know? (Laughing) Good information there, baby, and just a good strong
mindset. You know, it’s what it is that -- you know, that we need. It’s information
that we need to hear, it’s very strong, it’s very powerful. And if you really embellish
and take that in it really and truly can be lifesaving.

46

145. Dunbar and Sampson had strong financial motivations for willfully ignoring the red
flags and continuing to promote NovaTech. For example, Sampson reached the rank of Two Star
Ambassador on January 25, 2023, which earned her a bonus of $100,000. And despite advising
investors to “just hang in there,” Sampson privately began withdrawing heavily from NovaTech
starting on January 2, 2023, and continuing through March 2023, during which time she ultimately
withdrew  nearly  $1  million  in  crypto  assets  from  NovaTech.  Likewise,  Dunbar  continued  to
withdraw from NovaTech until as late as March or April 2023.
146. Dunbar  and  Sampson  also discouraged  investors  from  contacting  regulators  or
government  authorities  about  NovaTech. In  a  video  posted  to  his  Vimeo  channel  in  May  2023
(which also became available on YouTube), Dunbar stated:
Let me tell you guys, some of you saying, “I’m gonna call the SEC, I’m gonna call
the CFTC.” Go ahead and call and see if everybody doesn’t lose their money. No
institution higher up wants to see people win. We have to protect what we have and
we do that by being patient.

147. In  a  YouTube  live  stream  interview  on  May  16,  2023  that  received  over  9,000
views, Dunbar admonished concerned investors: “[t]he more negativity you put out there, the more
at risk our funds are.”
148. Like  Dunbar,  Sampson  also  discouraged  at  least  one  concerned  investor  from
contacting the SEC. During a call with the investor in January 2023, the investor asked Sampson
if  they   could share her contact information with the SEC. Sampson refused and responded: “[w]hy
would you do that? Why would you share our information with a government agency? Because
you  haven’t  been  able  to  get  your  withdrawals?  Just  like  others  have  not  been  able  to  get  their
withdrawals? Are you doing it out of spite? Out of spite?”

47

149. Individuals  continued  to  invest  and/or  reinvest  in  NovaTech’s  scheme  following
Sampson’s and Dunbar’s deceptive acts and their awareness of the red flags. And Sampson and
Dunbar continued to benefit from the same. Based on the information available at this time, at least
two of Dunbar’s direct recruits invested in NovaTech after November 2022. Although Sampson’s
last  known  direct  recruit  invested  in  NovaTech  on  or  around  November  15,  2022,  she  was
promoted to Two Star Ambassador on January 25, 2023, which, according to NovaTech’s terms,
means that her downline investors continued to invest and reinvest after November 2022 to allow
her to cross the $100 million threshold to reach the rank of Two Star Ambassador in January 2023.
On  information  and  belief,  Sampson’s  and  Dunbar’s  respective  downlines continued  to  invest
and/or reinvest in NovaTech, as well as solicit and sponsor new investors, until NovaTech shut
down its U.S. operations in May 2023.
V. CLAIMS FOR RELIEF
FIRST CLAIM FOR RELIEF
Violations of Section 17(a)(1) of the Securities Act
[15 U.S.C. § 77q(a)(1)]
(Against NovaTech, the Petions, Corbett, Dunbar, and Sampson)
150. The  SEC  re-alleges  and  incorporates  paragraphs  1–149  above by  reference  as  if
fully set forth hereunder.
151. By engaging in the conduct described herein, and as alleged in paragraphs 23–92
above, the Petions and NovaTech, and as alleged in paragraphs 115–149 above, Corbett, Dunbar,
and Sampson, directly or indirectly, in the offer or sale of securities, by the use of the means or

48

instruments of transportation or communication in interstate commerce or by use of the mails, have
employed a device, scheme, or artifice to defraud.
152. With regard to the violations of Section 17(a)(1) of the Securities Act, Defendants
NovaTech,  the  Petions,  Corbett,  Dunbar,  and  Sampson  acted  with  scienter  and  engaged  in  the
referenced acts knowingly and/or with severe recklessness.
153. By reason of the foregoing, Defendants NovaTech, the Petions, Corbett, Dunbar,
and Sampson have violated, and unless enjoined will continue to violate, Section 17(a)(1) of the
Securities Act [15 U.S.C. § 77q(a)(1)].
SECOND CLAIM FOR RELIEF
Violations of Section 17(a)(2) of the Securities Act [15 U.S.C. § 77q(a)(2)]
(Against NovaTech, the Petions, and Zizi)
154. The  SEC  re-alleges  and  incorporates  paragraphs  1–149 above  by  reference  as  if
fully set forth hereunder.
155. By engaging in the conduct described herein, and as alleged in paragraphs 23–92
above, the Petions and NovaTech, and as alleged in paragraphs 115–123 above, Zizi, directly or
indirectly, in the offer or sale of securities, by the use of the means or instruments of transportation
or communication in interstate commerce or by use of the mails, have obtained money or property
by means of an untrue statement of a material fact or an omission to state a material fact necessary
in order to make the statements made, in light of the circumstances under which they were made,
not misleading.
156. With regard to the violations of Section 17(a)(2) of the Securities Act, Defendants
NovaTech, the Petions, and Zizi acted at least negligently.

49

157. By  reason  of  the  foregoing,  NovaTech,  the  Petions,  and  Zizi  have  violated,  and
unless  enjoined  will  continue  to  violate,  Section  17(a)(2)  of  the  Securities  Act  [15  U.S.C.
§ 77q(a)(2)].
THIRD CLAIM FOR RELIEF
Violations of Section 17(a)(3) of the Securities Act
[15 U.S.C. § 77q(a)(3)]
(Against NovaTech, the Petions, Zizi, Corbett, Dunbar, and Sampson)
158. The  SEC  re-alleges  and  incorporates  paragraphs  1–149  above  by  reference  as  if
fully set forth hereunder.
159. By engaging in the conduct described herein, and as alleged in paragraphs 23–92
above,  the  Petions  and  NovaTech,  and  as  alleged  in  paragraphs  115–149  above,  Zizi,  Corbett,
Dunbar,  and  Sampson,  directly  or  indirectly,  in  the  offer  or  sale  of  securities,  by  the  use  of  the
means or instruments of transportation or communication in interstate commerce or by use of the
mails,  have  engaged  in  a  transaction,  practice,  or  course  of  business  which  operated  or  would
operate as a fraud or deceit upon the purchaser.
160. With regard to the violations of Section 17(a)(3) of the Securities Act, Defendants
NovaTech, the Petions, Zizi, Corbett, Dunbar, and Sampson acted at least negligently.
161. By  reason  of  the  foregoing,  Defendants  NovaTech,  the  Petions,  Zizi,  Corbett,
Dunbar, and Sampson have violated, and unless enjoined will continue to violate, Section 17(a)(3)
of the Securities Act [15 U.S.C. § 77q(a)(3)].
FOURTH CLAIM FOR RELIEF
Violations of Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)]
and Rules 10b-5(a) and (c) thereunder [17 C.F.R. §§ 240.10b-5(a) and (c)]
(Against NovaTech, the Petions, Corbett, Dunbar, and Sampson)

50

162. The  SEC  re-alleges  and  incorporates  paragraphs  1–149 above  by  reference  as  if
fully set forth hereunder.
163. By engaging in the conduct described herein, and as alleged in paragraphs 23–92
above, NovaTech and the Petions, and as alleged in paragraphs 115–149 above, Corbett, Dunbar,
and  Sampson,  directly  or  indirectly,  singly  or  in  concert  with  others,  in  connection  with  the
purchase or sale of securities, by the use of any means or instrumentality of interstate commerce,
or of the mails or of any facility of any national securities exchange:
• employed a device, scheme, or artifice to defraud; and/or
• engaged  in  acts,  practices,  or  courses  of  business  which  operated  or  would
operate as a fraud or deceit upon any person.
164. With regard to the violations of Section 10(b) of the Exchange Act and Rule 10b-
5(a) and (c) thereunder, NovaTech, the Petions, Corbett, Dunbar, and Sampson acted with
scienter and engaged in the referenced acts knowingly and/or with severe recklessness.
165. By reason of the foregoing, NovaTech, the Petions, Corbett, Dunbar, and Sampson
have violated, and unless enjoined will continue to violate, Section 10(b) of the Exchange Act [15
U.S.C. § 78j(b)] and Rules 10b-5(a) and (c) thereunder [17 C.F.R. §§ 240.10b-5(a) and (c)].
FIFTH CLAIM FOR RELIEF
Violations of Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)]
and Rule 10b-5(b) thereunder [17 C.F.R. § 240.10b-5(b)]
(Against NovaTech and the Petions)
166. The  SEC  re-alleges  and  incorporates  paragraphs  1–149 above  by  reference  as  if
fully set forth hereunder.
167. By engaging in the conduct described herein, and as alleged in paragraphs 23–92
above, NovaTech  and the  Petions,  directly  or  indirectly,  singly  or  in  concert  with  others,  in

51

connection with the purchase or sale of securities, by the use of any means or instrumentality of
interstate commerce, or of the mails or of any facility of any national securities exchange,  made
untrue statements of material facts or omitted to state material facts necessary in order to make the
statements made, in light of the circumstances under which they were made, not misleading.
168. With regard to the violations of Section 10(b) of the Exchange Act and Rule 10b-
5(b) thereunder, NovaTech and the Petions acted with scienter and engaged in the referenced
acts knowingly and/or with severe recklessness.
169. By  reason  of  the  foregoing,  NovaTech and the  Petions  have  violated,  and  unless
enjoined will continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule
10b-5(b) thereunder [17 C.F.R. § 240.10b-5(b)].
SIXTH CLAIM FOR RELIEF
Unregistered Securities Offerings in Violation of
Sections 5(a) and 5(c) of the Securities Act [15 U.S.C. §§ 77e(a) and (c)]
(Against all Defendants)
170. The  SEC  re-alleges  and  incorporates  paragraphs  1–149 above  by  reference  as  if
fully set forth hereunder.
171. By engaging in the acts and conduct alleged herein, each of the Defendants, directly
or indirectly:
• made  use  of  the  means  or  instruments  of  transportation  or  communication  in
interstate commerce or of the mails to sell, through the use or medium of any
prospectus or otherwise, securities as to which no registration statement was in
effect; and/or
• for  the  purpose  of  sale  or  delivery  after  sale,  carried  or  caused  to  be  carried
through  the  mails  or  in  interstate  commerce,  by  means  or  instrument  of

52

transportation,  securities  as  to  which  no  registration  statement  was  in  effect;
and/or
• made  use  of  means  or  instruments  of  transportation  or  communication  in
interstate commerce or of the mails to offer to sell, through the use or medium
of any prospectus or otherwise, securities as to which no registration statement
had been filed.
172. By engaging in the conduct described above, Defendants have violated, and unless
restrained and enjoined, will continue to violate Sections 5(a) and 5(c) of the Securities Act [15
U.S.C. §§ 77e(a) and 77e(c)].
SEVENTH CLAIM FOR RELIEF
Unregistered Broker in Violation of
Section 15(a) of the Exchange Act [15 U.S.C. § 78o(a)]
(Against the Promoter Defendants)
173. The  SEC  re-alleges  and  incorporates  paragraphs  1–149 above  by  reference  as  if
fully set forth hereunder.
174. At various times during the Relevant Period and as further detailed and alleged in,
among other places, paragraphs 93–149 above, each of the Promoter Defendants acted as a broker
within the meaning of Section 3(a)(4) of the Exchange Act [15 U.S.C. § 78c(4)],  and made use of
the  mails  or  the  means  or  instrumentality of  interstate  commerce  to effect  transactions  in,  or  to
induce or attempt to induce the purchase or sale of, securities.
175. During  the  Relevant  Period  and  at  all  relevant  times,  none  of  the  Promoter
Defendants  were  registered  with  the  SEC  as  a  broker  or dealer  or  as  an  associated person  of  a
broker or dealer registered with the SEC, in accordance with Section 15(b) of the Exchange Act
[15 U.S.C. §78o(b)]. Nor did any exemption from the broker registration requirements exist with

53

respect  to  the  securities,  transactions,  and/or  any  Defendants’  conduct  alleged  and  described
herein.
176. By engaging in the conduct described above, each of the Promoter Defendants have
violated, and unless restrained and enjoined will continue to violate, Section 15(a) of the Exchange
Act [15 U.S.C. § 78o(a)].
VI. PRAYER FOR RELIEF
177. WHEREFORE, the  SEC  respectfully  requests  that  this  Court  enter  a  Final
Judgment:
• Permanently  restraining  and  enjoining  NovaTech  and  the  Petions  from
violating, directly or indirectly, Sections 5(a), 5(c), and 17(a) of the Securities Act, Section 10(b)
of the Exchange Act, and Rule 10b-5 thereunder;
• Permanently restraining and enjoining Corbett, Dunbar, and Sampson from
violating, directly or indirectly, Sections 5(a), 5(c)  , 17(a)(1), and 17(a)(3) of the Securities Act,
Sections 10(b) and 15(a) of the Exchange Act, and Rule 10b-5(a) and (c) thereunder;
• Permanently  restraining  and  enjoining  Zizi  from  violating,  directly  or
indirectly, Sections 5(a), 5(c), 17(a)(2), and 17(a)(3) of the Securities Act and Section 15(a) of the
Exchange Act;
• Permanently restraining and enjoining Garofano and Hadley from violating,
directly  or  indirectly,  Sections  5(a)  and  5(c)  of  the  Securities  Act  and  Section  15(a)  of  the
Exchange Act;
• Permanently restraining and enjoining NovaTech, the Petions, Zizi, Corbett,
Sampson,  Dunbar,  Hadley,  and  Garofano—directly  or  indirectly,  including  but  not  limited  to,
through any entity owned or controlled by them—from: (i) offering, operating, or participating in

54

any marketing or sales program in which the participant is compensated or promised compensation
solely or primarily for (A) inducing another person to become a participant in the program; or (B)
if  such  induced  person  induces  another  to  become  a  participant  in  the  program;  and  (ii)
participating  directly  or  indirectly  in  any  offering  of  securities;  provided,  however,  that,  such
injunction shall not prevent Cynthia Petion, Eddy Petion, Zizi, Corbett, Sampson, Dunbar, Hadley,
or Garofano from purchasing or selling securities for their own personal accounts;
• Ordering NovaTech and the Petions to disgorge all ill-gotten gains received
as a result of the violations alleged herein, together with pre-judgment interest thereon, on a joint
and  several  basis  by  and  between  NovaTech,  Cynthia  Petion,  and  Eddy  Petion,  pursuant  to  the
Court’s equitable powers and Sections 21(d)(3), 21(d)(5), and 21(d)(7) of the Exchange Act [15
U.S.C. §§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)];
• Ordering each Promoter Defendant to disgorge all ill-gotten gains he or she
received as a result of the violations alleged herein, together with pre-judgment interest thereon,
pursuant  to  the  Court’s  equitable  powers  and  Sections  21(d)(3),  21(d)(5),  and  21(d)(7)  of  the
Exchange Act;
• Ordering each Defendant to pay civil penalties pursuant to Section 20(d) of
the  Securities  Act  [15  U.S.C.  §  77t(d)]  and  Section  21(d)(3)  of  the  Exchange  Act  [15  U.S.C.
§ 78u(d)(3)]; and
• Granting such other and further relief as this Court may deem appropriate,
just, equitable, and/or necessary.
VII. JURY DEMAND

178. The SEC demands trial by jury in this action on all issues so triable.

55

Dated: August 12, 2024   Respectfully submitted,

/s/ Patrick Disbennett
      Patrick Disbennett
      S.D. Fla. Special Bar ID A5503234
Securities and Exchange Commission
801 Cherry Street, Suite 1900
Fort Worth, Texas 76102
Tel: (817) 266-9633 (Disbennett)
[email protected]

Attorney for Plaintiff

1 
 

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 

SECURITIES AND EXCHANGE COMMISSION, 

   Plaintiff, 

 v. 

NOVA TECH LTD, CYNTHIA PETION, 
EDDY PETION, MARTIN ZIZI, JAMES 
CORBETT, CORRIE SAMPSON, DAPILINU 
DUNBAR, JOHN GAROFANO, MARSHA 
HADLEY, 
 

 Defendants.  
 

 

 
         
         Civ. Action No. 1:24-cv-23058 

    JURY TRIAL DEMANDED 

 

COMPLAINT 

The Securities and Exchange Commission (“SEC”) files this Complaint against 

Defendants Nova Tech Ltd. (“NovaTech”), Cynthia Petion, Eddy Petion, Martin Zizi (“Zizi”), 

James Corbett (“Corbett”), Corrie Sampson (“Sampson”), Dapilinu Dunbar (“Dunbar”), John 

Garofano (“Garofano”), and Marsha Hadley (“Hadley”) (collectively, “Defendants”), and 

alleges as follows: 

I. SUMMARY  

1. From June 2019 to approximately May 2023, Cynthia Petion and Eddy Petion 

(together, the “Petions”) operated a fraudulent crypto trading investment and pyramid scheme 

primarily through NovaTech, a company registered in St. Vincent and the Grenadines. The Petions 

used a multi-level marketing (“MLM”) structure to raise crypto assets worth more than $650 

million from over 200,000 investors in the United States and abroad, including many in the 

Haitian-American community.  

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 1 of 55



2 
 

2. In solicitations made through its public website, social media, and network of 

promoters, NovaTech claimed to pool investors’ crypto assets and trade them on the crypto asset 

and foreign currency markets. NovaTech promised to pay profits to investors from this trading 

activity on a weekly basis. NovaTech purportedly never posted a weekly trading loss and, from 

2019 to 2023, reported average returns of 2–3% per week.   

3. In reality, NovaTech appears to have traded only a small fraction of investor assets, 

it suffered significant trading losses, and it had no other known sources of revenues besides 

investor deposits. In other words, NovaTech was a pyramid scheme that depended on the 

recruitment of new investors or new investments from existing investors to fund its enterprise.    

4. The Petions misappropriated investor assets for unauthorized purposes, including 

transferring millions of dollars of commingled investor assets to themselves. On information and 

belief, they also used investor funds to make payments to existing investors and commission 

payments to promoters.  

5. In promoting NovaTech, the Petions also made a barrage of false and misleading 

statements relating to NovaTech’s use of investors assets for trading, the profitability of its trading, 

its status as an alleged “registered hedge fund,” and the purported safety and security of the 

investment. The scheme collapsed in or around May 2023, after investors experienced withdrawal 

delays and regulators in several U.S. states and Canadian provinces took action against, or issued 

fraud warnings about, NovaTech and the Petions. As NovaTech collapsed, most investors were 

unable to withdraw their investments, resulting in substantial losses.  

6. Defendants each marketed the NovaTech investment to investors who were 

inexperienced in crypto assets and who wanted to participate in the crypto markets. Certain 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 2 of 55



3 
 

Defendants targeted affinity groups, in particular the Haitian-American community, and used 

religious overtones and appeals to financial freedom and independence to solicit investors. 

7. Defendants Zizi, Corbett, Sampson, Dunbar, Garofano, and Hadley (collectively, 

the “Promoter Defendants”) were instrumental in offering, marketing, and distributing the 

NovaTech investment. The Promoter Defendants held themselves out as “leaders” and rose to the 

highest ranks of NovaTech’s MLM program. They did so by recruiting, developing, and 

maintaining a wide network of “downline” investors, many of whom became recruiters themselves 

and brought in additional investors. The Promoter Defendants received substantial commission 

payments from NovaTech for recruiting investors into their downlines.  

8. Certain Promoter Defendants—Zizi, Corbett, Dunbar, and Sampson—became 

aware of actions against NovaTech by regulators in the United States and Canada, investors 

experiencing withdrawal delays, NovaTech suspending withdrawals, and other red flags that raised 

questions about the legitimacy of NovaTech and the legality of its offering and selling activities. 

Nevertheless, these Promoter Defendants continued to promote NovaTech, recruit investors, and 

operate their MLM networks in the face of these red flags. They also actively downplayed the red 

flags to prospective investors and downline promoters.   

9. By engaging in the acts and conduct alleged herein, Defendants NovaTech and the 

Petitions violated the antifraud and securities-registration provisions of the federal securities laws, 

Defendants Zizi, Corbett, Dunbar, and Sampson violated the antifraud, securities-registration, and 

broker-registration provisions of the federal securities laws, and Defendants Garofano and Hadley 

violated the securities-registration and broker-registration provisions of the federal securities laws. 

In the interest of protecting the public from further violations and enforcing the federal securities 

laws, the SEC brings this action seeking permanent injunctive relief, disgorgement of ill-gotten 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 3 of 55



4 
 

gains plus prejudgment interest, civil penalties, and all other equitable and ancillary relief the Court 

deems necessary and proper.  

II. JURISDICTION AND VENUE 

10. The SEC brings this action pursuant to the authority conferred upon it by Sections 

20(b) and 20(d) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77t(b) and 77t(d)] 

and Sections 21(d) and 21(e) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. 

§§ 78u(d) and 78u(e)]. 

11. This Court has jurisdiction over this action pursuant to Sections 20 and 22(a) of the 

Securities Act [15 U.S.C. §§ 77t and 77v(a)] and Sections 21(d), 21(e), and 27 of the Exchange 

Act [15 U.S.C. §§ 78u(d), (e), and 78aa]. 

12. Defendants, directly or indirectly, made use of the mails or means or 

instrumentalities of interstate commerce in connection with the acts, practices, transactions, and 

courses of business alleged in this Complaint. 

13. Venue is proper in this District pursuant to Section 22(a) of the Securities Act [15 

U.S.C. § 77v(a)] and Section 27 of the Exchange Act [15 U.S.C. § 78aa]. At least one Defendant, 

Defendant Dunbar, is found, is an inhabitant, and transacts business in this District. In addition, 

certain acts, practices, transactions, and courses of business constituting violations of the securities 

laws alleged herein occurred within this District, and the offer or sale of securities at issue in this 

case took place in this District. Prior to approximately May 2022, the Petions are believed to have 

resided in this District, wherefrom, on information and belief, they engaged in certain acts, 

practices, transactions, and courses of business constituting violations of the federal securities laws 

alleged in this Complaint.  

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 4 of 55



5 
 

III. DEFENDANTS 

14. Defendant Nova Tech Ltd. is a company registered and formed under the laws of 

St. Vincent and the Grenadines in September 2019. According to its Disclosure Document dated 

August 15, 2019 (the “Disclosure Document”) that was provided to investors, NovaTech is and/or 

was responsible for “the management of Cryptocurrency trading accounts for qualified investors” 

within the NovaTech organization.   

15. Defendant Cynthia Petion is a U.S. citizen. On information and belief, she is 

currently residing in Panama, and prior to approximately May 2022, she resided in Wellington, 

Florida. Cynthia Petion is and/or has been described as the founder, sole shareholder, Director, 

Managing Member, and CEO of NovaTech. According to NovaTech’s Disclosure Document, 

Cynthia Petion is “responsible for creating, planning, implementing, and integrating the strategic 

direction of [NovaTech], managing and implementing [NovaTech’s] research and development of 

cryptocurrency strategies, and overseeing and managing [NovaTech’s] overall operations.”  

16. Defendant Eddy Petion is a U.S. citizen and the husband of Cynthia Petion. On 

information and belief, he is currently residing in Panama, and prior to approximately May 2022, 

he resided in Wellington, Florida. Eddy Petion is and/or has been described as a Managing Member 

and Chief Operating Officer (“COO”) of NovaTech. According to NovaTech’s Disclosure 

Document, Eddy Petion “oversees daily operations and trading for client accounts” at NovaTech, 

and purportedly “conducted independent research on trading strategies using his proprietary 

cryptocurrency trading account where he tested various trading strategies including value investor, 

swing trading, short term trading and algorithmic and machine trading.” 

17. Defendant Martin Zizi is a resident of Kennesaw, Georgia. He was the first 

NovaTech promoter to achieve the rank of Two Star Ambassador, the highest promoter rank within 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 5 of 55



6 
 

NovaTech’s MLM program. He also founded one of the most successful NovaTech promotional 

groups: Team Trinity of Success Club.   

18. Defendant James Corbett is a resident of Mastic Beach, New York. Cynthia Petion 

referred to him as a “Founding Leader” of NovaTech. He achieved the rank of Two Star 

Ambassador in NovaTech’s MLM program.  

19. Defendant Corrie Sampson is a resident of Fairburn, Georgia. She was a Two Star 

Ambassador in NovaTech’s MLM program. She cofounded one of the most successful NovaTech 

promotional groups: Team Diamond. As of January 2023, Team Diamond had over 50,000 

members who were investors in NovaTech.  

20. Defendant Dapilinu Dunbar is a resident of Miami, Florida. He was a One Star 

Ambassador in NovaTech’s MLM program, the second highest rank behind Two Star 

Ambassador. He was one of the most prolific promoters for NovaTech. He was a member of Team 

Diamond, where he often collaborated with Sampson and Hadley to market and promote 

NovaTech to investors and prospective investors.  

21. Defendant John Garofano is a resident of Brooksville, Florida. He was a Two Star 

Ambassador in NovaTech’s MLM program. Corbett originally recruited Garofano to invest and 

participate in NovaTech and its MLM program, and the two often worked together to market and 

promote NovaTech to investors and prospective investors. 

22. Defendant Marsha Hadley is a resident of Murrietta, California. She was a One Star 

Ambassador in NovaTech’s MLM program. Hadley and Sampson cofounded Team Diamond.  

IV. FACTS 

A. The Petions Founded NovaTech in June 2019. 

23. Before founding NovaTech, the Petions were the top U.S. promoters for another 

alleged MLM crypto investment scheme: AWS Mining PTY Ltd (“AWS”). Operating as “Team 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 6 of 55



7 
 

Nova,” the Petions were the highest ranked promoters in AWS’s MLM program, commonly 

referred to as the “founding presidents” of AWS’s operations in the United States. AWS offered 

investments in cryptocurrency mining contracts to investors and paid bonuses and commissions to 

an MLM network of sales agents who sold those investments for AWS and recruited additional 

agents into its MLM program.  

24. In November 2018, the Texas State Securities Board (“TSSB”) found that AWS 

violated Texas securities laws and ordered AWS to cease and desist from offering its securities in 

Texas. Among other things, the TSSB found that AWS violated Texas securities laws by making 

false and misleading statements to investors about the profitability of the investments sold, offering 

unregistered securities, and recruiting sales agents to offer and sell securities without a registration 

or license to sell such securities. The AWS scheme collapsed soon thereafter.  

25. At or around the time of AWS’s collapse, court records indicate that the Petions 

were facing personal financial issues, including: (i) in April 2018, a credit card issuer sued Cynthia 

Petion in state court in Palm Beach County, Florida, and subsequently obtained a judgment against 

her for $11,776.55 in unpaid debt; (ii) in July 2018, a mortgage lender sued the Petions in state 

court in Palm Beach County, Florida, in an action to foreclose a defaulted mortgage on a residential 

real property held by the Petions; and (iii) in August 2019, a debt buyer sued Cynthia Petion in 

state court in Palm Beach County, Florida, alleging that she had failed or refused to repay a loan.      

26. The Petions began to publicly distance themselves from AWS as it collapsed. They 

blamed AWS’s collapse on its principals and claimed that they, too, were victims of the alleged 

scheme (even though Cynthia Petion privately acknowledged that she made over $3 million in 

connection with AWS). The Petions then pivoted to creating and running their own MLM crypto 

investment scheme—“NovaTech”—which Cynthia Petion told prospective investors was created 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 7 of 55



8 
 

as a way for former AWS investors to recoup losses suffered when AWS collapsed. To help ensure 

NovaTech’s success, the Petions lured other top AWS promoters to promote NovaTech to their 

respective followings of investors. 

27. Taking what they learned from AWS, the Petions founded and operated NovaTech 

between approximately June 2019 and May 2023 (the “Relevant Period”). The Petions developed 

and implemented an MLM structure for NovaTech—discussed further in paragraphs 34–43 

below—modeled after AWS’s MLM program. And in an attempt to avoid the TSSB’s scrutiny, 

Cynthia Petion included Texas on NovaTech’s list of “Restricted Areas” and claimed not to offer 

NovaTech to Texas residents.  

28. Throughout the Relevant Period, the Petions marketed NovaTech—among other 

places, on its website, social media, through Telegram and WhatsApp, and in presentations made 

available to investors—as an investment program that promised lucrative profits purportedly 

earned from trading in crypto asset and foreign currency markets by NovaTech’s supposed “team 

of experienced traders.” In addition to offering this “passive” investment opportunity, NovaTech 

also paid commissions, through an MLM structure, to members who recruited new investors. 

NovaTech’s marketing to investors heavily emphasized the MLM “business opportunity.” 

29. Throughout the Relevant Period, the Petions held themselves out as the founders 

and control persons of NovaTech, with Cynthia Petion serving as CEO and Eddy Petion as COO. 

Cynthia Petion registered and maintained the novatechfx.com and novatechfx.io domains. Cynthia 

Petion also registered and maintained the NovaTech website, novatechfx.com, that was marketed 

to and used by investors. The website was hosted on a server provided by a U.S. company.  

30. To participate in the NovaTech investment program, investors created a user 

account on NovaTech’s website and funded their accounts with crypto assets worth a minimum of 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 8 of 55



9 
 

$99. While creating their accounts, investors could identify their “sponsor” (i.e., the person who 

recruited them) by, among other means, following a unique URL provided by the sponsor.  

31. By creating an account on NovaTech’s website, investors could access marketing 

and training materials, access NovaTech’s official Telegram channel, invest crypto assets into 

NovaTech’s program, track their account balances (including purported trading profits and 

recruitment commissions credited to their account), re-invest purported profits and commissions, 

and submit a request to withdraw purported profits, commissions, and invested capital. 

NovaTech’s website referred to this suite of features as the “back office.” The Petions hired, 

directed, and paid software development companies to develop and maintain the back office.   

32. Throughout the Relevant Period, NovaTech provided investors certain written 

disclosures during online enrollment, including the “Disclosure Document” (as defined in 

paragraph 14 above). When an investor sought to invest their crypto assets in NovaTech, the 

NovaTech website automatically directed the investor to a separate webpage featuring a unique, 

single-use wallet address to which the investor was directed to send crypto assets for deposit into 

an account controlled by NovaTech and the Petions.   

33. The Petions established and controlled the methods by which NovaTech sent and 

received crypto assets to and from investors. NovaTech used a crypto payment processor located 

in Lithuania (and in Estonia for part of the Relevant Period) (the “Payment Processor”). The 

Petions controlled NovaTech’s account with the Payment Processor. The manner in which the 

Petions elected to process payments using the Payment Processor obscured both incoming 

transactions by investors to NovaTech and the onward transfer of investors’ assets from NovaTech.  

B. The NovaTech Investment Offering.  

34. Throughout the Relevant Period, the Petions promoted—among other places, on 

NovaTech’s website and in presentations to investors that they authored, helped author, and/or 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 9 of 55



10 
 

approved—the NovaTech investment program as offering a participation interest in a pool of 

crypto assets that NovaTech purportedly traded on behalf of investors. On its website, NovaTech 

referred to this participation interest as a “PAMM account,” which its website described as a 

product that allows investors to earn without having to trade. You 
can invest your funds in NovaTech’s master accounts to be traded 
by our experienced team of traders. We receive a percentage of the 
profits we earn from trading with your funds as a reward. No 
experience necessary. 

 
NovaTech’s website further explained that the “PAMM system allows more money to be brought 

into play while distributing the risk of one trader across (usually) multiple investors.”   

35. In its Disclosure Document provided to investors, NovaTech represented that its 

investment objective was “to trade in and out of cryptocurrencies achieving gains in the Client’s 

portfolio using proprietary buy and sell trading signals it has developed.” NovaTech represented 

that it purportedly kept 30% of any purported trading profits and distributed 70% to investors.  

36. Throughout the Relevant Period, NovaTech’s back office displayed two accounts 

for each investor: a “Trading Account” and a “Bonus Account.” An investor’s “Trading Account” 

reflected the investor’s capital contributions (whether initial or subsequent). NovaTech claimed to 

be actively trading all crypto assets in each investor’s Trading Account. The “Bonus Account” 

purportedly reflected amounts that NovaTech credited, on a weekly basis, with the investor’s pro 

rata share of alleged trading profits and any commissions the investor received from participating 

in the MLM program. In the Disclosure Document and other back-office materials, NovaTech 

represented to investors that assets in the Bonus Account were not traded, but at all times investors 

had the option to “rollover” (i.e., reinvest) the purported profits and any commissions accumulated 

in the Bonus Account by transferring any portion of them to the Trading Account. NovaTech also 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 10 of 55



11 
 

represented that investors could withdraw crypto assets from the Trading Account and the Bonus 

Account, subject to certain terms, as described, among other places, in paragraphs 40–42 below.  

37. NovaTech’s fee structure incentivized investors to increase their Trading Account 

balance by either contributing additional assets out of pocket or by rolling over their Bonus 

Account balances to their Trading Account. For example, if an investor’s Trading Account balance 

exceeded $25,000 for a full calendar month (“VIP” level), NovaTech waived its monthly service 

fee for the investor and credited the investor a 1% “cash back reward” that was 1% of monthly 

trading profits (expressed as a percentage that NovaTech called the “ROI”). If an investor’s 

Trading Account balance exceeded $100,000 for a full calendar month (“President’s Club” level), 

NovaTech waived its monthly service fee for the investor and credited the investor a 2.5% cash 

back reward and a $1,000 gift card bonus. 

38. NovaTech’s promoters and the Petions also encouraged investors to rollover their 

Bonus Account balances into their Trading Account, purportedly to increase the weekly profits 

investors received. For example, in a Zoom presentation given near the end of 2020 and later 

posted to YouTube on or around January 3, 2021, Zizi—a top-ranked NovaTech promoter— 

advised that prospective investors should take at least 10% of their money 

and have it work for you…by putting it in your trading account, and once you have 
that done, the second -- the third step is for you to take the babies of the money that 
is making for you, and then put those babies back to work where we get to 
compound interest, having money working for you, making babies every single 
week.  
 
Yes, you’re making money from your group volume. How much of that is going 
back into your trading account? Ten percent of that must go back…  
 
39. As another example, in a video posted to YouTube on May 4, 2022, Cynthia Petion 

told investors, in relevant part: “[w]hen you earn your bonuses every week,…you have the option 

of redepositing it so that your account continues to grow, and that’s the best way to grow your 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 11 of 55



12 
 

account without having to add any additional funds out of your own pocket.” In this same video, 

Cynthia Petion also acknowledged that NovaTech incentivized its promoters to persuade investors 

in their downlines to increase their Trading Account balances, stating: “I know as affiliate 

marketers we want people to put in as much as possible. Why? Because there’s check matching 

and there’s all the other—there’s direct referral fees, and everything else. And as accounts grow, 

our business grows, I get that.” 

40. Throughout the Relevant Period, the Petions touted investors’ supposed ready 

access to capital and “weekly liquidity” that NovaTech provided, both in the Trading and Bonus 

Accounts, claiming that these purported features differentiated NovaTech from other MLM 

investment programs. For example, this selling point was described on the following slide from a 

NovaTech marketing deck—authored and approved by the Petions—that NovaTech made 

available to all investors in the back office between approximately October 2021 and April 2023:  

 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 12 of 55



13 
 

41. NovaTech disclosed to investors certain investment terms in writing prior to the 

investment. These terms were located, among other places, in NovaTech’s Compensation Plan 

dated August 3, 2019 (“Compensation Plan”)—which, on information and belief, was published 

to NovaTech’s back office between approximately August 3, 2019 and October 2020—and an 

updated Compensation Plan dated October 2020 (“Updated Compensation Plan”), which, on 

information and belief, was published to NovaTech’s back office between approximately October 

2020 and January 2023. Cynthia Petion drafted both documents and Eddy Petion participated in 

the drafting process and reviewed drafts. As further detailed in paragraph 53–56 below, the Petions 

and NovaTech modified these terms in 2023. 

42. The Updated Compensation Plan provided, among other things, that investor 

requests to withdraw crypto assets from the Trading Account were to be processed within 7–14 

business days and, if made within 90 days of registration, were subject to a 15% “processing fee.” 

As to investor requests to withdraw from the Bonus Account, the Updated Compensation Plan 

provided that such requests were to be processed within 24–48 hours. 

43. Neither NovaTech nor any of its affiliates have ever been registered with the SEC 

as brokers, investment advisers, or in any other capacity. And the NovaTech securities offerings 

and sales described herein have never been registered with the SEC. The Petions and the Promoter 

Defendants have never been registered with the SEC as brokers, investment advisers, or in any 

other capacity and have never been associated with a broker or dealer registered with the SEC.  

C. The Petions Designed and Implemented NovaTech’s MLM Program to Promote and 
Distribute NovaTech’s Investment Offering.  

44. The Petions designed and implemented NovaTech’s MLM program, which 

facilitated the distribution of NovaTech’s investment offering. Each of the Petions also personally 

solicited investors. The Promoter Defendants were prominent participants in NovaTech’s MLM 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 13 of 55



14 
 

program, through which they solicited investors to invest in the NovaTech investment offering. 

During the Relevant Period, NovaTech raised crypto assets worth more than $650 million, valued 

as of the time the crypto assets were deposited, using its MLM program to recruit over 200,000 

investors.  

45. Throughout the Relevant Period, the Petions solicited potential investors to invest 

in the NovaTech investment offering through, among other means, NovaTech’s website, social 

media (including Instagram and Facebook), presentations led by the Petions that were broadcast 

on Zoom to potential investors (and some of which were recorded and distributed publicly on 

YouTube or other sites), and Telegram channels and WhatsApp groups controlled by the Petions.  

46. The Petions also developed an MLM program designed to solicit prospective 

investors to invest in NovaTech. This MLM program relied on and incentivized a wide network 

of promoters to recruit new investors. Promoters stood to gain from recruiting new investors and 

new promoters into their “downlines.” A promoter’s downline included the investors that the 

promoter directly recruited to invest in NovaTech, plus all investors who were recruited to invest 

in NovaTech by others in that promoter’s downline.   

47. The Petions sought to cultivate and maintain relationships with top promoters. They 

personally recruited at least two Promoter Defendants, Zizi and Corbett, whom the Petions sought 

out because of the large networks Zizi and Corbett had developed with other MLM programs, like 

AWS. They also personally met with the top-performing promoters. In or around December 2021, 

the Petions held a party for top promoters on a boat in Miami, which Zizi, Dunbar, and Garofano 

attended. In April 2023, Zizi and Dunbar attended Cynthia Petion’s birthday party in Panama, and 

before that, in or around February 2023, Dunbar visited the Petions at their residence in Panama.   

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 14 of 55



15 
 

48. Throughout the Relevant Period, NovaTech’s marketing materials—which the 

Petions authored and approved—were geared primarily toward persuading investors to recruit 

others into their downlines (through the promise of generous commissions), while only describing 

the trading program in brief and generic terms. NovaTech-branded marketing materials were made 

available for all investors to download from NovaTech’s back office. These materials included a 

slide deck that Cynthia Petion drafted and Eddy Petion reviewed and approved. Zizi, Corbett, and 

Garofano, among others, used this slide deck in weekly Zoom meetings with prospective investors 

throughout the Relevant Period. 

49. When the Petions and certain Promoter Defendants solicited investors, they 

frequently employed religious overtones, appealed to the financial freedom and independence 

purportedly attained by investing in crypto assets and participating in MLM programs, and targeted 

certain affinity groups, in particular the Haitian-American community.  

50. Throughout the Relevant Period, Cynthia Petion branded herself as “The Reverend 

CEO” in NovaTech promotional materials and laced her investor pitches with religious appeals. 

For example, in an interview posted to YouTube on October 6, 2022, Cynthia Petion described her 

founding of NovaTech as “God’s vision.” In another video in which Cynthia Petion trained 

promoters on how to present NovaTech to prospective investors, which was posted to YouTube 

on May 4, 2022, Cynthia Petion stated: “Jesus was the best affiliate marketer in the world.”   

D. NovaTech Rapidly Collapsed and Halted Its U.S. Operations by May 2023.   

51. By at least around October 2022, investors began to experience substantial delays 

in withdrawing their crypto assets from NovaTech. In communications to investors, the Petions 

attributed these delays to technical issues caused by NovaTech’s rapid growth. For example, in a 

post to its official Telegram channel on October 28, 2022, NovaTech acknowledged “a growing 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 15 of 55



16 
 

number of issues arising concerning USDT cash out requests,” and attributed these issues to “the 

payment processor being unable to process” the requests. 

52. Around the same time, NovaTech came under scrutiny from regulators in U.S. 

states and Canadian provinces. On October 11, 2022, the British Columbia Securities Commission 

issued a fraud warning regarding NovaTech, and on October 12, 2022, the Alberta Securities 

Commission issued its own fraud warning. On November 22, 2022, the California Department of 

Financial Protection and Innovation issued a desist and refrain order (the “California Order”). 

The California Order found that NovaTech, certain NovaTech entities, and the Petions violated 

California state securities-registration and anti-fraud statutes by: offering securities without being 

permitted or qualified to do so, making material misstatements about, among other things, 

NovaTech’s purported registration status, and failing to provide any qualifications to substantiate 

claims that investor funds were managed and traded by experienced traders. NovaTech could have 

contested the California Order pursuant to California law, but it never did so.  

53. On January 24, 2023, “NovaTech Admin”—which, on information and belief, is an 

account controlled by Cynthia Petion—posted an announcement to investors through the back 

office, attributing the withdrawal delays to “unusually high volumes in cashout requests, in 

addition to the implementation of new payment processing systems and recent updates.”  

54. On February 5, 2023, “NovaTech Admin” posted an announcement to investors 

through the back office, announcing that NovaTech was instituting a 60-day “temporary freeze” 

on all investor withdrawals from Trading Accounts. In the announcement, this pause was attributed 

to “the forced closures of accounts” that were “due to regulatory changes in specific regions,” as 

well as “the massive amounts of withdrawals we had to initiate.”   

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 16 of 55



17 
 

55. On or around March 31, 2023, the day before the previously announced 60-day 

“temporary freeze” was due to be lifted, Cynthia Petion posted an announcement to the back office, 

outlining NovaTech’s new compensation plan and new withdrawal terms applicable to all existing 

and new investors that would take effect the following day. These terms severely restricted the 

frequency of withdrawals that investors could request from their Trading Accounts, as well as the 

amount of crypto assets that investors could withdraw from their Trading Accounts, while 

continuing to permit, with fewer restrictions, withdrawals from Bonus Accounts.   

56. On or around May 11, 2023, NovaTech announced it was halting U.S. operations, 

and its website was disabled shortly thereafter, after which investors could no longer make any 

withdrawals from their NovaTech accounts. Ultimately, most investors were unable to withdraw 

their investments from NovaTech, resulting in substantial losses.    

E. The Petions Operated NovaTech as a Fraud on Investors.   

57. The Petions did not provide the SEC access to NovaTech’s internal records during 

the SEC’s investigation that preceded the filing of this Complaint. Instead, the Petions and 

NovaTech ignored the SEC’s investigative subpoenas and failed to produce any documents or 

provide testimony in response to those subpoenas. Nevertheless, the SEC obtained substantial 

evidence concerning NovaTech’s crypto asset transactions and trading, including but not limited 

to public blockchain data, Payment Processor data, other data from various crypto asset exchanges, 

and documents and information obtained from NovaTech’s former Chief Technology Officer. 

58. NovaTech raised crypto assets during the Relevant Period worth more than $650 

million, valued at the time of investor deposits, from more than 200,000 investors in multiple U.S. 

states and foreign countries. These figures are primarily based on an analysis of cryptocurrency 

transaction data pertaining to NovaTech, including relevant blockchain data, Payment Processor 

data, and other relevant data from various crypto asset exchanges.    

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 17 of 55



18 
 

59. While soliciting these investments, NovaTech represented to investors that the 

returns it credited to investor accounts were derived from crypto asset and foreign currency trading 

activity. During the Relevant Period, NovaTech reported to investors average returns of 2–3% per 

week from its purported trading. Aside from the investor deposits and “profits” from its purported 

trading activity, NovaTech had no other known profit-generating operations or inflow of assets. 

Thus, to pay the returns that it reported and credited to investors, as well as the very significant 

commission payments as part of the MLM program, while also keeping 30% of the profits for 

itself, NovaTech’s trading activities had to generate significant profits above and beyond the 

hundreds of millions of dollars’ worth of crypto assets that NovaTech received from investors. 

However, NovaTech used only a small fraction of crypto assets contributed by investors to trade 

on trading platforms, and NovaTech’s limited trading was not profitable.    

60. NovaTech failed to generate anywhere near the returns it represented to investors 

through the small percentage of crypto assets that were traded. To the contrary, records from 

NovaTech’s known trading platforms show that traders and accounts associated with NovaTech 

lost approximately $18 million in trading these assets during the Relevant Period. 

61. NovaTech had an automated system to maintain the accounting for investors’ 

Trading and Bonus Accounts. On a weekly basis, this system calculated the amounts to be credited 

to investors’ accounts based on the trading profits purportedly achieved that week. During the 

Relevant Period, this system was not linked to any trading venue or trading system that NovaTech 

used. Instead, the sole input into the accounting system for the reported trading profits/ROI was 

provided manually by Cynthia Petion on a weekly basis. Specifically, Cynthia Petion manually 

entered the weekly performance percentage in the back office and would then “run” the software 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 18 of 55



19 
 

code that would use such manually entered percentage to generate each investor’s weekly profit 

and commissions amounts and post those amounts to each investor’s back office account.      

62. The Petions also caused NovaTech to transfer from wallets in which it aggregated 

investor assets to accounts or wallets that the Petions owned and/or controlled. During the Relevant 

Period, at least $4.3 million in crypto assets were transferred from NovaTech into accounts or 

wallets owned and/or controlled by Cynthia Petion, and at least $1.5 million in crypto assets were 

transferred from NovaTech into accounts known to be owned and/or controlled by Eddy Petion.  

63. In addition, NovaTech transferred an additional approximately $35.2 million in 

crypto assets from wallets in which it aggregated investor assets to accounts or wallets that, on 

information and belief, were owned and/or controlled by Eddy Petion. This is based on evidence 

that these crypto assets were initially withdrawn from NovaTech’s Payment Processor account 

with the internal note “EP” (Eddy Petion’s initials), and evidence that at least some of the assets 

withdrawn from the NovaTech Payment Processor account merged with crypto assets withdrawn 

from Eddy Petion’s known crypto asset platform account before being simultaneously transferred, 

in a single transaction, to Eddy Petion’s suspected deposit address.  

64. NovaTech failed to generate returns from its crypto asset and foreign exchange 

trading, it used only a fraction of investor assets to trade, and it had no other known sources of 

revenues besides investor deposits and trading activity. The NovaTech enterprise, thus, was a 

pyramid scheme that depended on the recruitment of new investors or new investments from 

existing investors to fund the payouts of purported returns and commissions to existing investors. 

Inevitably, the new investments NovaTech brought in could not sustain the returns and 

commissions it owed to existing investors, eventually leading to NovaTech’s collapse in May 

2023. Investors suffered pecuniary harm as a result of investing in NovaTech.  

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 19 of 55



20 
 

F. NovaTech and the Petions Made False and Misleading Statements to Investors in 
Furtherance of Their Fraudulent Scheme.  

65. NovaTech and the Petions made several false and misleading statements to 

investors in furtherance of their fraudulent scheme. These misrepresentations created for investors 

the false appearance that NovaTech and the Petions were operating a legitimate trading enterprise, 

when in fact, NovaTech was a fraudulent and illegal pyramid scheme. As alleged below, NovaTech 

and the Petions made at least five categories of misstatements. 

i. Misstatements regarding the use of assets invested by investors. 
 

66. Throughout the Relevant Period, the Petions and NovaTech made false and 

misleading statements to investors regarding how NovaTech used or would use the crypto assets 

it received from investors. The following are examples of just some of these misrepresentations.  

67. First, NovaTech’s Disclosure Document—which Cynthia Petion drafted and Eddy 

Petion reviewed and participated in drafting, and which was made available to investors between 

at least August 15, 2019 and May 2023—stated, in relevant part:  

The investment objective of the Trading Advisor [NovaTech] is to achieve capital 
appreciation and maximize absolute returns for ‘cryptocurrency’ trading clients 
using the Company’s proprietary trading systems. The Trading Advisor seeks to 
trade in and out of cryptocurrencies achieving gains in the Client’s portfolio using 
proprietary buy and sell trading signals it has developed.  
 
68. Second, an affiliate PowerPoint presentation dated January 2022 stated: “LIVE 

TRADING EXPERIENCE – We trade for you on the LIVE global Forex Market. Test your skills 

on our Demo Account and see what our professional traders do daily to ensure your financial 

success!” Cynthia Petion drafted this presentation and Eddy Petion participated in the drafting 

process. NovaTech posted this presentation to its back office and official Telegram channel 

between January 2022 and May 2023, and NovaTech and/or its promoters gave the presentation 

to investors and prospective investors at various times during this period.  

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 20 of 55



21 
 

69. Third, NovaTech’s Compensation Plan dated August 3, 2019 represented to 

investors and prospective investors that trading of investors’ crypto assets deposited with 

NovaTech commenced “within approximately 48–72 hours of initial deposit.” Cynthia Petion 

drafted this document and Eddy Petion participated in the drafting process. Between approximately 

August 3, 2019 and October 2020, NovaTech and the Petions published this document to 

NovaTech’s back office, where investors and prospective investors accessed and reviewed it. 

NovaTech updated its Compensation Plan in October 2020. In the Updated Compensation Plan 

dated October 2020—described in paragraph 41 above—NovaTech represented to investors and 

prospective investors that trading of investor crypto assets deposited with NovaTech commences 

“within approximately 24–48 hours of initial deposit.” Cynthia Petion drafted this document and 

Eddy Petion participated in the drafting process. Between approximately October 2020 and April 

2023, NovaTech and the Petions published this document to NovaTech’s back office, where 

investors and prospective investors accessed and reviewed it. 

70. Fourth, in a March 25, 2020 WhatsApp message to prospective investors, Cynthia 

Petion stated: “We are trading your balances, anything we pay out is profit from those deposits.”  

71. Fifth, throughout the Relevant Period, NovaTech’s website—which the Petions 

controlled—stated: “What we pay out on Friday is a culmination of profits made from the trading 

activity that took place during the week.”   

72. Sixth, in a Zoom presentation on May 4, 2022 intended for prospective investors 

and posted on YouTube, Cynthia Petion stated, “we’ve been able to return every penny to every 

single user since we’ve started this program, and that’s because you give us the funds to trade, we 

report only what we make, and the rest is still there trading.”   

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 21 of 55



22 
 

73. Seventh, in a Zoom presentation on June 23, 2022, intended for prospective 

investors and posted to YouTube, Eddy Petion stated: “We don’t just hold your funds and hoping 

for the market to do better. The funds are being actively traded. Up or down, we make money.” 

74. Eighth, in almost-daily “opportunity calls” with prospective investors throughout 

January–May 2023, two Promoter Defendants (Sampson and Hadley) presented a PowerPoint—

which Cynthia Petion approved—that stated “100% of your investment traded.”  

75. As the Petions and NovaTech knew, or were severely reckless in not knowing, these 

statements were false, or at least misleading, at the time they were made. These statements created 

the false and misleading impression that NovaTech: traded all crypto assets received from 

investors, did so soon after those assets were invested (“within approximately 24–48 hours of 

initial deposit”), and only reported and paid out the profits it generated from trading. As alleged in 

paragraphs 57–64 above, however, NovaTech was a fraudulent crypto trading investment and 

pyramid scheme, it traded only a fraction of the crypto assets that investors deposited, it reported 

fabricated returns and commissions, and it appears to have paid out purported returns and 

commissions to investors using new investments.   

ii. Misstatements regarding NovaTech’s trading performance.  
 

76. Throughout the Relevant Period, the Petions and NovaTech also made false and 

misleading statements to investors regarding the supposed profitability of NovaTech’s trading. 

The following are examples of just some of these misrepresentations. 

77. From at least October 2, 2020 through November 22, 2022, the Petions and 

NovaTech posted to investors through the back office a “trading performance report” on a weekly 

basis reflecting NovaTech’s supposed trading performance for the week. During this period, 

NovaTech reported weekly returns ranging from 0.65% to 4.20%, with an average weekly return 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 22 of 55



23 
 

of 3.18%, and no week in which a loss was reported. During or around this period, NovaTech also 

posted the same information on its official Telegram channel, which on information and belief, 

Cynthia Petion controlled.   

78. Similarly, in a March 26, 2020 WhatsApp message to prospective investors, 

Cynthia Petion posted a chart reflecting NovaTech’s purported trading performance between 

November 2019 and March 2020, which reflected average weekly profits of approximately 4.7%.   

79. Throughout the Relevant Period, Cynthia Petion and NovaTech also 

misrepresented investors’ account balances. As discussed in paragraph 61 above, these numbers 

were manually generated by Cynthia Petion, who caused NovaTech to credit investors’ accounts 

based on these fictitious returns.  

80. As NovaTech and the Petions knew, or were severely reckless in not knowing, these 

statements were false and misleading at the time they were made. Among other things—and as 

alleged in detail, among other places, in paragraphs 57–64 above—the commissions and returns 

reported to investors’ back-office accounts did not reflect NovaTech’s actual trading performance, 

NovaTech’s trading was not profitable or at least not as profitable as represented to investors, and 

the numbers reported to investors were fabricated. NovaTech was a fraudulent crypto investment 

and pyramid scheme, and it appears to have paid out purported returns and commissions to 

investors using new investments. NovaTech and the Petions knew or were severely reckless in not 

knowing these facts, among other reasons, because the Petions controlled all NovaTech 

accounts/wallets, controlled the commissions and returns reported to investors’ back-office 

accounts, and were aware of all of NovaTech’s trading activity, which was either reported to them 

or conducted in accounts/wallets that they controlled.  

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 23 of 55



24 
 

iii. Misstatements regarding NovaTech’s legitimacy.  
 

81. Throughout the Relevant Period, the Petions and NovaTech made false and 

misleading statements to investors purporting to portray NovaTech as a legitimate financial 

services company. The following are examples of just some of these misrepresentations. 

82. In a slide deck dated October 2021 that was posted to the back office—which 

Cynthia Petion drafted and Eddy Petion reviewed and participated in drafting—NovaTech stated 

that it was a “[l]egally registered hedge fund.” On July 15, 2022, NovaTech repeated this statement 

in a post published to investors on its Telegram channel, which the Petions controlled.  

83. In a March 25, 2020 WhatsApp message to prospective investors, Cynthia Petion 

stated that “[w]e are registered in USA as a hedge fund and money management company.” Eddy 

Petion sent this same message to prospective investors via WhatsApp on March 25, 2020. In a 

Zoom presentation on May 4, 2022, intended for prospective investors and posted on YouTube, 

Cynthia Petion stated that, “[i]n the United States, we’re registered as a hedge fund company.”   

84. In a March 26, 2020 WhatsApp message to prospective investors, Cynthia Petion 

represented that “[w]e are registered Brokers” at NovaTech.  

85. As the Petions and NovaTech knew, or were severely reckless in not knowing, these 

statements were false at the time they were made. Neither NovaTech nor the Petions were 

registered with the SEC or with any regulatory authority in the United States as a “hedge fund,” 

“money management company,” investment adviser, broker, or dealer. At a minimum, these 

statements were highly misleading, because they created the false impression that NovaTech was 

a legitimate financial services company that operated in compliance with U.S. laws and regulations 

and under the oversight of U.S. regulators, when in fact, it operated as an unregistered entity and 

a fraudulent crypto trading investment and pyramid scheme.  

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 24 of 55



25 
 

iv. Misstatements regarding the safety and security of the investment.  
 

86. Throughout the Relevant Period, the Petions and NovaTech also made false and 

misleading statements to investors regarding the safety and security of their investments with 

NovaTech. The following are examples of just some of these misrepresentations. 

87. In the Updated Compensation Plan dated October 2020—described in paragraph 

41 above—NovaTech and the Petions claimed that investors could withdraw their assets from 

NovaTech at any time, and that such withdrawal requests would be processed within 24–48 hours 

if withdrawn from the Trading Account and 7–14 business days if withdrawn from the Bonus 

Account. Similarly, marketing decks made available to investors in the back office throughout the 

Relevant Period—including, among others, a January 2022 Affiliate PowerPoint presentation 

further described in paragraph 68 above and an October 2021 slide deck further described in 

paragraphs 40 and 82 above—contained the representation that there were “no withdrawal limits.”  

88. In a Zoom presentation on May 5, 2022, which was posted to YouTube, Cynthia 

Petion stated that, “[i]n this program, you’re in profit from day one, because again you have access 

to that capital.” 

89. As the Petions and NovaTech knew, or were severely reckless in not knowing, these 

statements were false, or at least misleading, at the time they were made because they created for 

investors the false impression that NovaTech’s disclosed business model could fund investor 

withdrawals with minimal restrictions. In reality, because the Petions and NovaTech were not 

trading enough capital and were not generating enough profits from that trading to satisfy the 

weekly returns they claimed to be earning, NovaTech’s ability to satisfy investor withdrawal 

requests depended on its continued recruitment of new investors and new investments. 

Consequently, NovaTech and the Petions did not have the capital to honor all withdrawal requests 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 25 of 55



26 
 

as promised and represented to investors. Inevitably, their representations to the contrary to 

investors proved false when the new investments raised could not keep pace with the assets that 

other investors sought to withdraw, eventually leading to the collapse of the scheme.      

v. Misstatements in response to investor concerns.  
 

90. In furtherance of the fraudulent scheme, Cynthia Petion also made false and 

misleading statements to assure investors that the withdrawal issues that NovaTech was 

experiencing in late 2022 and early 2023 were not indicative of fraud. These misstatements helped 

enable NovaTech and the Petions to continue operating their fraudulent scheme and to bilk 

investors of millions of dollars’ worth of additional crypto assets invested.  

91. On February 28, 2023, a Promoter Defendant (Dunbar) posted to his Vimeo channel 

a voice memo from Cynthia Petion intended for NovaTech investors and promoters. In the voice 

memo, Cynthia Petion blamed delays in withdrawals on “everything going on in the market” and 

system downtime due to the volume of investor deposits and withdrawals. She continued: 

I wish I could give people the calmness that we ourselves feel internally knowing 
that things are under control and improving every day. . . . No business allows 
people to just withdraw huge sums of money at free will. It’s not our intention to 
not give people their capital. However, people need to understand the nature of the 
business. And if money is trading and everybody wants to panic and withdraw and 
do everything else, it’s going to cause a backlog in doing so. Because we have to 
forcibly close trades to release and that’s what we’ve been trying not to do. You 
guys have seen the market recently whether somebody’s trading or not trading, 
whatever, there’s freezes going on all over the place. So we’re not doing anything 
that’s not normal. 
 
92. As Cynthia Petion knew or was severely reckless in not knowing, these statements 

were false or misleading at the time they were made. Among other things, investors’ assets were 

not tied up in trading as Cynthia Petion represented, because, as discussed, NovaTech deployed 

only a small percentage of investors’ assets towards trading. As Cynthia Petion knew or was 

severely reckless in not knowing, investors experienced issues withdrawing their assets from 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 26 of 55



27 
 

NovaTech—not because assets were tied up in trades or due to market issues—but primarily 

because NovaTech was collapsing and lacked the assets to satisfy all investor withdrawal requests. 

G. The Promoter Defendants Marketed NovaTech to Investors.  

93. The Promoter Defendants—including Zizi, Corbett, Sampson, Dunbar, Garofano, 

and Hadley—played a critical role in helping the Petions distribute the NovaTech investment 

offering to investors. As further discussed below, the Promoter Defendants marketed and offered 

the NovaTech investment to investors, recruited and maintained a wide network of “downline” 

investors, many of whom became recruiters themselves and brought in additional investors, and 

received substantial commission payments and bonuses in connection with their efforts to 

distribute the NovaTech investment offering to investors.  

i. The Promoter Defendants solicited investors to invest in NovaTech.  
 

94. The Promoter Defendants rose to the highest ranks in the NovaTech MLM program, 

including four “Two Star Ambassadors” (Zizi, Corbett, Garofano, and Sampson), and two “One 

Star Ambassadors” (Dunbar and Hadley).  

95. A Two Star Ambassador was the highest of nine ranks in NovaTech’s MLM 

program and required, among other things, “group volume”1 of at least $100 million in crypto 

assets invested by the promoter’s downline. A One Star Ambassador was the second highest rank 

in NovaTech’s MLM program and required, among other things, “group volume” of at least $50 

million in crypto assets. Aside from the commissions that promoters received from successfully 

recruiting others to invest in NovaTech, promoters also stood to earn a “rank achievement bonus” 

 
1 As used by NovaTech, group volume referred to the amount of crypto assets invested by a 
promoter’s downline, including crypto assets that investors in the promoter’s downline contributed 
or transferred to NovaTech and any purported trading profits or commissions that investors in the 
promoter’s downline chose to “rollover” or reinvest.  

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 27 of 55



28 
 

for achieving the next highest promoter rank. For example, upon achieving the rank of Two Star 

Ambassador, a promoter earned $100,000; upon achieving the rank of One Star Ambassador, a 

promoter earned $50,000.  

96. As further described below, each Promoter Defendant: (a) received commissions 

and/or other transaction-based compensation from NovaTech for successfully recruiting new 

investors; (b) regularly participated in securities transactions for NovaTech at key points in the 

chain of distribution; (c) provided advice to NovaTech investors and prospective investors 

regarding the merits of investing and reinvesting in NovaTech; and (d) actively marketed and 

promoted the NovaTech investment opportunity to investors and prospective investors.     

a. Martin Zizi 

97. Zizi was a Two Star Ambassador. He acted as a promoter for NovaTech between 

approximately October 2019 and at least February 2023. Before NovaTech, he promoted and 

solicited investors for at least two other securities issuers: AWS and ZeekRewards.2 As a 

NovaTech promoter, Zizi directly recruited at least 30 investors to invest in NovaTech, and he 

developed and maintained a downline that totaled approximately 120,000 to 140,000 investors. 

Though Zizi broadly promoted NovaTech, a significant number of investors whom he recruited 

into NovaTech were from the Haitian-American community. 

98. Zizi promoted NovaTech through email and his personal website and by, among 

other means, organizing and appearing in four weekly Zoom sessions: two (in English and in 

Haitian Creole) aimed at recruiting new investors (“opportunity calls”) and two (one in English, 

the other in Haitian Creole) aimed at training downline promoters to recruit investors (“training 

 
2 ZeekRewards was a fraudulent scheme that the SEC halted in 2012. See SEC v. Rex Venture 
Grp., LLC d/b/a ZeekRewards.com, No. 3:12-cv-0519 (W.D.N.C. 2012).  

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 28 of 55



29 
 

calls”). Zizi also hosted multiple in-person events for his vast NovaTech downline to attend. For 

example, in November 2022, Zizi hosted and was the keynote speaker at a NovaTech “Gratitude 

Gala” in Orlando, and on January 21, 2023, he hosted another NovaTech gala in Atlanta. Through 

these efforts, Zizi solicited existing and prospective investors to invest and/or reinvest in 

NovaTech, provided advice relating to investing in NovaTech, made statements or opinions 

relating to the merits of investing and/or reinvesting in NovaTech, trained investors how to create 

a NovaTech account, and answered investor questions. 

99. Like the Petions, Zizi often employed religious overtones and appealed to the 

financial freedom and independence that investing in NovaTech purportedly offered investors. As 

an example, in a video presentation posted to YouTube and dated January 21, 2022, Zizi told 

investors and prospective investors that the Petions are “the people that God g[a]ve the vision to 

start this company.” During that presentation, he further advised:  

And it’s very difficult to make a decision to take a little bit of your hard-earned 
money, and this is why I make you comfortable in a sense that with NovaTech, 
there are different levels. And Pastor Bob just shows you that you could start as low 
as $500 all the way down to a million bucks. It’s based on where you are at and 
how comfortable you are. Now, we do know there are some people are going 
through some financial struggle that probably lost their job during the pandemic 
and are looking for a solid way to improve their financial wellbeing. Based on our 
experience with the owners of the company and with the robots who’s been blessing 
us for the past 28 going on 29 months, we feel comfortable presenting this project 
as a way that will change our lives. 
 
100. As another example, in a January 3, 2021 video presentation posted to YouTube, 

Zizi told investors and prospective investors of NovaTech:  

You need to take ten percent of your paycheck and get that ten percent to work for 
you, and that’s the term, and I got it really right from the book when we talk about 
having your money making babies for you. Find a vehicle that can grow that ten 
percent over and over. Find a vehicle, do you—and we find a vehicle. Now, we 
have to fund multiple vehicles, but we have one solid one which you are sitting on 
right now which is NovaTech, and having that vehicle spilling out money for you. 
One key thing is said in that lecture was that you have to make sure that the vehicle 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 29 of 55



30 
 

that you are using, the person or the director of that vehicle know well about money. 
They know how to have money work for you. . . . Now, it’s said in the book a 
minimum of ten percent. So, you’ve got to take ten percent of your money and have 
it work for you, and you already know how it’s going to work for you by putting it 
in your trading account, and once you have that done, the second – the third step is 
for you to take the babies of the money that is making for you, and then put those 
babies back to work where we get compound interest, having money working for 
you, making babies every single week. 
 

b. James Corbett 

101. Corbett was a Two Star Ambassador. He acted as a promoter for NovaTech 

between approximately August 2020 and February 2023. Corbett was a top AWS promoter that 

Cynthia Petion directly recruited to NovaTech. He has promoted and solicited investors for at least 

one other dubious securities issuer that operated an MLM program: AWS. As a NovaTech 

promoter, Corbett directly solicited and sponsored at least 21 investors to invest in NovaTech, and 

he developed and maintained a downline at NovaTech that totaled approximately 80,000 investors. 

Corbett aggressively promoted NovaTech and recruited investors through weekly Zoom meetings, 

which he promoted on social media, as well as through his personal website. Through these efforts, 

Corbett solicited existing and prospective investors to invest and/or reinvest in NovaTech, 

provided advice relating to investing in NovaTech, and made statements or opinions relating to 

the merits of investing and/or reinvesting in NovaTech. At the end of his Zoom meetings with 

investors and prospective investors, Corbett would typically hold a Q&A session where he 

answered investor questions.  

102. As an example, in a May 12, 2022 video presentation that Corbett titled “Why 

NovaTech is the BEST Opportunity, by Global Ambassador James Corbett,” Corbett told investors 

and prospective investors: “NovaTech was, simply put, designed for the common man to be 

successful at.” In a video presentation to NovaTech investors and prospective investors dated 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 30 of 55



31 
 

February 19, 2022, Corbett opined: “A thousand dollars for one year, you can turn into $5,410.” 

He further assured investors and prospective investors:  

So look at this, and don’t be scared because you’ve finally found a place that not 
only are you going to see it’s very easy, extremely easy to use, you don’t need to 
go to college to learn how to do NovaTech. You sit down with a leader for an hour 
and you’ll know -- not even an hour -- half-an-hour -- and you’ll know the basics 
on how to be successful in this program. I mean it doesn’t take a big learning curve. 
But try to give yourself a week or two to at least understand it, right? 
 

c. John Garofano 

103. Garofano was a Two Star Ambassador. He acted as a promoter for NovaTech 

between approximately January 2021 and February 2023. As a NovaTech promoter, Garofano 

directly solicited and sponsored at least 12 investors to invest in NovaTech, and he developed and 

maintained a downline of investors who collectively invested and/or reinvested at least $100 

million in crypto assets into NovaTech. Garofano worked closely with Corbett, who recruited 

Garofano to invest in and join NovaTech. Like Corbett, Garofano aggressively promoted 

NovaTech and recruited investors through weekly Zoom meetings. Through these efforts, 

Garofano solicited existing and prospective investors to invest and/or reinvest in NovaTech, 

provided advice relating to investing in NovaTech, and made statements or opinions relating to 

the merits of investing and/or reinvesting in NovaTech. At the end of his Zoom meetings, he (along 

with Corbett) typically held a Q&A session where he answered investor questions. 

104. As an example, in a video presentation titled “NovaTech PAMM Account 

Presentation_Earn Passive Income” and uploaded to Vimeo on or about July 2, 2022, Garofano 

advised investors and prospective investors, among other things:  

There’s no skills required to trade unlike other platforms…. 
 
The company provides customers with affordable financial solutions including 
trading the trading of cryptocurrencies and forex online and some of the using some 
of the most sophisticated technologies like MetaTrader platform….  

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 31 of 55



32 
 

 
 [O]ne of the deepest liquidity pools in the industry…. 
 
They’re using professional software and professional management team…. 
 
Really like a mutual fund…. 

 
NovaTech has expert traders…. 
 
About 70-80% profit wins on their trades…. 
 
So it’s not tied up in any contract if I’ve done contracts before with other type of 
investments, especially with mining cryptocurrency mining if you’re familiar with 
that and that’s locked up, you can’t you don’t have access to it. Once you invest 
with NovaTech, you have a hundred percent access at all times to your balances. 
What I do recommend, this is what I do.  I teach this or explain this to my people I 
get in is, you know, add a little bit more each month or each week or every pay 
period or when you can because you really want to get these balances up a little bit 
more towards the bronze the silver area [referring to investment packages] to make 
it really worthwhile…. 
 

d. Corrie Sampson 

105. Sampson was a Two Star Ambassador. She acted as a promoter for NovaTech 

between approximately July 2021 and June 2023. She co-founded “Team Diamond,” the brand 

under which she promoted NovaTech. Sampson directly solicited and sponsored approximately 

35–40 investors and had over 50,000 investors in her downline. Sampson aggressively promoted 

NovaTech primarily through weekly Zoom meetings, as well as through phone, text message, and 

Telegram. Certain Team Diamond Zoom presentations were recorded and then posted to YouTube. 

On April 17, 2022, Sampson was one of three women who joined Cynthia Petion in a “Boss 

Ladies” Zoom webinar that was open to the public and during which Sampson described, among 

other things, how she had been successful in building Team Diamond. Through these and other 

efforts, Sampson solicited existing and prospective investors to invest and/or reinvest in 

NovaTech, provided advice relating to investing in NovaTech, made statements or opinions 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 32 of 55



33 
 

relating to the merits of investing and/or reinvesting in NovaTech, trained and assisted investors 

on how to create an account, and answered investor questions.   

106. As an example, in a February 21, 2022 video presentation, Sampson advised 

investors and prospective investors of NovaTech: “This will change your lives, not just for you 

but for generations to come. We are able to create generational wealth here, family. You want to 

leave a legacy, get started. Get started right away.” Similarly, in her weekly Zoom presentations, 

Sampson often used an online compound interest calculator to demonstrate how much investors 

stood to earn based on NovaTech’s purported trading results.   

e. Dapilinu (“Dap”) Dunbar 

107. Dunbar was a One Star Ambassador. He acted as a promoter for NovaTech between 

approximately September 2021 and May 2023. He has promoted and/or been involved in at least 

30 other network marketing businesses that focus on crypto assets. As a NovaTech promoter, he 

directly solicited and sponsored at least 110 investors to invest in NovaTech, and he developed 

and maintained a downline of at least 10,000 investors. Dunbar, who Hadley recruited into 

NovaTech, was a member of Team Diamond, and frequently appeared as a presenter in Team 

Diamond’s weekly Zoom presentations to prospective investors. Dunbar aggressively recruited 

investors through Telegram, Zoom meetings, and videos he posted on a Vimeo channel he 

operated. Dunbar used his Vimeo channel to promote NovaTech and provide updates to his 

downline. Through these and other efforts, Dunbar solicited existing and prospective investors to 

invest and/or reinvest in NovaTech, provided advice relating to investing in NovaTech, made 

statements or opinions relating to the merits of investing and/or reinvesting in NovaTech, trained 

investors on how to create an account, and answered investor questions. On occasion, Dunbar also 

represented to investors and prospective investors that he was assisting NovaTech with clearing 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 33 of 55



34 
 

tech support tickets submitted by investors in order to minimize the delays in processing investors’ 

withdrawal requests.  

108. In January 2023, Dunbar emceed NovaTech’s “New Year’s” live YouTube webinar 

that featured Cynthia Petion and had over 4,000 viewers. As another example, in a YouTube video 

posted on April 2, 2023, Dunbar advised investors and prospective investors about “seven ways 

that NovaTech will pay you.” He further advised about how NovaTech worked, its alleged 

profitability, and how investors could make money by investing in NovaTech. And in the course 

of promoting NovaTech, Dunbar further advised prospective investors about the merits of 

obtaining investment exposure to crypto asset markets through NovaTech:  

[T]he crypto market is where you want to be, okay? Do not let the outside voices 
distract you from the potential of what you can earn…. And with that being said, 
guys, your future, freedom, and dreams start right now. Dream big…. Guys, I’m 
telling you, build your future, guys, alright? Use Bitcoin. Stack your Bitcoin…. 
Retirement is going away. If you are in the U.S., Social Security is going away. 
There are going to be other ways for you to secure your future. And I’m telling you 
this just happens to be one of those ways. 
 

f. Marsha Hadley 

109. Hadley was a One Star Ambassador. She acted as a promoter for NovaTech 

between approximately 2021 and June 2023. On information and belief, she directly solicited and 

sponsored investors to invest in NovaTech, including Dunbar. And her rank as a One Star 

Ambassador implies that she developed and maintained a downline of investors at NovaTech who 

collectively invested and/or reinvested at least $50 million in crypto assets into NovaTech.3 Hadley 

also co-founded Team Diamond with Sampson. Like Sampson, Hadley used Zoom, Telegram, 

WhatsApp, and YouTube to aggressively promote NovaTech and recruit investors. Through these 

 
3 As explained in footnote 1 above, this $50 million could include investments of newly 
contributed crypto assets, plus any purported trading profits or commissions that investors in 
Hadley’s downline chose to “rollover.” 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 34 of 55



35 
 

and other efforts, Hadley solicited existing and prospective investors to invest and/or reinvest in 

NovaTech, provided advice relating to investing in NovaTech, and made statements or opinions 

relating to the merits of investing and/or reinvesting in NovaTech.   

110. As an example, in a February 21, 2022 video presentation to investors and 

prospective investors of NovaTech, Hadley stated:  

Those of you that’s in the stock market, stocks were going down, down, down, like 
crazy. Cryptocurrency was going down, down, down like crazy. And then as we 
look at it, we still came out on top. NovaTech, we had a 1.85 percent profit? Okay. 
Sign me up, all day, every day. So why is NovaTech different, ladies and 
gentlemen? …  
 
Number one, no expiration date and no earning caps. We can earn whatever you 
want to earn for yourself and your family, the company says we don’t want to limit 
anyone. Whatever your desires are that you need to come in every month in profits, 
have at it. You can trade as long as you want, no repurchase requirements. And we 
can cancel at any time. So I was talking to the cofounder of our team, Corrie J., 
right? Call her Corrie J. bad to the bone Sampson, I said, Corrie J., wait a second, 
so we’re not doing any trading at all; we don’t have to have any knowledge of 
cryptocurrency or trading. The experts is doing everything. We get paid every 
Friday. Who would want to cancel? 
 

ii. The Promoter Defendants were compensated for soliciting investors.  
 

111. Each Promoter Defendant received commissions from NovaTech for recruiting 

new investors and for raising crypto asset investments in NovaTech. The Promoter Defendants 

received these commissions pursuant to NovaTech’s MLM compensation structure, which the 

Petions designed, implemented, and operated.  

112. NovaTech’s MLM compensation structure provided substantial incentives for the 

Promoter Defendants and other promoters to recruit new investors. For example, by recruiting a 

“direct referral,” i.e., a person directly sponsored by a promoter and thus positioned one level 

below that promoter in the downline, such a promoter stood to be paid: (i) 1% to 5% of the direct 

referral’s investment (the “direct referral bonus”); (ii) 0.5% to 5% of the direct referral bonuses 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 35 of 55



36 
 

earned by any recruits up to seven levels down in the promoter’s downline; (iii) 0.25% to 5% of 

the trading “profit” paid to recruits up to nine levels down in the promoter’s downline; (iv) 0.25% 

to 5% of the service fees paid by recruits up to nine levels down in the promoter’s downline; and 

(v) additional “fast track” and “rank achievement” bonuses that incentivized quickly recruiting a 

large downline.  

113. NovaTech referred to this complicated compensation structure as “7 ways to get 

paid.” NovaTech promoted this heavily, including in the marketing slide deck that Cynthia Petion 

prepared (a slide from which is depicted below) and which was made available to investors in the 

back office. Each of these “7 ways to get paid” resulted in transaction-based compensation being 

paid to each Promoter Defendant and other promoters at NovaTech to incentivize them to bring 

additional investors and/or investments into NovaTech.  

 

114. Ultimately, each Promoter Defendant received commissions and/or other 

transaction-based compensation pursuant to NovaTech’s Compensation Plan and/or Updated 

Compensation Plan (together, the “Compensation Plans”), which are further detailed in paragraph 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 36 of 55



37 
 

84 above. Given the significant commissions they were credited through NovaTech’s 

Compensation Plans, the Promoter Defendants were able to withdraw significant compensation 

from NovaTech in comparison to the amount of crypto assets they invested. Zizi, Sampson, 

Garofano, Dunbar, and Corbett each withdrew more than the amount each invested in NovaTech. 

On information and belief, Hadley also withdrew more than she invested.  

H. Four Promoter Defendants Engaged in Deceptive Acts in Furtherance of NovaTech’s 
Fraudulent Scheme in the Face of Red Flags. 

115. Four of the Promoter Defendants—Zizi, Corbett, Dunbar, and Sampson—became 

aware of red flags putting them on notice that NovaTech was not a legitimate investment program. 

These Promoter Defendants faced a choice: cease promoting NovaTech in light of the alarming 

information they knew or follow the strong financial motivations they had under NovaTech’s 

Compensation Plans to ignore the red flags and continue to promote NovaTech. Each of these four 

Promoter Defendants chose the latter. In the face of the red flags, they continued to promote and 

support the Petions and NovaTech’s fraudulent scheme and engaged in other deceptive acts in 

furtherance of the scheme. In doing so, they helped create the false impression that NovaTech was 

a legitimate investment opportunity, when, in fact, it was on the brink of collapse. These Promoter 

Defendants, thus, helped the Petions and NovaTech continue operating, recruiting promoters, and 

raising new investments from unwitting investors.  

i. Zizi engaged in conduct in furtherance of the fraudulent scheme.  
 

116. Zizi became aware of the Canadian province fraud warnings at or around the time 

they were issued in October 2022. He became aware of the California Order at or around the time 

it was issued on November 22, 2022. And he became aware of the delays and pause in withdrawals 

at or around the time they occurred in November 2022 and early 2023.  

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 37 of 55



38 
 

117. Zizi testified that Cynthia Petion told him that there were times when NovaTech 

was not profitable, and that when reporting trading results, she used profits from other profitable 

weeks to avoid reporting a loss or lower profit in the weekly ROI figures.  

118. Despite serving in a role where he advised investors and prospective investors about 

the merits of the NovaTech investment, Zizi did not adequately investigate these red flags. In 

regard to the Canadian province fraud warnings and California Order, for example, Zizi did 

nothing more than take Cynthia Petion at her word that “legal is on top of it.”  

119. In the face of these red flags, Zizi at least negligently continued to promote and 

solicit investors for NovaTech. Indeed, Zizi continued to promote NovaTech and solicit investors 

for NovaTech until at least February 2023. He testified that he continued holding NovaTech 

opportunity calls, aimed at recruiting new prospective investors to invest in NovaTech, until 

February 2023, and that he continued to use his personal marketing website to promote NovaTech 

until February or March of 2023. He also testified that he continued doing training webinars with 

NovaTech investors until April or May of 2023.   

120. After becoming aware of the facts referenced in paragraph 117 above, Zizi failed 

to disclose this material information about how Cynthia calculated and reported the weekly ROI 

numbers to investors. Acting as an unregistered broker, Zizi provided advice to investors about the 

merits of investing in NovaTech and held himself out as having special insight and knowledge 

about NovaTech through his relationship with the Petions. He used this position to market and 

promote NovaTech, encourage investors to invest, and advise investors about investing.  

121. In addition, Zizi testified that he generally told investors, in presentations to and/or 

communications with investors throughout the Relevant Period, that the ROI varied every week 

based on how NovaTech performed. On information and belief, Zizi was aware of the facts 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 38 of 55



39 
 

referenced in paragraph 117 above at the time of at least some of the instances in which he made 

this representation to investors, but he failed to disclose this material information to investors at 

that time or in subsequent communications with investors.  

122. Zizi also actively sought to either discredit or undermine the California Order. For 

example, in a WhatsApp chat with a group of high-level NovaTech promoters (who also were 

investors), Zizi sent a message on or about November 27, 2022 that discredited the California 

Order on the basis that it was unsigned. Zizi also testified that, on unspecified dates, he told 

California investors to circumvent the California Order by forming a Wyoming limited liability 

company and opening an account in that entity’s name.    

123. Zizi had financial motivations to ignore the red flags and continue to promote 

NovaTech. Zizi continued to benefit from investors joining or reinvesting in NovaTech. Zizi’s last 

known direct recruit that he solicited and sponsored invested in NovaTech on or about January 4, 

2023. On information and belief, Zizi’s downline of investors continued to invest and/or reinvest 

in NovaTech, as well as solicit and sponsor new investors, until NovaTech shut down its U.S. 

operations in May 2023. Zizi also continued to make withdrawals from NovaTech after becoming 

aware of the red flags through at least the beginning of 2023. 

ii. Corbett engaged in conduct in furtherance of the fraudulent scheme. 
 

124. Through his experience with AWS, Corbett was aware of the signs of a fraudulent 

MLM crypto asset investment program. For example, he knew that investors in AWS suffered 

losses after AWS paused or delayed investor withdrawals and the TSSB issued a cease-and-desist 

order finding that AWS violated Texas securities laws.  

125. After signing up to promote NovaTech’s program, Corbett became aware of 

allegations made against NovaTech. As early as August 2020, for example, Corbett was aware of 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 39 of 55



40 
 

social media posts in the MLM space accusing NovaTech of being a scam or Ponzi scheme, which 

he affirmatively attempted to refute through his own comments and posts online. For example, on 

or around August 25, 2020, Corbett posted a comment to an online article published on 

BehindMLM.com, a website that purports to be a “resource to people curious about the MLM 

industry and the companies that exist within it.”4 In response to other posts and comments to the 

article that questioned the legitimacy of NovaTech, Corbett wrote:  

Like the opinion editor and Not a real reporter you give us your opinion without 
talking to whom your [sic] bashing. I know for a fact you did Bias research on 
Nova. Tell me what slim [sic] gave you your info? I was in AWS for 3 years and 
can assure everyone Cynthia was NEVER a [sic] owner. All she ever did is try and 
help everyone. Nova tech was developed to clear Cynthia’s name. I can tell you 
this she will stop at nothing to prove you wrong. As for the slime who paid you to 
post this FALSE evaluation, I suspect he lost money (who hasn’t lost money?)…. 
Sincerely James Corbett Servant leader.   
 
126. As another example, in January 2021, Corbett received an email from a prospective 

investor asking: “[h]ow do we know that real trading takes place and this is not just a Ponzi using 

new money to pay old?” Corbett testified that this was a question he heard “quite frequently” while 

promoting NovaTech.   

127. Corbett also became aware of the Canadian province fraud warnings at or around 

the time they were issued in October 2022. He became aware of the California Order at or around 

the time it was issued on November 22, 2022. And he became aware of the delays and pause in 

withdrawals at or around the time they occurred in November 2022 and early 2023. These were 

the same or similar red flags as were present at AWS before its collapse.  

128. Corbett was also aware that the crypto asset markets fluctuated throughout the 

Relevant Period, with various times where crypto assets that NovaTech purported to trade dropped 

 
4 “About BehindMLM,” https://behindmlm.com/about/ (last visited Aug. 7, 2024). 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 40 of 55



41 
 

in value. Yet, as Corbett knew, NovaTech purported to report weekly trading profits throughout 

the Relevant Period. 

129. The red flags discussed in paragraphs 124–128 above put Corbett on notice that 

NovaTech was not a legitimate investment program, was defrauding investors, and/or was making 

false or misleading statements or omissions to investors. Despite serving in a role where he advised 

investors and prospective investors about the merits of the NovaTech investment and holding 

himself out as having special knowledge and insight into NovaTech, Corbett did nothing to 

independently investigate these red flags or allegations levied against NovaTech. For example, 

Corbett testified that he regularly asked Cynthia Petion for additional information about 

NovaTech’s trading, including as early as January 2021, but she refused to provide it. He also 

testified that he did nothing to investigate the California Order aside from asking Cynthia Petion 

about it, who merely told him the Order was not final and had not been served on NovaTech yet. 

He did not even bother to search online for the Order.   

130. Well after learning of these red flags, Corbett continued to promote and solicit 

investors for NovaTech through at least May 2023. He also continued to support NovaTech in the 

face of red flags indicating that it was not operating as a legitimate investment program.   

131. For example, Corbett continued to promote NovaTech on his personal website until 

at least June 2023. Corbett also continued to advise and support his downline of NovaTech 

investors until at least May 2023. In December 2022, for instance, he sent a WhatsApp message 

to other NovaTech leaders discussing how his “group” in the Canadian provinces where the fraud 

warnings were issued “has about 1700 members and was hoping to leave [their investments] in 

unless they are told to withdraw.” He further wrote: “[t]he way Im [sic] reading this is if they are 

not asked to withdraw and close account then they can still trade.” On information and belief, he 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 41 of 55



42 
 

subsequently advised at least some of these investors about keeping their investments in 

NovaTech.  

132. As another example, in early January 2023, Corbett participated in a recorded 

interview with a YouTuber who runs the channel “Ponzi Patrol.” The interview was conducted via 

Zoom and was posted to the Ponzi Patrol YouTube channel on or about January 11, 2023. Corbett 

knew that the interview was recorded, would be posted online to the general public, and would 

address allegations that NovaTech was a Ponzi scheme.  

133. In the interview, Corbett held himself out as having a close relationship with the 

Petions and denied that NovaTech was a Ponzi scheme. He also addressed allegations and investor 

concerns relating to NovaTech, including concerns over delayed withdrawals, the Canadian 

province fraud warnings, and the California Order. The following are examples of some of the 

statements that Corbett made during the interview:  

I’ve been defending NovaTech for four years. I traveled the world with these people 
the three prior years. I know the development and what happened, and what they 
did to develop NovaTech. I know the trading and the board meetings and how they 
go -- went about, and the story of how they opened up, and why they even opened 
up a trading certificate…. 
… 
First of all, California, they can still trade on this platform. They haven’t been 
stopped from trading. They’re still running their things.…Canada is shutting down 
there, but – but think about what you’re saying. They’re paying back everybody in 
Canada that was trading on their platforms, and it’s going on right now.  
…. 
They’re not a Ponzi scheme, because I know that they’re not running a Ponzi 
scheme. I know these people. I know they’re trading with the funds that 
they’re…receiving….   
 
134. Corbett did not “know that they’re not running a Ponzi scheme.” He did not know 

what, if any, trading NovaTech actually did. His statements further sought to refute or quell 

investor concerns about the regulatory scrutiny and withdrawal issues that NovaTech was 

experiencing at the time, even though he lacked direct knowledge or evidence to say, for example, 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 42 of 55



43 
 

that NovaTech was “paying back everybody in Canada.” His statements created the false and 

misleading impression that NovaTech was a legitimate investment program and that the issues it 

faced would pass and/or not prevent investors from recouping their investments. And he made 

these statements despite being aware of the red flags, acting as an unregistered broker to investors, 

and holding himself out to investors as having a special relationship and access to NovaTech and 

its founders and special insight into and knowledge of NovaTech’s operations.  

135. Individuals continued to invest and/or reinvest in NovaTech following Corbett’s 

deceptive acts and his awareness of the red flags. On information and belief, Corbett’s downline 

of investors continued to invest and/or reinvest in NovaTech, as well as solicit and sponsor new 

investors, until NovaTech shut down its U.S. operations in May 2023. 

iii. Dunbar and Sampson engaged in conduct in furtherance of the fraudulent 
scheme. 

 
136. Sampson and Dunbar, who together promoted NovaTech as part of Team Diamond, 

became aware of the Canadian province fraud warnings at or around the time they were issued in 

October 2022. They also became aware of the California Order at or around the time it was issued 

on November 22, 2022. And they became aware of the delays and pause in withdrawals at or 

around the time they occurred in November 2022 and early 2023. These red flags put Sampson 

and Dunbar on notice that NovaTech was not a legitimate investment program, was defrauding 

investors, and/or was making false or misleading statements or omissions to investors. Indeed, 

Dunbar testified that he knew, based on his experience with other failed crypto and MLM 

programs, that one sign that an MLM and/or crypto company is on the verge of collapse is when 

the company stops paying out as often as it previously did.  

137. Despite serving in a role where they advised investors and prospective investors 

about the merits of the NovaTech investment, Sampson and Dunbar did nothing to independently 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 43 of 55



44 
 

investigate these red flags. Sampson even testified that she took no steps to determine whether the 

California Order was legitimate.   

138. Dunbar and Sampson continued to promote and solicit investors for NovaTech well 

after becoming aware of the red flags. Specifically, they both continued to promote NovaTech and 

appear on NovaTech promotional Zoom meetings until at least May 2023.   

139. Sampson and Dunbar also sought to discredit or undermine the California Order. 

For example, in a video presentation hosted by Sampson and posted to the Team Diamond 

Telegram channel on or about May 20, 2023, Dunbar stated: 

[W]e allowed a person, not a state . . . a person who filed a cease and refrain that 
meant diddlysquat to scare hundreds of thousands of people into thinking 
NovaTech was going away because they got a cease and refrain in California.  
Never got signed by anyone in California.5 It was like you going and putting a 
restraining order on someone by filing documentation and paying $89. 
 
140. At the end of Dunbar’s rant seeking to discredit the California Order, Sampson 

stated her agreement with Dunbar’s description of the California Order. She did so in her trusted 

position as the cofounder and leader of Team Diamond, to whom Dunbar directed his comments.   

141. Dunbar and Sampson also sought to undermine and quell investor concerns about 

withdrawal issues and encourage and advise investors and prospective investors to invest in 

NovaTech in spite of the red flags.   

142. For example, in or around March or April 2023, Dunbar posted a video “short” to 

his BTGi6 Telegram chat, which was subsequently posted to YouTube on or about May 29, 2023, 

 
5 The version of the California Order that was posted to the website of the California Department 
of Financial Protection and Innovation (“DFPI”) was/is unsigned, like other orders posted to 
DFPI’s website, consistent with DFPI’s policy of not publicly posting signed orders to avoid 
issues with forged/copied signatures. 
6 “BTGi” is shorthand for “Bridging the Gap Internationally,” an acronym that Dunbar used on 
social media and online.  

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 44 of 55



45 
 

titled “Novatechfx. Dap [Dunbar] and the CEO working on efficiency of the payouts. Listen”, 

where he appears with Cynthia Petion in what appears to be Panama. In this video, Dunbar claimed 

to be helping resolve support tickets so that NovaTech could resume processing investors’ 

withdrawal requests. On February 28, 2023, he posted to his Vimeo account a voice memo from 

Cynthia Petion, in which she blamed withdrawal delays on assets tied up in trades, technical issues, 

and market factors. Dunbar’s statements and actions created the false and misleading impression 

that the investors’ withdrawal issues would soon be resolved and were not cause for alarm. 

143. Likewise, Sampson sought to allay investor concerns over NovaTech’s withdrawal 

issues. In her May 20, 2023 video posted to the Team Diamond Telegram channel, Sampson 

advised investors to “just hang in there as long as we possibly need to.” She also advised: “[w]e’re 

gonna get paid again, y’all, and it won’t be long. I don’t know. No one told me that. That’s my 

thought, and it’s also my prayer.”  

144. In that same May 20, 2023 video, Dunbar and Sampson continued to promote 

NovaTech and advise investors and prospective investors to believe and invest in NovaTech:  

MR. DUNBAR: NovaTech is who we all believe in, and NovaTech is who we’re 
all going to continue to believe in until we have no reason to, and at this point we 
have every reason – 
 
MS. SAMPSON: Every reason 
 
MR. DUNBAR: -- to believe. All right? So -- 
 
MS. SAMPSON: Praise the lord.  
 
MR. DUNBAR: Queen, I’m going to go ahead and let you go for now, and then 
we’ll continue and dive and unpack a little more for that. So -- 
 
MS. SAMPSON: All right, young king. Well, I sure appreciate you letting me do 
that. You know? (Laughing) Good information there, baby, and just a good strong 
mindset. You know, it’s what it is that -- you know, that we need. It’s information 
that we need to hear, it’s very strong, it’s very powerful. And if you really embellish 
and take that in it really and truly can be lifesaving.  

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 45 of 55



46 
 

 
145. Dunbar and Sampson had strong financial motivations for willfully ignoring the red 

flags and continuing to promote NovaTech. For example, Sampson reached the rank of Two Star 

Ambassador on January 25, 2023, which earned her a bonus of $100,000. And despite advising 

investors to “just hang in there,” Sampson privately began withdrawing heavily from NovaTech 

starting on January 2, 2023, and continuing through March 2023, during which time she ultimately 

withdrew nearly $1 million in crypto assets from NovaTech. Likewise, Dunbar continued to 

withdraw from NovaTech until as late as March or April 2023.    

146. Dunbar and Sampson also discouraged investors from contacting regulators or 

government authorities about NovaTech. In a video posted to his Vimeo channel in May 2023 

(which also became available on YouTube), Dunbar stated:   

Let me tell you guys, some of you saying, “I’m gonna call the SEC, I’m gonna call 
the CFTC.” Go ahead and call and see if everybody doesn’t lose their money. No 
institution higher up wants to see people win. We have to protect what we have and 
we do that by being patient. 
 
147. In a YouTube live stream interview on May 16, 2023 that received over 9,000 

views, Dunbar admonished concerned investors: “[t]he more negativity you put out there, the more 

at risk our funds are.”  

148. Like Dunbar, Sampson also discouraged at least one concerned investor from 

contacting the SEC. During a call with the investor in January 2023, the investor asked Sampson 

if they could share her contact information with the SEC. Sampson refused and responded: “[w]hy 

would you do that? Why would you share our information with a government agency? Because 

you haven’t been able to get your withdrawals? Just like others have not been able to get their 

withdrawals? Are you doing it out of spite? Out of spite?”    

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 46 of 55



47 
 

149. Individuals continued to invest and/or reinvest in NovaTech’s scheme following 

Sampson’s and Dunbar’s deceptive acts and their awareness of the red flags. And Sampson and 

Dunbar continued to benefit from the same. Based on the information available at this time, at least 

two of Dunbar’s direct recruits invested in NovaTech after November 2022. Although Sampson’s 

last known direct recruit invested in NovaTech on or around November 15, 2022, she was 

promoted to Two Star Ambassador on January 25, 2023, which, according to NovaTech’s terms, 

means that her downline investors continued to invest and reinvest after November 2022 to allow 

her to cross the $100 million threshold to reach the rank of Two Star Ambassador in January 2023. 

On information and belief, Sampson’s and Dunbar’s respective downlines continued to invest 

and/or reinvest in NovaTech, as well as solicit and sponsor new investors, until NovaTech shut 

down its U.S. operations in May 2023.      

V. CLAIMS FOR RELIEF 

FIRST CLAIM FOR RELIEF 

Violations of Section 17(a)(1) of the Securities Act  
[15 U.S.C. § 77q(a)(1)] 

(Against NovaTech, the Petions, Corbett, Dunbar, and Sampson) 

150. The SEC re-alleges and incorporates paragraphs 1–149 above by reference as if 

fully set forth hereunder.  

151. By engaging in the conduct described herein, and as alleged in paragraphs 23–92 

above, the Petions and NovaTech, and as alleged in paragraphs 115–149 above, Corbett, Dunbar, 

and Sampson, directly or indirectly, in the offer or sale of securities, by the use of the means or 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 47 of 55



48 
 

instruments of transportation or communication in interstate commerce or by use of the mails, have 

employed a device, scheme, or artifice to defraud.   

152. With regard to the violations of Section 17(a)(1) of the Securities Act, Defendants 

NovaTech, the Petions, Corbett, Dunbar, and Sampson acted with scienter and engaged in the 

referenced acts knowingly and/or with severe recklessness.  

153. By reason of the foregoing, Defendants NovaTech, the Petions, Corbett, Dunbar, 

and Sampson have violated, and unless enjoined will continue to violate, Section 17(a)(1) of the 

Securities Act [15 U.S.C. § 77q(a)(1)]. 

SECOND CLAIM FOR RELIEF 

Violations of Section 17(a)(2) of the Securities Act [15 U.S.C. § 77q(a)(2)] 

(Against NovaTech, the Petions, and Zizi) 

154. The SEC re-alleges and incorporates paragraphs 1–149 above by reference as if 

fully set forth hereunder.  

155. By engaging in the conduct described herein, and as alleged in paragraphs 23–92 

above, the Petions and NovaTech, and as alleged in paragraphs 115–123 above, Zizi, directly or 

indirectly, in the offer or sale of securities, by the use of the means or instruments of transportation 

or communication in interstate commerce or by use of the mails, have obtained money or property 

by means of an untrue statement of a material fact or an omission to state a material fact necessary 

in order to make the statements made, in light of the circumstances under which they were made, 

not misleading.  

156. With regard to the violations of Section 17(a)(2) of the Securities Act, Defendants 

NovaTech, the Petions, and Zizi acted at least negligently. 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 48 of 55



49 
 

157. By reason of the foregoing, NovaTech, the Petions, and Zizi have violated, and 

unless enjoined will continue to violate, Section 17(a)(2) of the Securities Act [15 U.S.C. 

§ 77q(a)(2)]. 

THIRD CLAIM FOR RELIEF 

Violations of Section 17(a)(3) of the Securities Act  
[15 U.S.C. § 77q(a)(3)] 

(Against NovaTech, the Petions, Zizi, Corbett, Dunbar, and Sampson) 

158. The SEC re-alleges and incorporates paragraphs 1–149 above by reference as if 

fully set forth hereunder.  

159. By engaging in the conduct described herein, and as alleged in paragraphs 23–92 

above, the Petions and NovaTech, and as alleged in paragraphs 115–149 above, Zizi, Corbett, 

Dunbar, and Sampson, directly or indirectly, in the offer or sale of securities, by the use of the 

means or instruments of transportation or communication in interstate commerce or by use of the 

mails, have engaged in a transaction, practice, or course of business which operated or would 

operate as a fraud or deceit upon the purchaser.  

160. With regard to the violations of Section 17(a)(3) of the Securities Act, Defendants 

NovaTech, the Petions, Zizi, Corbett, Dunbar, and Sampson acted at least negligently. 

161. By reason of the foregoing, Defendants NovaTech, the Petions, Zizi, Corbett, 

Dunbar, and Sampson have violated, and unless enjoined will continue to violate, Section 17(a)(3) 

of the Securities Act [15 U.S.C. § 77q(a)(3)]. 

FOURTH CLAIM FOR RELIEF 

Violations of Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)]  
and Rules 10b-5(a) and (c) thereunder [17 C.F.R. §§ 240.10b-5(a) and (c)] 

(Against NovaTech, the Petions, Corbett, Dunbar, and Sampson) 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 49 of 55



50 
 

162. The SEC re-alleges and incorporates paragraphs 1–149 above by reference as if 

fully set forth hereunder. 

163. By engaging in the conduct described herein, and as alleged in paragraphs 23–92 

above, NovaTech and the Petions, and as alleged in paragraphs 115–149 above, Corbett, Dunbar, 

and Sampson, directly or indirectly, singly or in concert with others, in connection with the 

purchase or sale of securities, by the use of any means or instrumentality of interstate commerce, 

or of the mails or of any facility of any national securities exchange: 

• employed a device, scheme, or artifice to defraud; and/or  

• engaged in acts, practices, or courses of business which operated or would 

operate as a fraud or deceit upon any person. 

164. With regard to the violations of Section 10(b) of the Exchange Act and Rule 10b-

5(a) and (c) thereunder, NovaTech, the Petions, Corbett, Dunbar, and Sampson acted with 

scienter and engaged in the referenced acts knowingly and/or with severe recklessness. 

165. By reason of the foregoing, NovaTech, the Petions, Corbett, Dunbar, and Sampson 

have violated, and unless enjoined will continue to violate, Section 10(b) of the Exchange Act [15 

U.S.C. § 78j(b)] and Rules 10b-5(a) and (c) thereunder [17 C.F.R. §§ 240.10b-5(a) and (c)].  

FIFTH CLAIM FOR RELIEF 

Violations of Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)]  
and Rule 10b-5(b) thereunder [17 C.F.R. § 240.10b-5(b)] 

(Against NovaTech and the Petions) 

166. The SEC re-alleges and incorporates paragraphs 1–149 above by reference as if 

fully set forth hereunder. 

167. By engaging in the conduct described herein, and as alleged in paragraphs 23–92 

above, NovaTech and the Petions, directly or indirectly, singly or in concert with others, in 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 50 of 55



51 
 

connection with the purchase or sale of securities, by the use of any means or instrumentality of 

interstate commerce, or of the mails or of any facility of any national securities exchange, made 

untrue statements of material facts or omitted to state material facts necessary in order to make the 

statements made, in light of the circumstances under which they were made, not misleading.   

168. With regard to the violations of Section 10(b) of the Exchange Act and Rule 10b-

5(b) thereunder, NovaTech and the Petions acted with scienter and engaged in the referenced 

acts knowingly and/or with severe recklessness. 

169. By reason of the foregoing, NovaTech and the Petions have violated, and unless 

enjoined will continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 

10b-5(b) thereunder [17 C.F.R. § 240.10b-5(b)].  

SIXTH CLAIM FOR RELIEF 

Unregistered Securities Offerings in Violation of  
Sections 5(a) and 5(c) of the Securities Act [15 U.S.C. §§ 77e(a) and (c)] 

(Against all Defendants) 

170. The SEC re-alleges and incorporates paragraphs 1–149 above by reference as if 

fully set forth hereunder. 

171. By engaging in the acts and conduct alleged herein, each of the Defendants, directly 

or indirectly: 

• made use of the means or instruments of transportation or communication in 

interstate commerce or of the mails to sell, through the use or medium of any 

prospectus or otherwise, securities as to which no registration statement was in 

effect; and/or 

• for the purpose of sale or delivery after sale, carried or caused to be carried 

through the mails or in interstate commerce, by means or instrument of 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 51 of 55



52 
 

transportation, securities as to which no registration statement was in effect; 

and/or 

• made use of means or instruments of transportation or communication in 

interstate commerce or of the mails to offer to sell, through the use or medium 

of any prospectus or otherwise, securities as to which no registration statement 

had been filed. 

172. By engaging in the conduct described above, Defendants have violated, and unless 

restrained and enjoined, will continue to violate Sections 5(a) and 5(c) of the Securities Act [15 

U.S.C. §§ 77e(a) and 77e(c)]. 

SEVENTH CLAIM FOR RELIEF 

Unregistered Broker in Violation of 
Section 15(a) of the Exchange Act [15 U.S.C. § 78o(a)] 

(Against the Promoter Defendants) 

173. The SEC re-alleges and incorporates paragraphs 1–149 above by reference as if 

fully set forth hereunder. 

174. At various times during the Relevant Period and as further detailed and alleged in, 

among other places, paragraphs 93–149 above, each of the Promoter Defendants acted as a broker 

within the meaning of Section 3(a)(4) of the Exchange Act [15 U.S.C. § 78c(4)], and made use of 

the mails or the means or instrumentality of interstate commerce to effect transactions in, or to 

induce or attempt to induce the purchase or sale of, securities.  

175. During the Relevant Period and at all relevant times, none of the Promoter 

Defendants were registered with the SEC as a broker or dealer or as an associated person of a 

broker or dealer registered with the SEC, in accordance with Section 15(b) of the Exchange Act 

[15 U.S.C. §78o(b)]. Nor did any exemption from the broker registration requirements exist with 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 52 of 55



53 
 

respect to the securities, transactions, and/or any Defendants’ conduct alleged and described 

herein.  

176. By engaging in the conduct described above, each of the Promoter Defendants have 

violated, and unless restrained and enjoined will continue to violate, Section 15(a) of the Exchange 

Act [15 U.S.C. § 78o(a)]. 

VI. PRAYER FOR RELIEF 

177. WHEREFORE, the SEC respectfully requests that this Court enter a Final 

Judgment:  

• Permanently restraining and enjoining NovaTech and the Petions from 

violating, directly or indirectly, Sections 5(a), 5(c), and 17(a) of the Securities Act, Section 10(b) 

of the Exchange Act, and Rule 10b-5 thereunder; 

• Permanently restraining and enjoining Corbett, Dunbar, and Sampson from 

violating, directly or indirectly, Sections 5(a), 5(c), 17(a)(1), and 17(a)(3) of the Securities Act, 

Sections 10(b) and 15(a) of the Exchange Act, and Rule 10b-5(a) and (c) thereunder; 

• Permanently restraining and enjoining Zizi from violating, directly or 

indirectly, Sections 5(a), 5(c), 17(a)(2), and 17(a)(3) of the Securities Act and Section 15(a) of the 

Exchange Act; 

• Permanently restraining and enjoining Garofano and Hadley from violating, 

directly or indirectly, Sections 5(a) and 5(c) of the Securities Act and Section 15(a) of the 

Exchange Act; 

• Permanently restraining and enjoining NovaTech, the Petions, Zizi, Corbett, 

Sampson, Dunbar, Hadley, and Garofano—directly or indirectly, including but not limited to, 

through any entity owned or controlled by them—from: (i) offering, operating, or participating in 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 53 of 55



54 
 

any marketing or sales program in which the participant is compensated or promised compensation 

solely or primarily for (A) inducing another person to become a participant in the program; or (B) 

if such induced person induces another to become a participant in the program; and (ii) 

participating directly or indirectly in any offering of securities; provided, however, that, such 

injunction shall not prevent Cynthia Petion, Eddy Petion, Zizi, Corbett, Sampson, Dunbar, Hadley, 

or Garofano from purchasing or selling securities for their own personal accounts;   

• Ordering NovaTech and the Petions to disgorge all ill-gotten gains received 

as a result of the violations alleged herein, together with pre-judgment interest thereon, on a joint 

and several basis by and between NovaTech, Cynthia Petion, and Eddy Petion, pursuant to the 

Court’s equitable powers and Sections 21(d)(3), 21(d)(5), and 21(d)(7) of the Exchange Act [15 

U.S.C. §§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)]; 

• Ordering each Promoter Defendant to disgorge all ill-gotten gains he or she 

received as a result of the violations alleged herein, together with pre-judgment interest thereon, 

pursuant to the Court’s equitable powers and Sections 21(d)(3), 21(d)(5), and 21(d)(7) of the 

Exchange Act; 

• Ordering each Defendant to pay civil penalties pursuant to Section 20(d) of 

the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C. 

§ 78u(d)(3)]; and  

• Granting such other and further relief as this Court may deem appropriate, 

just, equitable, and/or necessary.  

VII. JURY DEMAND 
  

178. The SEC demands trial by jury in this action on all issues so triable. 

 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 54 of 55



55 
 

Dated: August 12, 2024   Respectfully submitted, 
 

/s/ Patrick Disbennett 
      Patrick Disbennett 
      S.D. Fla. Special Bar ID A5503234 

Securities and Exchange Commission 
801 Cherry Street, Suite 1900 
Fort Worth, Texas 76102 
Tel: (817) 266-9633 (Disbennett) 
[email protected]  
 
Attorney for Plaintiff  

            

  

        

 
 

 

Case 1:24-cv-23058-XXXX   Document 1   Entered on FLSD Docket 08/12/2024   Page 55 of 55

mailto:[email protected]

	I. SUMMARY
	II. JURISDICTION AND VENUE
	III. DEFENDANTS
	IV. FACTS
	A. The Petions Founded NovaTech in June 2019.
	B. The NovaTech Investment Offering.
	C. The Petions Designed and Implemented NovaTech’s MLM Program to Promote and Distribute NovaTech’s Investment Offering.
	D. NovaTech Rapidly Collapsed and Halted Its U.S. Operations by May 2023.
	E. The Petions Operated NovaTech as a Fraud on Investors.
	F. NovaTech and the Petions Made False and Misleading Statements to Investors in Furtherance of Their Fraudulent Scheme.
	i. Misstatements regarding the use of assets invested by investors.
	ii. Misstatements regarding NovaTech’s trading performance.
	iii. Misstatements regarding NovaTech’s legitimacy.
	iv. Misstatements regarding the safety and security of the investment.
	v. Misstatements in response to investor concerns.

	G. The Promoter Defendants Marketed NovaTech to Investors.
	i. The Promoter Defendants solicited investors to invest in NovaTech.
	a. Martin Zizi
	b. James Corbett
	c. John Garofano
	d. Corrie Sampson
	e. Dapilinu (“Dap”) Dunbar
	f. Marsha Hadley

	ii. The Promoter Defendants were compensated for soliciting investors.

	H. Four Promoter Defendants Engaged in Deceptive Acts in Furtherance of NovaTech’s Fraudulent Scheme in the Face of Red Flags.
	i. Zizi engaged in conduct in furtherance of the fraudulent scheme.
	ii. Corbett engaged in conduct in furtherance of the fraudulent scheme.
	iii. Dunbar and Sampson engaged in conduct in furtherance of the fraudulent scheme.