According to the Complaint, Voyager Financial Group LLC is a limited liability company organized under the laws of Delaware with a principal place of business in Little Rock, Arkansas. It makes money by the sale of Securities in the form of contracts for the right to receive Veterans Administration and other military structured payments, awards, pensions and/or disability incomes owned by Veterans and Military Retirees throughout the United States.

The Defendants' business includes finding individuals who are receiving structured payments, pensions and/or disability incomes from the government, and offering a lump sum in exchange for their promise to turn over all or a portion of their payments. These individuals, or "sellers", are often ex-military, injured during service and in need of a large amount of money quickly. Defendants enter into contracts with "sellers" which assign Defendants the right to sell the Securities once an investor is found. The Investor, or "buyer", often retired, is looking for a secure, risk free investment. Defendants use local Selling Agents to participate in the transactions and obtain money from the Investors to pay a lump sum to the Veteran exchange for a contract assigning the rights to the Veterans' Benefits to the Class Member.

The Complaint alleges that Defendants induced Plaintiff and the other Class Members to enter into such agreements and purchase of such Securities when they knew or should have known that the assignment of such government benefits is illegal under 38 USC 21 § 5301, Nonassignability and Exempt Status of Benefits, facts which were unknown to the Class Members. Defendants knew that the sale of these Securities was not lawful, was not risk free, was not guaranteed to the Investor by the United States government, would not benefit Veterans and would in fact lead to loss of all of some of the Investors' money and gain to Defendants. This scheme did in fact lead to the loss of all or some of the Class Members' money invested and to unlawful gain by Defendants. Defendants fraudulently failed to disclose the true facts to Plaintiff and the other Class Members.

On March 27, 2013, a First Amended Complaint was filed by the Plaintiffs against the Defendants.