SEC v. FAIZ M. CHOWDHURY; DTI HOLDINGS, INC.; and QUANTUM AGE CORPORATION, No. 8:23-cv-01741, Central District of California (Sept. 19, 2023) — Complaint

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DARREN E. LONG (pro hac vice pending)
Email:  [email protected]
Telephone: (202) 551-4788
BRIAN D. VANN (pro hac vice pending)
Email:  [email protected]
Telephone: (202) 551-7165
Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549-5985

LOCAL COUNSEL:
GARY Y. LEUNG (Cal. Bar No. 302928)
Email: [email protected]
Securities and Exchange Commission
444 S. Flower Street, Suite 900
Los Angeles, CA 90071
Telephone:  (323) 965-3988
Facsimile:  (213) 443-1904

Attorneys for Plaintiff
Securities and Exchange Commission

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

SECURITIES AND EXCHANGE
COMMISSION,

                    Plaintiff,

          vs.

FAIZ M. CHOWDHURY, DTI
HOLDINGS, INC. and QUANTUM AGE
CORPORATION,

                    Defendants.
Case No.

COMPLAINT

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Plaintiff Securities and Exchange Commission alleges:
I. JURISDICTION AND VENUE
1. The  Court  has  jurisdiction  over  this  action  pursuant  to  the  Securities
Act of 1933 (“Securities Act”) Sections 20(b), 20(d) and 22(a) [15 U.S.C. §§ 77t(b),
77t(d)  and  77v(a)]  and  the  Securities  Exchange  Act  of  1934  (“Exchange  Act”)
Sections 21(d) and 27(a) [15 U.S.C. §§ 78u(d) and 78aa(a)].
2. In connection with the conduct alleged in this Complaint, Defendants,
directly and indirectly, singly, or in concert with others, have made use of the means
or   instrumentalities   of   interstate   commerce,   the   means   or   instruments   of
transportation  or  communication  in  interstate  commerce,  the  mails,  and/or  the
facilities of a national securities exchange.
3. Venue is proper in this district pursuant to Securities Act Section 22(a)
[15 U.S.C. § 77v(a) and Exchange Act Section 27 [15 U.S.C. § 78aa] because certain
of  the  acts  and  transactions  constituting  the  violations  alleged  in  this  Complaint
occurred in this district, and because all Defendants reside or resided in this district.
II. DEFENDANTS
4. Faiz  M.  Chowdhury  (“Chowdhury”),  age  54,  resides  in  Irvine,
California  and  is  a  dual  citizen  of  Bangladesh  and  the  United  States.    He  is  the
founder and majority shareholder of both DTI and QAC, and at all times relevant to
the  complaint  was  the  chairman,  president,  and  chief  executive  officer  of  each
company.
5. DTI  Holdings,  Inc.  (“DTI”)  is  a  defunct  Delaware  corporation  that
previously had its principal office in Irvine, California.
6. Quantum  Age  Corp.  (“QAC”)  is  a  Delaware  corporation  with  its
principal office in Irvine, California.
III. INTRODUCTION
7. The  Commission  brings  this  action  to  enjoin  Chowdhury  and  his
companies DTI and QAC (collectively, “Defendants”) from violating the antifraud

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provisions  of  the  federal  securities  laws.    Beginning  in  at  least  2018,  Defendants
engaged  in  a  scheme  to  raise  money  from  investors  through  a  series  of  material
misrepresentations and other deceptive acts, raising over $25 million from more than
50 debt and equity investors in the United States and around the world.  Investors
were told they were investing in a global enterprise of groundbreaking, IP-rich start-
up companies, and were misled about the assets, technologies, and finances of DTI
and QAC, as well as Chowdhury’s own experience and credentials.
8. In  his  marketing  pitches  to  potential  investors,  Chowdhury  falsely
presented  himself  as  a  Doctor  of  Science,  a  physicist,  and  an  intellectual  prodigy.
He   fabricated   an   elite   academic   pedigree,   including   degrees   from   Harvard
University, the Massachusetts Institute of Technology (“MIT”), and Johns Hopkins
University.
9. Chowdhury promised investors that their money would be used by his
companies,  DTI  and  QAC,  to  “Pioneer  the  Next  Age  of  Humanity”  through
innovative graphene-based technologies.  He falsely told investors that he was the
original inventor of graphene but could not be publicly credited because the work
had been top secret.
10. Chowdhury assured investors that he would use their money to fund a
vast  array  of  affiliated  and  subsidiary  start-up  companies  working  on  game-
changing, graphene-based nanotechnologies, including fast-charge batteries, cancer
detection  and  treatment  solutions,  anti-counterfeiting  devices,  and  snake-venom
antidotes.  Promising that his graphene-based technologies were “commercial-ready
solutions”  that  would  soon  be  available  on  the  market,  Chowdhury  presented
investors with misleading financial proformas projecting astronomical revenues into
the tens and even hundreds of millions of dollars.
11. In reality, only a small amount of investor money was used for business
purposes.  In addition to his own salary, Chowdhury used the DTI and QAC bank
accounts  as  a  personal  piggy  bank,  making  excessive  cash  withdrawals,  funding

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extravagant  trips  around  the  world,  transferring  funds  to  various  entities  he
controlled, purchasing luxury items for himself and his family, and using investor
funds to indulge in gambling and leisure.
12. As  a  result  of  the  conduct  alleged  in  this  Complaint,  Defendants
violated  Securities  Act  Section  17(a)  [15  U.S.C.  §§  77(q)(a)]  and  Exchange  Act
Section  10(b)  [15  U.S.C.  §  78j(b)]  and  Rule  10b-5  thereunder  [17  C.F.R.  §§
240.10b-5].  Chowdhury also aided and abetted DTI’s and QAC’s violations of the
foregoing anti-fraud provisions pursuant to Exchange Act Section 20(e) [15 U.S.C.
§  78t(e)],  and  alternatively  is  liable  as  a  control  person  of  both  DTI  and  QAC
pursuant to Exchange Act Section 20(a) [15 U.S.C. § 78t(a)].
13. Unless  restrained  and  enjoined,  Defendants  are  reasonably  likely  to
continue to violate the federal securities laws.
IV. FACTS
A. History of DTI and QAC
14. Chowdhury has controlled, operated, and held executive positions with
DTI and QAC since their inceptions.  Beginning no later than May 2018, Defendants
have  offered  and  sold  securities  in  the  form  of  subscription  agreements  and
convertible promissory notes, first in DTI and later in QAC, raising over $25 million
from more than 50 debt and equity investors.
15. Chowdhury incorporated DTI on June 23, 2016, and has always served
as  the  company’s  CEO,  chairman,  and  majority  shareholder.    He  rented  a  large
commercial space for its headquarters in Irvine, California, and by no later than May
2018, was raising money from U.S. and overseas investors, primarily in Asia.
16. Chowdhury   touted   DTI   as   a   holding   company   of   cutting-edge
technology  companies  purportedly  using  a  material  called  graphene  to  forge  new
advances in health, energy, and transportation.  Promising to “Pioneer the Next Age
of  Humanity,”  Chowdhury  presented  himself  as  a  degreed  academic,  a  visionary,
and an accomplished businessman who had started and successfully exited numerous

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technology companies.
17. In marketing materials, Chowdhury described DTI as a company that
was already “inventing, innovating, and commercializing disruptive technologies”
through  wholly-owned  subsidiaries,  many  of  which  were  headed  by  several
prominent scientists, inventors, and academics.  Chowdhury told investors that these
companies  were  ready  to  commercialize  revolutionary  discoveries  in  areas  like
cancer detection, fast-charging batteries, and antibody research.
18. As  discussed  below,  Chowdhury’s  representations  to  investors  about
his  academic  credentials  and  experience,  as  well  as  DTI’s  and  its  subsidiaries’
ownership   of   intellectual   property   and   ability   to   commercialize   purported
technology, were false and misleading.  And while Chowdhury spent some investor
money  furthering  the  aims  of  DTI  by  making  small  payments  to  contractors  and
other   companies   with   which   Chowdhury   had   some   connection,   he   largely
misappropriated  investor  funds,  contrary  to  his  promises  and  representations  to
investors.
19. By   late   2019,   some   investors   in   DTI   began   complaining   that
Chowdhury had misled them, mismanaged their investments, and failed to make any
progress toward commercializing the purported technologies.  Chowdhury created
QAC on September 23, 2019, to rebrand the DTI venture and separate the growing
number of disgruntled DTI investors from his continuing solicitations for investor
money.
20. Since its inception, Chowdhury has served as QAC’s CEO, chairman,
and majority shareholder.  Chowdhury used the same marketing model for touting
QAC that he used for DTI, claiming he operated a holding company of graphene-
centered  tech  companies  on  the  verge  of  bringing  groundbreaking  products  to
market.    Chowdhury  claimed  that  QAC  would  “dynamically  address  the  unmet
needs  that  are  foundational  to  our  existence,”  and  that  it  invented  and  developed
“products and solutions that are critical to sustain life.”

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21. When  some  DTI  investors  began  demanding  their  money  back,
Chowdhury used some of the new investor funds raised by QAC to make Ponzi-like
payments to prior investors.  DTI is currently defunct, though Chowdhury continues
to operate QAC.
B. Chowdhury’s Material Misrepresentations to Investors
22. During  in-person  meetings,  calls,  communications,  and  on-screen
presentations   to   investors,   Defendants   made   materially   false   and   misleading
statements about Chowdhury, DTI, and QAC.  Defendants knew or were reckless in
not knowing that these statements were false and misleading.  Chowdhury had the
ultimate authority over all statements made to investors.
1. Material Misrepresentations Regarding the Use of Investor
Funds
23. Defendants promised investors that the funds raised from their purchase
of  securities  would  be  used  to  develop  and  commercialize  the  technologies  of  the
purported  subsidiaries,  or  for  other  operating  expenses  such  as  rent,  payroll,  and
insurance.    These  statements,  however,  were  materially  false  and  misleading.    As
described in more detail in Section C below, less than $7 million of the more than
$25 million raised by the Defendants was used for those purposes.
24. In addition to general misrepresentations regarding DTI’s and QAC’s
use   of   investor   funds,   Chowdhury   made   specific   misstatements   about   the
companies’  uses  of  funds  during  personal  appeals  to  individual  investors.  For
instance, Chowdhury approached an existing DTI investor in November 2019 and
asked for an additional $100,000 investment so he could pay employee salaries for
the  holidays  and  back-rent  that  DTI  owed.    The  investor  provided  the  funds,  but
Chowdhury did not pay employee salaries or the rent as promised.
25. Chowdhury told another potential investor during a sales pitch for DTI
that 300 Cells, Inc. (“300 Cells”) – a purported DTI subsidiary working on cancer
detection technologies – had discovered a cure for cancer.  That individual invested

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$150,000 based on Chowdhury’s promise that the funds would be used to further the
mission  of  300  Cells.    In  fact,  neither  DTI  nor  300  Cells  had  discovered  or  even
attempted to develop a cure for cancer, and the investor’s funds were not used for or
transferred to 300 Cells.
2. Material Misrepresentations Regarding DTI and QAC
Assets & Technology
26. Starting     no     later     than     2018,     Defendants     made     material
misrepresentations to investors about the assets purportedly held by DTI and QAC.
They  falsely  told  investors  that  DTI  and  QAC  were  holding  companies  with
subsidiaries that owned intellectual property rights over numerous technologies and
the  associated  right  to  any  revenue  and  profits  from  those  technologies.    These
claims  were  false.    Nearly  all  of  the  purported  subsidiary  companies  touted  to
investors were either companies not owned or affiliated with DTI or QAC, or were
shell companies with little or no revenue, assets, or operations.
27. Chowdhury  frequently  claimed  to  investors  that  DTI  owned  various
subsidiaries  that  operated  in  multi-billion-dollar  markets.    Some  of  the  purported
subsidiaries included 300 Cells, Quantum Core Corporation (“QCC”), and Vittoria
Tire, Ltd. (“Vittoria”).
28. In one investor presentation, Chowdhury claimed that Vittoria was one
of DTI’s “current subsidiaries” providing $70M of revenue.  Vittoria was an Italian
tire  manufacturer  that  had  been  in  business  for  nearly  70  years,  but  it  was  never
owned  or  affiliated  with  DTI  or  Chowdhury.    Chowdhury  approached  Vittoria  in
2017 concerning a possible acquisition or affiliation, but nothing resulted from that
inquiry.  Chowdhury falsely claimed the company was a DTI subsidiary for years
afterward.
29. Chowdhury  also  misrepresented  the  intellectual  property  and  other
assets DTI and QAC purportedly owned through its subsidiaries.  Chowdhury falsely
claimed  in  documents  provided  and  shown  to  investors  that  DTI  and  QAC

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subsidiaries owned or had exclusive use of patents and other forms of intellectual
property, including the right to distribute numerous revolutionary technologies.
30. In  one  presentation,  Chowdhury  claimed  that  QAC  owned  or  had
exclusive use of seven or more patents and other forms of intellectual property.  This
claim was false.  Neither DTI nor QAC owned any patents.  While DTI did lease
from a few third parties the option to use their intellectual property for limited uses,
Defendants  did  not  make  the  scheduled  payments  as  agreed,  did  not  use  the
intellectual property toward commercializing any products, and the options expired.
31. Chowdhury  also  misled  investors  about  when  DTI’s  and  QAC’s
technologies would be commercially viable.
32. In one marketing document, Chowdhury told investors that purported
subsidiaries Quantum Dots and 300 Cells were “commercially ready solutions,” and
that  DTI’s  fast-charging  battery  “will  start  generating  revenue  in  Q4  2018.”    In
another DTI marketing document, Chowdhury told investors that QCC was “ready
for commercialization” and would be “in product” by 2018.  These statements were
materially and knowingly misleading as Chowdhury had no reasonable factual basis
for making them.  In fact, only one company in the DTI or QAC family – a small
manufacturer of medical cooling vests that operated for years before Chowdhury’s
involvement  –  ever  generated  any  revenue,  and  that  revenue  totaled  less  than
$100,000.  That company ultimately ceased all operations after Chowdhury left it so
cash-strapped that it was unable to pay its employees.
33. On  more  than  one  occasion,  Chowdhury falsely told investors during
marketing pitches that DTI had created a cure for cancer.  In one instance, aware that
the mother-in-law of one investor had recently died from cancer and that the issue
was  emotional  for  him,  Chowdhury  went  so  far  as  to  hold  up  a  vile  filled  with  a
black liquid and falsely told the audience it contained a “cure for cancer.”
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3. Material Misrepresentations Regarding Chowdhury’s
Experience and Credentials
34. Chowdhury  repeatedly  made  material  misrepresentations  to  investors
about his experience, accomplishments, and academic credentials.
35. Chowdhury  falsely  represented  that  as  a  child  in  Bangladesh,  village
leaders identified him as a savant and that the U.S. government later recruited him
to work on a top-secret government program to develop graphene for military and
commercial applications.  Chowdhury falsely told investors that he was the original
inventor of graphene, but because of the secrecy of his government work, he could
not be named on any patent or given credit in any public sphere.  He also falsely told
investors  that  before  he  left  the  government  he  served  as  a  scientific  advisor  to
President  George  W.  Bush  and  that  he  was  later  an  advisor  and  friend  of  Senator
John McCain.
36. Chowdhury   falsely   represented   to   investors   that   he   “pioneered
scientific breakthroughs” at some of the nation’s most prestigious scientific research
centers, including the National Aeronautics and Space Administration, Oak Ridge
National  Laboratory,  California  Institute  of  Technology  and  the  Johns  Hopkins
Applied Physics Lab.
37. Chowdhury  also  touted  completely  fabricated  academic  credentials.
Presenting himself in person and in documents with the title “Doctor,” he claimed at
different times and in different settings the following academic credentials:
 Doctor of Science in Physics from MIT
 Doctor of Science in Nuclear and Particle Physics from MIT
 Doctor of Science in Quantum Physics from Johns Hopkins APL
 Senior Executive Fellow at Harvard Kennedy School of Government
 Senior Executive Fellow at MIT Sloan
These claims were material and false.
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4. Material Misrepresentations Regarding Chowdhury’s Own
Investment in DTI
38. Chowdhury falsely told several investors that he had invested anywhere
between $1 million and $3 million of his own money in DTI.  He falsely told one
investor  that  he  had  acquired  the  money  he  invested  in  DTI  by  selling  to  a  major
Korean electronics company a patent for a valuable technology he invented.
39. In fact, Chowdhury did not invest any of his own money in DTI.  His
only  so-called  personal  investment  in  the  company  was  a  purported  $1  million
“loan” from one investor who had himself invested several million dollars in DTI.
Chowdhury used the loan to pay his own salary and personal expenses.
5. Material Misrepresentations Regarding Projected Revenue
of DTI and QAC
40. DTI  and  QAC  marketing  documents  shown  to  prospective  investors
contained revenue projections that were false and misleading because there was no
reasonable factual basis for the projections.
41. One  DTI  marketing  document  that  Chowdhury  used  during  investor
pitches  in  2018  provided  an  “Income  Statement”  for  QCC,  one  of  the  purported
subsidiaries of DTI.  It projected QCC would produce a majority of DTI’s revenue
between 2019 and 2021, including $18 million in 2019, $39.7 million in 2020, and
$78.8 million in 2021.  QCC was not a subsidiary of DTI and had no employees or
revenue, and Chowdhury had not reasonable basis for these projections.
42. DTI sent a May 2018 marketing presentation for one of its purported
subsidiaries,  QCC,  to  an  investor  in  advance  of  a  June  2018  investment.    That
document  projected  QCC  revenue  of  $11.5  million  for  2019,  $143.5  million  for
2020, $341 million for 2021, and $577 million for 2022.  Later that year, Chowdhury
updated the projected revenue of QCC to $2 billion by 2025.
43. On  December  10,  2018,  Chowdhury  emailed  an  investor  a  DTI
financial model “base case” and noted in his cover email that “we will have over $15

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million  cash  in  2020  and  $40  million  cash  in  2021”  in  what  he  described  as  “the
worst-case  scenario.”    Chowdhury  went  on  to  claim  that  “we  shall  generate  over
$100 million EBITDA by 2023 which will give DTI a value over $1 Billion USD.”
44. Chowdhury had no reasonable basis for making these statements.
45. A  QAC  marketing  document  utilized  by  Chowdhury  during  investor
presentations   in   2020   included   2021   revenue   projections   for   the   purported
subsidiaries of QAC.  It projected $5.3 million of revenue for Quantum Cyber AI,
$3.7  million  for  3RDGP  Corporation,  and  $5.5  million  for  a  subsidiary  called
QZULU  Corporation.    Chowdhury  had  no  reasonable  basis  for  these  revenue
projections.
46. Chowdhury  emailed  another  investor  on  July  1,  2020,  attaching  a
prospectus  for  QZULU  Corporation.    In  the  cover  email,  Chowdhury  told  the
investor that the only challenge for the QZULU project was “timing,” and assured
him that they would receive “a good amount of fund [sic] in July,” from five different
investors.    The  prospectus  itself  claimed  that  QZULU  was  offering  $8  million  of
preferred stock in the form of QZULU tokens (which never launched), and projected
year-one  revenue  of  more  than  $15  million  from  QZULU’s  two  biggest  projects,
QPOWER and QFARMS, and year-five revenue from the same entities of more than
$1.5 billion.
47. These  materially  misleading  revenue  forecasts  were  unsupported  and
internally  inconsistent.    Despite  the  claims  of  massive  future  revenue,  only  one
company owned by DTI or QAC ever produced actual revenue.  The revenue from
that  company  was  less  than  $100,000  before  it  became  illiquid  and  ceased
operations.
C. Chowdhury’s Misappropriation of Investor Funds and Other
Deceptive Acts
48. All told, Chowdhury raised approximately $26.4 million from DTI and
QAC  investors  between  May  2018  and  December  2022.    Chowdhury  promised

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investors the funds would be used to develop and commercialize the technologies of
the purported subsidiaries, or for other operating expenses, such as rent, payroll, and
insurance.
49. While he used some funds for such expenses, Chowdhury fraudulently
misappropriated  most  of  the  DTI  and  QAC  investor  funds,  transferring  money  to
overseas bank accounts and entities with no apparent connection to DTI or QAC, or
using them for his personal expenditures.  Chowdhury also used investor funds to
make Ponzi-like payments, as money from new investors was used to pay current
investors who had accused Chowdhury of misconduct, threatened legal action, and
demanded their money be returned.
50. For   example,   one   investor   in   early   November   2018   demanded
Chowdhury  return  his  $150,000  investment  in  DTI  after  he  became  suspicious  of
Chowdhury.  Within a week, Chowdhury received three new investments from other
investors, totaling $150,000, which Chowdhury used to pay the prior investor.
51. As  another  example,  Chowdhury  in  texts  throughout  2020  and  2021
repeatedly told an investor who was seeking repayment of promissory notes that DTI
had  no  money  to  pay  him  until  he  could  secure  investments  from  new  investors.
Chowdhury’s pitches to the new QAC investors did not disclose that funds would
be used to pay off previous investors in DTI.
52. To   conceal   his   misappropriation   of   investor   funds,   Chowdhury
maintained tight control of DTI’s and QAC’s finances and enlisted family members
with little or no financial experience to help him.  For example, Chowdhury hired
his  cousin,  who  had  no  previous  experience  in  accounting  or  finance,  as  DTI’s
purported  “Corporate  Controller.”    He  added  his  cousin’s  wife  –  who  had  no
experience with finances – as a co-signer on QAC bank accounts, also listing her,
falsely, as the company’s “Controller.”  He falsely listed his wife, who had no role
with  either  DTI  or  QAC,  as  the  companies’  “Corporate  Secretary”  to  sign  and
authorize bank account opening documents.

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53. Chowdhury also maintained at least 40 bank accounts at four different
banks  and  created  no  less  than  30  entities  purportedly  related  to  DTI  and  QAC.
Neither  DTI  nor  QAC  kept  consistent  financial  records,  and  neither  undertook
independent or internal audits.  Chowdhury did not use a transfer agent and did not
appear to adequately record and maintain the companies’ stock issuances.  At one
point,  Chowdhury  hired  a  contractor  to  organize  the  companies’  finances,  but  did
not provide that person complete access to banking and financial records, and soon
stopped paying his invoices.
54. Records indicate that Chowdhury used the money he raised from DTI
and QAC investors in the following ways:
 $2.1 million withdrawn from ATM machines or bank tellers in cash by
Chowdhury  and  his  family,  including  numerous  withdrawals  from
ATM machines located at casinos in Lake Tahoe and Las Vegas
 $1 million used by Chowdhury and his family for personal expenses,
including car payments, meals, wine, travel and jewelry
 $7.9  million  wired  to  businesses  that  have  no  known  or  apparent
connection to DTI or QAC
 $1.8 million used to pay back other investors in Ponzi-like payments,
often   after   investors   raised   concerns   about   Chowdhury   and   his
companies
 $7   million   unaccounted   for,   largely   due   to   Chowdhury’s   many
domestic  and  overseas  bank  accounts,  spread  across  four  different
financial institutions, and encompassing thousands of unexplained bank
transactions
55. Defendants  used  only  about  $6.6  million  of  the  $26.4  million  they
raised from investors for operating expenditures relating to DTI and QAC, including
rent, payroll, investments, equipment, and insurance.
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THE STATUTORY PERIOD HAS BEEN TOLLED
56. On February 1, 2023, Chowdhury entered into a tolling agreement with
the  SEC  (“Tolling  Agreement”)  on  behalf  of  himself,  DTI,  and  QAC  (as  CEO  of
both entities) tolling and suspending the statute of limitations from March 1, 2023
to September 1, 2023.
FIRST CLAIM FOR RELIEF
Violations of Section 17(a) of the Securities Act
(All Defendants)
57. The Commission repeats and realleges Paragraphs 1 through 56 of its
Complaint.
58. From  no  later  than  May  2018  through  at  least  2022,  Defendants,  by
engaging in the conduct described above, directly or indirectly, in the offer or sale
of securities, by the use of means or instruments of transportation or communication
in  interstate  commerce  or  by  the  use  of  the  mails:    (a)  with  scienter,  employed
devices, schemes, or artifices to defraud; (b) obtained money or property by means
of untrue statements of material fact or by omitting 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; and (c) engaged in transactions, practices, or courses of
business that operated or would operate as a fraud or deceit upon the purchaser of
such securities.
59. By reason of the foregoing, Defendants violated, and unless enjoined
are reasonably likely to continue to violate, Securities Act Section 17(a) [15 U.S.C.
§ 77q(a)(1), (2) and (3)].
SECOND CLAIM FOR RELIEF
Violations of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder
(All Defendants)
60. The Commission repeats and realleges Paragraphs 1 through 56 of its
Complaint.

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61. From  no  later  than  May  2018  through  at  least  2022,  Defendants,  by
engaging in the conduct described above, directly or indirectly, in connection with
the  purchase  or  sale  of  a  security;  by  the  use  of  means  or  instrumentalities  of
interstate  commerce,  or  of  the  mails,  or  of  the  facilities  of  a  national  securities
exchange, with scienter:  (a) employed devices, schemes, or artifices to defraud; (b)
made untrue statements of material fact or omitted 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; and (c) engaged in acts, practices, or courses of business
which operated or would operate as a fraud or deceit upon any person.
62. By reason of the foregoing, Defendants violated, and unless enjoined
are reasonably likely to continue to violate, Exchange Act Section 10(b) and Rule
10b-5 [15 U.S.C. § 78j(b) and 17 C.F.R. § 240.10b-5(a), (b) and (c)].
THIRD CLAIM FOR RELIEF
Aiding and Abetting Violations of Section 17(a) of the Securities Act
(Defendant Chowdhury)
63. The Commission repeats and realleges Paragraphs 1 through 56 of its
Complaint.
64. From  no  later  than  May  2018  through  at  least  2022,  Defendants  DTI
and QAC, by engaging in the conduct described above, directly or indirectly, in the
offer  or  sale  of  securities,  by  the  use  of  means or instruments of transportation or
communication in interstate commerce or by the use of the mails:  (a) with scienter,
employed devices, schemes, or artifices to defraud; (b) obtained money or property
by means of untrue statements of material fact or by omitting 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; and (c) engaged in transactions, practices, or
courses  of  business  that  operated  or  would  operate  as  a  fraud  or  deceit  upon  the
purchaser of such securities.
65. By   reason   of   the   conduct   described   above,   Chowdhury,   acting

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knowingly or recklessly, provided substantial assistance to, and thereby aided and
abetted, DTI’s and QAC’s violations of Securities Act Section 17(a) [15 U.S.C. §
77q(a)(1), (2) and (3)].
66. Accordingly,  Chowdhury,  pursuant  to  Securities  Act  Section  15(b)
[15 U.S.C. § 77o(b)], is liable for those violations.
FOURTH CLAIM FOR RELIEF
Aiding and Abetting Violations of Section 10(b) of the Exchange Act and Rule
10b-5 thereunder
(Defendant Chowdhury)
67. The Commission repeats and realleges Paragraphs 1 through 56 of its
Complaint.
68. From  no  later  than  May  2018  through  at  least  2022,  Defendants  DTI
and  QAC,  by  engaging  in  the  conduct  described  above,  directly  or  indirectly,  in
connection  with  the  purchase  or  sale  of  a  security;  by  the  use  of  means  or
instrumentalities  of  interstate  commerce,  or  of  the  mails,  or  of  the  facilities  of  a
national  securities  exchange,  with  scienter:    (a)  employed  devices,  schemes,  or
artifices to defraud; (b) made untrue statements of material fact or omitted 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; and (c) engaged in acts,
practices, or courses of business which operated or would operate as a fraud or deceit
upon any person.
69. By   reason   of   the   conduct   described   above,   Chowdhury,   acting
knowingly or recklessly, provided substantial assistance to, and thereby aided and
abetted, DTI’s and QAC’s violations of Exchange Act Section 10(b) and Rule 10b-
5 [15 U.S.C. § 78j(b) and 17 C.F.R. § 240.10b-5(a), (b) and (c)].
70. Accordingly, Chowdhury, pursuant to Exchange Act Section 20(e) [15
U.S.C. § 78t(e)], is liable for these violations.
///

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FIFTH CLAIM FOR RELIEF
Control Person Liability
(Defendant Chowdhury)
71. The Commission repeats and realleges Paragraphs 1 through 56 of its
Complaint.
72. From  no  later  than  May  2018  through  at  least  2022,  Defendants  DTI
and  QAC,  which  were  under  Chowdhury’s  control,  by  engaging  in  the  conduct
described above, directly or indirectly, in connection with the purchase or sale of a
security; by the use of means or instrumentalities of interstate commerce, or of the
mails,  or  of  the  facilities  of  a  national  securities  exchange,  with  scienter:    (a)
employed devices, schemes, or artifices to defraud; (b) made untrue statements of
material  fact  or  omitted  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; and (c) engaged in acts, practices, or courses of business which operated
or would operate as a fraud or deceit upon any person.
73. By  reason  of  the  conduct  described  above,  Chowdhury  was  a  control
person of DTI and QAC in that Chowdhury exercised actual power and control over
DTI  and  QAC  and  was  a  culpable  participant  in  their  violations  of  Exchange  Act
Section  10(b)  and  Rule  10b-5  thereunder  [15  U.S.C.  §  78j(b)  and  17  C.F.R.
§ 240.10b-5(a), (b) and (c)].
74. Accordingly, Chowdhury, pursuant to Exchange Act Section 20(a) [15
U.S.C. § 78t(a)], is liable for these violations.
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that the Court:
I.
Issue findings of fact and conclusions of law that Defendants committed the
alleged violations.
///

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II.
Issue judgments, in a form consistent with Rule 65(d) of the Federal Rules of
Civil Procedure, permanently restraining and enjoining Defendants from, directly or
indirectly, violating Securities Act Section 17(a) [15 U.S.C. § 77q(a)] and Exchange
Act  Section  10(b)  [15  U.S.C.  §  78j(b)]  and  Rule  10b-5  thereunder  [17  C.F.R.  §§
240.10b-5].
III.
Issue judgments, in a form consistent with Rule 65(d) of the Federal Rules of
Civil Procedure, permanently restraining and enjoining Defendant Chowdhury from
aiding or abetting any violation of Securities Act Section 17(a) [15 U.S.C. § 77q(a)]
and Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17
C.F.R. §§ 240.10b-5].
IV.
Issue judgments, in a form consistent with Rule 65(d) of the Federal Rules of
Civil Procedure, permanently restraining and enjoining Defendants from directly or
indirectly, including, but not limited to, through any entity owned or controlled by
them,  participating  in  the  issuance,  purchase,  offer,  or  sale  of  any  securities,
provided,  however,  that  such  injunction  shall  not  prevent  Defendant  Chowdhury
from purchasing or selling securities listed on a national securities exchange for his
own personal account.
V.
Order  Defendants  to  disgorge  all  funds  received  from  their  illegal  conduct,
together  with  prejudgment  interest  thereon,  pursuant  to  pursuant  to  Exchange  Act
Sections 21(d)(5) and 21(d)(7) [15 U.S.C. §§ 78u(d)(5) and 78u(d)(7)].
VI.
Order Defendants to pay civil penalties under Securities Act Section 20(d) [15
U.S.C. § 77t(d)] and Exchange Act Section 21(d) [15 U.S.C. § 78u(d)(3)].
///

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VII.
Bar Defendant Chowdhury from serving as an officer or director of a public
company pursuant to Securities Act Section 20(e) [15 U.S.C. § 77t(e)] and Exchange
Act Section 21(d)(3) [15 U.S.C. § 78u(d)(6)].
VIII.
Retain jurisdiction of this action in accordance with the principles of equity
and  the  Federal  Rules  of  Civil  Procedure  in  order  to  implement  and  carry  out  the
terms  of  all  orders  and  decrees  that  may  be  entered,  or  to  entertain  any  suitable
application or motion for additional relief within the jurisdiction of this Court.
IX.
Grant such other and further relief as this Court may deem just, equitable, or
necessary in connection with the enforcement of the federal securities laws and for
the protection of investors.

DATED:  Se
ptember 19, 2023
  /s/ Gary Y. Leung
  Gary Y. Leung
Counsel for Plaintiff
Securities and Exchange Commission
444 S. Flower Street, Suite 900
Los Angeles, CA 90071
Telephone:  (323) 965-3988
Facsimile:  (213) 443-1904
Email:  [email protected]

Darren E. Long
Email:  [email protected]
Telephone: (202) 551-4788
Brian D. Vann
Email:  [email protected]
Telephone: (202) 551-7165
Counsel for Plaintiff
Securities and Exchange Commission
100 F Street N.E.
Washin
gton, DC 20549-5985

Complaints and Other Initiating Documents
8:23-cv-01741 Securities and Exchange Commission v. Chowdhury et al
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
Notice of Electronic Filing
The following transaction was entered by Leung, Gary on 9/19/2023 at 9:23 AM PDT and filed on 9/19/2023
Case Name:Securities and Exchange Commission v. Chowdhury et al
Case Number:8:23-cv-01741
Filer:Securities and Exchange Commission
Document Number:1
Docket Text:
COMPLAINT No Fee Required - US Government, filed by Plaintiff Securities and Exchange Commission. (Attorney
Gary Y. Leung added to party Securities and Exchange Commission(pty:pla))(Leung, Gary)
8:23-cv-01741 Notice has been electronically mailed to:
Gary Y. Leung     [email protected], [email protected], [email protected], [email protected]
8:23-cv-01741 Notice has been delivered by First Class U. S. Mail or by other means BY THE FILER to :
The following document(s) are associated with this transaction:
Document description:Main Document
Original filename:C:\fakepath\2023-09-19 DTI Complaint (final for filing).pdf
Electronic document Stamp:
[STAMP cacdStamp_ID=1020290914 [Date=9/19/2023] [FileNumber=36562457-0
] [b256505d224036a3897e9b73ae6d5b269a63c1e409c4f2e6191babdd2becbe6184b
98360aa99630e68a6266857c110e865c96873f3307e0fab3dfd6d4f7cd685]]

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DARREN E. LONG (pro hac vice pending) 
Email:  [email protected] 
Telephone: (202) 551-4788 
BRIAN D. VANN (pro hac vice pending) 
Email:  [email protected] 
Telephone: (202) 551-7165 
Securities and Exchange Commission 
100 F Street N.E. 
Washington, DC 20549-5985 
 
 
LOCAL COUNSEL: 
GARY Y. LEUNG (Cal. Bar No. 302928) 
Email: [email protected] 
Securities and Exchange Commission 
444 S. Flower Street, Suite 900 
Los Angeles, CA 90071 
Telephone:  (323) 965-3988 
Facsimile:  (213) 443-1904 
 
Attorneys for Plaintiff 
Securities and Exchange Commission 
 

UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

 
 
SECURITIES AND EXCHANGE 
COMMISSION, 
 
  Plaintiff, 
 
 vs. 
 
FAIZ M. CHOWDHURY, DTI 
HOLDINGS, INC. and QUANTUM AGE 
CORPORATION, 
 
  Defendants. 

Case No.  
 
COMPLAINT 
 
 
 

  

Case 8:23-cv-01741   Document 1   Filed 09/19/23   Page 1 of 19   Page ID #:1



 

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Plaintiff Securities and Exchange Commission alleges: 

I. JURISDICTION AND VENUE 

1. The Court has jurisdiction over this action pursuant to the Securities 

Act of 1933 (“Securities Act”) Sections 20(b), 20(d) and 22(a) [15 U.S.C. §§ 77t(b), 

77t(d) and 77v(a)] and the Securities Exchange Act of 1934 (“Exchange Act”) 

Sections 21(d) and 27(a) [15 U.S.C. §§ 78u(d) and 78aa(a)]. 

2. In connection with the conduct alleged in this Complaint, Defendants, 

directly and indirectly, singly, or in concert with others, have made use of the means 

or instrumentalities of interstate commerce, the means or instruments of 

transportation or communication in interstate commerce, the mails, and/or the 

facilities of a national securities exchange. 

3. Venue is proper in this district pursuant to Securities Act Section 22(a) 

[15 U.S.C. § 77v(a) and Exchange Act Section 27 [15 U.S.C. § 78aa] because certain 

of the acts and transactions constituting the violations alleged in this Complaint 

occurred in this district, and because all Defendants reside or resided in this district. 

II. DEFENDANTS 

4. Faiz M. Chowdhury (“Chowdhury”), age 54, resides in Irvine, 

California and is a dual citizen of Bangladesh and the United States.  He is the 

founder and majority shareholder of both DTI and QAC, and at all times relevant to 

the complaint was the chairman, president, and chief executive officer of each 

company.   

5. DTI Holdings, Inc. (“DTI”) is a defunct Delaware corporation that 

previously had its principal office in Irvine, California.   

6. Quantum Age Corp. (“QAC”) is a Delaware corporation with its 

principal office in Irvine, California. 

III. INTRODUCTION 

7. The Commission brings this action to enjoin Chowdhury and his 

companies DTI and QAC (collectively, “Defendants”) from violating the antifraud 

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provisions of the federal securities laws.  Beginning in at least 2018, Defendants 

engaged in a scheme to raise money from investors through a series of material 

misrepresentations and other deceptive acts, raising over $25 million from more than 

50 debt and equity investors in the United States and around the world.  Investors 

were told they were investing in a global enterprise of groundbreaking, IP-rich start-

up companies, and were misled about the assets, technologies, and finances of DTI 

and QAC, as well as Chowdhury’s own experience and credentials. 

8. In his marketing pitches to potential investors, Chowdhury falsely 

presented himself as a Doctor of Science, a physicist, and an intellectual prodigy.  

He fabricated an elite academic pedigree, including degrees from Harvard 

University, the Massachusetts Institute of Technology (“MIT”), and Johns Hopkins 

University. 

9. Chowdhury promised investors that their money would be used by his 

companies, DTI and QAC, to “Pioneer the Next Age of Humanity” through 

innovative graphene-based technologies.  He falsely told investors that he was the 

original inventor of graphene but could not be publicly credited because the work 

had been top secret. 

10. Chowdhury assured investors that he would use their money to fund a 

vast array of affiliated and subsidiary start-up companies working on game-

changing, graphene-based nanotechnologies, including fast-charge batteries, cancer 

detection and treatment solutions, anti-counterfeiting devices, and snake-venom 

antidotes.  Promising that his graphene-based technologies were “commercial-ready 

solutions” that would soon be available on the market, Chowdhury presented 

investors with misleading financial proformas projecting astronomical revenues into 

the tens and even hundreds of millions of dollars. 

11. In reality, only a small amount of investor money was used for business 

purposes.  In addition to his own salary, Chowdhury used the DTI and QAC bank 

accounts as a personal piggy bank, making excessive cash withdrawals, funding 

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extravagant trips around the world, transferring funds to various entities he 

controlled, purchasing luxury items for himself and his family, and using investor 

funds to indulge in gambling and leisure. 

12. As a result of the conduct alleged in this Complaint, Defendants 

violated Securities Act Section 17(a) [15 U.S.C. §§ 77(q)(a)] and Exchange Act 

Section 10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. §§ 

240.10b-5].  Chowdhury also aided and abetted DTI’s and QAC’s violations of the 

foregoing anti-fraud provisions pursuant to Exchange Act Section 20(e) [15 U.S.C. 

§ 78t(e)], and alternatively is liable as a control person of both DTI and QAC 

pursuant to Exchange Act Section 20(a) [15 U.S.C. § 78t(a)]. 

13. Unless restrained and enjoined, Defendants are reasonably likely to 

continue to violate the federal securities laws. 

IV. FACTS 

A. History of DTI and QAC 

14. Chowdhury has controlled, operated, and held executive positions with 

DTI and QAC since their inceptions.  Beginning no later than May 2018, Defendants 

have offered and sold securities in the form of subscription agreements and 

convertible promissory notes, first in DTI and later in QAC, raising over $25 million 

from more than 50 debt and equity investors.   

15. Chowdhury incorporated DTI on June 23, 2016, and has always served 

as the company’s CEO, chairman, and majority shareholder.  He rented a large 

commercial space for its headquarters in Irvine, California, and by no later than May 

2018, was raising money from U.S. and overseas investors, primarily in Asia. 

16. Chowdhury touted DTI as a holding company of cutting-edge 

technology companies purportedly using a material called graphene to forge new 

advances in health, energy, and transportation.  Promising to “Pioneer the Next Age 

of Humanity,” Chowdhury presented himself as a degreed academic, a visionary, 

and an accomplished businessman who had started and successfully exited numerous 

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technology companies. 

17. In marketing materials, Chowdhury described DTI as a company that 

was already “inventing, innovating, and commercializing disruptive technologies” 

through wholly-owned subsidiaries, many of which were headed by several 

prominent scientists, inventors, and academics.  Chowdhury told investors that these 

companies were ready to commercialize revolutionary discoveries in areas like 

cancer detection, fast-charging batteries, and antibody research.   

18. As discussed below, Chowdhury’s representations to investors about 

his academic credentials and experience, as well as DTI’s and its subsidiaries’ 

ownership of intellectual property and ability to commercialize purported 

technology, were false and misleading.  And while Chowdhury spent some investor 

money furthering the aims of DTI by making small payments to contractors and 

other companies with which Chowdhury had some connection, he largely 

misappropriated investor funds, contrary to his promises and representations to 

investors.   

19. By late 2019, some investors in DTI began complaining that 

Chowdhury had misled them, mismanaged their investments, and failed to make any 

progress toward commercializing the purported technologies.  Chowdhury created 

QAC on September 23, 2019, to rebrand the DTI venture and separate the growing 

number of disgruntled DTI investors from his continuing solicitations for investor 

money. 

20. Since its inception, Chowdhury has served as QAC’s CEO, chairman, 

and majority shareholder.  Chowdhury used the same marketing model for touting 

QAC that he used for DTI, claiming he operated a holding company of graphene-

centered tech companies on the verge of bringing groundbreaking products to 

market.  Chowdhury claimed that QAC would “dynamically address the unmet 

needs that are foundational to our existence,” and that it invented and developed 

“products and solutions that are critical to sustain life.” 

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21. When some DTI investors began demanding their money back, 

Chowdhury used some of the new investor funds raised by QAC to make Ponzi-like 

payments to prior investors.  DTI is currently defunct, though Chowdhury continues 

to operate QAC. 

B. Chowdhury’s Material Misrepresentations to Investors 

22. During in-person meetings, calls, communications, and on-screen 

presentations to investors, Defendants made materially false and misleading 

statements about Chowdhury, DTI, and QAC.  Defendants knew or were reckless in 

not knowing that these statements were false and misleading.  Chowdhury had the 

ultimate authority over all statements made to investors. 

1. Material Misrepresentations Regarding the Use of Investor 

Funds  

23. Defendants promised investors that the funds raised from their purchase 

of securities would be used to develop and commercialize the technologies of the 

purported subsidiaries, or for other operating expenses such as rent, payroll, and 

insurance.  These statements, however, were materially false and misleading.  As 

described in more detail in Section C below, less than $7 million of the more than 

$25 million raised by the Defendants was used for those purposes. 

24. In addition to general misrepresentations regarding DTI’s and QAC’s 

use of investor funds, Chowdhury made specific misstatements about the 

companies’ uses of funds during personal appeals to individual investors. For 

instance, Chowdhury approached an existing DTI investor in November 2019 and 

asked for an additional $100,000 investment so he could pay employee salaries for 

the holidays and back-rent that DTI owed.  The investor provided the funds, but 

Chowdhury did not pay employee salaries or the rent as promised. 

25. Chowdhury told another potential investor during a sales pitch for DTI 

that 300 Cells, Inc. (“300 Cells”) – a purported DTI subsidiary working on cancer 

detection technologies – had discovered a cure for cancer.  That individual invested 

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$150,000 based on Chowdhury’s promise that the funds would be used to further the 

mission of 300 Cells.  In fact, neither DTI nor 300 Cells had discovered or even 

attempted to develop a cure for cancer, and the investor’s funds were not used for or 

transferred to 300 Cells.   

2. Material Misrepresentations Regarding DTI and QAC 

Assets & Technology 

26. Starting no later than 2018, Defendants made material 

misrepresentations to investors about the assets purportedly held by DTI and QAC.  

They falsely told investors that DTI and QAC were holding companies with 

subsidiaries that owned intellectual property rights over numerous technologies and 

the associated right to any revenue and profits from those technologies.  These 

claims were false.  Nearly all of the purported subsidiary companies touted to 

investors were either companies not owned or affiliated with DTI or QAC, or were 

shell companies with little or no revenue, assets, or operations. 

27. Chowdhury frequently claimed to investors that DTI owned various 

subsidiaries that operated in multi-billion-dollar markets.  Some of the purported 

subsidiaries included 300 Cells, Quantum Core Corporation (“QCC”), and Vittoria 

Tire, Ltd. (“Vittoria”). 

28. In one investor presentation, Chowdhury claimed that Vittoria was one 

of DTI’s “current subsidiaries” providing $70M of revenue.  Vittoria was an Italian 

tire manufacturer that had been in business for nearly 70 years, but it was never 

owned or affiliated with DTI or Chowdhury.  Chowdhury approached Vittoria in 

2017 concerning a possible acquisition or affiliation, but nothing resulted from that 

inquiry.  Chowdhury falsely claimed the company was a DTI subsidiary for years 

afterward. 

29. Chowdhury also misrepresented the intellectual property and other 

assets DTI and QAC purportedly owned through its subsidiaries.  Chowdhury falsely 

claimed in documents provided and shown to investors that DTI and QAC 

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subsidiaries owned or had exclusive use of patents and other forms of intellectual 

property, including the right to distribute numerous revolutionary technologies. 

30. In one presentation, Chowdhury claimed that QAC owned or had 

exclusive use of seven or more patents and other forms of intellectual property.  This 

claim was false.  Neither DTI nor QAC owned any patents.  While DTI did lease 

from a few third parties the option to use their intellectual property for limited uses, 

Defendants did not make the scheduled payments as agreed, did not use the 

intellectual property toward commercializing any products, and the options expired. 

31. Chowdhury also misled investors about when DTI’s and QAC’s 

technologies would be commercially viable. 

32. In one marketing document, Chowdhury told investors that purported 

subsidiaries Quantum Dots and 300 Cells were “commercially ready solutions,” and 

that DTI’s fast-charging battery “will start generating revenue in Q4 2018.”  In 

another DTI marketing document, Chowdhury told investors that QCC was “ready 

for commercialization” and would be “in product” by 2018.  These statements were 

materially and knowingly misleading as Chowdhury had no reasonable factual basis 

for making them.  In fact, only one company in the DTI or QAC family – a small 

manufacturer of medical cooling vests that operated for years before Chowdhury’s 

involvement – ever generated any revenue, and that revenue totaled less than 

$100,000.  That company ultimately ceased all operations after Chowdhury left it so 

cash-strapped that it was unable to pay its employees. 

33. On more than one occasion, Chowdhury falsely told investors during 

marketing pitches that DTI had created a cure for cancer.  In one instance, aware that 

the mother-in-law of one investor had recently died from cancer and that the issue 

was emotional for him, Chowdhury went so far as to hold up a vile filled with a 

black liquid and falsely told the audience it contained a “cure for cancer.” 

/// 

/// 

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3. Material Misrepresentations Regarding Chowdhury’s 

Experience and Credentials 

34. Chowdhury repeatedly made material misrepresentations to investors 

about his experience, accomplishments, and academic credentials. 

35. Chowdhury falsely represented that as a child in Bangladesh, village 

leaders identified him as a savant and that the U.S. government later recruited him 

to work on a top-secret government program to develop graphene for military and 

commercial applications.  Chowdhury falsely told investors that he was the original 

inventor of graphene, but because of the secrecy of his government work, he could 

not be named on any patent or given credit in any public sphere.  He also falsely told 

investors that before he left the government he served as a scientific advisor to 

President George W. Bush and that he was later an advisor and friend of Senator 

John McCain. 

36. Chowdhury falsely represented to investors that he “pioneered 

scientific breakthroughs” at some of the nation’s most prestigious scientific research 

centers, including the National Aeronautics and Space Administration, Oak Ridge 

National Laboratory, California Institute of Technology and the Johns Hopkins 

Applied Physics Lab. 

37. Chowdhury also touted completely fabricated academic credentials.  

Presenting himself in person and in documents with the title “Doctor,” he claimed at 

different times and in different settings the following academic credentials: 

 Doctor of Science in Physics from MIT 

 Doctor of Science in Nuclear and Particle Physics from MIT 

 Doctor of Science in Quantum Physics from Johns Hopkins APL 

 Senior Executive Fellow at Harvard Kennedy School of Government 

 Senior Executive Fellow at MIT Sloan 

These claims were material and false. 

/// 

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4. Material Misrepresentations Regarding Chowdhury’s Own 

Investment in DTI  

38. Chowdhury falsely told several investors that he had invested anywhere 

between $1 million and $3 million of his own money in DTI.  He falsely told one 

investor that he had acquired the money he invested in DTI by selling to a major 

Korean electronics company a patent for a valuable technology he invented.   

39. In fact, Chowdhury did not invest any of his own money in DTI.  His 

only so-called personal investment in the company was a purported $1 million 

“loan” from one investor who had himself invested several million dollars in DTI.  

Chowdhury used the loan to pay his own salary and personal expenses. 

5. Material Misrepresentations Regarding Projected Revenue 

of DTI and QAC 

40. DTI and QAC marketing documents shown to prospective investors 

contained revenue projections that were false and misleading because there was no 

reasonable factual basis for the projections. 

41. One DTI marketing document that Chowdhury used during investor 

pitches in 2018 provided an “Income Statement” for QCC, one of the purported 

subsidiaries of DTI.  It projected QCC would produce a majority of DTI’s revenue 

between 2019 and 2021, including $18 million in 2019, $39.7 million in 2020, and 

$78.8 million in 2021.  QCC was not a subsidiary of DTI and had no employees or 

revenue, and Chowdhury had not reasonable basis for these projections.   

42. DTI sent a May 2018 marketing presentation for one of its purported 

subsidiaries, QCC, to an investor in advance of a June 2018 investment.  That 

document projected QCC revenue of $11.5 million for 2019, $143.5 million for 

2020, $341 million for 2021, and $577 million for 2022.  Later that year, Chowdhury 

updated the projected revenue of QCC to $2 billion by 2025. 

43. On December 10, 2018, Chowdhury emailed an investor a DTI 

financial model “base case” and noted in his cover email that “we will have over $15 

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million cash in 2020 and $40 million cash in 2021” in what he described as “the 

worst-case scenario.”  Chowdhury went on to claim that “we shall generate over 

$100 million EBITDA by 2023 which will give DTI a value over $1 Billion USD.” 

44. Chowdhury had no reasonable basis for making these statements. 

45. A QAC marketing document utilized by Chowdhury during investor 

presentations in 2020 included 2021 revenue projections for the purported 

subsidiaries of QAC.  It projected $5.3 million of revenue for Quantum Cyber AI, 

$3.7 million for 3RDGP Corporation, and $5.5 million for a subsidiary called 

QZULU Corporation.  Chowdhury had no reasonable basis for these revenue 

projections. 

46. Chowdhury emailed another investor on July 1, 2020, attaching a 

prospectus for QZULU Corporation.  In the cover email, Chowdhury told the 

investor that the only challenge for the QZULU project was “timing,” and assured 

him that they would receive “a good amount of fund [sic] in July,” from five different 

investors.  The prospectus itself claimed that QZULU was offering $8 million of 

preferred stock in the form of QZULU tokens (which never launched), and projected 

year-one revenue of more than $15 million from QZULU’s two biggest projects, 

QPOWER and QFARMS, and year-five revenue from the same entities of more than 

$1.5 billion. 

47. These materially misleading revenue forecasts were unsupported and 

internally inconsistent.  Despite the claims of massive future revenue, only one 

company owned by DTI or QAC ever produced actual revenue.  The revenue from 

that company was less than $100,000 before it became illiquid and ceased 

operations. 

C. Chowdhury’s Misappropriation of Investor Funds and Other 

Deceptive Acts 

48. All told, Chowdhury raised approximately $26.4 million from DTI and 

QAC investors between May 2018 and December 2022.  Chowdhury promised 

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investors the funds would be used to develop and commercialize the technologies of 

the purported subsidiaries, or for other operating expenses, such as rent, payroll, and 

insurance. 

49. While he used some funds for such expenses, Chowdhury fraudulently 

misappropriated most of the DTI and QAC investor funds, transferring money to 

overseas bank accounts and entities with no apparent connection to DTI or QAC, or 

using them for his personal expenditures.  Chowdhury also used investor funds to 

make Ponzi-like payments, as money from new investors was used to pay current 

investors who had accused Chowdhury of misconduct, threatened legal action, and 

demanded their money be returned. 

50. For example, one investor in early November 2018 demanded 

Chowdhury return his $150,000 investment in DTI after he became suspicious of 

Chowdhury.  Within a week, Chowdhury received three new investments from other 

investors, totaling $150,000, which Chowdhury used to pay the prior investor. 

51. As another example, Chowdhury in texts throughout 2020 and 2021 

repeatedly told an investor who was seeking repayment of promissory notes that DTI 

had no money to pay him until he could secure investments from new investors.  

Chowdhury’s pitches to the new QAC investors did not disclose that funds would 

be used to pay off previous investors in DTI. 

52. To conceal his misappropriation of investor funds, Chowdhury 

maintained tight control of DTI’s and QAC’s finances and enlisted family members 

with little or no financial experience to help him.  For example, Chowdhury hired 

his cousin, who had no previous experience in accounting or finance, as DTI’s 

purported “Corporate Controller.”  He added his cousin’s wife – who had no 

experience with finances – as a co-signer on QAC bank accounts, also listing her, 

falsely, as the company’s “Controller.”  He falsely listed his wife, who had no role 

with either DTI or QAC, as the companies’ “Corporate Secretary” to sign and 

authorize bank account opening documents.   

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53. Chowdhury also maintained at least 40 bank accounts at four different 

banks and created no less than 30 entities purportedly related to DTI and QAC.  

Neither DTI nor QAC kept consistent financial records, and neither undertook 

independent or internal audits.  Chowdhury did not use a transfer agent and did not 

appear to adequately record and maintain the companies’ stock issuances.  At one 

point, Chowdhury hired a contractor to organize the companies’ finances, but did 

not provide that person complete access to banking and financial records, and soon 

stopped paying his invoices. 

54. Records indicate that Chowdhury used the money he raised from DTI 

and QAC investors in the following ways: 

 $2.1 million withdrawn from ATM machines or bank tellers in cash by 

Chowdhury and his family, including numerous withdrawals from 

ATM machines located at casinos in Lake Tahoe and Las Vegas 

 $1 million used by Chowdhury and his family for personal expenses, 

including car payments, meals, wine, travel and jewelry 

 $7.9 million wired to businesses that have no known or apparent 

connection to DTI or QAC 

 $1.8 million used to pay back other investors in Ponzi-like payments, 

often after investors raised concerns about Chowdhury and his 

companies 

 $7 million unaccounted for, largely due to Chowdhury’s many 

domestic and overseas bank accounts, spread across four different 

financial institutions, and encompassing thousands of unexplained bank 

transactions 

55. Defendants used only about $6.6 million of the $26.4 million they 

raised from investors for operating expenditures relating to DTI and QAC, including 

rent, payroll, investments, equipment, and insurance. 

/// 

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THE STATUTORY PERIOD HAS BEEN TOLLED 

56. On February 1, 2023, Chowdhury entered into a tolling agreement with 

the SEC (“Tolling Agreement”) on behalf of himself, DTI, and QAC (as CEO of 

both entities) tolling and suspending the statute of limitations from March 1, 2023 

to September 1, 2023.   

FIRST CLAIM FOR RELIEF 

Violations of Section 17(a) of the Securities Act 

(All Defendants) 

57. The Commission repeats and realleges Paragraphs 1 through 56 of its 

Complaint. 

58. From no later than May 2018 through at least 2022, Defendants, by 

engaging in the conduct described above, directly or indirectly, in the offer or sale 

of securities, by the use of means or instruments of transportation or communication 

in interstate commerce or by the use of the mails:  (a) with scienter, employed 

devices, schemes, or artifices to defraud; (b) obtained money or property by means 

of untrue statements of material fact or by omitting 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; and (c) engaged in transactions, practices, or courses of 

business that operated or would operate as a fraud or deceit upon the purchaser of 

such securities. 

59. By reason of the foregoing, Defendants violated, and unless enjoined 

are reasonably likely to continue to violate, Securities Act Section 17(a) [15 U.S.C. 

§ 77q(a)(1), (2) and (3)]. 

SECOND CLAIM FOR RELIEF 

Violations of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder 

(All Defendants) 

60. The Commission repeats and realleges Paragraphs 1 through 56 of its 

Complaint. 

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61. From no later than May 2018 through at least 2022, Defendants, by 

engaging in the conduct described above, directly or indirectly, in connection with 

the purchase or sale of a security; by the use of means or instrumentalities of 

interstate commerce, or of the mails, or of the facilities of a national securities 

exchange, with scienter:  (a) employed devices, schemes, or artifices to defraud; (b) 

made untrue statements of material fact or omitted 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; and (c) engaged in acts, practices, or courses of business 

which operated or would operate as a fraud or deceit upon any person. 

62. By reason of the foregoing, Defendants violated, and unless enjoined 

are reasonably likely to continue to violate, Exchange Act Section 10(b) and Rule 

10b-5 [15 U.S.C. § 78j(b) and 17 C.F.R. § 240.10b-5(a), (b) and (c)]. 

THIRD CLAIM FOR RELIEF 

Aiding and Abetting Violations of Section 17(a) of the Securities Act 

(Defendant Chowdhury) 

63. The Commission repeats and realleges Paragraphs 1 through 56 of its 

Complaint. 

64. From no later than May 2018 through at least 2022, Defendants DTI 

and QAC, by engaging in the conduct described above, directly or indirectly, in the 

offer or sale of securities, by the use of means or instruments of transportation or 

communication in interstate commerce or by the use of the mails:  (a) with scienter, 

employed devices, schemes, or artifices to defraud; (b) obtained money or property 

by means of untrue statements of material fact or by omitting 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; and (c) engaged in transactions, practices, or 

courses of business that operated or would operate as a fraud or deceit upon the 

purchaser of such securities. 

65. By reason of the conduct described above, Chowdhury, acting 

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knowingly or recklessly, provided substantial assistance to, and thereby aided and 

abetted, DTI’s and QAC’s violations of Securities Act Section 17(a) [15 U.S.C. § 

77q(a)(1), (2) and (3)]. 

66. Accordingly, Chowdhury, pursuant to Securities Act Section 15(b) 

[15 U.S.C. § 77o(b)], is liable for those violations. 

FOURTH CLAIM FOR RELIEF 

Aiding and Abetting Violations of Section 10(b) of the Exchange Act and Rule 

10b-5 thereunder 

(Defendant Chowdhury) 

67. The Commission repeats and realleges Paragraphs 1 through 56 of its 

Complaint. 

68. From no later than May 2018 through at least 2022, Defendants DTI 

and QAC, by engaging in the conduct described above, directly or indirectly, in 

connection with the purchase or sale of a security; by the use of means or 

instrumentalities of interstate commerce, or of the mails, or of the facilities of a 

national securities exchange, with scienter:  (a) employed devices, schemes, or 

artifices to defraud; (b) made untrue statements of material fact or omitted 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; and (c) engaged in acts, 

practices, or courses of business which operated or would operate as a fraud or deceit 

upon any person. 

69. By reason of the conduct described above, Chowdhury, acting 

knowingly or recklessly, provided substantial assistance to, and thereby aided and 

abetted, DTI’s and QAC’s violations of Exchange Act Section 10(b) and Rule 10b-

5 [15 U.S.C. § 78j(b) and 17 C.F.R. § 240.10b-5(a), (b) and (c)]. 

70. Accordingly, Chowdhury, pursuant to Exchange Act Section 20(e) [15 

U.S.C. § 78t(e)], is liable for these violations. 

/// 

Case 8:23-cv-01741   Document 1   Filed 09/19/23   Page 16 of 19   Page ID #:16



 

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FIFTH CLAIM FOR RELIEF 

Control Person Liability 

(Defendant Chowdhury) 

71. The Commission repeats and realleges Paragraphs 1 through 56 of its 

Complaint. 

72. From no later than May 2018 through at least 2022, Defendants DTI 

and QAC, which were under Chowdhury’s control, by engaging in the conduct 

described above, directly or indirectly, in connection with the purchase or sale of a 

security; by the use of means or instrumentalities of interstate commerce, or of the 

mails, or of the facilities of a national securities exchange, with scienter:  (a) 

employed devices, schemes, or artifices to defraud; (b) made untrue statements of 

material fact or omitted 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; and (c) engaged in acts, practices, or courses of business which operated 

or would operate as a fraud or deceit upon any person. 

73. By reason of the conduct described above, Chowdhury was a control 

person of DTI and QAC in that Chowdhury exercised actual power and control over 

DTI and QAC and was a culpable participant in their violations of Exchange Act 

Section 10(b) and Rule 10b-5 thereunder [15 U.S.C. § 78j(b) and 17 C.F.R. 

§ 240.10b-5(a), (b) and (c)]. 

74. Accordingly, Chowdhury, pursuant to Exchange Act Section 20(a) [15 

U.S.C. § 78t(a)], is liable for these violations. 

PRAYER FOR RELIEF  

WHEREFORE, the Commission respectfully requests that the Court: 

I. 

Issue findings of fact and conclusions of law that Defendants committed the 

alleged violations. 

/// 

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II. 

Issue judgments, in a form consistent with Rule 65(d) of the Federal Rules of 

Civil Procedure, permanently restraining and enjoining Defendants from, directly or 

indirectly, violating Securities Act Section 17(a) [15 U.S.C. § 77q(a)] and Exchange 

Act Section 10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. §§ 

240.10b-5]. 

III. 

Issue judgments, in a form consistent with Rule 65(d) of the Federal Rules of 

Civil Procedure, permanently restraining and enjoining Defendant Chowdhury from 

aiding or abetting any violation of Securities Act Section 17(a) [15 U.S.C. § 77q(a)] 

and Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 

C.F.R. §§ 240.10b-5]. 

IV. 

Issue judgments, in a form consistent with Rule 65(d) of the Federal Rules of 

Civil Procedure, permanently restraining and enjoining Defendants from directly or 

indirectly, including, but not limited to, through any entity owned or controlled by 

them, participating in the issuance, purchase, offer, or sale of any securities, 

provided, however, that such injunction shall not prevent Defendant Chowdhury 

from purchasing or selling securities listed on a national securities exchange for his 

own personal account. 

V. 

Order Defendants to disgorge all funds received from their illegal conduct, 

together with prejudgment interest thereon, pursuant to pursuant to Exchange Act 

Sections 21(d)(5) and 21(d)(7) [15 U.S.C. §§ 78u(d)(5) and 78u(d)(7)]. 

VI. 

Order Defendants to pay civil penalties under Securities Act Section 20(d) [15 

U.S.C. § 77t(d)] and Exchange Act Section 21(d) [15 U.S.C. § 78u(d)(3)]. 

/// 

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VII. 

Bar Defendant Chowdhury from serving as an officer or director of a public 

company pursuant to Securities Act Section 20(e) [15 U.S.C. § 77t(e)] and Exchange 

Act Section 21(d)(3) [15 U.S.C. § 78u(d)(6)]. 

VIII. 

Retain jurisdiction of this action in accordance with the principles of equity 

and the Federal Rules of Civil Procedure in order to implement and carry out the 

terms of all orders and decrees that may be entered, or to entertain any suitable 

application or motion for additional relief within the jurisdiction of this Court. 

IX. 

Grant such other and further relief as this Court may deem just, equitable, or 

necessary in connection with the enforcement of the federal securities laws and for 

the protection of investors. 

   
DATED:  September 19, 2023  
  /s/ Gary Y. Leung 

  Gary Y. Leung 
Counsel for Plaintiff 
Securities and Exchange Commission 
444 S. Flower Street, Suite 900 
Los Angeles, CA 90071 
Telephone:  (323) 965-3988 
Facsimile:  (213) 443-1904 
Email:  [email protected] 
 
Darren E. Long 
Email:  [email protected] 
Telephone: (202) 551-4788 
Brian D. Vann 
Email:  [email protected] 
Telephone: (202) 551-7165 
Counsel for Plaintiff 
Securities and Exchange Commission 
100 F Street N.E. 
Washington, DC 20549-5985 

 

Case 8:23-cv-01741   Document 1   Filed 09/19/23   Page 19 of 19   Page ID #:19



Complaints and Other Initiating Documents
8:23-cv-01741 Securities and Exchange Commission v. Chowdhury et al

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

Notice of Electronic Filing

The following transaction was entered by Leung, Gary on 9/19/2023 at 9:23 AM PDT and filed on 9/19/2023
Case Name: Securities and Exchange Commission v. Chowdhury et al
Case Number: 8:23-cv-01741
Filer: Securities and Exchange Commission
Document Number:1

Docket Text:
COMPLAINT No Fee Required - US Government, filed by Plaintiff Securities and Exchange Commission. (Attorney
Gary Y. Leung added to party Securities and Exchange Commission(pty:pla))(Leung, Gary)

8:23-cv-01741 Notice has been electronically mailed to:

Gary Y. Leung     [email protected], [email protected], [email protected], [email protected]

8:23-cv-01741 Notice has been delivered by First Class U. S. Mail or by other means BY THE FILER to :

The following document(s) are associated with this transaction:

Document description:Main Document
Original filename:C:\fakepath\2023-09-19 DTI Complaint (final for filing).pdf
Electronic document Stamp:
[STAMP cacdStamp_ID=1020290914 [Date=9/19/2023] [FileNumber=36562457-0
] [b256505d224036a3897e9b73ae6d5b269a63c1e409c4f2e6191babdd2becbe6184b
98360aa99630e68a6266857c110e865c96873f3307e0fab3dfd6d4f7cd685]]

https://ecf.cacd.uscourts.gov/cgi-bin/DktRpt.pl?899133
https://ecf.cacd.uscourts.gov/cgi-bin/DktRpt.pl?899133
https://ecf.cacd.uscourts.gov/doc1/031140859600?caseid=899133&de_seq_num=5&magic_num=MAGIC