33.... Garza participated in an interview with a reporter for Cryptocoinsnews.com, during which he convinced a family member of a GAW Miners’ investor to pretend that ZenMiner was that person’s company and idea.

I spoke on the phone with Thomas Fraser of Zenminer

49. By October 2014, GAW Miners had oversold Hashlets to an even more extreme degree. It had oversold altcoin mining Hashlets by at least about 100 times its computing capacity, and bitcoin mining Hashlets by at least about 5 times its computing capacity.

51. Throughout the time that Hashlets were sold, from mid-August 2014 through December 2014, GAW Miners and ZenMiner sold at least $19 million of Hashlets, to more than 10,000 investors.

68... In September and October 2014 alone, GAW Miners, at Garza’s direction, converted over $1.5 million in cash to bitcoin to make mining payouts and thus perpetuate their fraud.

91. Hashlets constitute investment contracts, and thus “securities” under Section 2(a)(1) [15 U.S.C. §77b(1)] of the Securities Act.

92. No registration statement was filed with respect to the Hashlets sold by defendants, and no exemption from registration was availablefor these securities.