PCT Ltd (PCTL)

[beer$$money]

LOL PCTL Complaint against Defendant Auctus Fund, LLC

The PCT Settlement Obligations were fully satisfied by PCT.
Auctus Fund has breached the Settlement Agreement.
Auctus Fund made certain false representations to PCT’s transfer agent.
Shares fraudulently obtained by Auctus Fund through its unlawful exercise of the Warrant.
PCT has been, and continues to be, damaged by Auctus Fund’s blatant
breaches of its contractual obligations and unlawful conduct.

COUNT ONE (Breach of Contract) Auctus Fund has refused, and continues to refuse, to execute and return to PCT the Mutual Release in breach of its contractual obligations under Section 3 of the Settlement Agreement.

COUNT TWO (Breach of Implied Covenant of Good Faith and Fair Dealing)
Auctus Fund has refused to execute and deliver the Mutual Release to PCT.
Such conduct has been done in bad faith, inconsistent with the parties’
reasonable expectations under the Settlement Agreement.

COUNT THREE (Reformation of Mutual Release)
PCT and Auctus Fund “have agreed to enter into this [Settlement] Agreement in order to effect a full settlement of any claims each may have against the other and to fully release one another” and “intend to settle and finally resolve any and all claims. Specifically, the Mutual Release, as originally drafted by counsel for
Auctus Fund.

COUNT FOUR (Fraud)
Auctus Fund presented the Warrant to PCT’s transfer agent, Standard Registrar, under the false pretense that the Warrant was still a valid and legally binding instrument.

COUNT FIVE (Conversion)
Auctus Fund, through wrongful means, has taken and exercised
unauthorized possession and control over 2,593,999 shares of PCT common stock.
Such unlawful conduct on the part of Auctus Fund was intentional,
malicious, and done in bad faith, sufficient to entitle PCT to an award of punitive
damages pursuant to N.R.S. 42.005 in an amount no less than $300,000.00.


COUNT SIX (Unjust Enrichment)
Auctus Fund received 2,539,999 shares of PCT common stock, with a value of approximately $65,000.00, based upon its material and intentional misrepresentations of fact concerning the validity of the Warrant.