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part one/ UNITED STATES DISTRICT COURT/ Case 1:10-cv-23513-XXXX Document 1 Entered on FLSD Docket 09/30/2010 Page 1 of 16
SOUTHERN DISTRICT OF FLORIDA
CASE NO.
SECURITIES AND EXCHANGE COMMISSION, )
)
Plaintiff, )
v. )
)
QURI RESOURCES, INC. and )
JAIME SANTIAGO GOMEZ, )
)
Defendants. )
)

http://www.sec.gov/litigation/complaints/2010/comp21675.pdf

COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF
Plaintiff Securities and Exchange Commission alleges:
INTRODUCTION
1. Quri Resources, Inc. and its CEO and president, Jaime Santiago Gomez,
orchestrated a "pump-and-dump" stock fraud scheme by issuing false and misleading press
releases that artificially inflated Quri's stock price. Through a company he controlled, Gomez
sold more than half a million shares of Quri stock at these inflated prices.
2. From February to July 2009, Quri and Gomez issued a series of false and
misleading press releases about Quri's ownership and development of four mining projects in
Ecuador and Arizona. In these press releases, Quri falsely claimed the company: was ready to
drill at a mine in Ecuador that had a probable gold reserve worth more than $1 billion; had
signed letters of intent to acquire valuable mining projects in Arizona and Ecuador; and had
acquired a mining project in Ecuador that, within three months, would produce at least $100,000
worth of gold per month.
3. Among other things, Quri misrepresented in the press releases the value of the
Case 1:10-cv-23513-XXXX Document 1 Entered on FLSD Docket 09/30/2010 Page 1 of 16
assets it was claiming it had purchased, the status of its ownership claims, and the potential
revenue it could realize from the mining projects. In virtually every case, Quri omitted to
mention that it had no funds or reasonable prospect of funds needed to develop the mining
projects so they could realize anyrevenue.
4. Gomez also authored Quri's internet website and approved its profile on the social
network website LinkedIn. These falsely described Quri as having ongoing operations, 28
employees worldwide, a geologist with a PhD on staff, and an impressive management team led
by Gomez, a college graduate. None ofthese claims were true.
5. Gomez took advantage of the inflated price and trade volume the press releases
created by selling 690,000 Quri shares.from the account of another company he controlled. The
sale of these shares from March to July 2009 involved transactions improperly not registered
with the Commission. Quri realized approximately $27,100 from these particular sales, of which
Gomez received at least $17,500.
6. No registration statement was ever filed with the Commission or in effect for any
class of Quri shares, and there was no exemption from the registration requirements for Gomez's
stock sales.
7. Through their conduct, Quri and Gomez violated Section 1O(b) of the Securities
Exchange Act of 1934 ("Exchange Act"), 15 U.S.c. § 78j(b), and Exchange Act Rule 10b-5, 17
C.F.R. § 240.lOb-5. In addition, Gomez violated Sections 5(a), 5(c), and 17(a) of the Securities
Act of 1933 ("Securities Act"), 15 U.S.c. §§ 77e(a), 77e(c), and 77q(a), Unless the Court
enjoins the Defendants, they are reasonably likely to continue to violate these provisions of the
federal securities laws.
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DEFENDANTS
8. Quri is incorporated in Delaware, with its principal places of business in Miami,
Florida and Quito, Ecuador. Quri purports to be a gold, silver, and copper exploration and
mining company. Its stock is quoted on the Pink Sheets, operated by Pink aTC Markets Inc.
under the ticker symbol "QURS." Before July 21, 2009, the stock traded under the symbol
"QURI." Quri was previously named Transoft Technologies, Inc.
9. Gomez, 46, is a resident of Miami, Florida and Quito, Ecuador. He was Quri's
president at all relevant times. In 1993, the Commission barred Gomez from association with
any broker, dealer, municipal securities dealer, investment company or investment adviser.
RELEVANT ENTITY
10. G&G Mining Corp. is a private, non-reporting company, incorporated in Florida,
with its former principal place ofbusiness located in Miami, Florida. Gomez formed, controlled,
and managed G&G through a family friend and family members who held the titles of president
and directors. Gomez sold Quri shares and received sales· proceeds through an account in
G&G's name. During the relevant time period, G&G purported to be a mining company.
JURISDICTION AND VENUE
11. The Court has jurisdiction over this action pursuant to Sections 20(b), 20(d),
20(g), and 22(a) of the Securities Act, 15 U.S.c. §§ 77t(b), 77t(d), 77t(g), and 77v(a); and
Sections 21(d), 2I(e), and 27 ofthe Exchange Act, 15 U.S.c. §§ 78u(d), 78u(e), and 78aa.
12. This Court has personal jurisdiction over the Defendants, and venue is proper in
the Southern District of Florida because many of the Defendants' acts and transactions
constituting violations of the Securities Act and the Exchange Act occurred in the Southern
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District. In addition, at all relevant times, Quri's principal place of business was in the Southern
District, and Gomez resided in the District.
13. In connection with the conduct alleged in this Complaint, the Defendants, directly
and indirectly, singly or in concert with others, have made use of the means or instrumentalities
of interstate commerce, the means or instruments of transportation and communication in
interstate commerce, and the mails.
DEFENDANTS' PUMP-AND-DUMP SCHEME
A. Ouri's Business
14. Quri purports to be a gold, silver and copper exploration and mining company
with mining properties in various stages of exploration in Ecuador and the United States. Gomez
was the only Quri employee in the United States.
15. Gomez became president ofQuri in January 2009. He was involved in all aspects
of Quri's business including: evaluating potential mining properties; negotiating and signing
letters of intent to acquire mining properties; entering into service and consulting contracts;
seeking financing; handling creditors' requests for payment; and communicating with investors
and the public about Quri's business. He wrote the content for Quri's website and drafted and
issued press releases.
B. Quri's False and Misleading Press Releases
1. The Wellington Project Press Releases
16. On February 11, 2009, Quri and Gomez issued two press releases falsely touting
the imminent development of the Wellington Project, a gold mine in Ecuador. Both press
releases falsely represented the Wellington Project was in the "last phases of exploration" and
that Quri "was ready to begin a 16,000-meter drilling program to prove its resources."
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