Well Built American Customs, LLC v. Arman Khoshb integration

IN THE DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA WELL BUILT AMERICAN CUSTOMS, LLC, an Oklahoma limited liability company, Plaintiff, v. ARMAN KHOSHBIN, an individual; AMIR KHOSHBIN, an individual; KHOSHBIN CAPITAL LLC, a Florida limited liability company; JUSTIN SIDES, an individual; and AG ACUMEN LLC, a Florida limited liability company, d/b/a KORVATO; SEWWWWVER Private Services LLC, a Wyoming limited liability company, Defendants. FILED IN DISTRICT COURT OKLAHOMA COUNTY FEB 18 2026 RICK WARRICK COURT CLERK 109 Case No. ______________________ JURY TRIAL DEMANDED ATTORNEY LIEN CLAIMED VERIFIED ORIGINAL PETITION COMES NOW Plaintiff Well Built American Customs, LLC ("Well Built" or "Plaintiff"), and for its Petition against defendants, Arman Khoshbin ("Arman"), Amir Khoshbin ("Amir"), Justin Sides ("Sides"), Khoshbin Capital, LLC ("Khoshbin Capital"), AG Acumen LLC, d/b/a Korvato ("Korvato"), and Sewwwwer Private Services LLC ("Sewwwwer")(collectively, "Defendants"), alleges and states as follows: I. INTRODUCTION 1. This action arises from an international investment fraud scheme perpetrated upon Plaintiff that involved an unregulated online "brokerage" platform marketed as "Orca Markets" and an AI-driven trading service marketed as "MetaTrading.ai" / "MetaTrader.ai," followed by a successor/continuation phase marketed under the "Korvato" name. 2. Defendants, together with additional domestic and foreign participants, induced Plaintiff to wire them approximately $1,000,000.00 on September 16, 2025, to a JPMorgan Chase account designated by Defendants and held in the name of Sewwwwver Private Services LLC, by promising automated trading profits, legitimate brokerage custody, and withdraw ability of funds, while concealing material facts, conflicts, and the true destination of Plaintiff's money. 3. Contrary to those promises, Plaintiff's $1,000,000.00 was routed to a U.S. conduit account and then transferred offshore to a Citibank account in Columbia, after which withdrawals were denied, communications ceased, and the platforms went dark. 4. Defendants are among the principal organizers, promoters, and beneficiaries of the scheme. They acted in concert with additional domestic and foreign actors—including a foreign-based co-participant identified in the record whose service is presently impractical—whose conduct furthered the same enterprise and common plan. 5. By way of this action, Plaintiff asserts statutory securities claims, fraud, conversion, unjust enrichment, civil RICO, and requests comprehensive equitable relief (including asset restraints, accounting, constructive trust, preservation orders, and appointment of a receiver) to prevent further dissipation and preserve assets for execution. II. THE PARTIES A. PLAINTIFF 6. Wellbuilt is an Oklahoma limited liability company with its principal place of business in Oklahoma. B. DEFENDANTS 7. Defendant Arman is an individual co-conspirator who may be served with process at his primary residence located at 10255 Cypress Lakes Preserve Dr., Lake Worth, Florida 33449. 8. Defendant Amir is an individual co-conspirator who may be served with process at his primary residence located at 10255 Cypress Lakes Preserve Dr., Lake Worth, Florida 33449. 9. Defendant Sides is an individual conspirator who is believed to reside in Tehama County, California and who may be served with process at P.O. Box 225, Tehama, California 96090. 10. Defendant Khoshbin Capital is a Florida limited liability company and co-conspirator, formed on September 18, 2025. Arman Khoshbin is its registered agent for service of process, located at 10255 Cypress Lakes Preserve Dr., Lake Worth, Florida 33449, and its principal office is 222 Lakeview Ave., Suite 800, West Palm Beach, Florida 33401. 11. Defendant Korvato is a Florida limited liability company and co-conspirator, formed on December 17, 2021, that may be served with process at its principal office located at 446 3rd Street, Neptune Beach, Florida 32266 and/or through Incorp Services, Inc., 3458 Lakeshore Dr., Tallahassee, Florida 32312. 12. Defendant Sewwwver is, on information and belief, a foreign limited liability company and co-conspirator that may be served with process by and through its principal agent Arman at 10255 Cypress Lakes Preserve Dr., Lake Worth, Florida 33449 or Sides at P.O. Box 225, Tehama, California 96090. 13. The Defendants named above acted individually and in concert with one another and with additional persons and entities, known and unknown, as co-conspirators, agents, and joint actors in furtherance of the wrongful conduct alleged herein. Each Defendant is responsible for the acts of the others committed within the scope and in furtherance of the conspiracy and common scheme. III. JURISDICTION AND VENUE 14. This Court has specific personal jurisdiction over each Defendants because each purposefully directed conduct into Oklahoma, including, soliciting an Oklahoma business located in Lawton, Comanche County, sending and causing communications and representations to be received in Comanche County; inducing Plaintiff's wire transfers from Oklahoma on September 16, 2025; and causing injury to Plaintiff. 15. Venue is proper in Oklahoma County, Oklahoma, because Defendants purposefully directed tortious conduct into Oklahoma County, and the causes of action arose there, including that Defendants transmitted misrepresentations and omissions into Oklahoma County, those misrepresentations were received and relied upon in Oklahoma County, Defendants caused the wire transfers at issue to be initiated from Oklahoma County, and Defendants' conduct caused economic injury that was sustained in Oklahoma County. IV. FACTUAL ALLEGATIONS A. THE FRAUDULENT SCHEME AND THE ROLES DEFENDANTS 1. The Repeating Scheme and Its Common Methods 16. Defendants employed a repeating scheme in which victims were sold an "AI trading bot" concept marketed as MetaTrading.ai / MetaTrader.ai, were charged significant fees and induced to deposit trading capital, were then redirected to the Orca Markets platform after prior versions of the scheme experienced withdrawal failures, customer complaints, or operational shutdowns, and were ultimately routed through Korvato, all using overlapping personnel and common methods. 17. Orca Markets was marketed as an online Forex/CFD brokerage, was not registered with major financial regulators, claimed only an offshore business-company registration, advertised a Miami presence, and ultimately collapsed and disappeared, locking customers out of their accounts and denying withdrawals. 18. Korvato marketed an AI/algorithmic trading program and steered customers to use Orca Markets as the "broker" through which trades would purportedly be executed on the MetaTrader platform. 19. Defendants' scheme affected hundreds of victims, including Plaintiff, and resulted in losses in the tens of millions of dollars, including aggregate losses estimated between $14 million and $16 million across victims. 20. Defendants transmitted fraudulent solicitations, representations, and omissions to Plaintiff, which were received and relied upon in Oklahoma, through the following means: a. Sales calls and follow-up communications; b. Onboarding materials, including an onboarding "packet" supplied through scheme personnel; c. Platform websites and dashboards used to promote the scheme and display purported account activity; d. Wire instructions directing Plaintiff's deposits. 21. Defendants controlled and maintained the communications, scripts, onboarding materials, platform content, and transactional records used to solicit Plaintiff and effectuate the scheme, and retained custody and control over those materials and data at all relevant times, including call logs, emails, scripts, and platform records. 2. Justin Sides’s Solicitation and Misrepresentations 22. Between approximately July 2025 and September 16, 2025, and continuing into October and November 2025 during the period in which Plaintiff sought to withdraw funds, Defendant Justin Sides solicited Plaintiff through telephone calls and electronic communications received by Plaintiff’s principal, Aaron Harris, in Lawton, Comanche County, Oklahoma, and through onboarding materials, including an onboarding “packet,” supplied through scheme personnel. 23. During those communications, Sides represented that the AI trading program marketed as MetaTrading.ai / MetaTrader.ai, and later through Korvato-related offerings, was legitimate and capable of generating profits through automated trading, that Plaintiff’s deposited funds would be placed into a legitimate trading or brokerage account and used for Plaintiff’s benefit, and that Orca Markets was an appropriate, legitimate, and trustworthy platform through which trades would be executed. 24. Sides further represented that Plaintiff would be able to withdraw funds, and that any withdrawal issues were temporary, administrative in nature, or readily resolvable, thereby assuring Plaintiff that its funds would remain accessible and under its control. 25. At the same time, Sides omitted material facts, including that Orca Markets was not registered or regulated by major United States financial regulators, that Plaintiff's funds would be routed through shell entities and transferred offshore, and that intermediaries and the algorithm provider had undisclosed financial conflicts, including kickbacks tied to steering clients to Orca Markets. 26. Sides’s representations and omissions were material, were made for the purpose of inducing Plaintiff to continue participating in the program, and were relied upon by Plaintiff in Lawton, Comanche County, Oklahoma, in deciding to proceed with the investment and to refrain from withdrawing funds earlier. 27. As a direct and proximate result of Sides's misrepresentations and omissions, Plaintiff continued with the program and initiated the September 16, 2025 wire transfers totaling $1,000,000.00. 3. Korvato’s Marketing, Steering, and Undisclosed Conflicts 28. Between at least August 2025 and November 2025, including the period immediately preceding and following September 16, 2025, Korvato solicited Plaintiff through oral and electronic communications and customer-facing marketing materials received in Oklahoma, including representations made by Korvato representatives and executives and through Korvato’s websites and promotional pages, including www.korvato.com and start.korvato.com/welcometokorvato. 29. During those communications and through its online marketing materials, Korvato represented that it provided a legitimate AI-based trading and algorithmic investment solution, and directed customers, including Plaintiff, to use Orca Markets as the "broker" through which trades would be executed and funds held, representing that this recommendation was appropriate, independent, and unbiased. 30. Korvato further represented that its trading program had a proven track record, including claims of "3+ years of proven results," "third-party verification by FX Blue," and performance based on "verified user data," and promoted advertised average monthly growth of 5–9 percent and double-digit monthly returns to induce participation. 31. Korvato also represented that it was widely trusted and adopted, including claims that it was "trusted by thousands," had "3,212+ users," and maintained "over $50 million in user deposits verified by third parties," and displayed screenshot-style trading statistics purporting to show extraordinary performance, including "Total return +2,084.1%" and "Monthly return +10.7%," as representative of its software's actual results. 32. Korvato further represented that users maintained full control over their funds, including assurances that users could "withdraw any amount from your trading account anytime" and "pull profits whenever you want," thereby assuring Plaintiff that funds would remain accessible and under user control. 33. At the same time, Korvato omitted material facts, including that Korvato maintained a revenue-sharing and kickback arrangement with Orca Markets tied to referral and trading activity, which created a material conflict of interest and directly incentivized steering customers to Orca Markets regardless of suitability or risk. 34. Korvato further failed to disclose the true regulatory, custody, and counterparty risks associated with directing customers into an unregulated and ultimately disappearing platform, despite including general website disclaimers acknowledging that paid solicitors may have undisclosed conflicts and that minimizing or contradicting risk disclosures may indicate potential sales fraud. 35. Plaintiff relied on Korvato’s representations, promotional claims, and omission of conflicts and risks in proceeding to use Orca Markets as the platform through which Plaintiff’s funds were deposited and trading purportedly occurred, and in continuing participation in the scheme. 4. Arman Khoshbin’s Control and Direction of the Scheme 36. From at least early 2025 through late 2025, Defendant Arman, acting directly and through entities, platforms, and instrumentalities he controlled, orchestrated and directed the operation of the trading platforms and related infrastructure used to solicit Plaintiff and other victims. 37. During that period, Arman controlled and caused the dissemination of representations through platforms, websites, and operational structures designed to create the appearance of legitimacy, including customer-facing websites, onboarding processes, and routing structures associated with Orca Markets and related offerings. 38. Through those platforms and structures, Arman Khoshbin held Orca Markets out as a legitimate brokerage destination for customer funds, caused customers to be led to believe that their funds were placed into legitimate accounts and remained withdrawable, and promoted the appearance that trading activity and account balances reflected bona fide brokerage operations. 39. At the same time, Arman omitted and concealed material facts, including that customer funds were routed through shell entities and transferred offshore, that the custody and routing structure exposed customers to undisclosed risks of loss and non-withdrawal, and that customers were not informed of the true destination, handling, or risks associated with their funds. B. THE $1,000,000 WIRE TRANSFERS AND OFFSHORE DIVERSION OF FUNDS 40. On September 16, 2025, Plaintiff initiated two bank wire transfers of $500,000.00 each from Plaintiff's bank, All-America Bank, while Plaintiff was located in Oklahoma, and did so at the direction of Defendants as part of the scheme described herein. 41. The receiving name on the wire transfers was defendant Sewwwver with the funds deposited into an account at JPMorgan Chase, as designated by Defendants. 42. Those wired funds were then transferred offshore to a Citibank account in Colombia (Account No. 9154430389), a routing structure that contradicted Defendants’ representations that Plaintiff’s funds were held for legitimate trading and remained withdrawable, and instead concealed the true destination and handling of the funds. C. WITHDRAWAL DENIAL, GHOSTING, AND COLLAPSE 43. By November 2025, Orca Markets ceased communicating with Plaintiff and denied withdrawal requests, and the Orca Markets website and related MetaTrader5 platform access became inaccessible, preventing Plaintiff from accessing account information or funds. 44. Other victims experienced the same course of conduct, in which funds were accepted, communications abruptly stopped, withdrawal requests were ignored or denied, and victims were promised follow-ups that never occurred before being cut off entirely, reflecting a consistent pattern of behavior. 45. Plaintiff remains deprived of approximately $1,000,000.00 in principal and has sustained additional consequential damages, including lost use of funds, interest, and litigation-related expenses. D. INVESTIGATION AND MULTI-VICTIM PATTERN 46. By early December 2025, Plaintiff's investigation identified the structure and participants used to receive and route the wired funds, including the use of Sewwwver, as a domestic conduit, the formation of Khoshbin Capital on September 18, 2025—two days after Plaintiff's wire transfers—by Arman, and the involvement of an outsourced call-center operation known as "Whiz Finance," in which Sides acted as a supervisor. 47. On December 8, 2025, Plaintiff submitted a complaint to the Federal Bureau of Investigation's Internet Crime Complaint Center (IC3) describing the scheme as international investment fraud involving wire fraud and money laundering. 48. Plaintiff also initiated urgent bank and law-enforcement efforts to trace and recover the funds, including issuing a wire-recall demand and pursuing other measures intended to identify the movement and current location of the misappropriated funds. V. CLAIMS FOR RELIEF COUNT I —OKLAHOMA UNIFORM SECURITIES ACT— Plaintiff realleges and incorporates by reference Paragraphs 1 through 48 of this Petition as if fully set forth herein. 49. Defendants offered and sold to Plaintiff an investment contract, and therefore a security, by inducing Plaintiff to invest substantial funds into an arrangement marketed as an automated, AI-driven trading program in which Plaintiff was led to expect profits. 50. Plaintiff invested money in the arrangement, including approximately $15,000.00 in upfront fees and $1,000,000.00 in trading capital, with the expectation that profits would be generated through automated trading rather than through any trading decisions or efforts by Plaintiff. 51. Plaintiff's anticipated profits were derived primarily from the efforts of Defendants and the trading operation they controlled, including the purported AI system, the selection of Orca Markets as the trading platform, and the routing and handling of Plaintiff's funds, all of which were directed by Defendants. 52. Defendants required Plaintiff to follow Defendants' instructions regarding platform selection and funding, including directing Plaintiff to use Orca Markets as the platform through which funds would be deposited and trading would purportedly occur. 53. Defendants offered and sold the security to Plaintiff in Oklahoma through communications transmitted to and received by Plaintiff in Oklahoma, and Plaintiff paid consideration in Oklahoma, including the $15,000.00 fee and the September 16, 2025 wire transfers totaling $1,000,000.00. 54. The security offered and sold to Plaintiff was not registered in Oklahoma, and no exemption applied, including because Orca Markets and related entities were not registered with major financial regulators and operated without legitimate licensing, and because Korvato and its affiliates expressly disclaimed registration as regulated intermediaries through which lawful securities or retail forex transactions are ordinarily conducted. 55. Defendants sold the security by means of untrue statements of material fact and by omitting material facts necessary to make their statements not misleading, including misrepresentations and omissions regarding the legitimacy of the trading program, the safety and custody of Plaintiff's funds, the ability to withdraw funds, the performance and risk of the investment, and the existence of undisclosed conflicts and kickback arrangements. 56. At the time Plaintiff invested and funded the arrangement, Plaintiff did not know of the untruths or omissions described above and reasonably relied on Defendants' representations and omissions in deciding to proceed. 57. By means of those misrepresentations and omissions, Plaintiff invested and wired funds, including the $1,000,000.00 transferred on September 16, 2025, which Defendants then diverted and handled in the manner described herein. 58. Defendant Arman is liable as a control person, having exercised control over the entities, platforms, and instrumentalities used in the offer and sale of the security and in the conduct giving rise to Plaintiff's losses. 59. On information and belief, defendant Amir is also liable as a control person and participant, having directly or indirectly controlled, participated in, and benefitted from the enterprise and the offer and sale of the security, including through his role as a facilitator and asset holder. 60. Defendant Sides and Defendant Korvato are liable under control and material-aid principles based on their solicitation of Plaintiff, steering of Plaintiff's investment, promotion of the trading program, and concealment of material risks and conflicts, and because they materially aided the offer, sale, and conduct giving rise to liability. 61. As a result of Defendants’ violations, Plaintiff seeks statutory rescission or damages, statutory interest, costs, and attorneys’ fees as authorized by 71 O.S. § 1-509, and will tender or offer tender of any security interest as directed by the Court. COUNT II —COMMON-LAW FRAUD / FRAUD BY OMISSION / DECEIT— Plaintiff incorporates and realleges Paragraphs 1 through 50 of this Petition as if fully set forth herein. 62. Between July 2025 and September 16, 2025, Defendant Sides made material representations to Plaintiff through calls and electronic communications received in Oklahoma, and during that same period omitted material facts, including those concerning the legitimacy of the trading program, the safety and custody of Plaintiff's funds, and the ability to withdraw funds. 63. Between August 2025 and September 16, 2025, Defendant Korvato, made material representations to Plaintiff through marketing materials, solicitations, and online communications received in Oklahoma, and omitted material facts concerning conflicts of interest, compensation arrangements, and the risks associated with steering Plaintiff to Orca Markets. 64. Throughout 2025, Defendant Arman, acting directly and through platforms and structures he controlled, caused representations of legitimacy, brokerage custody, and withdrawability to be disseminated to Plaintiff, while omitting the true routing, handling, and offshore transfer of Plaintiff's funds. 65. These representations were false and misleading because Plaintiff's funds were not held for legitimate trading or withdrawal, but were instead routed through a shell receiver, transferred offshore to Colombia, and rendered inaccessible when withdrawal requests were denied and the platforms ceased operating. 66. Defendants knew the representations were false, or made them recklessly, including by designing the routing of funds through a shell entity and offshore account, concealing compensation and conflict structures tied to steering victims to Orca Markets, and engaging in a repeated pattern of soliciting funds, denying withdrawals, and cutting off communications. 67. Defendants intended Plaintiff to rely on their representations and omissions and to act by paying fees and wiring capital, including the September 16, 2025 wire transfers totaling $1,000,000.00. 68. Plaintiff reasonably relied on Defendants’ representations and omissions in Oklahoma by paying fees, continuing participation in the scheme, and wiring funds as directed. 69. As a direct and proximate result of Defendants’ conduct, Plaintiff suffered damages, including the loss of approximately $1,000,000.00 in principal, loss of fees net of any partial refund, consequential damages, and related losses. 70. Defendants’ conduct was willful, malicious, and in reckless disregard of Plaintiff’s rights, supporting an award of punitive or exemplary damages. COUNT III —CONVERSION— Plaintiff incorporates and realleges Paragraphs 1 through 70 of this Petition as if fully set forth herein. 71. Between July 2025 and September 16, 2025, Defendant Sides made material representations to Plaintiff through calls and electronic communications received in Oklahoma, and during that same period omitted material facts, including those concerning the legitimacy of the trading program, the safety and custody of Plaintiff's funds, and the ability to withdraw funds. 72. Between August 2025 and September 16, 2025, Defendant Korvato, made material representations to Plaintiff through marketing materials, solicitations, and online communications received in Oklahoma, and omitted material facts concerning conflicts of interest, compensation arrangements, and the risks associated with steering Plaintiff to Orca Markets. 73. Throughout 2025, Defendant Arman acting directly and through platforms and structures he controlled, caused representations of legitimacy, brokerage custody, and withdrawability to be disseminated to Plaintiff, while omitting the true routing, handling, and offshore transfer of Plaintiff's funds. 74. These representations were false and misleading because Plaintiff's funds were not held for legitimate trading or withdrawal, but were instead routed through a shell receiver, transferred offshore to Colombia, and rendered inaccessible when withdrawal requests were denied and the platforms ceased operating. 75. Defendants knew the representations were false, or made them recklessly, including by designing the routing of funds through a shell entity and offshore account, concealing compensation and conflict structures tied to steering victims to Orca Markets, and engaging in a repeated pattern of soliciting funds, denying withdrawals, and cutting off communications. 76. Defendants intended Plaintiff to rely on their representations and omissions and to act by paying fees and wiring capital, including the September 16, 2025 wire transfers totaling $1,000,000.00. 77. Plaintiff reasonably relied on Defendants’ representations and omissions in Oklahoma by paying fees, continuing participation in the scheme, and wiring funds as directed. 78. As a direct and proximate result of Defendants’ conduct, Plaintiff suffered damages, including the loss of approximately $1,000,000.00 in principal, loss of fees net of any partial refund, consequential damages, and related losses. 79. Defendants’ conduct was willful, malicious, and in reckless disregard of Plaintiff’s rights, supporting an award of punitive or exemplary damages. COUNT IV —UNJUST ENRICHMENT— Plaintiff incorporates and realleges Paragraphs 1 through 79 of this Petition as if fully set forth herein. 80. Defendants received and retained benefits directly traceable to Plaintiff's funds, including fees, commissions, kickbacks, and proceeds derived from the misappropriated money wired by Plaintiff. 81. Defendants' retention of these benefits is unjust, because the benefits were obtained through deceptive conduct, concealment of material facts, and the wrongful diversion and misuse of Plaintiff's money. 82. This claim is pled in the alternative to Plaintiff's legal claims, including to the extent Defendants dispute the existence of privity, deny contractual relationships, or challenge the characterization of the underlying transactions. 83. Plaintiff seeks restitution and disgorgement of all unjustly retained benefits, as well as the imposition of a constructive trust over all traceable proceeds and assets acquired with Plaintiff's funds. COUNT V —CIVIL RICO— Plaintiff incorporates and realleges Paragraphs 1 through 83 of this Petition as if fully set forth herein. 84. Each Defendant is a “person” within the meaning of the Racketeer Influenced and Corrupt Organizations Act ("RICO"). 85. Defendants associated together to form an association-in-fact enterprise that was distinct from each Defendant, and that functioned as a continuing unit with a common purpose of soliciting investor funds, routing those funds through controlled channels, obstructing withdrawals, and misappropriating proceeds. The enterprise consisted of the individual Defendants, their controlled entities and instrumentalities, the MetaTrading.ai / MetaTrader.ai operation and related structures, Korvato acting as the algorithm provider and steering intermediary, Orca Markets as the platform used to obtain deposits and deny withdrawals, defendant Sewwwver as a domestic conduit in the wire-transfer chain, and call-center operations used for solicitation and "support". 86. The alleged enterprise affected interstate and foreign commerce, including through interstate communications and the September 16, 2025 interstate and international wire transfers, which routed funds from the United States to Colombia. 87. Defendant Arman conducted and participated in the conduct of the Enterprise’s affairs by directing and controlling the platforms, routing structures, and operational mechanisms used to induce deposits, create the appearance of legitimacy, and facilitate offshore transfer and concealment of funds. 88. Defendant Sides conducted and participated in the enterprise’s affairs by soliciting Plaintiff, providing onboarding materials, steering Plaintiff into Orca Markets, and participating in the phase of the scheme in which withdrawal requests were obstructed and communications were cut off. 89. Defendant Korvato conducted and participated in the enterprise’s affairs by marketing the trading program, steering Plaintiff to Orca Markets, promoting extraordinary performance and withdrawal-control claims to induce participation, and concealing material conflicts and compensation arrangements that incentivized that steering. 90. On information and belief, defendant Amir conducted and participated in the enterprise’s affairs as a facilitator, beneficiary, and asset holder, including through involvement with and benefit from entities and structures controlled by Arman and used to further the enterprise’s objectives. 91. In conducting the enterprise’s affairs, Defendants committed a pattern of racketeering activity, including multiple acts of wire fraud in violation of 18 U.S.C. § 1343, consisting of interstate communications used to solicit Plaintiff and induce funding, the September 16, 2025 wire transfers to a JPMorgan Chase account designated by Defendants, the subsequent offshore transfer of those funds to Colombia, and continued interstate communications that denied withdrawals, falsely implied continued access, and culminated in the disappearance of the platforms. 92. These racketeering acts were related in purpose, method, participants, and victims, shared the objective of obtaining and misappropriating investor funds, and constituted both closed-ended continuity, spanning at least early 2025 through late 2025 and affecting multiple victims, and open-ended continuity, as demonstrated by serial rebranding and call-center-driven solicitation that posed a continuing threat of repetition absent injunctive relief. 93. Plaintiff was injured in its business and property by reason of Defendants’ racketeering conduct, including the loss of approximately $1,000,000.00, as well as related damages, and those injuries were proximately caused by Defendants’ solicitation, steering, and wire-transfer scheme. 94. Defendants conspired to violate 18 U.S.C. § 1962(c), and each knowingly agreed to and committed overt acts in furtherance of the conspiracy, including solicitation of investors, steering of funds, concealment of conflicts, and orchestration of the wire-routing and offshore transfer structure. COUNT VI —INJUNCTIVE AND EQUITABLE RELIEF— Plaintiff incorporates and realleges Paragraphs 1 through 94 of this Petition as if fully set forth herein. 95. Plaintiff has a substantial likelihood of success on the merits based on the facts alleged herein, which establish a coordinated scheme to induce the transfer of funds through deception, to route those funds through controlled channels, and to obstruct recovery. 96. Plaintiff will suffer immediate and irreparable harm absent equitable relief because the funds at issue have already been routed offshore and remain at high risk of further dissipation, Defendants have demonstrated the ability and willingness to go dark, conceal assets, and obstruct recovery, and the absence of preservation and restraint would render any judgment ineffectual. 97. The balance of equities favors Plaintiff, which seeks only to preserve potentially stolen proceeds and prevent further misuse or concealment of assets, and the public interest favors preventing fraud and preserving assets for restitution. 98. Plaintiff therefore seeks equitable relief, including restraining Defendants from transferring or encumbering assets traceable to Plaintiff's funds, requiring verified disclosures of accounts, assets, and transfers and a full accounting, ordering preservation of documents, electronically stored information, and platform records, imposing a constructive trust over traceable proceeds and assets acquired with Plaintiff's funds, and appointing a receiver to marshal and protect assets and preserve evidence. COUNT VII —ALTER EGO / INSTRUMENTALITY / ENTITY-FORMATION TO PERPETUATE FRAUD— Plaintiff incorporates and realleges Paragraphs 1 through 98 of this Petition as if fully set forth herein. 99. The corporate separateness of the defendants may be disregarded because the corporate defendants were used as a design or scheme to perpetrate fraud and operated as instrumentalities or agents to further the wrongful conduct alleged herein. 100. Khoshbin Capital was formed on September 18, 2025, two days after Plaintiff's wire transfers, and is controlled by Defendant Arman. Khoshbin Capital was formed and used to continue, conceal, hold, and benefit from proceeds of the scheme, and functioned as an instrumentality of Defendant Arman in furtherance of the fraudulent conduct alleged herein. Equity therefore requires that Khoshbin Capital be held jointly liable and subject to equitable remedies, including disregard of corporate separateness, to prevent fraud and injustice. VI. PRAYER FOR RELIEF WHEREFORE, Plaintiff respectfully requests judgment against Defendants, jointly and severally, as follows: A. Actual damages in an amount to be proven at trial, including at least $1,000,000.00; B. Statutory relief under the Oklahoma Uniform Securities Act, including rescission and/or damages, statutory interest, attorneys’ fees, and costs as authorized by law; C. Treble damages, attorneys’ fees, and costs under 18 U.S.C. § 1964(c); D. Punitive/exemplary damages as allowed under Oklahoma law; E. Restitution, disgorgement, and constructive trust over traceable proceeds and assets acquired with Plaintiff’s funds; F. Temporary restraining order, temporary injunction, and permanent injunction, including asset restraints, verified accounting/disclosures, and preservation orders; G. Appointment of a receiver to marshal and protect assets and preserve evidence; H. Pre-judgment and post-judgment interest as allowed by law; I. Costs of suit; and J. Such other and further relief as the Court deems just and proper. VII. JURY DEMAND Plaintiff demands a trial by jury on all issues so triable. Respectfully submitted, Tony Gould, OBA #18564 GOULD & ASSOCIATES, P.C. 136 N.W. 10th Street, Suite 202 Oklahoma City, Oklahoma 73103 Telephone: (405) 768-1220 Facsimile: (405) 768-1224 Email: [email protected] ATTORNEY FOR PLAINTIFF WELL BUILT AMERICAN CUSTOMS, LLC VERIFICATION STATE OF OKLAHOMA ) COUNTY OF OKLAHOMA ) ss. I, Aaron Harris, being first duly sworn, state as follows: 1. I am the Plaintiff in the foregoing action. 2. I have read the foregoing Original Petition, and I know the contents thereof. 3. The facts stated in the Original Petition are true and correct to the best of my personal knowledge, information, and belief. 4. I personally transferred funds in the amount of One Million Dollars ($1,000,000.00) in connection with the investment activity described in the Original Petition. 5. Defendants have not returned any portion of those funds, and I have suffered damages in the amount of $1,000,000.00, together with prejudgment interest and additional consequential damages as alleged. FURTHER AFFIANT SAYETH NOT. AARON HARRIS SUBSCRIBED AND SWORN TO before me this 12 day of February, 2026. MICHELLE LEIGH SCHNEIDER Notary Public My Commission Expires: 5/2/28 My Commission No.: 24C05906