Securities and Exchange Commission v. Titanium Blockchain Infrastructure Services, Inc.; EHI Internetwork and Systems Management, Inc. aka EHI-INSM, Inc.; and Michael Alan Stollery aka Michael Stollaire, Civil Action No. 18-cv-4315 DSF (JPRx).

NEW YORK, March 20, 2021 – The following notice has been issued by the receiver of the Titanium Blockchain Infrastructure Services, Inc. (“TBIS”) Estate pursuant to the Order authorizing Claims Process and Bar Date dated August 21, 2020, as modified December 15, 2020, in the action Securities and Exchange Commission v. Titanium Blockchain Infrastructure Services, Inc.; EHI Internetwork and Systems Management, Inc. aka EHI-INSM, Inc.; and Michael Alan Stollery aka Michael Stollaire, Civil Action No. 18-cv-4315 DSF (JPRx), before the United States District Court for the Central District of California.

Notice of claims process and claims bar date

This notice may affect your legal rights. Please read it carefully. Among other things, failure to timely submit a claim pursuant to the directions below may result in your claim being barred from a distribution.

To potential claimant

On May 30, 2018, the above-captioned Court entered an Order appointing Josias Dewey as Receiver for the estate of Titanium Blockchain Infrastructure Services (“TBIS Estate”). On August 21, 2020, the Court entered an Order authorizing the Claims Process and Bar Date, as modified December 15, 2020. Copies of these orders and other information regarding this case are available on the TBIS Receivership website at http://tbis.io.

You are receiving this Notice because our records indicate you may hold a claim against the TBIS Estate. Receiving this Notice does not mean that you hold a claim or that your claim will be eligible for a distribution from the TBIS Estate.

The TBIS case

As alleged by the United States Securities and Exchange Commission, Titanium President Michael Alan Stollery, a/k/a Michael Stollaire, lied about business relationships with the Federal Reserve and dozens of well-known firms for purposes of promoting an Initial Coin Offering (“ICO”). Titanium’s website contained fabricated testimonials from these supposed corporate customers. These fraudulent statements were used to promote the ICO, which Stollaire advertised through videos and social media. The SEC’s complaint charged Stollaire and Titanium with violating Sections 5(a), 5(c), and 17(a) of the Securities Act of 1933 and Section 10(b) of the Securities Exchange Act of 1934 and Rules 10b-5(a) and 10b-5(c) thereunder. The complaint charged another Stollaire company, EHI Internetwork and Systems Management Inc., with violating Section 17(a) of the Securities Act and Section 10(b) of the Exchange Act and Rules 10b-5(a) and 10b-5(c) thereunder.

Eligible claimants and claims process

You may be eligible to submit a claim if you: (i) are a creditor of Titanium; (ii) directly purchased Titanium Bar (“BAR”) or TBAR from Titanium; (iii) purchased BAR from a third party (other than Titanium) prior to February 22, 2018, held such BAR through February 22, 2018, received TBAR from Titanium by virtue of your BAR holdings, and held such TBAR through May 29, 2018; or (iv) purchased TBAR from a third party (other than Titanium) prior to May 29, 2018 and held such TBAR through May 29, 2018.

How do I submit a claim?

Information regarding the claims process is available on the Receiver’s website, http://tbis.io, including necessary instructions on how to submit a claim through the online claim system.

Deadline for submitting claims

Notice is hereby given that all people with potential claims for recovery from the TBIS Estate should file their claim with the Receiver so that it is actually submitted on the Receiver’s online claim system, http://tbis.io, by 11:59 p.m. (Pacific Time) on August 11, 2021 (the “Bar Date”). Claims should be filed electronically through this online claim system.

Individuals or entities that believe they have good cause to either extend the Bar Date or to submit their claim by other means should request this from the Receiver at tbis@hklaw.com no later than the Bar Date. Unless a claim is subject to a Receiver-granted exception, all claims against TBIS Estate assets that are not received by the Bar Date are barred.