According to the Complaint, from August 15, 2017 through September 15, 2017, Defendants ran the Paragon ICO
“presale” during which time they purportedly “sold out” of 70,000,000 ParagonCoins (“PRG Tokens”) priced between $0.75 and $0.90 per PRG Token. From September 15, 2017 through October 16, 2017, Defendants ran the Paragon ICO “crowd sale,” during which time PRG Tokens were offered and sold for $1 each on the first day and the price thereafter increased by $0.05 per day until the close of the Paragon ICO.
On November 2, 2017, Defendants emailed Paragon ICO investors an update which indicated that during the Paragon ICO “crowd sale” they had collected 533 BTC and 8,092 ETH— worth approximately $7.3 million and $10.2 million, respectively, as of January 12, 2018. In this update, Defendants also stated that these amounts did not include any of the cryptocurrencies they collected during the Paragon ICO “presale.” Given that Defendants have represented that the Paragon ICO “presale” sold 70,000,000 PRG Tokens at a minimum price of $0.75,3
and that the Paragon ICO “crowd sale” raised 533 BTC and 8,092 ETH, these representations indicate that Defendants collected at least $70 million during the Paragon ICO.
The Complaint alleges that Defendants marketed the Paragon ICO as offering a path towards legalization of cannabis and a way to solve nearly every issue facing the cannabis industry. As discussed herein, the Paragon ICO was in actuality a way for Defendants to raise capital to purchase real estate.