Therapeutic Solutions International Inc (TSOI)

[Rymung]

Let’s continue where we left off reviewing Tim Dixon’s SDSC Plaintiffs v DOES 1-50 declaration…

“24. On approximately August 23, 2021, a group of usernames and/or screen names, including DOES 1-7, began posting on the StockTwits.com (“StockTwits”) web page for TSOI. This group began promoting TSOI as the next best thing. These posts lasted several days.
25. However, the positive posts quickly became negative and defamatory. On September 27, 2021, a poster who now goes by the screen name DOE 2 “Slumboar” posted a single post that said, “Yo Tim, Screw your forum.” This is strangely close in time to when Dr. Ricordi and UM began realizing there was an issue with the IND and their rights.
26. This “Slumboar” screenname changes his screenname every couple of weeks and will likely change again before this cause of action is filed. From September 27, 2021, to present, “Slumboar” has attacked Plaintiffs and other TSOI personnel at a rate of approx. 40-50 posts on Stocktwits.com per day, with a running count of over 40,000 negative posts.
27. DOE 3 “Rosiebelle” and DOE 1 “CEOTimDixonIsAFraud” also began the same type of attack on TSOI to present, each of them also making tens of thousands of negative posts regarding Dixon, Ichim, and TSOI. By October 2021, all of DOES 1-7 were actively using the TSOI forum on Stocktwits.com and making defamatory and libelous statements against Plaintiffs.
28. Through these posts, DOES 1-7 accused TSOI of being a scam and fraudulent, attacked QuadraMune®, and accused Dr. Ichim and Mr. Dixon of being liars, thieves, and cocaine addicts. These posts also accused Dixon and Ichim of committing illegal acts. As an example, several posts accused Ichim and Dixon of secretly dumping millions of shares without reporting those stock sales as they are required to do under SEC rules. The fact is that Mr. Dixon last sold stock in 2014 and Dr. Ichim has not personally sold a single share of his holdings. There is a public record to that effect. Examples of the defamatory posts are referenced in this Complaint and are contained in Exhibits 1-7.
29. On October 17, 2021, TSOI stock was $0.04.
30. From at least October 16, 2021, to the date of the filing of Plaintiffs’ Complaint,
DOES 1- 20 posted negative comments about Plaintiffs and others. These posts accused
TSOI of being a scam, and that Dixon and others were liars, thieves, and frauds. Additionally,
the posts accused Dixon of secretly dumping millions of shares without reporting those stock
sales as he is required to do under SEC rules.
31. In late November of 2021 TSOI became aware of an Inter Parties Review (“IPR”) filed on September 29, 2021, with Patent Trial Appeals Board (“PTAB”) of the US Patent and Trademark Office in Restem LLC v. Jadi Cell, LLC Case # IPR2021-01535 through a social media post. Jadi Cell LLC, by virtue of the exclusive, worldwide, Patent License Agreement (“EPLA”) effective since February 9, 2021, had an obligation to inform TSOI of any challenges to the patent underlying EPLA, yet failed to do so for months after the filing of the IPR by Appellant Restem. The IPR was filed just two days after “Slumboar” posted his “Yo Tim, Screw your forum” post on September 27, 2021, and on information and belief, TSOI believes and thereon alleges that there is direct connection.
32. On October 17, 2022, the stock price for TSOI closed at $0.0102.
33. From October 17, 2022, the false, libelous, and defamatory posts on the
various platforms, including Stocktwits.com continued.
34. As of October 16, 2023, TSOI’s stock is trading at approximately $0.0015, and it has lost over $95,000,000 in market cap since October 2021.
35. From October 16, 2021 to October 16, 2023, revenue from QuadraMune® decreased from approximately to $203,951.00 to $95,208.00.
D. THE POSTS HAVE BEEN AND ARE UNTRUE.
36. The statements made by DOES 1-20 are untrue. There are hundreds of examples of defamatory statements made by DOES 1-20 through the relevant period, October 2021 through the date of the Complaint’s filing. Exhibits 1-7 contain examples of the defamatory statements that were published on the TSOI forum within at https://stocktwits.com/symbol/TSOI.”

https://roa.sdcourt.ca.gov/roa/faces/CaseSearch.xhtml

SDSC of California
2023 case# 00045520