SEC v. PlexCorps, Dominic LaCroix, and Sabrina Paradis-Royer
Case No. 17-cv-7007 (CBA) (RML) (E.D.N.Y.)

On December 1, 2017, the SEC filed a Complaint against PlexCorps, Dominic LaCroix ("LaCroix"), and Sabrina Paradis-Royer ("Paridis-Royer") (collectively, the "Defendants"), and at the same time, sought and obtained temporary restraining orders, to stop the Defendants' dissemination of a series of material false and misleading statements and the misappropriation of investor assets in connection with the illegal offering for unregistered securities known as PlexCoins through the PlexCoin Initial Coin Offering ("ICO"). In its complaint, the SEC alleged that PlexCorps, and its proprietors Lacroix and Paradis-Royer, fraudulently raised millions of dollars in virtual and fiat currency from the unregistered sales of PlexCoin based on a series of false and misleading statements to potential and actual investors, including misrepresentations about the size and scale of PlexCorps' operations, the use of funds raised in the PlexCoin ICO, and the amount of funds raised in the PlexCoin ICO. The SEC charged the Defendants with violations of 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 Section 17(a) of the Securities Act of 1933 ("Securities Act") [15 U.S.C. § 77q(a)]; and Lacroix and PlexCorps with violations of Sections 5(a) and 5(c) of the Securities Act [15 U.S.C. §§ 77e(a), 77(e)(c)]. See the SEC's Complaint.

On October 2, 2019, the U.S. District Court for the Eastern District of New York (the "District Court"), entered a final judgment against PlexCorps, Lacroix, and Paradis-Royer (the "Final Judgment"). Pursuant to the Final Judgment, the Defendants, without admitting or denying the allegations in the SEC's Complaint, are enjoined from further violations of Section 17(a) of the Securities Act, and Section 10(b) of the Exchange Act and Rule l0b-5 thereunder, and Lacroix and Paradis-Royer are additionally enjoined from violations of Sections 5(a) and 5(c) of the Securities Act and from participating in any digital-securities offerings. All Defendants are ordered to disgorge, on a joint and several basis, $4,563,468 in ill-gotten gains from the PlexCoin ICO plus $348,145 in prejudgment interest, and Lacroix and Paradis-Royer are ordered to each pay a $1,000,000 civil penalty. The Final Judgment requires the Defendants to forego their rights to the entirety of the investor funds seized by a receiver appointed by the Superior Court of Quebec, totaling approximately $4 million (the "Canadian Receiver"), as well as $800,000 in investor funds held by U.S.-based entities that were subject to an asset freeze issued by the District Court. See the Final Judgment.

The SEC will post on this webpage filings with the District Court concerning the disposition of collections on the Final Judgment and any information that the SEC seeks to communicate to investors.

At this time, the SEC anticipates coordinating any distribution to harmed investors with the Autorité des marchés financiers of Quebec ("QAMF"). On or about November 20, 2019, the SEC staff directed an Investor Notice of Distribution Plan to individuals and entities identified as having expressed interest in, or invested in, the ICO. If you invested in PlexCoin through the ICO, please review this notice.

The Canadian Receiver's website, which currently includes information in both English and French, including notices to investors, is located here. An English translation of the proposed plan is available on the Receiver’s website, here.

On January 2, 2020, the SEC filed a status report with the Court, updating the Court on the status of the disposition of the assets collected in the United States in this matter. In its status report, the SEC references a December 6, 2019, letter sent to the Court by Skip Shapiro, available here.

On January 31, 2020, the Receiver moved the Superior Court in Quebec, Canada, for a Declaratory Judgment; see English translation. The SEC has taken the position reflected in this letter regarding the request, sent by its local counsel to the Superior Court. On February 26, 2020, the Receiver filed a Report concerning the Request to Obtain a Declaratory Judgment. On or about March 25, 2020, the Receiver filed an Amended Report; see English translation.

On October 29, 2020, the Honorable Daniel Dumais of the Superior Court of Canada, Province and District of Quebec, issued a judgment on the Receiver’s Declaratory Judgment request, declaring that:

  1. If and when sent to the Receiver for distribution, the frozen assets in the United States should be distributed to Plexcoin investors as currently defined in clause 1.1.13 of the Plan;
  2. The frozen assets in Quebec should be distributed to the creditors of Dominic Lacroix; and
  3. Neither distribution will be subject to a de minimis debt value of $250.

An English translation of judgment is available here. The Court further ordered the Receiver to adjust the Plan and present it to the Superior Court for authorization as soon as possible.

On March 4, 2021, the Receiver filed a motion seeking approval of a Claims Procedure Order. An English translation of the proposed order is available here; the full (translated) motion can be viewed here.

On or about March 19, 2021, the Receiver filed an amended Claims Procedure Order, an English translation of the revised Order is available here, and a comparison of the revised Order to the original Order is available here.

On May 7, 2021, Judge Dumais issued a Claims Procedure Order, the English translation of which is here. By the Order, claims must be filed with the Receiver by August 4, 2021. By way of further instruction (from the Claims Procedure Order, [15]):

any Proof of Claim may only be filed with the Receiver by completing and filing the online claim form at the address:

https://www.raymondchabot.com/en/companies/public-records/dominic-lacroix/ and uploading any supporting evidence.

Any Proof of Claim received by mail, courier, fax or email will thus not be validly filed with the Receiver, unless there is a specific agreement between a Creditor and the Receiver.

If you have any questions regarding the claims process, including an inability to complete the online form, please contact the Receiver at plexcoin@rcgt.com or through the website below.

Please periodically review the Canadian Receiver’s website, here, for updates, including notices to investors, and filings in the Canadian Proceedings.

Please note, the SEC has no affiliation with the 'PlexCoin - Smart Team' Telegram Chatroom and provision of information to or through that chat room is not provision of information to the SEC.

For more information, please contact the Commission:

Office of Distributions
Email: ENFOfficeofDistributions@sec.gov