SEC v. Joecool.com, LLC; Joseph Ariel Haber; and Robert Tye Cournoyer, No. LR-26216, District of Nevada (Jan. 14, 2025) — Press Release

U.S. SECURITIES AND EXCHANGE COMMISSION Litigation Release No. 26216 / January 14, 2025 Securities and Exchange Commission v. Joecool.com, LLC; Joseph Ariel Haber; Robert Tye Cournoyer, Case No. 2:25-cv-00076 (D. Nev. Filed Jan. 13, 2025) SEC Charges Nevada Coffee Company, its CEO, and Recidivist Broker for Fraudulent Securities Offering The Securities and Exchange Commission today announced litigated charges against Joecool.com, LLC and its CEO, Joseph Ariel Haber, for their alleged misappropriation and misuse of investor funds and false and misleading statements to investors, and against recidivist securities law violator Robert Tye Cournoyer for his alleged false and misleading statements to investors and for acting as an unregistered broker. The SEC’s complaint, filed in federal district court in Nevada, alleges that between at least November 2019 and February 2024, Joecool raised approximately $2 million from investors through an unregistered securities offering by representing that investor funds would be used to produce, package, promote, and sell various CBD-infused coffee products. According to the complaint, Haber instead misappropriated and misused the majority of the received investor funds, including by spending the funds on various purchases at casinos, pawn shops, restaurants, and cigar lounges, and by paying Cournoyer for finding Joecool investors, persuading them to invest, and negotiating the terms of the investments. The complaint also charges the defendants with making false and misleading statements to investors with respect to Joecool’s purported negotiations and agreements with wholesaler customers, and further charges Cournoyer with acting as an unregistered broker. The complaint alleges that (i) all of the defendants violated Sections 5(a), 5(c), and 17(a)(2) of the Securities Act of 1933 and Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5(b) thereunder; (ii) Haber and Joecool also violated Sections 17(a)(1) and (3) of the Securities Act and Section 10(b) of the Exchange Act and Rules 10b-5(a) and (c) thereunder; and (iii) Cournoyer also violated Section 15(a) of the Exchange Act. The SEC seeks injunctions, disgorgement with prejudgment interest, and civil penalties against all defendants, as well as officer and director bars and conduct-based injunctions against Haber and Cournoyer. The SEC’s investigation was conducted by Zachary D. Williams and Yamini Piplani Grema with the assistance of Jodanna Haskins, Kerry Matticks, and Helena Engelhart Bean, and was supervised by Danielle R. Voorhees, Nicholas P. Heinke, and Jason J. Burt, all of the SEC’s Denver Regional Office. The SEC’s litigation will be conducted by Mr. Williams and Ms. Haskins and supervised by Gregory A. Kasper, Mr. Heinke, and Mr. Burt.

U.S. SECURITIES AND EXCHANGE COMMISSION Litigation Release No. 26216 / January 14, 2025 Securities and Exchange Commission v. Joecool.com, LLC; Joseph Ariel Haber; Robert Tye Cournoyer, Case No. 2:25-cv-00076 (D. Nev. Filed Jan. 13, 2025) SEC Charges Nevada Coffee Company, its CEO, and Recidivist Broker for Fraudulent Securities Offering The Securities and Exchange Commission today announced litigated charges against Joecool.com, LLC and its CEO, Joseph Ariel Haber, for their alleged misappropriation and misuse of investor funds and false and misleading statements to investors, and against recidivist securities law violator Robert Tye Cournoyer for his alleged false and misleading statements to investors and for acting as an unregistered broker. The SEC’s complaint, filed in federal district court in Nevada, alleges that between at least November 2019 and February 2024, Joecool raised approximately $2 million from investors through an unregistered securities offering by representing that investor funds would be used to produce, package, promote, and sell various CBD-infused coffee products. According to the complaint, Haber instead misappropriated and misused the majority of the received investor funds, including by spending the funds on various purchases at casinos, pawn shops, restaurants, and cigar lounges, and by paying Cournoyer for finding Joecool investors, persuading them to invest, and negotiating the terms of the investments. The complaint also charges the defendants with making false and misleading statements to investors with respect to Joecool’s purported negotiations and agreements with wholesaler customers, and further charges Cournoyer with acting as an unregistered broker. The complaint alleges that (i) all of the defendants violated Sections 5(a), 5(c), and 17(a)(2) of the Securities Act of 1933 and Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5(b) thereunder; (ii) Haber and Joecool also violated Sections 17(a)(1) and (3) of the Securities Act and Section 10(b) of the Exchange Act and Rules 10b-5(a) and (c) thereunder; and (iii) Cournoyer also violated Section 15(a) of the Exchange Act. The SEC seeks injunctions, disgorgement with prejudgment interest, and civil penalties against all defendants, as well as officer and director bars and conduct-based injunctions against Haber and Cournoyer. The SEC’s investigation was conducted by Zachary D. Williams and Yamini Piplani Grema with the assistance of Jodanna Haskins, Kerry Matticks, and Helena Engelhart Bean, and was supervised by Danielle R. Voorhees, Nicholas P. Heinke, and Jason J. Burt, all of the SEC’s Denver Regional Office. The SEC’s litigation will be conducted by Mr. Williams and Ms. Haskins and supervised by Gregory A. Kasper, Mr. Heinke, and Mr. Burt.