16. Other irregularities in Founder-1's email correspondence further signaled that "Eduard Grigoriann" and his purported representatives, Persona-1 through Persona-3, were all fake personas. For example:
- By on or about February 16, 2023, Persona-1 had misspelled the surname of his purported boss as "Grigorian" (rather than "Grigoriann") in at least four separate emails to Founder-1.
- On or about February 10, 2023, Persona-3 sent an email to a potential influencer, copying Founder-1, and signed the email as "Eduard Grigoriann," rather than as Persona-3. After the email recipient expressed confusion as to whether the sender was "Eduard Grigoriann" or Persona-3, Persona-3 quickly responded, in part, "Eduard forwarded this email to me and asked me to replay [sic] on his behalf."
17. Digital forensic evidence further confirms that "Eduard Grigoriann" and Persona-1 through Persona-3 (ie., the various "investor" personas) were, in truth and in fact, the same individual. For example, on approximately 39 occasions between in or about November 2023 and in or about July 2024, email accounts used by "Eduard Grigoriann" and Persona-1 to communicate with Founder-1 were accessed from the same Internet Protocol ("IP") address at around the same time. As another example, on or about January 10, 2023, Persona-1 emailed the text of a draft email to Persona-2, which Persona-2 then pasted into a new email and sent to Founder-1 from Persona-2's email account.
18. Founder-1 transmitted the "Eduard Grigoriann" profile to Commentator-1 to persuade Commentator-1 to perform work on behalf of "Eduard Grigoriann." On or about May 12, 2023, Founder-1 reported to Persona-1 that Commentator-1 had "a problem with the profile we sent over, specifically the reference to 'social justice.' I think it may be because that's usually
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