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To lure Mozido into their trap, defendants touted their contacts and presence in the Chinese market, representing that they had exclusive contracts with the owners of 477 shopping malls in China where Mozido’s mobile payment products could be deployed. Defendants also represented that they had an exclusive contract, as well as a close personal and business relationship with Neusoft, the largest provider of IT solutions and services in China, that would deliver 100 million new Chinese customers to Mozido.

In attempting to convince Mozido that their fraudulent representations were in fact true, defendants went to extraordinary lengths, including forging the signature of Neusoft’s Chairman and CEO on legally binding documents, and having an imposter pose as Neusoft’s Chairman and CEO in a critical conference call with Mozido executives. The defendants’ elaborate scheme worked, and they ultimately convinced Mozido to lend them $6.5 million as part of the broader promised business relationship with Neusoft that they had no intention of repaying and for which they pledged functionally worthless collateral in the form of securities.