I just finished reading the complaint. It's pretty cut and dry.
EMA says it tried twice to convert outstanding debt into common stock as per the terms of the note, but VYST refused to honor the conversion, allegedly because honoring the conversion would provide EMA with "too great a profit"
So EMA is alleging breach of contract, due to VYST's refusal to honor the notices of conversion as per the terms of the note.
They also allege that VYST switched transfer agents recently, but didn't inform EMA as per the terms of the note.
Additionally, they claim that VYST has failed to maintain the required collateral shares with the transfer agent allow for the full conversion of the debt as per the terms of the note.
They're asking the court to order VYST to honor the terms agreed to in the note and hand over the shares they're owed (totaling roughly 26 million shares), unrestricted, so they can sell them whenever they wish..(the Court has granted EMA's 'Order to Show Cause' request which means VYST will be issued a summons to appear in court)
They're also seeking monetary damages of at least $4,226,187 with the final amount to be determined in court. They're also seeking compensation for their legal fees.
I think that mostly covers the pertinent points contained in the complaint.