Defendant Apex Capital Group, LLC (“Apex Capital Group”) is a Wyoming limited liability company which has had business addresses at 31280 Oak Crest Drive, Suite 5, Westlake Village, California 91361; 690 S Highway 89, Suite 200, Jackson, Wyoming 83001; 8306 Wilshire Boulevard No. 1669, Beverly Hills, CA 90211; and 21300 Victory Boulevard, Ste. 740, Woodland Hills, CA 91367. At all times material to this Complaint, acting alone or in concert with others, Apex Capital Group has advertised, marketed, distributed, or sold products to consumers throughout the United States. Apex Capital Group transacts or has transacted business in this district and throughout the United States.
Omni Group Limited is a United Kingdom limited company. In its corporate filings, it initially provided as an office address the address of a residential property located in Bedford, United Kingdom, and later changed its address to that of a virtual office in London, United Kingdom. Dozens of other limited companies within the control of Apex Capital Group, Phillip Peikos, and David Barnett, including all of the companies listed in Paragraphs 10-19, provided one or both of the same addresses in their corporate filings. When Omni Group Limited was incorporated on July 28, 2015, its proposed directors and shareholders were Phillip Peikos and David Barnett. David Barnett transferred his shares to Phillip Peikos in late 2017, and Peikos is now the sole shareholder of Omni Group Limited. Omni Group Limited is or has been the sole or controlling shareholder of at least twenty limited entities, including the companies listed in Paragraphs 10-19. Many of these companies sold products to U.S. consumers and distributed the sales proceeds to Apex Capital Group, Phillip Peikos, and David Barnett. Omni Group Limited has also transferred millions of dollars from its own bank account to Apex Capital Group.
Capstone Capital Solutions Limited is a United Kingdom limited company. In its corporate filings, it initially provided as an office address the address of a residential property located in Bedford, United Kingdom, and later changed its address to that of a virtual office in London, United Kingdom. Its director, as listed in its corporate filings, is a U.S. resident. Its sole shareholder is Omni Group Limited, which is owned by Phillip Peikos, who resides in the United States. At times material to this Complaint, Apex Capital Group, Phillip Peikos, and David Barnett have used Capstone Capital Solutions Limited to sell products to U.S.-based consumers, to debit U.S. consumers’ credit cards and financial accounts, to open merchant accounts through which these charges are processed, and to distribute the sales proceeds to Apex Capital Group, Phillip Peikos, and David Barnett. At least nine merchant accounts have been established at a Latvian bank in the name of Capstone Capital Solutions Limited to process payments for online sales of products to consumers in the United States.
Clik Trix Limited is a United Kingdom limited company. In its corporate filings, it initially provided as an office address the address of a residential property located in Bedford, United Kingdom, and later changed its address to that of a different residential property located in London, United Kingdom. Its controlling shareholder is Omni Group Limited, which is owned by Phillip Peikos, who resides in the United States. At times material to this Complaint, Apex Capital Group, Phillip Peikos, and David Barnett have used Clik Trix Limited to sell products to U.S.-based consumers, to debit U.S. consumers’ credit cards and financial accounts, to open merchant accounts through which these charges are processed, and to distribute the sales proceeds to Apex Capital Group, Phillip Peikos, and David Barnett. At least one merchant account has been established at a Latvian bank in the name of Clik Trix Limited to process payments for online sales of products to consumers in the United States.
Empire Partners Limited is a United Kingdom limited company. In its corporate filings, it initially provided as an office address the address of a residential property located in Bedford, United Kingdom, and later changed its address to that of a different residential property located in London, United Kingdom. Its director, as listed in its corporate filings, is a U.S. resident. Its controlling shareholder is Omni Group Limited, which is owned by Phillip Peikos, who resides in the United States. At times material to this Complaint, Apex Capital Group, Phillip Peikos, and David Barnett have used Empire Partners Limited to sell products to U.S.-based consumers, to debit U.S. consumers’ credit cards and financial accounts, to open merchant accounts through which these charges are processed, and to distribute the sales proceeds to Apex Capital Group, Phillip Peikos, and David Barnett. At least seven merchant accounts have been established at a Latvian bank in the name of Empire Partners Limited to process payments for online sales of products to consumers in the United States.
Interzoom Capital Limited is a United Kingdom limited company. In its corporate filings, it initially provided as an office address the address of a residential property located in Bedford, United Kingdom, and later changed its address to that of a different residential property located in London, United Kingdom. Its director, as listed in its corporate filings, is a U.S. resident. Its controlling shareholder is Omni Group Limited, which is owned by Phillip Peikos, who resides in the United States. At times material to this Complaint, Apex Capital Group, Phillip Peikos, and David Barnett have used Interzoom Capital Solutions Limited to sell products to U.S.-based consumers, to debit U.S. consumers’ credit cards and financial accounts, to open merchant accounts through which these charges are processed, and to distribute the sales proceeds to Apex Capital Group, Phillip Peikos, and David Barnett. At least six merchant accounts have been established at a Latvian bank in the name of Interzoom Capital Limited to process payments for online sales of products to consumers in the United States.
Lead Blast Limited is a United Kingdom limited company. In its corporate filings, it initially provided as an office address the address of a residential property located in Bedford, United Kingdom, and later changed its address to that of a virtual office in London, United Kingdom. Its director, as listed in its corporate filings, is a U.S. resident. Its sole shareholder is Omni Group Limited, which is owned by Phillip Peikos, who resides in the United States. At times material to this Complaint, Apex Capital Group, Phillip Peikos, and David Barnett have used Lead Blast Limited to sell products to U.S.-based consumers, to debit U.S. consumers’ credit cards and financial accounts, to open merchant accounts through which these charges are processed, and to distribute the sales proceeds to Apex Capital Group, Phillip Peikos, and David Barnett. At least one merchant account has been established at a Latvian bank in the name of Lead Blast Limited to process payments for online sales of products to consumers in the United States.
Mountain Venture Solutions Limited is a United Kingdom limited company. In its corporate filings, it initially provided as an office address the address of a residential property located in Bedford, United Kingdom, and later changed its address to that of a virtual office in London, United Kingdom. Its director, as listed in its corporate filings, is a U.S. resident. Its sole shareholder is Omni Group Limited, which is owned by Phillip Peikos, who resides in the United States. At times material to this Complaint, Apex Capital Group, Phillip Peikos, and David Barnett have used Mountain Venture Solutions Limited to sell products to U.S.-based consumers, to debit U.S. consumers’ credit cards and financial accounts, to open merchant accounts through which these charges are processed, and to distribute the sales proceeds to Apex Capital Group, Phillip Peikos, and David Barnett. At least eight merchant accounts have been established at a Latvian bank in the name of Mountain Venture Solutions Limited to process payments for online sales of products to consumers in the United States.
Nutra Global Limited is a United Kingdom limited company. In its corporate filings, it initially provided as an office address the address of a residential property located in Bedford, United Kingdom, and later changed its address to that of a virtual office in London, United Kingdom. Its director, as listed in its corporate filings, is a U.S. resident. Its sole shareholder is Omni Group Limited, which is owned by Phillip Peikos, who resides in the United States. At times material to this Complaint, Apex Capital Group, Phillip Peikos, and David Barnett have used Nutra Global Limited to sell products to U.S.-based consumers, to debit U.S. consumers’ credit cards and financial accounts, to open merchant accounts through which these charges are processed, and to distribute the sales proceeds to Apex Capital Group, Phillip Peikos, and David Barnett. At least one merchant account has been established at a Latvian bank in the name of Nutra Global Limited to process payments for online sales of products to consumers in the United States.
Rendezvous IT Limited is a United Kingdom limited company. In its corporate filings, it initially provided as an office address the address of a residential property located in Bedford, United Kingdom, and later changed its address to that of a virtual office in London, United Kingdom. Its sole shareholder is Omni Group Limited, which is owned by Phillip Peikos, who resides in the United States. At times material to this Complaint, Apex Capital Group, Phillip Peikos, and David Barnett have used Rendezvous IT Limited to sell products to U.S.-based consumers, to debit U.S. consumers’ credit cards and financial accounts, to open merchant accounts through which these charges are processed, and to distribute the sales proceeds to Apex Capital Group, Phillip Peikos, and David Barnett. At least one merchant account has been established at a Latvian bank in the name of Rendezvous IT Limited to process payments for online sales of products to consumers in the United States.
Sky Blue Media Limited is a United Kingdom limited company. In its corporate filings, it initially provided as an office address the address of a residential property located in Bedford, United Kingdom, and later changed its address to that of a different residential property located in London, United Kingdom. Its controlling shareholder is Omni Group Limited, which is owned by Phillip Peikos who resides in the United States. At times material to this Complaint, Apex Capital Group, Phillip Peikos, and David Barnett have used Sky Blue Media Limited to sell products to U.S.-based consumers, to debit U.S. consumers’ credit cards and financial accounts, to open merchant accounts through which these charges are processed, and to distribute the sales proceeds to Apex Capital Group, Phillip Peikos, and David Barnett. At least eight merchant accounts have been established at a Latvian bank in the name of Sky Blue Media Limited to process payments for online sales of products to consumers in the United States.
Tactic Solutions Limited is a United Kingdom limited company. In its corporate filings, it initially provided as an office address the address of a residential property located in Bedford, United Kingdom, and later changed its address to that of a different residential property located in London, United Kingdom. Its director, as listed in its corporate filings, is a U.S. resident. Its controlling shareholder is Omni Group Limited, which is owned by Phillip Peikos, who resides in the United States. At times material to this Complaint, Apex Capital Group, Phillip Peikos, and David Barnett have used Tactic Solutions Limited to sell products to U.S.-based consumers, to debit U.S. consumers’ credit cards and financial accounts, to open merchant accounts through which these charges are processed, and to distribute the sales proceeds to Apex Capital Group, Phillip Peikos, and David Barnett. At least eight merchant accounts have been established at a Latvian bank in the name of Tactic Solutions Limited to process payments for online sales of products to consumers in the United States.
Capstone Capital Solutions Limited, Clik Trix Limited, Lead Blast Limited, Empire Partners Limited, Interzoom Capital Limited, Mountain Venture Solutions Limited, Nutra Global Limited, Rendezvous IT Limited, Sky Blue Media Limited, and Tactic Solutions Limited, are collectively referred to herein as the “UK Corporate Defendants.”
Defendant Phillip Peikos (“Peikos”) resides in Westlake Village, California. He is the Chief Executive Officer and co-owner of Apex Capital Group and the sole shareholder and director of Omni Group Limited, which is the sole or controlling shareholder of all of the UK Corporate Defendants. At all times material to this Complaint, acting alone or in concert with others, he has formulated, directed, controlled, had the authority to control, or participated in the acts and practices of Apex Capital Group, Omni Group Limited, and the UK Corporate Defendants, including the acts and practices set forth in this Complaint. Defendant Peikos resides in this district and, in connection with the matters alleged herein, transacts or has transacted business in this district and throughout the United States.
Defendant David Barnett (“Barnett”) is a California resident. He was the Chief Operating Officer of Apex Capital Group. He was a co-owner of Apex Capital Group until at least late 2017. He was also an owner and director of Omni Group Limited until November 2017, when he transferred his shares to Peikos. At times material to this Complaint, acting alone or in concert with others, he formulated, directed, controlled, had the authority to control, or participated in the acts and practices of Apex Capital Group, Omni Group Limited, and the UK Corporate Defendants, including the acts and practices set forth in this Complaint. Defendant Barnett resides in California and, in connection with the matters alleged herein, transacts or has transacted business in this district and throughout the United States.
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