III. FACTUAL ALLEGATIONS COMMON TO ALL CLAIMS
24 32. Beginning in early June 2025, GTSM repeatedly engaged in dual-side
25 spoofing, flashing large bid and ask sizes without execution intent. In the June 23, 2025
26 recording, GTSM’s bid at $0.0306 rapidly jumped from 154,000 to 224,000 shares
27 within seconds—yet no corresponding trades executed against this liquidity.
28 Simultaneously, NITE adjusted its ask levels in rapid succession (e.g., $0.0332 during
frames 94–145s), -6-
Case 2:26-cv-00175 Document 1 Filed 01/07/26 Page 6 of 39 Page ID #:6
1 repeatedly blocking upward movement while pulling its quote the moment buyers
2 approached.
3 33. During June and July 2025—a period marked by increased retail interest,
4 expanded corporate disclosures by AABB, and heightened trading volume—Defendants
5 GTSM and NITE executed a concentrated campaign of manipulative trading designed to
6 suppress the price of AABB common stock. Across multiple Level-2 video recordings,
7 Defendants’ activity in this period represents one of the clearest and most egregious
8 clusters of spoofing, bid layering, wash trading, and collusive order-book behavior in the
9 Class Period.
10 34. Across hundreds of sessions, Defendants repeatedly inundated the Level-2
11 order book with large bursts of non-bona fide orders—often flashing hundreds of
12 thousands of shares at multiple price levels—only to cancel them when the price
13 approached or buying pressure emerged. These “Spoofing Episodes” occurred throughout
14 the Class Period, frequently multiple times per hour.
15 35. Defendants placed these spoofing and layered orders either (a) for their own
16 proprietary benefit, or (b) while knowingly or recklessly facilitating manipulative trades
17 from affiliated accounts or coordinated traders. Their high-frequency systems allowed
18 real-time alterations of displayed depth, enabling Defendants to exploit microsecond
19 reaction times unavailable to ordinary investors.
20 36. Defendants intensified these tactics into July 2025. In the July 2025 video,
21 GTSM repeatedly adjusted its bid at $0.0262, increasing its displayed size from 16,000
22 to 50,000 shares during volume builds at approximately 56,000 shares—only to pull
23 back entirely once the upward pressure subsided. NITE simultaneously layered asks in
24 the $0.0294–$0.0300 range, padding resistance levels and preventing natural price
25 discovery.
26 37. These June–July 2025 sequences illustrate a coordinated strategy: Defendants
27 repeatedly built multi-level spoofing structures on both sides of the book, synchronized their layer
rotations, injected artificial selling and resistance behavior through wash trades, and reversed
28
upward momentum during critical periods of natural demand.
-7-
Case 2:26-cv-00175 Document 1 Filed 01/07/26 Page 7 of 39 Page ID #:7
1 38. This June–July 2025 cluster a broader pattern repeating across the Class
2 Period: Defendants achieved short-term and long-term control of the Level-2 environment
3 through spoofing, wash trading, and bid layering, thereby suppressing AABB’s market
4 price for their own financial advantage.
5 39. In December 2025, Defendants GTSM and NITE engaged in another intense
6 cluster of spoofing, bid layering, and coordinated wash trading, as captured in multiple pre7 market and intraday Level-2 videos. This period reflects one of the most blatant and synchronized
8 sequences of manipulation in the Class Period, marked by rapid quote flashing, artificial depth
9 creation, and dual-side suppression tactics.
10 40. In the December 2025 pre-market video, GTSM repeatedly flashed large
11 bid sizes—most notably increasing its displayed interest at $0.0131 from 10,000 shares
12 to over 100,000 shares within seconds—despite no corresponding execution interest.
13 These bid flashes appeared moments before clusters of micro-sell prints (e.g., 23-share, 47-
14 share, and 100-share lots at $0.0139), suggesting coordinated efforts to create the
15 appearance of steady selling pressure.
16 41. During this same period, GTSM engaged in ask-side spoofing by
17 flashing 20,000-share walls at $0.0147 and $0.0200, which evaporated immediately
18 upon the approach of buying activity. The fleeting nature of these orders confirms they
19 existed only to cap upward momentum during a period where AABB otherwise
20 exhibited natural buying strength.
21 42. GTSM acted in close coordination with NITE throughout this pre-market
22 sequence. GTSM frequently layered bids in the $0.0131–$0.0134 band, while also
23 flashing asks in the $0.0144–$0.0148 range, mirroring NITE’s rotations. These
24 synchronized adjustments created a persistent artificial ceiling, preventing price elevation
25 beyond short-term micro-bounces.
26 43. The December 2025 intraday video reveals an even more aggressive pattern.
27 In the opening minutes, GTSM’s bid at $0.0136 spikes from 100,000 to 200,000
28 shares despite minimal genuine sell-side pressure, and yet executes almost no volume
at those -8-
Case 2:26-cv-00175 Document 1 Filed 01/07/26 Page 8 of 39 Page ID #:8
1 levels. This confirms the orders were non-genuine and intended solely to manipulate
2 perceived depth.
3 44. As a result of Defendants’ manipulative conduct during December 2025,
4 AABB experienced sharp, repeated intraday reversals and failed breakouts that were
5 inconsistent with normal market dynamics. These effects directly harmed AABB by:
6 ? depressing market price during periods of natural demand,
7 ? distorting the perceived risk profile and liquidity of AABB stock,
8 ? suppressing valuation critical to financing negotiations, and
9 ? impairing the Company’s ability to raise capital under fair, non-manipulated
10 conditions.
11 45. The December 2025 sequences further illustrate the persistent pattern of
12 collusion between GTSM and NITE, the use of advanced HFT-style quoting tactics to
13 manipulate price, and the ongoing deployment of spoofing and wash trading to distort the
14 market for AABB common stock.
15 46. A third major cluster of manipulative trading occurred between July 2025
16 and late December 2025, during which GTSM and NITE intensified their coordinated
17 suppression of AABB’s market price. This period includes the July 2025 Level-2 video,
18 the December 2025 pre-market footage, and the December 2025 intraday session—each
19 demonstrating the same hallmark patterns of quote manipulation, layering, and artificial
20 selling pressure.
21 47. In the July 2025 video, NITE repeatedly manipulated the lower bid band at
22 $0.0262, oscillating its displayed size from 16,000 to 50,000 shares during modest volume
23 surges (~56,000 shares). These adjustments were not tied to legitimate supply; rather, they
24 were timed perfectly to fade upward momentum and induce micro-reversals. GTSM
25 simultaneously reinforced these suppressive tactics by layering asks in the $0.0294–
26 $0.0300 range, padding overhead resistance and preventing the price from breaking above
27 natural buying pressure.
28 48. The pattern resurfaced—more aggressively—in the December 2025 preCase 2:26-cv-00175 Document 1 Filed 01/07/26 Page 9 of 39 Page ID #:9
1 market session, where GTSM flashed large bids at $0.0131 (including bursts to 100,000
2 + shares) only to withdraw them instantly as the price approached. These spoofed bids
3 were paired with synchronous ask flashes at $0.0144–$0.0148, creating a tightly
4 controlled artificial channel that forced price stagnation and discouraged legitimate
5 counterparties from trading into the manipulated book.
6 49. NITE played an active role in maintaining these channels by repeatedly
7 layering bid stacks in the $0.0131–$0.0135 band and ask walls in the $0.0144–$0.0150
8 band. These layers collapsed or vanished as soon as the market probed for execution—
9 confirming they served no economic purpose other than to signal false depth.
10 50. The December 2025 intraday video revealed even clearer evidence of
11 coordinated manipulation. GTSM dramatically increased its displayed bid at $0.0136
12 from 100,000 to 200,000 shares, despite minimal actual sell volume at that level. These
13 bids evaporated seconds later, demonstrating they were spoofed solely to absorb
14 upward pressure and redirect momentum downward.
15 51. Simultaneously, GTSM orchestrated a series of rapid-fire ask-layer
16 flashes—each in the 50,000 to 100,000 share range—strategically timed to coincide with
17 buying attempts. These flashes artificially capped the price and were withdrawn at the
18 moment buying interest subsided. This “probe-and-fade” technique is a common spoofing
19 hallmark used by high-frequency traders to mislead investors about market strength.
20 52. Tape analysis from this July–December period further reveals a high
21 incidence of wash trades, including multiple examples of identical share quantities
22 executing at identical timestamps with no intervening third-party prints. These synthetic
23 prints created manufactured volume, amplified the illusion of persistent selling pressure,
24 and contributed to Defendants’ scheme to depress AABB’s price.
25 53. Despite positive Company developments during this period—including
26 sustained digital-asset development, operational updates from mining activity, and
27 increased retail investor engagement—the market repeatedly failed to reflect organic
28 demand. Instead, AABB experienced forced reversals, failed breakouts, and prolonged
Case 2:26-cv-00175 Document 1 Filed 01/07/26 Page 10 of 39 Page ID #:10
1 price suppression directly correlated with bursts of spoofing and wash trading by
2 GTSM and NITE.
3 54. The combined July–December 2025 cluster demonstrates a consistent
4 pattern: Defendants systematically manipulated both sides of the book, deployed non5 bona fide orders, and coordinated wash trades to distort the true buying and selling
6 interest in AABB. These practices materially harmed AABB by suppressing valuation,
7 reducing liquidity, impairing financing opportunities, and deterring natural market
8 participants.
9 55. Viewed collectively, the patterns in July 2025, December 2025 pre-market, and
10 December 2025 intraday recordings confirm Defendants’ sustained and intentional manipulation
11 of AABB’s market price, with effects that extended far beyond isolated sessions and permeated
12 the entire trading period.
13 56. In reality, Defendants’ malfeasance dates back to 2021 and Plaintiff has the
14 historical data to back it up. In subsequent pleadings Plaintiff is prepared to show long-term
15 quantitative data that exhibits what is explained in detail below. Defendants’ engaged in a
16 structured, coordinated effort to collude and manipulate the Plaintiff’s stock. This was a multi17 year structural shorting/suppression scheme conducted by the same small group of market makers
18 handling the most volume of the trading.
19 Statement 1: Early June 2025 GTSM Dual-Side Spoofing
20 57. Beginning in early June 2025, GTSM repeatedly engaged in dual-side spoofing,
21 flashing large bid and ask sizes without execution intent. In the June 23, 2025 recording [Exhibit
22 1], NITE’s bid at $0.0306 rapidly jumped from 154,000 to 224,000 shares within seconds—yet
23 no corresponding execution occurred against this liquidity. Simultaneously, NITE adjusted its ask
24 levels in rapid succession (e.g., $0.0332 during frames 94–145s), repeatedly blocking upward
25 movement while pulling its quote the moment buyers approached.
26 Statement 2: June and July 2025 Coordinated Suppression by GTSM and
27 NITE
28 58. During June and July 2025—a period marked by increased retail interest,
Case 2:26-cv-00175 Document 1 Filed 01/07/26 Page 11 of 39 Page ID #:11
1 expanded corporate disclosures by AABB, and heightened trading volume—Defendants
2 GTSM and NITE executed a concentrated campaign of manipulative trading designed to
3 suppress the price of AABB common stock. Across multiple Level-2 video recordings [Exhibits
4 2, 3, 4, 5, 6, 7], Defendants’ activity in this period represents one of the clearest and most
5 egregious clusters of spoofing, bid layering, wash trading, and collusive order-book behavior in
6
the Class Period.
7
Statement 3: July to December 2025 Intensified Manipulation Cluster
59. A third major cluster of manipulative trading occurred between July 2025 and late
8
9 December 2025, during which GTSM and NITE intensified their coordinated suppression
10 of AABB’s market price. This period includes the July 2025 Level-2 video [Exhibit 7],
11 the December 2025 pre-market footage [Exhibit 15], and the December 2025 intraday
12 session [Exhibit 16]—each demonstrating the same hallmark patterns of quote manipulation,
13 layering, and artificial selling pressure.
14 Statement 4: Non-Bona Fide Orders and Spoofing Episodes Across Sessions
15 60. Across hundreds of sessions, Defendants repeatedly inundated the Level-2 order
16
17 book with large bursts of non-bona fide orders—often flashing hundreds of thousands of shares at
18 multiple price levels—only to cancel them when the price approached or buying pressure
19 emerged. These “Spoofing Episodes” occurred throughout the Class Period, frequently multiple
20 times per hour, as documented in the June to December 2025 recordings [Exhibits 1–20].
21 Statement 5: Defendants' Proprietary or Facilitated Manipulative
22 Trades
23 61. Defendants placed these spoofing and layered orders either (a) for their own
24 proprietary benefit, or (b) while knowingly or recklessly facilitating manipulative trades from
25 affiliated accounts or coordinated traders. Their high-frequency systems allowed real-time
26 alterations of displayed depth, enabling Defendants to exploit microsecond reaction times
27 unavailable to ordinary investors, as seen in the coordinated quote behaviors across the reviewed
28 sessions [Exhibits 1–20].
Case 2:26-cv-00175 Document 1 Filed 01/07/26 Page 12 of 39 Page ID #:12
1 Statement 6: Intensified Tactics in July 2025
2 62. Defendants intensified these tactics into July 2025. In the July 2025 video [Exhibit
3 7], GTSM repeatedly adjusted its bid at $0.0262, increasing its displayed size from 16,000
4 to 50,000 shares during volume builds at approximately 56,000 shares—only to pull back
5 entirely once the upward pressure subsided. NITE simultaneously layered asks in the $0.0294–
6 $0.0300 range, padding overhead resistance and preventing natural price discovery.
7 Statement 7: Coordinated Strategy in June–July 2025
8 63. These June–July 2025 sequences illustrate a coordinated strategy: Defendants
9 repeatedly built multi-level spoofing structures on both sides of the book, synchronized their layer
10 rotations, injected artificial selling and resistance behavior through wash trades, and reversed
11 upward momentum during critical periods of natural demand, as evidenced in the analyzed
12 recordings [Exhibits 2–7].
13 Statement 8: December 2025 Intensified Spoofing and Layering by
14 GTSM and NITE
15 64. In December 2025, Defendants GTSM and NITE engaged in another intense
16 cluster of spoofing, bid layering, and coordinated wash trading, as captured in multiple pre17 market and intraday Level-2 videos [Exhibits 15, 16, 19]. This period reflects one of the most
18 blatant and synchronized sequences of manipulation in the Class Period, marked by rapid quote
19 flashing, artificial depth creation, and dual-side suppression tactics.
20 Statement 9: December 2025 Pre-Market Bid Spoofing by GTSM
21 65.In the December 2025 pre-market video [Exhibit 15], GTSM repeatedly flashed
22
23 large bids at $0.0131 (including bursts to 100,000+ shares) only to withdraw them instantly as the
24 price approached. These spoofed bids were paired with synchronous ask flashes at $0.0144–
25 $0.0148, creating a tightly controlled artificial channel that forced price stagnation and
26 discouraged legitimate counterparties from trading into the manipulated book.
27 Statement 10: GTSM Coordination with NITE in December 2025 Pre28 Market
Case 2:26-cv-00175 Document 1 Filed 01/07/26 Page 13 of 39 Page ID #:13
1 66. GTSM acted in close coordination with NITE throughout this pre-market sequence
2 [Exhibit 15]. GTSM frequently layered bids in the $0.0131–$0.0134 band, while also flashing
3 asks in the $0.0144–$0.0148 range, mirroring NITE’s rotations. These synchronized adjustments
4 created a persistent artificial ceiling, preventing price elevation beyond short-term micro-bounces.
5 Statement 11: December 2025 Intraday Bid Spoofing by GTSM
6 67. The December 2025 intraday video [Exhibit 16] reveals an even more aggressive
7 pattern. In the opening minutes, GTSM dramatically increased its displayed bid at $0.0136
8 from 100,000 to 200,000 shares, despite minimal actual execution at that level. These bids
9 executed almost no volume and were withdrawn seconds later, demonstrating they were spoofed
10 solely to absorb upward pressure and redirect momentum downward.
11 Statement 12: GTSM Ask Spoofing in December 2025 Intraday
12 68. Simultaneously in the December 2025 intraday session [Exhibit 16], GTSM
13
14 orchestrated a series of rapid-fire ask-layer flashes—each in the 50,000 to 100,000 share range—
15 strategically timed to coincide with buying attempts. These flashes artificially capped the price
16 and were withdrawn at the moment buying interest subsided. This “probe-and-fade” technique is
17 a common spoofing hallmark used by high-frequency traders to mislead investors about market
18 strength.
19 Statement 13: Wash Trades in July–December 2025
20 69. Tape analysis from this July–December period further reveals a high incidence of
21 wash trades, including multiple examples of identical share quantities executing at identical
22 timestamps with no intervening third-party prints. These synthetic prints created manufactured
23 volume, amplified the illusion of persistent selling pressure, and contributed to Defendants’
24 scheme to depress AABB’s price, as documented in the analyzed sessions [Exhibits 7, 15, 16].
25 Statement 14: Impact of Manipulation on AABB During July–December 2025
26 70. Despite positive Company developments during this period—including sustained
27
28 digital-asset development, operational updates from mining activity, and increased retail investor
Case 2:26-cv-00175 Document 1 Filed 01/07/26 Page 14 of 39 Page ID #:14
1 engagement—the market repeatedly failed to reflect organic demand. Instead, AABB experienced
2 sharp, repeated intraday reversals and failed breakouts that were inconsistent with normal market
3 dynamics, as shown in the July 2025 video [Exhibit 7], the December 2025 pre-market footage
4 [Exhibit 15], and the December 2025 intraday session [Exhibit 16].
5 Statement 15: Harm to AABB from Defendants' Conduct
6 71. These manipulative practices directly harmed AABB by: depressing market price
7 during periods of natural demand, distorting the perceived risk profile and liquidity of AABB
8 stock, suppressing valuation critical to financing negotiations, and impairing the Company’s
9 ability to raise capital under fair, non-manipulated conditions, as evidenced across the June to
10 December 2025 recordings [Exhibits 1–20].
11 Statement 16: Consistent Pattern in December 2025 Sessions
12 72. The December 2025 sequences further illustrate the persistent pattern of collusion
13 between GTSM and NITE, the use of advanced HFT-style quoting tactics to manipulate price,
14 and the ongoing deployment of spoofing and wash trading to distort the market for
15 AABB common stock, as captured in the pre-market and intraday sessions [Exhibits 15, 16].
16 Statement 17: Combined July–December 2025 Cluster of Manipulation
17 73. The combined July–December 2025 cluster demonstrates a consistent pattern:
18
19 Defendants systematically manipulated both sides of the book, deployed non-bona fide
20 orders, and coordinated wash trades to distort the true buying and selling interest in
21 AABB. These practices materially harmed AABB by suppressing valuation, reducing
22 liquidity, impairing financing opportunities, and deterring natural market participants, as
23 documented in the July 2025 video [Exhibit 7], the December 2025 pre-market footage [Exhibit
24 15], and the December 2025 intraday session [Exhibit 16].
25 Statement 18: Collective Impact Across Sessions
26 74. Viewed collectively, the patterns in July 2025, December 2025 pre-market, and
27 December 2025 intraday recordings confirm Defendants’ sustained and intentional manipulation
28 of AABB’s market price, with effects that extended far beyond isolated sessions and permeated
Case 2:26-cv-00175 Document 1 Filed 01/07/26 Page 15 of 39 Page ID #:15
1 the entire trading period, as evidenced in the analyzed exhibits [Exhibits 7, 15, 16].
Market Data 
Markets 
AI
