SEC v. Thomas Collins; Patrick Thomas; Gary Kouletas; Scott Levine; and Brian Kingsfield, No. 1:20-cr-00842, Northern District of Texas (June 30, 2023) — Complaint

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION
________________________________________________
        )
SECURITIES AND EXCHANGE COMMISSION, )
        )
 Plaintiff,      )
        ) Civil Action No.:
v.        )
        ) JURY TRIAL DEMANDED
THOMAS COLLINS,      )
PATRICK THOMAS,     )
GARY KOULETAS,     )
SCOTT LEVINE, and     )
BRIAN KINGSFIELD,            )
        )
Defendants.          )
________________________________________________)

COMPLAINT

Plaintiff Securities and Exchange Commission (the “Commission” or “SEC”) alleges:
NATURE OF THE ACTION
1. The Commission brings this action against Thomas Collins, Patrick Thomas, Gary
Kouletas,  Scott  Levine,  and  Brian  Kingsfield  (collectively,  “Defendants”)  for  violations  of  the
federal securities laws.  In a scheme that lasted for more than a year, Collins and Thomas secretly
gained  control  over  Global  Resource  Energy,  Inc.  (“GBEN”)  and  nearly  all  of  the  company’s
shares available for public trading.  Collins and Thomas then coordinated efforts with Kouletas,
Kingsfield, and Levine to fraudulently sell GBEN stock into the market, maintaining secrecy about
the  source  of  the  shares.    As  part  of  the  Defendants’  scheme,  Kingsfield  also  acted  as  an
unregistered  broker  in  soliciting  investors  to  purchase  GBEN  shares.    Defendants  collectively
received approximately $1.7 million in proceeds from these fraudulent securities transactions.

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2. GBEN was purportedly a health-and-wellness business, offering lifestyle products
including  the  distribution  of  a  ready-to-drink,  hemp-infused  cocktail  called  “Hemp  Hazed.”    In
February  2019,  Collins  and  Thomas  obtained  control  of  GBEN  through  a  series  of  misleading
transactions designed to conceal their control of the company and ownership of vast amounts of
GBEN stock.
3. Collins and Thomas engaged a network of salespeople, including Kingsfield, to sell
GBEN shares to the public.  Using sham consulting agreements, Collins and Thomas orchestrated
the  transfer  of  millions  of  restricted  shares  of  GBEN  stock  to  a  third-party  entity  to  give  the
appearance that the shares were freely tradeable.  Kingsfield and others then sold to the public the
shares  held  by  the  third-party  entity  to  generate  profits  that  Kingsfield split  with  Thomas  and
Collins.  In so doing, Kingsfield knowingly offered and sold GBEN stock without being registered
as a broker with the Commission.
4. To  carry  out  this  fraudulent  scheme,  Collins  also  enlisted  the  aid  of  Levine,  a
market-maker.   A market-maker is a person or entity who buys securities from sellers and sells to
buyers, providing liquidity to the market.  Collins directed Levine to identify incoming investor
bids to buy GBEN so that Collins and Thomas could dump their purportedly free-trading shares
through an entity owned by Kouletas (the “Kouletas Entity”) –   a process known as “flashing the
bid.”  Typically, Levine would sell short GBEN shares into the public market, thereby matching
with the  unsuspecting  investors  that  salespeople  like  Kingsfield  were  soliciting  and  advising  to
buy GBEN.  Collins agreed that Levine could keep approximately five-percent of the public sale
price for himself when he closed out his short positions.
5. To  further  conceal  their  control  of  GBEN  shares  that they  sold  to  the  market,
Collins and Thomas also entered into a sham agreement with the Kouletas Entity.  The Kouletas

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Entity then appeared to enter into an agreement with an entity that Thomas controlled to acquire
500,000 shares of GBEN stock for $10,000.  In reality, Thomas, Collins, and Kouletas had a secret
understanding, whereby the Kouletas Entity would only retain a percentage of the proceeds of the
sales of these shares to the public.  The Kouletas Entity t hen sold more than 1.3 million GBEN
shares to the public, generating approximately $938,000 in trading proceeds.
6. Collins  and  Thomas  planned  an  aggressive  promotional  campaign  to  “pump”
GBEN stock and obtain more trading profits, but these plans were thwarted when the Commission
suspended trading in GBEN stock in August 2020.
7. Through  their  actions,  Defendants  violated,  and  unless  enjoined  will  continue  to
violate,  the  antifraud  provisions  of  the  federal  securities  laws,  namely  Section  10(b)  of  the
Securities Exchange Act of 1934 (“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)] and Sections 17(a)(1) and (3) of the Securities
Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77q(a)(1) and (3)].
8.  Additionally,  through  his  actions,  Defendant  Kingsfield  violated,  and  unless
enjoined will continue to violate, the broker-registration provisions of the federal securities laws,
namely Section 15(a) of the Exchange Act [15 U.S.C. § 78o(a)].
9. To protect the public from further harm and fraudulent activity, the SEC brings this
action against Defendants and seeks: (i) permanent injunctive relief; (ii) disgorgement of ill-gotten
gains,  plus  prejudgment  interest;  (iii)  civil  penalties;  (iv) penny  stock  bars;  and  (v)  officer-and-
director bars against Collins and Thomas.
DEFENDANTS
10. Thomas Collins, age 50, formerly lived in Weatherford, Texas.  On December 13,
2022,  Collins  was  sentenced  to  41  months  imprisonment  after  he  pled  guilty  to  Conspiracy  to

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Commit Securities Fraud under 18 U.S.C. § 371.  United States v. Collins, et al., 1:20-cr-00842-
BYP  (N.D.  Ohio).    In  his  criminal  case,  Collins  was  also ordered  to  pay  restitution  of
$2,303,824.97 on a joint-and-several basis with the other Defendants.
11. Patrick Thomas, age 50, formerly lived in Carrolton, Texas.  On October 18, 2022,
Thomas was sentenced to 18 months imprisonment after he pled guilty to Conspiracy to Commit
Securities Fraud under 18 U.S.C. § 371.  United States v. Collins, et al., 1:20-cr-00842-BYP (N.D.
Ohio).  In his criminal case, Thomas was ordered to pay restitution of $2,848,372.97 on a joint-
and-several basis with the other Defendants.
12. Gary  Kouletas, age  47,  formerly  lived  in  Hasbrouck  Heights,  New  Jersey.    On
August 30, 2022, Kouletas pled guilty to Conspiracy to Commit Securities Fraud under 18 U.S.C.
§   371.  On March 17, 2023, Kouletas was sentenced to 43 months imprisonment and ordered to
pay  restitution  of  $902,564.57 on  a  joint-and-several  basis  with  the  other Defendants.   United
States v. Collins, et al., 1:20-cr-00842-BYP (N.D. Ohio).
13. Scott  Levine,  age 44,  lives  in  Delray  Beach,  Florida.    Levine  was  charged  by
criminal information on May 3,    2023 of one count of Conspiracy to Commit Securities Fraud under
18 U.S.C. § 371.  United States v.    Levine, 1:23-cr-00262-SL (N.D. Ohio).  Levine pleaded guilty
on June 12, 2023 and awaits sentencing.  The Financial Industry Regulatory Authority (“FINRA”)
suspended Levine on December 22, 2021 and permanently barred him on March 25, 2022.
14. Brian Kingsfield, age 53, formerly lived in Laguna Niguel, California.  In 2015,
Kingsfield was  convicted  on  November  20,  2017  of  one  count  of  Conspiracy  to  Commit  Wire
Fraud under 18 U.S.C. § 371 for a stock-related fraud unrelated to the facts of this case.  United
States  v.  Kingsfield,  15-cr-00014-JVS  (C.D.  Cal.).    On  July  27,  2022,  Kingsfield  pled  guilty  to
Conspiracy  to  Commit  Securities  Fraud  under  18  U.S.C.  §  371,  was  sentenced  to  37  months

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imprisonment, and was ordered to pay restitution of $584,950.63 on a joint-and-several basis with
the other Defendants.  United States v. Collins, et al., 1:20-cr-00842-BYP (N.D. Ohio).
Related Entity
15. Global Resource Energy, Inc. is a Nevada corporation with its principal place of
business in Fort Worth, Texas.  Global Resource Energy, Inc.’s common stock was quoted on OTC
Link,  an  electronic  inter-dealer  quotation  system, under  the  symbol  “GBEN,”  until  August  17,
2020,  when  the  Commission  suspended  trading  in  GBEN  pursuant  to Section  12(k)  of  the
Exchange Act.
JURISDICTION AND VENUE
16. The  Commission  brings  this  action  pursuant  to  authority  conferred  upon  it  by
Sections 20(b) and 20(d) of the Securities Act [15 U.S.C. §§ 77t(b) and 77t(d)] and Sections 21(d)
and 21(e) of the Exchange Act [15 U.S.C. §§ 78u(d) and 78u(e)].
17. This  Court  has  jurisdiction  over  this  action  pursuant  to  Section  22(a)  of  the
Securities  Act  [15  US.C.  §  77v(a)]  and  Sections  21(d),  21(e),  and  27  of  the  Exchange  Act  [15
U.S.C. §§ 78u(d), (e), and 78aa].
18. In connection with the conduct described in this Complaint, Defendants, directly or
indirectly, made use of the mails or the means or instruments of transportation or communication
in interstate commerce, including but not limited to email, wiring of funds, and use of brokerage
accounts.
19. Venue is proper in this District because Collins and Thomas resided in, and GBEN
had its principal place of business in, this District at all relevant times.  Further, acts, transactions,
and  courses  of  business  constituting  violations  of  the  federal  securities  laws  alleged  in  this

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Complaint  occurred  within  this  District,  including  Collins’s  and  Thomas’s  transmission  and
receipt of documents and proceeds that effectuated this scheme.
FACTUAL ALLEGATIONS
A. Background
20. Formed  in  November  2008,  GBEN  purported  to  be  engaged  in  the  health-and-
wellness  business,  offering  lifestyle  products  including  the  distribution  of  their  ready-to-drink,
hemp-infused  cocktail  called  “Hemp  Hazed.”    Although  GBEN  reported more  than  77  million
shares outstanding and a market capitalization of more than $40 million in June 2020, GBEN’s
financial  statements  for  the  period  ended  March  31,  2020,  showed that  the  company  had  total
revenue of negative $2,116, a net loss of $66,384, and negative retained earnings of $2,046,473.
B. Collins and Thomas Obtained Undisclosed Control of GBEN
21. Beginning  in  February  2019  through  the  date  of  the  Commission’s  trading
suspension in  GBEN’s  stock  on  August  17,  2020,  Collins  and  Thomas  exercised  undisclosed
control of the vast majority of GBEN’s securities with the intent to profit from shareholders via a
number of manipulative and deceptive actions.  Collins and Thomas had an agreement to split the
profits of their scheme.
22. On   or   about   February   26,   2019,   Thomas—through   multiple   companies   he
controlled—acquired seven million  shares  of  GBEN  stock  from  one  of  GBEN’s largest
shareholders.  Within a month, Thomas and Collins obtained control of GBEN through a reverse
merger  involving  a  company  Collins  controlled,  with  Collins’s wife taking  the  role  of  GBEN’s
nominal CEO.  Collins controlled all decisions related to GBEN’s securities.
23. Thomas,  although  not  a  licensed  public  accountant,  facilitated  the  preparation  of
GBEN’s  financial  statements  and posted  them  to  the  OTC  Markets  website.    As  a  controlling

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shareholder, Thomas knowingly failed to disclose in these statements the material fact that he had
acquired  two  outstanding  convertible  promissory  notes  from  a  single  GBEN shareholder,  thus
obtaining a near super majority of outstanding shares.
24. In  fact,  up until the  SEC  suspended  trading  in  GBEN’s stock in  August  2020,
GBEN’s  OTC  Disclosure  Statement  (published  on  June  23,  2020)  falsely  listed  the  convertible
promissory  notes  that  Thomas  had  acquired  as  still being  owned  by  the  prior  shareholder.    The
value of these two notes, based on the outstanding principal and accrued interest, allowed Collins
and Thomas to convert the notes into as much as 150 million shares of GBEN stock (out of the
250 million shares authorized).
C. Collins, Thomas, Kingsfield, and Levine Fraudulently Offered and Sold
Shares of GBEN Stock to Investors
25. Shortly after Collins and Thomas obtained their undisclosed control of GBEN, they
engaged in a series of fraudulent transactions to profit from their scheme.  On or about March 25,
2019, Collins and Thomas directed GBEN to issue three million restricted shares of GBEN stock
to  a  third-party entity (Company  A), pursuant  to a  fraudulent  consulting  agreement  between
Company A and GBEN dated January 7, 2019.
26. In  fact,  Company  A  did  not  actually  enter  into  this  agreement.    Instead,  Thomas
forged the signature of Company A’s CEO on the January 7, 2019 agreement.
27. Collins and Thomas then engaged a network of salespeople, including Kingsfield
and  others,  to  solicit  investors  to  purchase  the  restricted  GBEN  shares  issued  to  Company  A.
Unknown to those investors, Collins and Thomas agreed to pay up to 50% of the sales proceeds
of the GBEN shares to the salespeople.
28. Between April 2, 2019, and July 26, 2019, Collins and Thomas used Kingsfield and
others  to sell  approximately  2,921,261  shares  of  restricted  GBEN  stock  that  had  been  issued  to

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Company  A.    Those  sales  generated $784,125  in  proceeds,  which  was  split  evenly  between
Thomas, Collins, Kingsfield, and another salesperson.
29. Kingsfield also coordinated with Thomas to deceive investors with respect to the
GBEN stock held by Company A.  First, due to his previous criminal history, detailed in paragraph
14  above, Kingsfield  used  the  alias  “Brian  Evans”  when  offering  and  selling  GBEN  shares  to
investors.  Collins and Thomas both knew that Kingsfield used the alias when trying to sell the
GBEN stock.
30. Also, in part because of his criminal history, Kingfield and another salesperson sold
restricted GBEN shares to investors through another entity, Company B.  Kingsfield and Thomas
orchestrated a second sham consulting agreement to transfer 1,461,904 of these restricted shares
from Company A to Company B in three separate transfers.
31. Kingsfield   actively   solicited   investors   through   cold   calls,   advised potential
investors on the attractiveness of investing in GBEN, and received transaction-based compensation
from Collins and Thomas.  Throughout this time, Kingsfield knew that he was offering and selling
GBEN stock without being registered as a broker.
D. Collins and Thomas Dump GBEN Shares on the Market

32. Collins  and  Thomas  sold unrestricted shares  of  GBEN  stock  that they  owned  in
several fraudulent ways, including through orchestrated open-market transactions.
33. Collins and Thomas directed Kingsfield and others to solicit GBEN shareholders
and others to purchase GBEN shares on the open market.  For these open-market trades, Collins
and   Thomas   paid   Kingsfield   and   others   transaction-based   compensation   amounting   to
approximately 35% of the sales’ proceeds.

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34. To assist Collins in carrying out the scheme, Kingsfield advised investors by phone
as to specific prices and volumes for their open market trades.  Later, Kingsfield contacted Collins
and informed him of the amounts that each investor was willing to purchase.
35. Collins  then used  the  information  conveyed  by  Kingsfield  to  direct Levine,  a
market-maker.  Collins asked Levine to look for incoming bids of GBEN stock so that Collins and
Thomas  could  dump  their  free-trading  shares—a  process  known  as  “flashing  the  bid.”    Levine
knew  that  Collins  and  Thomas  had  purported free-trading  shares  that they  were  selling  into  the
market.  As part of the scheme, Levine typically engaged in short selling GBEN shares into the
public market, thereby matching with the unsuspecting investors that Kingsfield and others had
solicited and advised to buy GBEN.
36. Collins and Levine had an agreement with Levine that he could keep five-percent
of the public purchase price upon closing out his short positions.
37. Collins and Thomas also sold shares of GBEN stock into the market through the
Kouletas Entity.  In order to conceal the fact that Collins and Thomas were the source of the GBEN
shares  being  dumped on  the  market,  the  Kouletas  Entity  executed  a  Stock  Purchase  Agreement
(“SPA”) with an entity controlled by Thomas.  Pursuant to the SPA, the Kouletas Entity purported
to acquire 500,000 shares of GBEN stock for $10,000 on or about March 27, 2019.
38. In reality, Collins and Thomas had a handshake agreement with Kouletas that his
entity was merely a pass-through entity for sales of GBEN stock, for which Collins and Thomas
agreed that the Kouletas Entity could retain up to 17% of the proceeds from the sales of GBEN
stock.  Collins, Thomas, and Kouletas failed to disclose this fact to GBEN’s transfer agent when
the Kouletas Entity presented the SPA for the transfer of GBEN shares.

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39. Between July 3, 2019, and July 13, 2020, the Kouletas Entity sold more than 1.3
million shares of  Collins’s  and  Thomas’s  GBEN  stock to  the  market,  generating  approximately
$938,000 in trading proceeds.  The Kouletas Entity then wired the majority of the trading proceeds
to bank accounts controlled by Thomas.  A significant number of the Kouletas Entity’s sales of
GBEN stock were matched with Levine’s transactions closing out his short positions.
40. As  he  conducted  the  Kouletas  Entity  transactions, Levine  knew  that Collins  and
Thomas were the only sellers of GBEN stock.
CLAIMS FOR RELIEF
FIRST CLAIM FOR RELIEF

Fraud in Connection with the Purchase or Sale of a Security

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 All Defendants
41. Plaintiff re-alleges and incorporates paragraphs 1 through 40 of this Complaint by
reference as if set forth verbatim in this Claim.
42. By  engaging  in  the  acts  and  conduct  alleged  herein,  Defendants,  directly  or
indirectly,  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, knowingly or with severe recklessness:
a. employed a device, scheme, or artifice to defraud; and/or
b. engaged  in  an  act,  practice,  or course  of  business  which  operated  or  would
operate as a fraud or deceit upon any person.

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43. By reason of the foregoing, Defendants 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)].
SECOND CLAIM FOR RELIEF

Fraud in the Offer or Sale of a Security

Violations of Sections 17(a)(1) and 17(a)(3) of the Securities Act
[15 U.S.C. §§ 77q(a)(1) and (3)]

Against All Defendants

44. Plaintiff re-alleges and incorporates paragraphs 1 through 40 of this Complaint by
reference as if set forth verbatim in this Claim.
45. By  engaging  in  the  acts  and  conduct  alleged  herein,  Defendants,  directly  or
indirectly, in the offer or sale of a security, by the use of any means or instruments of transportation
or communication in interstate commerce or by use of the mails, directly or indirectly, have:
a. knowingly  or  with  severe  recklessness  employed  a  device,  scheme,  or
artifice to defraud; and/or
b. knowingly (or with severe recklessness), recklessly, or negligently engaged
in  a  transaction,  practice,  or  course  of  business  which  operated  or  would  operate  as  a  fraud  or
deceit upon the purchaser.
46. By  reason  of  the  foregoing,  Defendants  have  violated,  and  unless  enjoined  will
continue to violate, Sections 17(a)(1) and (3) of the Securities Act [15 U.S.C. §§ 77q(a)(1) and
(3)].

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THIRD CLAIM FOR RELIEF

Broker-Registration Violations

Violations of Sections 15(a) of the Exchange Act
[15 U.S.C. § 78o(a)]

Against Kingsfield
47. Plaintiff re-alleges and incorporates paragraphs 1 through 40 of this Complaint by
reference as if set forth verbatim in this Claim.
48. By engaging in the conduct described herein, Defendant Kingsfield, while
engaged in the business of effecting transactions in securities for the account(s) of others, made
use of the mails or any means or instrumentality of interstate commerce to effect transactions in,
or to induce or attempt to induce the purchase or sale of, a security without being registered with
the Commission as a broker or dealer or as an associated person of a registered broker or dealer,
in accordance with Section 15(b) of the Exchange Act.
49. By engaging in this conduct, Defendant Kingsfield has violated, and unless
enjoined will continue to violate, Section 15(a) of the Exchange Act [15 U.S.C. § 78o(a)].

PRAYER FOR RELIEF

WHEREFORE, the Commission respectfully requests that the Court enter a judgment:
1. Permanently enjoining the Defendants from violating Sections 17(a)(1) and (3) of
the  Securities  Act  [15  U.S.C.  §§  77q(a)(1)  and  (3)]  and  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)];
2. Permanently  enjoining  Defendant  Kingsfield  from  violating  Section  15(a)  of  the
Exchange Act [15 U.S.C. § 78o(a)];

3.Permanently barring Defendants from participating in an offering of penny stock,
including engaging in activities with a broker, dealer, or issuer for purposes of issuing, trading, or
inducing or attempting to induce the purchase or sale of any penny stock. A penny stock is any
equity security that has a price of less than five dollars, except as provided in Rule 3a51-1 under
the Exchange Act [17 C.F.R. 240.3a51-1];
4.Permanently enjoining Defendants Collins and Thomas from serving as an officer
or director of any issuer required to file reports with the SEC under Section 12(b), 12(g), or 15(d)
ofthe Exchange Act [15 U.S.C. §§ 781(b), 781(g), and 78o(d)] pursuant to Section 21(d)(2) ofthe
Exchange Act [15 U.S.C. § 78u(d)(2)];
5.Ordering the Defendants to disgorge all ill-gotten gains received as a result of the
violations alleged herein, plus prejudgment interest on those amounts, pursuant to the Court's
equitable powers and Section 21(d)(3), 21(d)(5), and 21(d)(7) ofthe Exchange Act [15 U.S.C. §§
78u(d)(3), (5), and (7);
6.Ordering the Defendants to pay civil penalties pursuant to Section 20(d) of the
Securities Act [15 U.S.C. § 77t(d)] and Section 2l(d)(3) of the Exchange Act [15 U.S.C. §
78u(d)(3)]; and
7.Imposing such other and further relief as the Court may deem just and proper.
Dated: June 30, 2023
.  272325
United States Securities and
Exchange Commission
Burnett Plaza, Suite 1900
801 Cherry Street, Unit 18
Fort Worth, TX 76102
Telephone: (817) 978-3821
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Facsimile:  (817) 978-4927
[email protected]

Attorney for Plaintiff

ATTORNEY FOR PLAINTIFF SECURITIES
AND EXCHANGE COMMISSION

IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 
________________________________________________ 
        ) 
SECURITIES AND EXCHANGE COMMISSION, ) 
        )  
 Plaintiff,      ) 
        ) Civil Action No.:    
v.        )  
        ) JURY TRIAL DEMANDED 
THOMAS COLLINS,      ) 
PATRICK THOMAS,     )  
GARY KOULETAS,     ) 
SCOTT LEVINE, and     ) 
BRIAN KINGSFIELD,        ) 
        ) 

Defendants.      ) 
________________________________________________) 

 
COMPLAINT 

 
Plaintiff Securities and Exchange Commission (the “Commission” or “SEC”) alleges: 

NATURE OF THE ACTION 

1. The Commission brings this action against Thomas Collins, Patrick Thomas, Gary 

Kouletas, Scott Levine, and Brian Kingsfield (collectively, “Defendants”) for violations of the 

federal securities laws.  In a scheme that lasted for more than a year, Collins and Thomas secretly 

gained control over Global Resource Energy, Inc. (“GBEN”) and nearly all of the company’s 

shares available for public trading.  Collins and Thomas then coordinated efforts with Kouletas, 

Kingsfield, and Levine to fraudulently sell GBEN stock into the market, maintaining secrecy about 

the source of the shares.  As part of the Defendants’ scheme, Kingsfield also acted as an 

unregistered broker in soliciting investors to purchase GBEN shares.  Defendants collectively 

received approximately $1.7 million in proceeds from these fraudulent securities transactions.  

Case 4:23-cv-00676-O   Document 1   Filed 06/30/23    Page 1 of 14   PageID 1



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2. GBEN was purportedly a health-and-wellness business, offering lifestyle products 

including the distribution of a ready-to-drink, hemp-infused cocktail called “Hemp Hazed.”  In 

February 2019, Collins and Thomas obtained control of GBEN through a series of misleading 

transactions designed to conceal their control of the company and ownership of vast amounts of 

GBEN stock.     

3. Collins and Thomas engaged a network of salespeople, including Kingsfield, to sell 

GBEN shares to the public.  Using sham consulting agreements, Collins and Thomas orchestrated 

the transfer of millions of restricted shares of GBEN stock to a third-party entity to give the 

appearance that the shares were freely tradeable.  Kingsfield and others then sold to the public the 

shares held by the third-party entity to generate profits that Kingsfield split with Thomas and 

Collins.  In so doing, Kingsfield knowingly offered and sold GBEN stock without being registered 

as a broker with the Commission.   

4. To carry out this fraudulent scheme, Collins also enlisted the aid of Levine, a 

market-maker.  A market-maker is a person or entity who buys securities from sellers and sells to 

buyers, providing liquidity to the market.  Collins directed Levine to identify incoming investor 

bids to buy GBEN so that Collins and Thomas could dump their purportedly free-trading shares 

through an entity owned by Kouletas (the “Kouletas Entity”) – a process known as “flashing the 

bid.”  Typically, Levine would sell short GBEN shares into the public market, thereby matching 

with the unsuspecting investors that salespeople like Kingsfield were soliciting and advising to 

buy GBEN.  Collins agreed that Levine could keep approximately five-percent of the public sale 

price for himself when he closed out his short positions. 

5. To further conceal their control of GBEN shares that they sold to the market, 

Collins and Thomas also entered into a sham agreement with the Kouletas Entity.  The Kouletas 

Case 4:23-cv-00676-O   Document 1   Filed 06/30/23    Page 2 of 14   PageID 2



3 
 

Entity then appeared to enter into an agreement with an entity that Thomas controlled to acquire 

500,000 shares of GBEN stock for $10,000.  In reality, Thomas, Collins, and Kouletas had a secret 

understanding, whereby the Kouletas Entity would only retain a percentage of the proceeds of the 

sales of these shares to the public.  The Kouletas Entity then sold more than 1.3 million GBEN 

shares to the public, generating approximately $938,000 in trading proceeds. 

6. Collins and Thomas planned an aggressive promotional campaign to “pump” 

GBEN stock and obtain more trading profits, but these plans were thwarted when the Commission 

suspended trading in GBEN stock in August 2020.   

7. Through their actions, Defendants violated, and unless enjoined will continue to 

violate, the antifraud provisions of the federal securities laws, namely Section 10(b) of the 

Securities Exchange Act of 1934 (“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)] and Sections 17(a)(1) and (3) of the Securities 

Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77q(a)(1) and (3)].   

8.  Additionally, through his actions, Defendant Kingsfield violated, and unless 

enjoined will continue to violate, the broker-registration provisions of the federal securities laws, 

namely Section 15(a) of the Exchange Act [15 U.S.C. § 78o(a)].  

9. To protect the public from further harm and fraudulent activity, the SEC brings this 

action against Defendants and seeks: (i) permanent injunctive relief; (ii) disgorgement of ill-gotten 

gains, plus prejudgment interest; (iii) civil penalties; (iv) penny stock bars; and (v) officer-and-

director bars against Collins and Thomas. 

DEFENDANTS 

10. Thomas Collins, age 50, formerly lived in Weatherford, Texas.  On December 13, 

2022, Collins was sentenced to 41 months imprisonment after he pled guilty to Conspiracy to 

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Commit Securities Fraud under 18 U.S.C. § 371.  United States v. Collins, et al., 1:20-cr-00842-

BYP (N.D. Ohio).  In his criminal case, Collins was also ordered to pay restitution of 

$2,303,824.97 on a joint-and-several basis with the other Defendants.   

11. Patrick Thomas, age 50, formerly lived in Carrolton, Texas.  On October 18, 2022, 

Thomas was sentenced to 18 months imprisonment after he pled guilty to Conspiracy to Commit 

Securities Fraud under 18 U.S.C. § 371.  United States v. Collins, et al., 1:20-cr-00842-BYP (N.D. 

Ohio).  In his criminal case, Thomas was ordered to pay restitution of $2,848,372.97 on a joint-

and-several basis with the other Defendants. 

12. Gary Kouletas, age 47, formerly lived in Hasbrouck Heights, New Jersey.  On 

August 30, 2022, Kouletas pled guilty to Conspiracy to Commit Securities Fraud under 18 U.S.C. 

§ 371.  On March 17, 2023, Kouletas was sentenced to 43 months imprisonment and ordered to 

pay restitution of $902,564.57 on a joint-and-several basis with the other Defendants.  United 

States v. Collins, et al., 1:20-cr-00842-BYP (N.D. Ohio).  

13. Scott Levine, age 44, lives in Delray Beach, Florida.  Levine was charged by 

criminal information on May 3, 2023 of one count of Conspiracy to Commit Securities Fraud under 

18 U.S.C. § 371.  United States v. Levine, 1:23-cr-00262-SL (N.D. Ohio).  Levine pleaded guilty 

on June 12, 2023 and awaits sentencing.  The Financial Industry Regulatory Authority (“FINRA”) 

suspended Levine on December 22, 2021 and permanently barred him on March 25, 2022.   

14. Brian Kingsfield, age 53, formerly lived in Laguna Niguel, California.  In 2015, 

Kingsfield was convicted on November 20, 2017 of one count of Conspiracy to Commit Wire 

Fraud under 18 U.S.C. § 371 for a stock-related fraud unrelated to the facts of this case.  United 

States v. Kingsfield, 15-cr-00014-JVS (C.D. Cal.).  On July 27, 2022, Kingsfield pled guilty to 

Conspiracy to Commit Securities Fraud under 18 U.S.C. § 371, was sentenced to 37 months 

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imprisonment, and was ordered to pay restitution of $584,950.63 on a joint-and-several basis with 

the other Defendants.  United States v. Collins, et al., 1:20-cr-00842-BYP (N.D. Ohio).   

Related Entity 

15. Global Resource Energy, Inc. is a Nevada corporation with its principal place of 

business in Fort Worth, Texas.  Global Resource Energy, Inc.’s common stock was quoted on OTC 

Link, an electronic inter-dealer quotation system, under the symbol “GBEN,” until August 17, 

2020, when the Commission suspended trading in GBEN pursuant to Section 12(k) of the 

Exchange Act. 

JURISDICTION AND VENUE 

16. The Commission brings this action pursuant to authority conferred upon it by 

Sections 20(b) and 20(d) of the Securities Act [15 U.S.C. §§ 77t(b) and 77t(d)] and Sections 21(d) 

and 21(e) of the Exchange Act [15 U.S.C. §§ 78u(d) and 78u(e)]. 

17. This Court has jurisdiction over this action pursuant to Section 22(a) of the 

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

U.S.C. §§ 78u(d), (e), and 78aa]. 

18. In connection with the conduct described in this Complaint, Defendants, directly or 

indirectly, made use of the mails or the means or instruments of transportation or communication 

in interstate commerce, including but not limited to email, wiring of funds, and use of brokerage 

accounts.  

19. Venue is proper in this District because Collins and Thomas resided in, and GBEN 

had its principal place of business in, this District at all relevant times.  Further, acts, transactions, 

and courses of business constituting violations of the federal securities laws alleged in this 

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Complaint occurred within this District, including Collins’s and Thomas’s transmission and 

receipt of documents and proceeds that effectuated this scheme.  

FACTUAL ALLEGATIONS 

A. Background  

20. Formed in November 2008, GBEN purported to be engaged in the health-and-

wellness business, offering lifestyle products including the distribution of their ready-to-drink, 

hemp-infused cocktail called “Hemp Hazed.”  Although GBEN reported more than 77 million 

shares outstanding and a market capitalization of more than $40 million in June 2020, GBEN’s 

financial statements for the period ended March 31, 2020, showed that the company had total 

revenue of negative $2,116, a net loss of $66,384, and negative retained earnings of $2,046,473.   

B. Collins and Thomas Obtained Undisclosed Control of GBEN 

21. Beginning in February 2019 through the date of the Commission’s trading 

suspension in GBEN’s stock on August 17, 2020, Collins and Thomas exercised undisclosed 

control of the vast majority of GBEN’s securities with the intent to profit from shareholders via a 

number of manipulative and deceptive actions.  Collins and Thomas had an agreement to split the 

profits of their scheme.   

22. On or about February 26, 2019, Thomas—through multiple companies he 

controlled—acquired seven million shares of GBEN stock from one of GBEN’s largest 

shareholders.  Within a month, Thomas and Collins obtained control of GBEN through a reverse 

merger involving a company Collins controlled, with Collins’s wife taking the role of GBEN’s 

nominal CEO.  Collins controlled all decisions related to GBEN’s securities.   

23. Thomas, although not a licensed public accountant, facilitated the preparation of 

GBEN’s financial statements and posted them to the OTC Markets website.  As a controlling 

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shareholder, Thomas knowingly failed to disclose in these statements the material fact that he had 

acquired two outstanding convertible promissory notes from a single GBEN shareholder, thus 

obtaining a near super majority of outstanding shares.     

24. In fact, up until the SEC suspended trading in GBEN’s stock in August 2020, 

GBEN’s OTC Disclosure Statement (published on June 23, 2020) falsely listed the convertible 

promissory notes that Thomas had acquired as still being owned by the prior shareholder.  The 

value of these two notes, based on the outstanding principal and accrued interest, allowed Collins 

and Thomas to convert the notes into as much as 150 million shares of GBEN stock (out of the 

250 million shares authorized). 

C. Collins, Thomas, Kingsfield, and Levine Fraudulently Offered and Sold 
Shares of GBEN Stock to Investors 

25. Shortly after Collins and Thomas obtained their undisclosed control of GBEN, they 

engaged in a series of fraudulent transactions to profit from their scheme.  On or about March 25, 

2019, Collins and Thomas directed GBEN to issue three million restricted shares of GBEN stock 

to a third-party entity (Company A), pursuant to a fraudulent consulting agreement between 

Company A and GBEN dated January 7, 2019.   

26. In fact, Company A did not actually enter into this agreement.  Instead, Thomas 

forged the signature of Company A’s CEO on the January 7, 2019 agreement.   

27. Collins and Thomas then engaged a network of salespeople, including Kingsfield 

and others, to solicit investors to purchase the restricted GBEN shares issued to Company A.  

Unknown to those investors, Collins and Thomas agreed to pay up to 50% of the sales proceeds 

of the GBEN shares to the salespeople.   

28. Between April 2, 2019, and July 26, 2019, Collins and Thomas used Kingsfield and 

others to sell approximately 2,921,261 shares of restricted GBEN stock that had been issued to 

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Company A.  Those sales generated $784,125 in proceeds, which was split evenly between 

Thomas, Collins, Kingsfield, and another salesperson.     

29. Kingsfield also coordinated with Thomas to deceive investors with respect to the 

GBEN stock held by Company A.  First, due to his previous criminal history, detailed in paragraph 

14 above, Kingsfield used the alias “Brian Evans” when offering and selling GBEN shares to 

investors.  Collins and Thomas both knew that Kingsfield used the alias when trying to sell the 

GBEN stock.   

30. Also, in part because of his criminal history, Kingfield and another salesperson sold 

restricted GBEN shares to investors through another entity, Company B.  Kingsfield and Thomas 

orchestrated a second sham consulting agreement to transfer 1,461,904 of these restricted shares 

from Company A to Company B in three separate transfers. 

31. Kingsfield actively solicited investors through cold calls, advised potential 

investors on the attractiveness of investing in GBEN, and received transaction-based compensation 

from Collins and Thomas.  Throughout this time, Kingsfield knew that he was offering and selling 

GBEN stock without being registered as a broker. 

D. Collins and Thomas Dump GBEN Shares on the Market 
 

32. Collins and Thomas sold unrestricted shares of GBEN stock that they owned in 

several fraudulent ways, including through orchestrated open-market transactions.   

33. Collins and Thomas directed Kingsfield and others to solicit GBEN shareholders 

and others to purchase GBEN shares on the open market.  For these open-market trades, Collins 

and Thomas paid Kingsfield and others transaction-based compensation amounting to 

approximately 35% of the sales’ proceeds.   

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34. To assist Collins in carrying out the scheme, Kingsfield advised investors by phone 

as to specific prices and volumes for their open market trades.  Later, Kingsfield contacted Collins 

and informed him of the amounts that each investor was willing to purchase.   

35. Collins then used the information conveyed by Kingsfield to direct Levine, a 

market-maker.  Collins asked Levine to look for incoming bids of GBEN stock so that Collins and 

Thomas could dump their free-trading shares—a process known as “flashing the bid.”  Levine 

knew that Collins and Thomas had purported free-trading shares that they were selling into the 

market.  As part of the scheme, Levine typically engaged in short selling GBEN shares into the 

public market, thereby matching with the unsuspecting investors that Kingsfield and others had 

solicited and advised to buy GBEN.   

36. Collins and Levine had an agreement with Levine that he could keep five-percent 

of the public purchase price upon closing out his short positions. 

37. Collins and Thomas also sold shares of GBEN stock into the market through the 

Kouletas Entity.  In order to conceal the fact that Collins and Thomas were the source of the GBEN 

shares being dumped on the market, the Kouletas Entity executed a Stock Purchase Agreement 

(“SPA”) with an entity controlled by Thomas.  Pursuant to the SPA, the Kouletas Entity purported 

to acquire 500,000 shares of GBEN stock for $10,000 on or about March 27, 2019.   

38. In reality, Collins and Thomas had a handshake agreement with Kouletas that his 

entity was merely a pass-through entity for sales of GBEN stock, for which Collins and Thomas 

agreed that the Kouletas Entity could retain up to 17% of the proceeds from the sales of GBEN 

stock.  Collins, Thomas, and Kouletas failed to disclose this fact to GBEN’s transfer agent when 

the Kouletas Entity presented the SPA for the transfer of GBEN shares.   

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39. Between July 3, 2019, and July 13, 2020, the Kouletas Entity sold more than 1.3 

million shares of Collins’s and Thomas’s GBEN stock to the market, generating approximately 

$938,000 in trading proceeds.  The Kouletas Entity then wired the majority of the trading proceeds 

to bank accounts controlled by Thomas.  A significant number of the Kouletas Entity’s sales of 

GBEN stock were matched with Levine’s transactions closing out his short positions.   

40. As he conducted the Kouletas Entity transactions, Levine knew that Collins and 

Thomas were the only sellers of GBEN stock. 

CLAIMS FOR RELIEF 

FIRST CLAIM FOR RELIEF 
 

Fraud in Connection with the Purchase or Sale of a Security 
 

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 All Defendants 

41. Plaintiff re-alleges and incorporates paragraphs 1 through 40 of this Complaint by 

reference as if set forth verbatim in this Claim. 

42. By engaging in the acts and conduct alleged herein, Defendants, directly or 

indirectly, 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, knowingly or with severe recklessness:  

a. employed a device, scheme, or artifice to defraud; and/or 

b. engaged in an act, practice, or course of business which operated or would 

operate as a fraud or deceit upon any person. 

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43. By reason of the foregoing, Defendants 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)]. 

SECOND CLAIM FOR RELIEF 
 

Fraud in the Offer or Sale of a Security 
 

Violations of Sections 17(a)(1) and 17(a)(3) of the Securities Act  
[15 U.S.C. §§ 77q(a)(1) and (3)] 

 
Against All Defendants 

 
44. Plaintiff re-alleges and incorporates paragraphs 1 through 40 of this Complaint by 

reference as if set forth verbatim in this Claim. 

45. By engaging in the acts and conduct alleged herein, Defendants, directly or 

indirectly, in the offer or sale of a security, by the use of any means or instruments of transportation 

or communication in interstate commerce or by use of the mails, directly or indirectly, have: 

a. knowingly or with severe recklessness employed a device, scheme, or 

artifice to defraud; and/or 

b. knowingly (or with severe recklessness), recklessly, or negligently engaged 

in a transaction, practice, or course of business which operated or would operate as a fraud or 

deceit upon the purchaser. 

46. By reason of the foregoing, Defendants have violated, and unless enjoined will 

continue to violate, Sections 17(a)(1) and (3) of the Securities Act [15 U.S.C. §§ 77q(a)(1) and 

(3)]. 

 

 

 

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THIRD CLAIM FOR RELIEF 
 

Broker-Registration Violations 
 

Violations of Sections 15(a) of the Exchange Act 
[15 U.S.C. § 78o(a)] 

 
Against Kingsfield 

47. Plaintiff re-alleges and incorporates paragraphs 1 through 40 of this Complaint by 

reference as if set forth verbatim in this Claim. 

48. By engaging in the conduct described herein, Defendant Kingsfield, while 

engaged in the business of effecting transactions in securities for the account(s) of others, made 

use of the mails or any means or instrumentality of interstate commerce to effect transactions in, 

or to induce or attempt to induce the purchase or sale of, a security without being registered with 

the Commission as a broker or dealer or as an associated person of a registered broker or dealer, 

in accordance with Section 15(b) of the Exchange Act. 

49. By engaging in this conduct, Defendant Kingsfield has violated, and unless 

enjoined will continue to violate, Section 15(a) of the Exchange Act [15 U.S.C. § 78o(a)]. 

 

PRAYER FOR RELIEF  
 

WHEREFORE, the Commission respectfully requests that the Court enter a judgment:  

1. Permanently enjoining the Defendants from violating Sections 17(a)(1) and (3) of 

the Securities Act [15 U.S.C. §§ 77q(a)(1) and (3)] and 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)]; 

2. Permanently enjoining Defendant Kingsfield from violating Section 15(a) of the 

Exchange Act [15 U.S.C. § 78o(a)]; 

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3. Permanently barring Defendants from participating in an offering of penny stock,

including engaging in activities with a broker, dealer, or issuer for purposes of issuing, trading, or

inducing or attempting to induce the purchase or sale of any penny stock. A penny stock is any

equity security that has a price of less than five dollars, except as provided in Rule 3a51-1 under

the Exchange Act [17 C.F.R. 240.3a51-1];

4. Permanently enjoining Defendants Collins and Thomas from serving as an officer

or director of any issuer required to file reports with the SEC under Section 12(b), 12(g), or 15(d)

of the Exchange Act [15 U.S.C. §§ 781(b), 781(g), and 78o(d)] pursuant to Section 21(d)(2) of the

Exchange Act [15 U.S.C. § 78u(d)(2)];

5. Ordering the Defendants to disgorge all ill-gotten gains received as a result of the

violations alleged herein, plus prejudgment interest on those amounts, pursuant to the Court's

equitable powers and Section 21(d)(3), 21(d)(5), and 21(d)(7) of the Exchange Act [15 U.S.C. §§

78u(d)(3), (5), and (7);

6. Ordering the Defendants to pay civil penalties pursuant to Section 20(d) of the

Securities Act [15 U.S.C. § 77t(d)] and Section 2l(d)(3) of the Exchange Act [15 U.S.C. §

78u(d)(3)]; and

7. Imposing such other and further relief as the Court may deem just and proper.

Dated: June 30, 2023

. 272325
United States Securities and
Exchange Commission
Burnett Plaza, Suite 1900
801 Cherry Street, Unit 18
Fort Worth, TX 76102
Telephone: (817) 978-3821

13

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Facsimile:  (817) 978-4927 
[email protected] 
 
Attorney for Plaintiff 
 
ATTORNEY FOR PLAINTIFF SECURITIES 
AND EXCHANGE COMMISSION 

  
 
 

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