SEC v. CHEETAH X INC. (d/b/a Go X); ALEXANDER DEBELOV; and KHODR SALAM, No. 1:25-cv-23002, Southern District of Florida (July 3, 2025) — Complaint

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

SECURITIES AND EXCHANGE COMMISSION

Plaintiff,                                                       CASE NO.:

 v.

CHEETAH X INC. (d/b/a Go X),
ALEXANDER DEBELOV,
and KHODR SALAM,

Defendants.

       /

COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF
AND DEMAND FOR JURY TRIAL

Plaintiff Securities and Exchange Commission (the “Commission”) alleges as follows:
I. INTRODUCTION
1. From  approximately  July  2021  through  November  2023,  Defendants Cheetah  X
Inc.,  which  does  business  as  “Go  X”  (“Go  X”);   Go  X’s  founder,  majority  owner, and  CEO,
Alexander Debelov (“Debelov”);  and Go X’s P resident of Operations, Khodr Salam, a/k/a Khodor
Salam  (“Salam”) (collectively,  “Defendants”)  raised  approximately  $4  million  from  about  300
investors located across multiple states, through the fraudulent and unregistered sale of securities.
2. Go X operates a scooter rental business in markets including several Florida cities,
Honolulu, and Las Vegas.  Defendants promoted Go X’s investment program on its public website,
in videos posted on YouTube, in direct communications with prospective investors, and in written
agreements.

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3. In  their  sales  pitch,  Defendants  represented  to  investors  that  Go  X  would  pay
investors a share of its gross profits from scooter rental fees, in exchange for the investors’ principal
payment  to  Go X,  which  typically  ranged  from  $2,000  to  $30,000.    They  also represented that
through the  profit-sharing,  investors  could expect  to  be  paid  back  their  principal  plus  receive
returns up to 100 percent in a year or less. The Go X website claimed that investors had earned
more than $3 million by August 2022.  In addition, Defendants portrayed Go X as less risky than
investing in the S&P 500, touting “guaranteed” investor refunds upon request and claiming that
investor funds could be lost only if Go X went out of business.
4. These representations were false and misleading.  By the end of 2023, Go X had
paid investors only about $1.45 million—less than half of the approximately $4 million in principal
it raised from investors.  Go X also failed to pay supposedly “guaranteed” refunds when investors
requested  them.    In  addition,  Go  X  operated  a  sharply  unprofitable  business,  putting unwitting
investors at substantial risk.
5. The poor performance  of  the  Go  X  investment  led  to  multiple  complaints  from
dissatisfied investors, yet Defendants continued to sell the investment with the same sales pitch.
6. By  engaging  in  the  conduct  described  in  this Complaint, Go  X  violated  Sections
5(a), 5(c), and 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77e(a), 77e(c),
and 77q(a)],  and  Section  10(b)  of  the  Securities  Exchange  Act  of  1934  (“Exchange  Act”)  [15
U.S.C.  §  78j(b)]  and  Rule  10b-5  thereunder  [17  C.F.R.  § 240.10b-5]  ;  and  Debelov  and  Salam
violated  Sections  5(a),  5(c),  17(a)(1),   and  17(a)(3)  of  the  Securities  Act  [15  U.S.C.  §§ 77e(a),
77e(c), 77q(a)(1), and 77q(a)(3)], and Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and
Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]  .

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7. Unless  enjoined,  Defendants  will  continue  to  violate  the  federal  securities  laws.
Accordingly, the  Commission  seeks  injunctive  relief  and  civil  money  penalties  against  the
Defendants.    The  Commission  also  seeks  disgorgement of  ill-gotten  gains  with  prejudgment
interest against Go X.
II. DEFENDANTS
8. Cheetah X Inc., which does business as “Go X,” is a Delaware corporation formed
in June 2018.  Go X operates its scooter rental business in Florida, Hawaii, and Nevada and sold
its investment program to investors located across multiple states.
9. Alexander Debelov, age 37, maintains residences in Hallandale Beach, Florida and
San  Francisco,  California.    He  is  the  founder  of  Go  X  and  has  been  its  CEO  since  June  2018.
Debelov owns approximately 85 percent of Go X’s stock and controlled Go X during the relevant
period.
10. Khodr Salam, age 30, resides in Sanford, Florida.  He has been a Go X employee
since  June  2018  and  Go  X’s  President  of  Operations  since  approximately  March  2021.    Salam
owns approximately two percent of Go X’s stock.
III. JURISDICTION AND VENUE
11. The Court has jurisdiction over this action pursuant to Sections 20(b), 20(d), and
22(a) of the Securities Act [ 15 U.S.C. §§ 77t(b), 77t(d), and 77v(a)]  and Sections 21(d), 21(e), and
27 of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), and 78aa].
12. In connection with the conduct alleged in this Complaint, Defendants, directly or
indirectly, singly  or  in  concert  with  others,  made  use  of  the  means  and  instrumentalities  of
interstate  commerce,  the  means  or  instruments  of  transportation  or  communication  in  interstate
commerce, or of the mails.

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13. This Court has personal jurisdiction over the Defendants and venue is proper in this
District pursuant to Section 22(a) of the Securities Act [15 U.S.C. § 77v(a)] and Section 27(a) of
the Exchange Act [15 U.S.C. § 78aa(a)] because  certain offers and sales of securities, acts, and
transactions that form the basis for the violations alleged in this Complaint occurred in this District.
For example, during the relevant time, Go X maintained an office in Miami, Florida which Debelov
has  described  as  Go  X’s  “headquarters”  and  Debelov  maintains  a  residence  in  this  District.
Additionally, at least six investors resided in this District when they invested.
IV. FACTUAL ALLEGATIONS
A. The Go X Business and Securities Offering
14. Go X offers scooters for rent to the public in markets located in U.S. cities including
Honolulu, Hawaii;  Las Vegas, Nevada; Daytona Beach, Florida;  and other Florida cities.  Go X
pays a portion of the rental fees it collects to its “partners,” which are the operators of the locations
where the scooters are docked, typically retail stores and hotels in resort areas.
15. From  approximately  July  2021  through  November 2023,  Go  X  raised  around  $4
million by offering and selling securities to approximately 300 investors in multiple U.S. states.
Go  X  promoted  its  investment  program  through  various means  including content  on  its public
website, which content was overseen and approved by Debelov, and videos posted to YouTube in
which Debelov appeared and spoke as the company’s CEO.  Debelov also personally promoted
the  Go  X  investment  program  to  prospective  investors,  including  through email  and telephone
conversations.
16. When  individuals  expressed  interest  in  the  Go  X  investment  through  the  Go  X
website, Debelov provided Salam with their contact information to follow up.  Salam then reached
out  to  the  prospective  investors  by  telephone,  email,  and/or  text  message.    Salam described  the

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investment program to the prospects, including among other things, the expected rates of return
and that investors would receive monthly payments of their returns.  He also directed prospects to
the Go X videos on YouTube.
17. About half  of  the  investors  signed  written  agreements  with  Go  X to  effect  their
investments  (“investor  agreements”).    Debelov  approved  the  form  of  the  investor  agreements.
Using his CEO title, Debelov was also Go X’s signatory on the investor agreements.  Both Debelov
and Salam provided investors with investor agreements to sign, typically by emailing the investor
a website link to an electronic copy of the agreement.  Investors that were not provided investor
agreements effectuated their investment by paying Go X their principal investment amounts.
18. Investors typically  paid  between  $2,000  and  $30,000  for  an  investment.    Some
made multiple investments.  Investor funds were comingled in common bank accounts that Go X
used to pay its general operating expenses.
19. Investors were passive and had a reasonable expectation of earning a profit or return
which  was  derived  entirely  from  the  purported  efforts  and  strategies  of  the  Defendants.    For
example, the  investor  agreements  stated:    “Go  X  will  take  care  of  all  operations,  provide  the
software solution, fix and deploy scooters at all partner locations.  Go X will also retain a legal
firm, PR firm and run online ads in order to increase the rentability of scooters. . . .  All of this will
help  the  [investor]  recoup  and  earn  .  .  .  interest  on  their  purchase  in  the  most  reasonable  time
frame.”
20. Echoing  this  language,  Salam  sent  emails  and  text  messages  to  prospective  and
existing investors stating variously that:  (i) “Investing in Go X is an opportunity to earn passive
income  by  owning  a  percentage  of  our  fleet;”  (ii)  investors  were  “tapping  into”  Go  X’s  “total
revenue” from all of its markets; and (iii) “You don’t own 25 individual scooters; rather, you hold

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a  stake  in  the  earnings  generated  collectively  by  1,500  scooters  across  our  Hawaii  and  Florida
markets.”  Debelov also emailed existing investors representing that the Go X investment program
offered “passive income.”
21. Indeed,  Go  X  made  the  essential  managerial  efforts  that  affected  the  success  or
failure of its business and the investment program.  This included, but was not limited to, launching
operations in various markets; marketing scooters to consumers; recruiting, contracting with,  and
paying  the  partners;  collecting scooter rental  fees;  maintaining the scooters;  and  handling
permitting and other legal requirements of the cities where Go X operated.
B. The Pitch to Investors
22. As Defendants framed the Go X program for investors—including in the investor
agreements,  on the Go X website, in the YouTube videos, and in Debelov’s and Salam’s direct
communications  with  investors—investors  would  receive a  share of the gross  profits  that Go  X
earned from renting scooters.
23. In  promoting  the  Go  X  investment  program,  Defendants  told  investors  to  expect
that this profit-sharing would provide investors with extraordinary returns in a short period of time
with exceptionally low risk.
24. For  example,  Go  X  promoted  the  investment program  with  content  on  its  public
website that  was  overseen  and  approved  by  Debelov.    At  various  times  during the fraudulent
offering, the website included the following claims:
• “YOU MAKE $ WHEN SOMEONE RENTS A SCOOTER FROM US.  WE WILL
SHARE 50% OF THE GROSS PROFIT” (emphasis in original)
• Through such profit-sharing, an investor could “1.5X YOUR MONEY” in as little as “88
days”

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• “INVESTORS ON GO X PLATFORM EARNED” more than $3 million “IN THE LAST
180 DAYS”
• A person who “in August 2021 . . . invested $20k into Go X” would have achieved a “gain”
of “+100%” by May 2022
• The  100  percent  gain  “is  just  compared  [sic]  based  on  returns,  but  if  you  look  at  other
attributes of this investment like risk-tolerance, liquidity and your ability to lose money,
then Go X stands in a completely different league (!) compared to all investments on the
market”
• Unlike investors in the S&P 500, Go X investors had “0 Risk” and “[No] . . . Ability to
Lose Money . . . *Unless Go X goes out of business”
25. The  promotion  of  the  Go  X  investment  program  also included videos  posted  to
YouTube in approximately October and November 2022.  In these videos, Debelov appeared and
spoke over the caption “CEO, Go X.”   He claimed that early investors had made returns of “I think
it was 100 percent over twelve months” and that later investors were “getting a 50 percent return.”
26. In a separate YouTube video narrated by Debelov and posted in approximately June
2022, Debelov claimed that Go X provided investors with “monthly cash flow.”
27. Debelov   and   Salam   also   promoted   the   Go   X   investment   in   their direct
communications with investors.  For example:
• Salam typically had phone calls with prospective investors in which he described how the
Go X program worked, including the expected rate of return.
• In or about January 2023, Salam claimed in text messages to  a prospective investor that the
Go X “platform” was “completely sold out” and had “limited availability right now,” but
the prospect could invest a “max” of “$20k.”  Salam also assured the prospect that he  could

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reasonably expect a fifty percent return in one year and would receive monthly payments
from Go X.
• In a phone call around the same time, the prospect expressed skepticism to Salam that Go
X could provide such a return, and Salam assured the prospect that Go X could do so.
• Salam  and  Debelov  each sent  prospective  investors  emails  claiming  that “our investors
[had] made over $3M on the platform.  As we calculated the average rate of return across
all markets, it came out to an astonishing 87% annual return for a typical investor on
[the] Go X platform!” (emphasis in original).  Their emails also claimed that the Go X
investment was “no-risk,” provided “monthly payouts,” and “produces returns that are 4x
of  leading  funds,”   and urged  prospective  investors  to  “see  how  it  compares  to  other
products on the market here: https://goxapp.com/invest.”
28. The  investor  agreements,  which  Debelov  and  Salam  provided  to  investors, also
touted the performance of the Go X investment.  Two iterations of the investor agreement were
used, an original “1.0” version and a later “2.0” version.  These variously included statements that
1.0 investors could expect to “be paid” double their investment amount and expect to “earn that
money anywhere between 3-6 months”; that the “majority” of 1.0 investors had “doubled or were
on track to double their funds within 6-11 months of their initial investment”; that 2.0 investors
“should expect to 1.5x their investment within 6-12 months”; and that 2.0 investors would “be paid
monthly on their earnings.”
29. The  investor  agreements  further stated  that  Go  X  provided  a  “100%  product
guarantee” and would refund investments upon investor request.  Consistent with this claim, in the
June  2022  YouTube  video identified  above, Debelov  said,  “[I]f  you’re  not  happy  with  your
investment, you can request a refund and we’ll happily refund your money within that same day.”

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Likewise,  in  February  2023,  Salam  emailed  a  prospective  investor  a “welcome  letter”  from
Debelov, which said:  “At any point,  if you would like to get your money back, then just email me
. . . and I’ll make sure you get it refunded to your card or wired within 24 hours.”
C. Defendants Violated the Antifraud Provisions of the Exchange Act and Securities
Act
30. Defendants knew,  or were severely reckless in not knowing, that the sales pitch to
investors was false and misleading because it overstated past performance of the Go X investment,
overstated potential future performance of the investment, and understated investment risk.
31. The  claim  that  investors  had  “EARNED”  more  than  $3  million  “IN  THE  LAST
180 DAYS” suggested that the Go X investment had performed well in the past and that it was
likely to continue to do so in the future.  But the claim was false and misleading.
32. The claim first appeared on the Go X website no later than August 2022.  By then,
however, Go X had only paid roughly $800,000 in returns to investors—far short of $3 million—
according to its accounting records.  The claim was repeated on the website in December 2022 and
in March, June, and September 2023.
33. According  to  Go  X  accounting  records,  during  the  relevant  time,  Go  X  never
returned  $3  million  to  investors.    Through  December  2023, Go  X  paid  only approximately
$1.45 million  in  returns  to  investors;  in  other  words,  Go  X  had  returned  less  than  half  of  the
approximately $4  million  in  principal  it  raised  from  investors.    Debelov  knew,  or  was  severely
reckless in not knowing, that the claim that Go X investors had earned more than $3 million in 180
days falsely  and  misleadingly  portrayed  the  Go  X  investment’s  past  and  expected  future
performance because  he  regularly  reviewed  Go  X  accounting records  showing the  amount  of
returns paid to investors.  Debelov also knew,  or was severely reckless in not knowing, that the

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extraordinary past and expected future performance of the Go X investment touted elsewhere on
the  Go  X  website,  in the  investor  agreements,  in  the  YouTube  videos,  and  in his  emails  to
prospective investors, as described above, was likewise false and misleading.
34. The sales pitch also falsely and misleadingly understated investment risk because
Go X lacked the financial strength to perform as the pitch told investors to expect.  As Debelov
knew,  or   was severely reckless in not knowing, from his review of Go X accounting records, Go
X’s  scooter  rental  revenue  during  2021  through  2023  totaled  roughly  $8.5  million—meaning  it
would take half of that revenue just to return the principal Go X raised from investors.  From the
same accounting records, Debelov also knew, or was severely reckless in not knowing, that Go X
recorded a  negative  net  income  in  each  of  2021,  2022,  and  2023,  with  a  cumulative  recorded
negative net income across the three years of approximately $1 million.  These facts cast serious
doubt on the company’s ability to return investor principal, let alone pay the touted extraordinary
returns,  and to guarantee refunds.   Debelov therefore also knew, or was severely reckless in not
knowing, that the “0 Risk” claim and comparison to the S&P 500 on the Go X website described
above were false and misleading.
35. Investor complaints received by Debelov further show that Debelov knew,  or was
severely reckless in not knowing, that the Go X investment did not perform as represented in the
investor sales  pitch.    From  at  least  June 2022  to  November  2023,  Debelov  received  multiple
complaints from dissatisfied investors, including complaints about not receiving expected returns
and unpaid refunds.  Yet Debelov and Go X continued promoting the investment to new investors
using the same sales pitch containing misrepresentations about past performance, expected returns,
and guaranteed refunds.

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36. Salam also knew,  or was severely reckless in not knowing, that the Go X sales pitch
was false and misleading.  Among other things, he monitored the Go X website, which contained
the past and expected future performance claims described above; he described the Go X program
to  prospective  investors,  including  the  expected  rates  of  return;  he provided  investors  with  the
investor agreements, which included the claims of past and expected future performance as well
as the refund guarantee described above; and he sent the emails to prospective investors referenced
above describing past performance of the Go X investment.  Salam therefore knew,  or was severely
reckless in not knowing, that Go X, a small scooter rental company, implausibly offered investors
the prospect of extraordinary returns, guaranteed refunds,  and less risk than investing in the S&P
500.
37. Salam also learned of investor complaints, as shown by the following examples:
• In June 2022, Salam was copied on an investor’s email complaining to Debelov where the
investor stated:  “I’ve reached out a few times and I’m wondering what I need to do to start
getting my monthly payouts. . . .  It’s been several months and I still have yet to get a single
payout from my balance.”  The investor had invested in November 2021.
• In August 2022, an investor complained to Salam and Debelov by email about not receiving
monthly payments.  In February 2023, the investor complained again to Salam by email,
copying Debelov, writing that he still was not receiving the payments.  Salam replied to
the  investor  that the  investor  could  expect  a  payment  that  week.    In  March  2023,  the
investor emailed Salam, copying Debelov, noting that he did not receive the payment.
• In October 2022, an investor complained by email to Salam, stating:  “I am past my $5k
payback  and  contract  states  that  contract/agree  [sic]  make  double  your  money  which
clearly I have not.”

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• In March 2023, an investor began complaining to Salam and Debelov in an email string
about missing monthly payments.  Later in the string, in June 2023, the investor wrote:  “I
am  having  trouble  with  payouts  again.  .  .  .  Schedule  [sic]  payouts  were  never  met.”    In
August 2023, the investor wrote in the string that he still was owed money.  He also wrote
in an email to Debelov:   “I’m starting to feel like I got scammed.”
• In April 2023, an investor emailed Salam and Debelov that he and two other individuals
who were “early investors” in Go X had been receiving low payments or no payment in
some months.  The investor also wrote:  “There has [sic] been constant inconsistencies with
payment time frames . . . .  We are always having to reach out for our monthly deposits,
asking several times for payment.  We are completely confused and lost as to what’s going
on with our money and need clarification.”
• In May 2023, an investor complained by email to Salam and Debelov that she had invested
in November 2022, and based on the investment performance so far, “it will take years to
make a profit, as opposed to the 10 months I was told.”
• In June 2023, Salam and Debelov received an email complaint from an investor stating that
after approximately sixteen months, “I havent [sic] seen a return on my initial investment.”
• In August 2023, an investor complained by email to Salam and Debelov that he had “asked
kindly to withdraw my remaining $3,000 from my account for almost a year,” adding, “I
am turning all of this over to my lawyer next week if I don’t hear back from you.”
• Also in August 2023, an investor complained by email to Salam and Debelov that “[i]t has
been  almost  2  years  with  no  [sic]  even  receiving  my  initial  investment  back  which  is
laughable.”  The investor also asked that Go X pay him his “remaining balance . . . or I
will have no choice but to look at alternative options to get your attention.”

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• Additionally in  August  2023,  an  investor  complained  by  email  to  Salam,  “I  have  not
receive  [sic]  a  payout”;  “I  want  to  pull  out  everything”;  and  “I  will  go  to  the  proper
authorities!”
38. Even  after  receiving  these  complaints,  Salam  continued  using  the  false  and
misleading sales pitch to solicit investors.  In particular, after the August 2023 complaints, Salam
went on to sell investments tied to a new market Go X was launching in Las Vegas.
39. Despite the investor complaints,  and  the  implausible  returns,  purported  low  risk,
and guaranteed refunds touted in the Go X sales pitch, Salam never investigated   the truthfulness
of the representations he used to solicit investors.
40. The false and misleading representations that Defendants disseminated to investors
in the sales pitch described above were material.  In making an investment decision, it would have
been important for a reasonable investor to know, for example, that the purported past performance
of the Go X investment, including the repeated $3 million claim, was false; that Go X failed to pay
refunds upon request; and that Go X was unprofitable.
D. Defendants Violated Federal Securities Registration Provisions
41. As stated above, Go X, through Debelov and Salam, offered and sold approximately
$4 million in securities to approximately 300 investors residing in multiple states.  In doing so,
Defendants used general solicitation, including a public website and YouTube videos, and did not
take reasonable steps to verify investors’ accredited investor status.
42. Contrary to the requirements of the federal securities laws, no registration statement
was on file with the Commission or in effect for any of these offers or sales, and no exemption
from registration applied to the offers or the sales.

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V. CLAIMS FOR RELIEF
COUNT I
Violations of Section 10(b) of the Exchange Act and Rule 10b-5(a)
(Against all Defendants)

43. The  Commission  realleges  and  incorporates  Paragraphs 1  through  42 of  this
Complaint.
44. From approximately  July  2021  through  November  2023, Go  X,  Debelov,  and
Salam, directly or indirectly, by use of the means and instrumentalities of interstate commerce, or
of the mails, knowingly or severely recklessly employed devices, schemes or artifices to defraud
in connection with the purchase or sale of securities.
45. By  reason  of  the  foregoing,  Go  X,  Debelov,  and  Salam  directly  or  indirectly
violated and, unless enjoined, are reasonably likely to continue to violate, Section 10(b) of the
Exchange Act [15 U.S.C. § 78j(b)], and Rule 10b-5(a) [17 C.F.R. § 240.10b-5(a)].
COUNT II
Violations of Section 10(b) of the Exchange Act and Rule 10b-5(b)
(Against all Defendants)

46. The  Commission  realleges  and  incorporates  Paragraphs 1  through  42 of  this
Complaint.
47. From approximately  July  2021  through  November  2023, Go  X,  Debelov,  and
Salam, directly or indirectly, by use of the means and instrumentalities of interstate commerce, or
of the mails, in connection with the purchase or sale of securities, knowingly or severely recklessly
made untrue statements of material facts or omitted to state material facts necessary to make the
statements made, in light of the circumstances under which they were made, not misleading.

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48. By  reason  of  the  foregoing,  Go  X,  Debelov,  and  Salam  directly  or  indirectly
violated  and,  unless  enjoined,  are  reasonably  likely  to  continue  to  violate,  Section  10(b)  of  the
Exchange Act [15 U.S.C. § 78j(b)], and Rule 10b-5(b) [17 C.F.R. § 240.10b-5(b)].
COUNT III

Violations of Section 10(b) of the Exchange Act and Rule 10b-5(c)
(Against all Defendants)

49. The  Commission  realleges  and  incorporates  Paragraphs  1  through  42 of  this
Complaint.
50. From approximately  July  2021  through  November  2023,  Go  X,  Debelov,  and
Salam, directly or indirectly, by use of the means and instrumentalities of interstate commerce, or
of the mails, in connection with the purchase or sale of securities, knowingly or severely recklessly
engaged in acts, practices, and courses of business which operated or would operate as a fraud or
deceit upon the purchasers of such securities.
51. By  reason  of  the  foregoing,  Go  X,  Debelov,  and  Salam  directly  or  indirectly
violated  and,  unless  enjoined,  are  reasonably  likely  to  continue  to  violate,  Section  10(b)  of  the
Exchange Act [15 U.S.C. § 78j(b)], and Rule 10b-5(c) [17 C.F.R. § 240.10b-5(c)].
COUNT IV
Violations of Section 17(a)(1) of the Securities Act
(Against all Defendants)

52. The Commission  realleges  and  incorporates  Paragraphs  1  through  42 of  this
Complaint.
53. From approximately July 2021 through November 2023, Go X, Debelov, and Salam,
in  the  offer  or  sale  of  securities  by  use  of  the  means  or  instruments  of  transportation  or

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communication in interstate commerce or by use of the mails, directly or indirectly, knowingly or
severely recklessly employed devices, schemes, or artifices to defraud.
54. By  reason  of  the  foregoing,  Go  X,  Debelov,  and  Salam  directly  and  indirectly
violated and, unless enjoined, are reasonably likely to continue to violate, Section 17(a)(1) of the
Securities Act [15 U.S.C. § 77q(a)(1)].
COUNT V
Violations of Section 17(a)(2) of the Securities Act
(Against Go X)

55. The Commission  realleges  and  incorporates  Paragraphs  1  through  42 of  this
Complaint.
56. From approximately July 2021 through November 2023, Go X, in the offer or sale
of securities by use of the means or instruments of transportation or communication in interstate
commerce or by use of the mails, directly and indirectly, negligently obtained money or property
by means of untrue statements of material facts or omissions to state material facts necessary to
make  the  statements  made,  in  the  light  of  the  circumstances  under  which  they  were  made,  not
misleading.
57. By reason  of  the  foregoing,  Go  X directly  and  indirectly  violated  and,  unless
enjoined, is  reasonably  likely  to  continue  to  violate,  Section  17(a)(2)  of  the  Securities  Act  [15
U.S.C. § 77(q)(a)(2)].
COUNT VI
Violations of Section 17(a)(3) of the Securities Act
(Against all Defendants)

58. The  Commission  realleges  and  incorporates  Paragraphs  1  through  42  of  this
Complaint.

17

59. From  approximately  July  2021  through  November  2023, Go  X,  Debelov,  and
Salam,  in  the  offer  or  sale  of  securities  by  use  of  the  means  or  instruments  of  transportation  or
communication  in  interstate  commerce  or by  the  use  of  the  mails,  directly  and  indirectly,
negligently engaged in transactions, practices, and courses of business which operated as a fraud
or deceit upon the purchasers.
60. By reason  of  the  foregoing,  Go  X,  Debelov,  and  Salam  directly  and  indirectly
violated and, unless enjoined, are reasonably likely to continue to violate, Section 17(a)(3) of the
Securities Act [15 U.S.C. § 77(q)(a)(3)].
COUNT VII
Violations of Sections 5(a) and 5(c) of the Securities Act
(Against All Defendants)

61. The  Commission  realleges  and  incorporates  Paragraphs  1  through  42 of  this
Complaint.
62. No registration statement was filed or in effect with the Commission pursuant to
the  Securities  Act  with  respect  to  the  securities  issuances and  transactions  by  Defendants  as
described  in  this  Complaint, and  no  exemption  from  registration  existed  with  respect  to  these
securities and transactions.
63. From approximately  July  2021  through  November  2023,  Go  X,  Debelov,  and
Salam directly or indirectly:
a. made use of any means or instruments of transportation or communication
in interstate commerce or of the mails to sell securities, through the use or
medium of a prospectus or otherwise;

18

b. carried or caused to be carried securities through the mails or in interstate
commerce, by any means or instruments of transportation, for the purpose
of sale or delivery after sale; or
c. made use of any means or instruments of transportation or communication
in interstate commerce or of the mails to offer to sell or offer to buy through
the use or medium of any prospectus or otherwise any security,
without  a  registration  statement  having  been  filed  or  being  in  effect  with  the  Commission  as  to
such securities.
64.  By  reason  of  the  foregoing,  Go  X,  Debelov,  and  Salam  directly  or  indirectly
violated and, unless enjoined, are  reasonably likely to continue to violate Sections 5(a)  and 5(c)
of the Securities Act [15 U.S.C. §§ 77e(a) and 77e(c)].
VI. REQUESTED RELIEF
The Commission respectfully requests the Court find that the Defendants committed the
foregoing violations, and:
A. Permanent Injunction
Issue  a  permanent injunction  enjoining Go  X,  Debelov,  and  Salam  from  directly  or
indirectly violating Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5 [17
C.F.R.  §  240.10b-5]  thereunder,  and  Sections  5(a)  and 5(c)  of  the  Securities  Act  [15  U.S.C.  §§
77e(a) and 77e(c)]; permanently enjoining Go X from directly or indirectly violating Section 17(a)
of the Securities Act [15 U.S.C. § 77q(a)]; and permanently enjoining Debelov and Salam from
directly  or  indirectly  violating  Section  17(a)(1)  and  Section  17(a)(3)  of  the  Securities  Act  [15
U.S.C. §§ 77q(a)(1) and 77q(a)(3)].

19

B. Disgorgement with Prejudgment Interest
(Against Go X)

Issue an order requiring Go X to disgorge all ill-gotten gains or proceeds, with prejudgment
interest thereon, resulting from the acts and/or courses of conduct alleged in this Complaint.
C. Civil Monetary Penalties
Issue an order requiring Go X, Debelov, and Salam to pay civil monetary penalties pursuant
to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d) of the Exchange Act
[15 U.S.C. § 78u(d)].
D. Retention of Jurisdiction
Retain jurisdiction of this action and over the Defendants 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 by
the Commission for additional relief within the jurisdiction of this Court.
E. Further Relief
Grant such other and further relief as this Court may determine to be just, equitable, and
necessary.
DEMAND OF JURY TRIAL
The Commission  hereby  demands  a  trial  by  jury  on  any  and  all  issues  in  this  action  so
triable.
      Respectfully submitted,

July 3, 2025        s/Christine Nestor
       Christine Nestor, Esq.
       Senior Trial Counsel
       Florida Bar # 597211
       Telephone: (305) 982-6367
       E-mail:  [email protected]

20

ATTORNEY FOR PLAINTIFF
SECURITIES AND EXCHANGE
COMMISSION
801 Brickell Avenue, Suite 1950
       Miami, Florida 33131
       Telephone: (305) 982-6300
       Facsimile: (305) 536-4154

UNITED STATES DISTRICT COURT  
SOUTHERN DISTRICT OF FLORIDA  

 
SECURITIES AND EXCHANGE COMMISSION 
 
 

Plaintiff,                                                       CASE NO.:  
 
 v. 
 
CHEETAH X INC. (d/b/a Go X),  
ALEXANDER DEBELOV,  
and KHODR SALAM,  
 

Defendants. 
 
       / 
 
 

COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF  
AND DEMAND FOR JURY TRIAL 

 
Plaintiff Securities and Exchange Commission (the “Commission”) alleges as follows: 

I. INTRODUCTION 

1. From approximately July 2021 through November 2023, Defendants Cheetah X 

Inc., which does business as “Go X” (“Go X”); Go X’s founder, majority owner, and CEO, 

Alexander Debelov (“Debelov”); and Go X’s President of Operations, Khodr Salam, a/k/a Khodor 

Salam (“Salam”) (collectively, “Defendants”) raised approximately $4 million from about 300 

investors located across multiple states, through the fraudulent and unregistered sale of securities.   

2. Go X operates a scooter rental business in markets including several Florida cities, 

Honolulu, and Las Vegas.  Defendants promoted Go X’s investment program on its public website, 

in videos posted on YouTube, in direct communications with prospective investors, and in written 

agreements.  

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3. In their sales pitch, Defendants represented to investors that Go X would pay 

investors a share of its gross profits from scooter rental fees, in exchange for the investors’ principal 

payment to Go X, which typically ranged from $2,000 to $30,000.  They also represented that 

through the profit-sharing, investors could expect to be paid back their principal plus receive 

returns up to 100 percent in a year or less. The Go X website claimed that investors had earned 

more than $3 million by August 2022.  In addition, Defendants portrayed Go X as less risky than 

investing in the S&P 500, touting “guaranteed” investor refunds upon request and claiming that 

investor funds could be lost only if Go X went out of business.  

4. These representations were false and misleading.  By the end of 2023, Go X had 

paid investors only about $1.45 million—less than half of the approximately $4 million in principal 

it raised from investors.  Go X also failed to pay supposedly “guaranteed” refunds when investors 

requested them.  In addition, Go X operated a sharply unprofitable business, putting unwitting 

investors at substantial risk.  

5. The poor performance of the Go X investment led to multiple complaints from 

dissatisfied investors, yet Defendants continued to sell the investment with the same sales pitch.   

6. By engaging in the conduct described in this Complaint, Go X violated Sections 

5(a), 5(c), and 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77e(a), 77e(c), 

and 77q(a)], and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 

U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]; and Debelov and Salam 

violated Sections 5(a), 5(c), 17(a)(1), and 17(a)(3) of the Securities Act [15 U.S.C. §§ 77e(a), 

77e(c), 77q(a)(1), and 77q(a)(3)], and Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and 

Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].   

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7. Unless enjoined, Defendants will continue to violate the federal securities laws.  

Accordingly, the Commission seeks injunctive relief and civil money penalties against the 

Defendants.  The Commission also seeks disgorgement of ill-gotten gains with prejudgment 

interest against Go X.  

II. DEFENDANTS 

8. Cheetah X Inc., which does business as “Go X,” is a Delaware corporation formed 

in June 2018.  Go X operates its scooter rental business in Florida, Hawaii, and Nevada and sold  

its investment program to investors located across multiple states.     

9. Alexander Debelov, age 37, maintains residences in Hallandale Beach, Florida and 

San Francisco, California.  He is the founder of Go X and has been its CEO since June 2018.  

Debelov owns approximately 85 percent of Go X’s stock and controlled Go X during the relevant 

period. 

10. Khodr Salam, age 30, resides in Sanford, Florida.  He has been a Go X employee 

since June 2018 and Go X’s President of Operations since approximately March 2021.  Salam 

owns approximately two percent of Go X’s stock.  

III. JURISDICTION AND VENUE 

11. The Court has jurisdiction over this action pursuant to Sections 20(b), 20(d), and 

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

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

12. In connection with the conduct alleged in this Complaint, Defendants, directly or 

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

interstate commerce, the means or instruments of transportation or communication in interstate 

commerce, or of the mails.   

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13. This Court has personal jurisdiction over the Defendants and venue is proper in this 

District pursuant to Section 22(a) of the Securities Act [15 U.S.C. § 77v(a)] and Section 27(a) of 

the Exchange Act [15 U.S.C. § 78aa(a)] because certain offers and sales of securities, acts, and 

transactions that form the basis for the violations alleged in this Complaint occurred in this District.  

For example, during the relevant time, Go X maintained an office in Miami, Florida which Debelov 

has described as Go X’s “headquarters” and Debelov maintains a residence in this District.  

Additionally, at least six investors resided in this District when they invested.      

IV. FACTUAL ALLEGATIONS 

A. The Go X Business and Securities Offering 

14. Go X offers scooters for rent to the public in markets located in U.S. cities including 

Honolulu, Hawaii; Las Vegas, Nevada; Daytona Beach, Florida; and other Florida cities.  Go X 

pays a portion of the rental fees it collects to its “partners,” which are the operators of the locations 

where the scooters are docked, typically retail stores and hotels in resort areas.   

15. From approximately July 2021 through November 2023, Go X raised around $4 

million by offering and selling securities to approximately 300 investors in multiple U.S. states.  

Go X promoted its investment program through various means including content on its public 

website, which content was overseen and approved by Debelov, and videos posted to YouTube in 

which Debelov appeared and spoke as the company’s CEO.  Debelov also personally promoted 

the Go X investment program to prospective investors, including through email and telephone 

conversations. 

16. When individuals expressed interest in the Go X investment through the Go X 

website, Debelov provided Salam with their contact information to follow up.  Salam then reached 

out to the prospective investors by telephone, email, and/or text message.  Salam described the 

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investment program to the prospects, including among other things, the expected rates of return 

and that investors would receive monthly payments of their returns.  He also directed prospects to 

the Go X videos on YouTube.   

17. About half of the investors signed written agreements with Go X to effect their 

investments (“investor agreements”).  Debelov approved the form of the investor agreements.  

Using his CEO title, Debelov was also Go X’s signatory on the investor agreements.  Both Debelov 

and Salam provided investors with investor agreements to sign, typically by emailing the investor 

a website link to an electronic copy of the agreement.  Investors that were not provided investor 

agreements effectuated their investment by paying Go X their principal investment amounts. 

18. Investors typically paid between $2,000 and $30,000 for an investment.  Some 

made multiple investments.  Investor funds were comingled in common bank accounts that Go X 

used to pay its general operating expenses.  

19. Investors were passive and had a reasonable expectation of earning a profit or return 

which was derived entirely from the purported efforts and strategies of the Defendants.  For 

example, the investor agreements stated:  “Go X will take care of all operations, provide the 

software solution, fix and deploy scooters at all partner locations.  Go X will also retain a legal 

firm, PR firm and run online ads in order to increase the rentability of scooters. . . .  All of this will 

help the [investor] recoup and earn . . . interest on their purchase in the most reasonable time 

frame.”   

20. Echoing this language, Salam sent emails and text messages to prospective and 

existing investors stating variously that:  (i) “Investing in Go X is an opportunity to earn passive 

income by owning a percentage of our fleet;” (ii) investors were “tapping into” Go X’s “total 

revenue” from all of its markets; and (iii) “You don’t own 25 individual scooters; rather, you hold 

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a stake in the earnings generated collectively by 1,500 scooters across our Hawaii and Florida 

markets.”  Debelov also emailed existing investors representing that the Go X investment program 

offered “passive income.”   

21. Indeed, Go X made the essential managerial efforts that affected the success or 

failure of its business and the investment program.  This included, but was not limited to, launching 

operations in various markets; marketing scooters to consumers; recruiting, contracting with, and 

paying the partners; collecting scooter rental fees; maintaining the scooters; and handling 

permitting and other legal requirements of the cities where Go X operated.   

B. The Pitch to Investors 

22. As Defendants framed the Go X program for investors—including in the investor 

agreements, on the Go X website, in the YouTube videos, and in Debelov’s and Salam’s direct 

communications with investors—investors would receive a share of the gross profits that Go X 

earned from renting scooters.   

23. In promoting the Go X investment program, Defendants told investors to expect 

that this profit-sharing would provide investors with extraordinary returns in a short period of time 

with exceptionally low risk.   

24. For example, Go X promoted the investment program with content on its public 

website that was overseen and approved by Debelov.  At various times during the fraudulent 

offering, the website included the following claims: 

• “YOU MAKE $ WHEN SOMEONE RENTS A SCOOTER FROM US.  WE WILL 

SHARE 50% OF THE GROSS PROFIT” (emphasis in original) 

• Through such profit-sharing, an investor could “1.5X YOUR MONEY” in as little as “88 

days” 

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• “INVESTORS ON GO X PLATFORM EARNED” more than $3 million “IN THE LAST 

180 DAYS”  

• A person who “in August 2021 . . . invested $20k into Go X” would have achieved a “gain” 

of “+100%” by May 2022 

• The 100 percent gain “is just compared [sic] based on returns, but if you look at other 

attributes of this investment like risk-tolerance, liquidity and your ability to lose money, 

then Go X stands in a completely different league (!) compared to all investments on the 

market” 

• Unlike investors in the S&P 500, Go X investors had “0 Risk” and “[No] . . . Ability to 

Lose Money . . . *Unless Go X goes out of business” 

25. The promotion of the Go X investment program also included videos posted to 

YouTube in approximately October and November 2022.  In these videos, Debelov appeared and 

spoke over the caption “CEO, Go X.”  He claimed that early investors had made returns of “I think 

it was 100 percent over twelve months” and that later investors were “getting a 50 percent return.”   

26. In a separate YouTube video narrated by Debelov and posted in approximately June 

2022, Debelov claimed that Go X provided investors with “monthly cash flow.”     

27. Debelov and Salam also promoted the Go X investment in their direct 

communications with investors.  For example: 

• Salam typically had phone calls with prospective investors in which he described how the 

Go X program worked, including the expected rate of return.   

• In or about January 2023, Salam claimed in text messages to a prospective investor that the 

Go X “platform” was “completely sold out” and had “limited availability right now,” but 

the prospect could invest a “max” of “$20k.”  Salam also assured the prospect that he  could 

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reasonably expect a fifty percent return in one year and would receive monthly payments 

from Go X.   

• In a phone call around the same time, the prospect expressed skepticism to Salam that Go 

X could provide such a return, and Salam assured the prospect that Go X could do so.   

• Salam and Debelov each sent prospective investors emails claiming that “our investors 

[had] made over $3M on the platform.  As we calculated the average rate of return across 

all markets, it came out to an astonishing 87% annual return for a typical investor on 

[the] Go X platform!” (emphasis in original).  Their emails also claimed that the Go X 

investment was “no-risk,” provided “monthly payouts,” and “produces returns that are 4x 

of leading funds,” and urged prospective investors to “see how it compares to other 

products on the market here: https://goxapp.com/invest.”  

28. The investor agreements, which Debelov and Salam provided to investors, also 

touted the performance of the Go X investment.  Two iterations of the investor agreement were 

used, an original “1.0” version and a later “2.0” version.  These variously included statements that 

1.0 investors could expect to “be paid” double their investment amount and expect to “earn that 

money anywhere between 3-6 months”; that the “majority” of 1.0 investors had “doubled or were 

on track to double their funds within 6-11 months of their initial investment”; that 2.0 investors 

“should expect to 1.5x their investment within 6-12 months”; and that 2.0 investors would “be paid 

monthly on their earnings.”   

29. The investor agreements further stated that Go X provided a “100% product 

guarantee” and would refund investments upon investor request.  Consistent with this claim, in the 

June 2022 YouTube video identified above, Debelov said, “[I]f you’re not happy with your 

investment, you can request a refund and we’ll happily refund your money within that same day.”  

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Likewise, in February 2023, Salam emailed a prospective investor a “welcome letter” from 

Debelov, which said:  “At any point, if you would like to get your money back, then just email me 

. . . and I’ll make sure you get it refunded to your card or wired within 24 hours.”     

C. Defendants Violated the Antifraud Provisions of the Exchange Act and Securities 

Act 

30. Defendants knew, or were severely reckless in not knowing, that the sales pitch to 

investors was false and misleading because it overstated past performance of the Go X investment, 

overstated potential future performance of the investment, and understated investment risk. 

31. The claim that investors had “EARNED” more than $3 million “IN THE LAST 

180 DAYS” suggested that the Go X investment had performed well in the past and that it was 

likely to continue to do so in the future.  But the claim was false and misleading. 

32. The claim first appeared on the Go X website no later than August 2022.  By then, 

however, Go X had only paid roughly $800,000 in returns to investors—far short of $3 million— 

according to its accounting records.  The claim was repeated on the website in December 2022 and 

in March, June, and September 2023.   

33. According to Go X accounting records, during the relevant time, Go X never 

returned $3 million to investors.  Through December 2023, Go X paid only approximately 

$1.45 million in returns to investors; in other words, Go X had returned less than half of the 

approximately $4 million in principal it raised from investors.  Debelov knew, or was severely 

reckless in not knowing, that the claim that Go X investors had earned more than $3 million in 180 

days falsely and misleadingly portrayed the Go X investment’s past and expected future 

performance because he regularly reviewed Go X accounting records showing the amount of 

returns paid to investors.  Debelov also knew, or was severely reckless in not knowing, that the 

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extraordinary past and expected future performance of the Go X investment touted elsewhere on 

the Go X website, in the investor agreements, in the YouTube videos, and in his emails to 

prospective investors, as described above, was likewise false and misleading.   

34. The sales pitch also falsely and misleadingly understated investment risk because 

Go X lacked the financial strength to perform as the pitch told investors to expect.  As Debelov 

knew, or was severely reckless in not knowing, from his review of Go X accounting records, Go 

X’s scooter rental revenue during 2021 through 2023 totaled roughly $8.5 million—meaning it 

would take half of that revenue just to return the principal Go X raised from investors.  From the 

same accounting records, Debelov also knew, or was severely reckless in not knowing, that Go X 

recorded a negative net income in each of 2021, 2022, and 2023, with a cumulative recorded 

negative net income across the three years of approximately $1 million.  These facts cast serious 

doubt on the company’s ability to return investor principal, let alone pay the touted extraordinary 

returns, and to guarantee refunds.  Debelov therefore also knew, or was severely reckless in not 

knowing, that the “0 Risk” claim and comparison to the S&P 500 on the Go X website described 

above were false and misleading.  

35. Investor complaints received by Debelov further show that Debelov knew, or was 

severely reckless in not knowing, that the Go X investment did not perform as represented in the 

investor sales pitch.  From at least June 2022 to November 2023, Debelov received multiple 

complaints from dissatisfied investors, including complaints about not receiving expected returns 

and unpaid refunds.  Yet Debelov and Go X continued promoting the investment to new investors 

using the same sales pitch containing misrepresentations about past performance, expected returns, 

and guaranteed refunds. 

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36. Salam also knew, or was severely reckless in not knowing, that the Go X sales pitch 

was false and misleading.  Among other things, he monitored the Go X website, which contained 

the past and expected future performance claims described above; he described the Go X program 

to prospective investors, including the expected rates of return; he provided investors with the 

investor agreements, which included the claims of past and expected future performance as well 

as the refund guarantee described above; and he sent the emails to prospective investors referenced 

above describing past performance of the Go X investment.  Salam therefore knew, or was severely 

reckless in not knowing, that Go X, a small scooter rental company, implausibly offered investors 

the prospect of extraordinary returns, guaranteed refunds, and less risk than investing in the S&P 

500.   

37. Salam also learned of investor complaints, as shown by the following examples: 

• In June 2022, Salam was copied on an investor’s email complaining to Debelov where the 

investor stated:  “I’ve reached out a few times and I’m wondering what I need to do to start 

getting my monthly payouts. . . .  It’s been several months and I still have yet to get a single 

payout from my balance.”  The investor had invested in November 2021. 

• In August 2022, an investor complained to Salam and Debelov by email about not receiving 

monthly payments.  In February 2023, the investor complained again to Salam by email, 

copying Debelov, writing that he still was not receiving the payments.  Salam replied to 

the investor that the investor could expect a payment that week.  In March 2023, the 

investor emailed Salam, copying Debelov, noting that he did not receive the payment.  

• In October 2022, an investor complained by email to Salam, stating:  “I am past my $5k 

payback and contract states that contract/agree [sic] make double your money which 

clearly I have not.”  

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• In March 2023, an investor began complaining to Salam and Debelov in an email string 

about missing monthly payments.  Later in the string, in June 2023, the investor wrote:  “I 

am having trouble with payouts again. . . . Schedule [sic] payouts were never met.”  In 

August 2023, the investor wrote in the string that he still was owed money.  He also wrote 

in an email to Debelov:  “I’m starting to feel like I got scammed.”  

• In April 2023, an investor emailed Salam and Debelov that he and two other individuals 

who were “early investors” in Go X had been receiving low payments or no payment in 

some months.  The investor also wrote:  “There has [sic] been constant inconsistencies with 

payment time frames . . . .  We are always having to reach out for our monthly deposits, 

asking several times for payment.  We are completely confused and lost as to what’s going 

on with our money and need clarification.” 

• In May 2023, an investor complained by email to Salam and Debelov that she had invested 

in November 2022, and based on the investment performance so far, “it will take years to 

make a profit, as opposed to the 10 months I was told.” 

• In June 2023, Salam and Debelov received an email complaint from an investor stating that 

after approximately sixteen months, “I havent [sic] seen a return on my initial investment.” 

• In August 2023, an investor complained by email to Salam and Debelov that he had “asked 

kindly to withdraw my remaining $3,000 from my account for almost a year,” adding, “I 

am turning all of this over to my lawyer next week if I don’t hear back from you.” 

• Also in August 2023, an investor complained by email to Salam and Debelov that “[i]t has 

been almost 2 years with no [sic] even receiving my initial investment back which is 

laughable.”  The investor also asked that Go X pay him his “remaining balance . . . or I 

will have no choice but to look at alternative options to get your attention.” 

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• Additionally in August 2023, an investor complained by email to Salam, “I have not 

receive [sic] a payout”; “I want to pull out everything”; and “I will go to the proper 

authorities!”  

38. Even after receiving these complaints, Salam continued using the false and 

misleading sales pitch to solicit investors.  In particular, after the August 2023 complaints, Salam 

went on to sell investments tied to a new market Go X was launching in Las Vegas.    

39. Despite the investor complaints, and the implausible returns, purported low risk, 

and guaranteed refunds touted in the Go X sales pitch, Salam never investigated the truthfulness 

of the representations he used to solicit investors.   

40. The false and misleading representations that Defendants disseminated to investors 

in the sales pitch described above were material.  In making an investment decision, it would have 

been important for a reasonable investor to know, for example, that the purported past performance 

of the Go X investment, including the repeated $3 million claim, was false; that Go X failed to pay 

refunds upon request; and that Go X was unprofitable. 

D. Defendants Violated Federal Securities Registration Provisions           

41. As stated above, Go X, through Debelov and Salam, offered and sold approximately 

$4 million in securities to approximately 300 investors residing in multiple states.  In doing so, 

Defendants used general solicitation, including a public website and YouTube videos, and did not 

take reasonable steps to verify investors’ accredited investor status.  

42. Contrary to the requirements of the federal securities laws, no registration statement 

was on file with the Commission or in effect for any of these offers or sales, and no exemption 

from registration applied to the offers or the sales.   

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V. CLAIMS FOR RELIEF 

COUNT I 

Violations of Section 10(b) of the Exchange Act and Rule 10b-5(a) 
(Against all Defendants) 

 
43. The Commission realleges and incorporates Paragraphs 1 through 42 of this 

Complaint. 

44. From approximately July 2021 through November 2023, Go X, Debelov, and 

Salam, directly or indirectly, by use of the means and instrumentalities of interstate commerce, or 

of the mails, knowingly or severely recklessly employed devices, schemes or artifices to defraud 

in connection with the purchase or sale of securities.  

45. By reason of the foregoing, Go X, Debelov, and Salam directly or indirectly 

violated and, unless enjoined, are reasonably likely to continue to violate, Section 10(b) of the 

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

COUNT II 

Violations of Section 10(b) of the Exchange Act and Rule 10b-5(b) 
(Against all Defendants) 

 
46. The Commission realleges and incorporates Paragraphs 1 through 42 of this 

Complaint. 

47. From approximately July 2021 through November 2023, Go X, Debelov, and 

Salam, directly or indirectly, by use of the means and instrumentalities of interstate commerce, or 

of the mails, in connection with the purchase or sale of securities, knowingly or severely recklessly 

made untrue statements of material facts or omitted to state material facts necessary to make the 

statements made, in light of the circumstances under which they were made, not misleading.  

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48. By reason of the foregoing, Go X, Debelov, and Salam directly or indirectly 

violated and, unless enjoined, are reasonably likely to continue to violate, Section 10(b) of the 

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

COUNT III 
 

Violations of Section 10(b) of the Exchange Act and Rule 10b-5(c) 
(Against all Defendants) 

 
49. The Commission realleges and incorporates Paragraphs 1 through 42 of this 

Complaint. 

50. From approximately July 2021 through November 2023, Go X, Debelov, and 

Salam, directly or indirectly, by use of the means and instrumentalities of interstate commerce, or 

of the mails, in connection with the purchase or sale of securities, knowingly or severely recklessly 

engaged in acts, practices, and courses of business which operated or would operate as a fraud or 

deceit upon the purchasers of such securities.   

51. By reason of the foregoing, Go X, Debelov, and Salam directly or indirectly 

violated and, unless enjoined, are reasonably likely to continue to violate, Section 10(b) of the 

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

COUNT IV 

Violations of Section 17(a)(1) of the Securities Act 
(Against all Defendants) 

 
52. The Commission realleges and incorporates Paragraphs 1 through 42 of this 

Complaint. 

53. From approximately July 2021 through November 2023, Go X, Debelov, and Salam, 

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

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

severely recklessly employed devices, schemes, or artifices to defraud. 

54. By reason of the foregoing, Go X, Debelov, and Salam directly and indirectly  

violated and, unless enjoined, are reasonably likely to continue to violate, Section 17(a)(1) of the 

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

COUNT V 

Violations of Section 17(a)(2) of the Securities Act 
(Against Go X) 

 
55. The Commission realleges and incorporates Paragraphs 1 through 42 of this 

Complaint. 

56. From approximately July 2021 through November 2023, Go X, in the offer or sale 

of securities by use of the means or instruments of transportation or communication in interstate 

commerce or by use of the mails, directly and indirectly, negligently obtained money or property 

by means of untrue statements of material facts or omissions to state material facts necessary to 

make the statements made, in the light of the circumstances under which they were made, not 

misleading. 

57. By reason of the foregoing, Go X directly and indirectly violated and, unless 

enjoined, is reasonably likely to continue to violate, Section 17(a)(2) of the Securities Act [15 

U.S.C. § 77(q)(a)(2)]. 

COUNT VI 

Violations of Section 17(a)(3) of the Securities Act 
(Against all Defendants) 

 
58. The Commission realleges and incorporates Paragraphs 1 through 42 of this 

Complaint. 

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59. From approximately July 2021 through November 2023, Go X, Debelov, and 

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

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

negligently engaged in transactions, practices, and courses of business which operated as a fraud 

or deceit upon the purchasers. 

60. By reason of the foregoing, Go X, Debelov, and Salam directly and indirectly  

violated and, unless enjoined, are reasonably likely to continue to violate, Section 17(a)(3) of the 

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

COUNT VII 

Violations of Sections 5(a) and 5(c) of the Securities Act  
(Against All Defendants) 

 
61. The Commission realleges and incorporates Paragraphs 1 through 42 of this 

Complaint. 

62. No registration statement was filed or in effect with the Commission pursuant to 

the Securities Act with respect to the securities issuances and transactions by Defendants as 

described in this Complaint, and no exemption from registration existed with respect to these 

securities and transactions.  

63. From approximately July 2021 through November 2023, Go X, Debelov, and 

Salam directly or indirectly: 

a. made use of any means or instruments of transportation or communication 

in interstate commerce or of the mails to sell securities, through the use or 

medium of a prospectus or otherwise; 

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b. carried or caused to be carried securities through the mails or in interstate 

commerce, by any means or instruments of transportation, for the purpose 

of sale or delivery after sale; or 

c. made use of any means or instruments of transportation or communication 

in interstate commerce or of the mails to offer to sell or offer to buy through 

the use or medium of any prospectus or otherwise any security, 

without a registration statement having been filed or being in effect with the Commission as to 

such securities.  

64.  By reason of the foregoing, Go X, Debelov, and Salam directly or indirectly 

violated and, unless enjoined, are  reasonably likely to continue to violate Sections 5(a) and 5(c) 

of the Securities Act [15 U.S.C. §§ 77e(a) and 77e(c)].  

VI. REQUESTED RELIEF 

The Commission respectfully requests the Court find that the Defendants committed the 

foregoing violations, and: 

A. Permanent Injunction 

Issue a permanent injunction enjoining Go X, Debelov, and Salam from directly or 

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

C.F.R. § 240.10b-5] thereunder, and Sections 5(a) and 5(c) of the Securities Act [15 U.S.C. §§ 

77e(a) and 77e(c)]; permanently enjoining Go X from directly or indirectly violating Section 17(a) 

of the Securities Act [15 U.S.C. § 77q(a)]; and permanently enjoining Debelov and Salam from 

directly or indirectly violating Section 17(a)(1) and Section 17(a)(3) of the Securities Act [15 

U.S.C. §§ 77q(a)(1) and 77q(a)(3)].   

 

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B. Disgorgement with Prejudgment Interest 
(Against Go X) 

 
Issue an order requiring Go X to disgorge all ill-gotten gains or proceeds, with prejudgment 

interest thereon, resulting from the acts and/or courses of conduct alleged in this Complaint. 

C. Civil Monetary Penalties 

Issue an order requiring Go X, Debelov, and Salam to pay civil monetary penalties pursuant 

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

[15 U.S.C. § 78u(d)]. 

D. Retention of Jurisdiction 

Retain jurisdiction of this action and over the Defendants 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 by 

the Commission for additional relief within the jurisdiction of this Court. 

E. Further Relief 

Grant such other and further relief as this Court may determine to be just, equitable, and 

necessary. 

DEMAND OF JURY TRIAL 

The Commission hereby demands a trial by jury on any and all issues in this action so 

triable. 

      Respectfully submitted, 
 

July 3, 2025     s/Christine Nestor   
       Christine Nestor, Esq. 
       Senior Trial Counsel 
       Florida Bar # 597211 
       Telephone: (305) 982-6367 
       E-mail:  [email protected] 

 

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ATTORNEY FOR PLAINTIFF 
SECURITIES AND EXCHANGE 
COMMISSION 
801 Brickell Avenue, Suite 1950 

       Miami, Florida 33131 
       Telephone: (305) 982-6300 
       Facsimile: (305) 536-4154 

 

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