Complaint Against Huang Huang Chen, John Does 1-10, Raj Suthar , Filed by MS2 Capital LLC. Service Due by 6/25/2026
NATURE OF THE ACTION
1This action arises from a calculated cryptocurrency fraud scheme through which Defendants stole approximately $3.7 million from Plaintiff. Acting in concert, Defendants induced Plaintiff to transfer Solana (“SOL”) cryptocurrency for purported cryptocurrency ventures that were never legitimately pursued.
2:26-cv-01319-RMG
2:26-cv-01319-RMG Date Filed 03/27/26 Entry Number 1 Page 1 of 31
2 of 31
2Every dollar Plaintiff transferred was immediately routed through ChangeNOW, a non- custodial cryptocurrency exchange favored by cybercriminals for its anonymity, in a laundering operation that Defendant Chen pre-configured before Plaintiff’s funds ever left its wallet.
3This scheme depended on trust and deception. Defendant Suthar cultivated a relationship of personal trust and confidence with Spruill in Charleston, South Carolina. When Suthar had earned Spruill's trust, he exploited it by introducing Spruill to various business ventures (e.g. HTTP, JPGdotfun, Myth, and others1) before introducing him to Defendant Chen.
4Upon information and belief, Defendant Chen operated anonymously under the Telegram handle @WeFreezeTime while publicly maintaining the well-known cryptocurrency persona @CookerFlips on X (formerly Twitter).
5@CookerFlips holds himself out as a crypto trader/influencer who goes by Cooker / Kms.eth and publicly describes himself as the founder of PastelAlpha. His posts center on crypto trading, Solana/memecoins, and sports/esports betting. He has appeared in crypto podcast interviews discussing trading and betting.
6Upon information and belief, @CookerFlips’ real name is Defendant Huang Huang Chen.
7Suthar vouched for Chen’s identity and credentials. In turn, Chen leveraged the reputation of @CookerFlips, with its 133,400 followers and association with the Pastel Alpha brand, to create an aura of legitimacy that induced Plaintiff to transfer millions of dollars in cryptocurrency. 1 Many of these projects were “memecoins.” A “memecoin” is a type of cryptocurrency token that derives its perceived value primarily from internet culture, social media hype, and community speculation rather than from any underlying technology, utility, or fundamental economic purpose. Memecoins are typically launched with minimal development effort and are highly susceptible to price manipulation. “JPGdotfun” was a non-fungible token exchange that never materialized.
2:26-cv-01319-RMG Date Filed 03/27/26 Entry Number 1 Page 2 of 31
3 of 31
8Within the very Telegram group through which the fraud was perpetrated, Chen (as @WeFreezeTime) repeatedly referenced “Pastel,” implying PastelAlpha, the cryptocurrency community exclusively operated by @CookerFlips, as his own community.
9Based on Suthar’s introduction and Chen’s fabricated venture proposals, Plaintiff transferred approximately $2.5 million to Chen and approximately $1.2 million directly to Suthar for related projects.
10None of these ventures materialized. None of these funds have been returned. Plaintiff’s total loss exceeds approximately $3.7 million.
11Plaintiff brings this action to recover its losses, to hold Defendants jointly and severally liable for fraud, conversion, civil conspiracy, and related claims, to obtain punitive damages, and to obtain emergency relief freezing Defendants’ assets, including on-chain cryptocurrency and real property acquired with the proceeds of the fraud, before those assets are further dissipated or concealed.
THE PARTIES
12C. Micah Spruill is an individual and citizen of the State of South Carolina, residing in Charleston, South Carolina. Spruill is the Managing Partner of Ms2 Capital, LLC.
13Plaintiff Ms2 Capital, LLC is a Georgia limited liability company with its principal place of business at 850 Morrison Drive, Suite 375, Charleston, South Carolina 29403. However, Plaintiff is a citizen of South Carolina for diversity purposes because its two members, C. Micah Spruill and his wife, are citizens of South Carolina.
14Defendant Raj Suthar (“Suthar”) is an individual, upon information and belief approximately 30 years of age, who formerly resided in Charleston, South Carolina and currently resides in or around Denver, Colorado. Suthar is self-employed in his family’s hotel business and
2:26-cv-01319-RMG Date Filed 03/27/26 Entry Number 1 Page 3 of 31
4 of 31
has a history of launching cryptocurrency tokens on the Solana blockchain platform Pump.fun. Suthar maintains multiple online identities: Telegram handles @thecapitalcartel and @godcandleprints, X handle @godcandle, and email address [email protected]. Suthar also operated a defunct Google reviews business at devmandeep.com. Upon information and belief, Suthar maintains offshore bank accounts that he uses for tax evasion, as he has admitted in written communications.
15Defendant Huang Huang Chen (“Chen”), also known as “Huang Chen,” “Lucky Chen,” “Roman,” “CookerFlips,” “TimeFreeze,” and “WeFreezeTime,” is an individual who resides in San Diego, California.
16Upon information and belief, Defendant Chen is the individual who operated the Telegram account @WeFreezeTime, who directly received Plaintiff’s cryptocurrency transfers totaling approximately $2.5 million2, and who pre-configured the laundering of those funds through ChangeNOW. Chen is associated with the X account @CookerFlips, the Telegram account @CookerFlips, and the cryptocurrency business Pastel Alpha (@PastelAlpha on X).
17John Does 1–10 are individuals and/or entities whose identities are presently unknown but who participated in, aided and abetted, or conspired with Suthar and/or Chen in the scheme described herein, including but not limited to: individuals who had access to the @WeFreezeTime Telegram account, individuals who controlled destination wallets on ChangeNOW, and Key Opinion Leaders (“KOLs”), marketers, or other participants engaged to promote the fraudulent 2 This figure represents the cryptocurrency transferred to wallet addresses directed by Chen (as @WeFreezeTime), comprising the Aeturnum and SZN venture transfers. Separately, Plaintiff transferred approximately $1,100,000 (6,107.88 SOL) directly to Defendant Suthar across three categories: (1) approximately $360,000 (2,279.41 SOL) beginning in or around April 2025 through July 2025, prior to Suthar’s introduction of Chen; (2) approximately $411,500 (2,308.47 SOL) for ventures known as HTTP, JPGdotfun, Myth, and other token launches in or around August 2025; and (3) approximately $327,000 (1,520 SOL) for the Aeturnum venture, with the balance of the Aeturnum funding sent to Chen-directed addresses, as well as $81,000 for SZN. See infra ¶¶ 50, 66–69. Upon information and belief, Chen may also have been a recipient of some of the funds sent to Suthar.
2:26-cv-01319-RMG Date Filed 03/27/26 Entry Number 1 Page 4 of 31
5 of 31
ventures (including but not limited to individuals known as “Orangie” (X handle @orangie), “Kiko”, “Eric from Zurich”). Plaintiff will amend this Complaint to identify the John Doe Defendants when their identities are ascertained.
JURISDICTION AND VENUE
18This Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1332 (diversity jurisdiction) because the amount in controversy exceeds $75,000, exclusive of interest and costs, and complete diversity of citizenship exists. Plaintiff is a citizen of South Carolina. Defendant Suthar is a citizen of Colorado and Defendant Chen is a citizen of California.
19This Court also has subject matter jurisdiction pursuant to 28 U.S.C. § 1331 over Plaintiff’s claims arising under the Computer Fraud and Abuse Act, 18 U.S.C. § 1030, and supplemental jurisdiction pursuant to 28 U.S.C. § 1367 over Plaintiff’s state law claims, which form part of the same case or controversy.
20This Court has personal jurisdiction over Defendant Suthar because he formerly resided in Charleston, South Carolina, cultivated a business relationship with Spruill in South Carolina over a period of years, directed ongoing electronic communications into South Carolina via Telegram, text message, telephone, FaceTime, and X, and committed tortious acts directed at and causing injury to a South Carolina resident and South Carolina limited liability company. Suthar’s contacts with South Carolina were continuous, systematic, purposeful, and directly related to the claims asserted herein.
21This Court has personal jurisdiction over Defendant Chen because, upon information and belief, he directed communications to Spruill in South Carolina via Telegram, solicited and received cryptocurrency transfers originating from South Carolina, participated in a Telegram group specifically created to conduct business with a South Carolina resident, discussed specific
2:26-cv-01319-RMG Date Filed 03/27/26 Entry Number 1 Page 5 of 31
Read the full filing
You’re reading pages 1–5 of 31. Register free to read the complete 31-page transcript on this page.
Register free to continue reading →
These are public U.S. federal court records, available free from PACER and the court. Registration unlocks our full on-page transcript — a convenience service.
advertisement
Public U.S. federal court record (district court docket 73105073, document 1). Source via the RECAP Archive (Free Law Project). The same record is available from PACER. Informational only — not legal advice.