Larry Cermak, head of analysis at The Block, published an article containing false information about BCT Inc. and CG Blockchain, Inc. that caused them reputational and financial harm. The plaintiffs notified Cermak prior to publication that some information was incorrect and offered to meet and correct any false statements, but Cermak cancelled the meeting and published the article anyway without verification. The plaintiffs are suing Cermak for defamation and libel, seeking $40 million in damages for publishing false information that harmed their businesses and launch of a new product.

1. SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
______________________________________________ Index No.:
Date Filed:
BCT INC SECZ AND
CG BLOCKCHAIN, INC
SUMMONS
Plaintiffs,
Plaintiffs designate
-against- New York County
as the Place of Trial
LARRY CERMAK
The basis of venue is
Defendant. the Defendant’s
place of business and the place of
business of CG Blockchain, Inc
________________________________________________
To the above-named defendant:
YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a
copy of your answer, or, if the complaint is not served with this summons, to serve a notice of
appearance, on the Plaintiff’s attorney within twenty (20) days after the service of this summons,
exclusive of the date of service (or within thirty (30) days after the service is complete if this
summons is not personally delivered to you within the State of New York); and in case of your
failure to appear or answer, judgment will be taken against you by default for the relief requested
in the complaint.
Dated: New York, NY
December 13, 2018
Edith Pardo Mehler Esq.
Attorney for the Plaintiff
Address: 77 Water Street, Suite 700
New York, NY 10005
Tel: (212) 390-8368
Defendant address:
Larry Cermak
Head Of Analysis
The Block
18 West 18th St
New York, NY 10011
larry@theblockcrypto.com

2. SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
---------------------------------------------------------------------x Index No.:
Date Filed:
BCT INC SEZC
Plaintiff, VERIFIED
COMPLAINT
-against-
LARRY CERMAK
Defendant.
---------------------------------------------------------------------x
Plaintiffs, BCT INC SECZ (“BCT”) AND CG BLOCKCHAIN, INC (“CG”), by their
attorney, Edith Pardo Mehler, Esq., as and for their verified complaint against the defendant,
LARRY CERMAK (“Cermak”), allege as follows:
AS AND FOR A FIRST CAUSE OF ACTION
1. At all relevant times hereinafter mentioned, BCT was and is a Cayman Islands
exempted company, with an office address of Floor 4, Willow House, Cricket Square, Grand
Cayman KY1-9010 Cayman Islands.
2. At all relevant times hereinafter mentioned, CG was and is a New York
corporation, with an office address of 77 Water Street, Suite 700, New York, NY 10005.
3. Upon information and belief, and at all relevant times hereinafter mentioned,
Cermak was and is a domestic resident, with an business address of 18 West 18th St, New York,
NY 10011.
4. Upon information and belief, Cermak is the Head of Analysis at The Block, a
cryptocurrency website.
5. On October 29, 2018, Cermak reached out via email to a former contractor of CG
inquiring about the participation of an individual, Ran Neu-Ner (“Neu-Ner”), in the purchase of
digital tokens issued by BCT (“BCT Tokens”). Information regarding purchasers of BCT Tokens

3. is considered private and confidential, and the Plaintiffs did not provide to Cermak any
information about Neu-Ner’s alleged purchase of BCT Tokens.
6. On December 10, 2018, one day before Cermak published an article about the
Plaintiffs, an associate of Cermak at The Block reached out to the Plaintiffs through indirect
means, including LinkedIn and the general contact webform for Estey-Hoover, Inc, an affiliate of
the Plaintiffs, in a veiled attempt to provide a record of contacting the Plaintiffs while avoiding
direct contact with the CEO of BCT, Josh Dettman (“Dettman”), whose email address was
publicly available, and who was available to assist Cermak and his associates with the pending
article.
7. Dettman, however, came across the LinkedIn message and immediately
responded to Cermak’s associate via email. In two emails Dettman advised Cermak’s associate
that he was happy to speak about the pending article.
8. Dettman further advised Cermak’s associate in his second email that the
publication of misinformation could cause the Plaintiffs irreparable harm and urged the associate
not to publish anything until he could verify facts.
9. Dettman then sent an email to Cermak stating that the information alleging that
Neu-Ner was an investor was false. Dettman further reiterated for Cermak that the publication of
misinformation could cause the Plaintiffs irreparable harm and urged Cermak not to publish
anything until he could verify facts. Dettman suggested a call between himself and Cermak to
discuss the pending article and to address any questions.
10. Dettman further made multiple calls to Cermak, notifying Cermak that the
Plaintiffs had reason to believe that Cermak was provided incorrect information, and requesting a
meeting so he could help verify and confirm pertinent facts, to which Cermak agreed. A time for
the meeting was set for the evening of December 10, 2018, which was prior to the scheduled
publication of the article on the following day.

4. 11. Dettman further disclosed his intention to have the meeting in the presence of
legal counsel, and to have the meeting recorded and provide both parties a copy of the meeting
transcript so that there would be no misunderstanding regarding the meeting discussions.
12. Prior to the pre-arranged meeting, Cermak abruptly cancelled the meeting, and
published his article on December 10, 2018, one day prior to the scheduled publication date.
13. Cermak had been informed by Dettman that some of his information proposed for
the article was incorrect, and that Dettman was willing, even on short-notice, to provide feedback
to correct the information proposed to be published by Cermak.
14. Cermak acting negligently and in opposition to journalistic standards and
practices by not verifying the information in the article, even after being clearly notified that
certain information was incorrect, and that the Plaintiffs were willing to assist Cermak in
correcting false information.
15. Upon information and belief, Cermak used former contractors of the Plaintiffs
who were disgruntled and unreliable sources. Cermak knew or should have known that such
sources would be conflicted and untrustworthy. In fact, a reasonable due diligence effort would
have revealed substantial evidence that many of these former contractors are part of a direct
competitor of Plaintiffs that is (a) leading a private and public smear campaign against the
Plaintiffs and (b) is illegally using the Plaintiffs’ intellectual property without authorization.
16. The incorrect information is now in the public domain and has caused irreparable
harm to the Plaintiffs’ reputations, the launch of the BCT product, and its BCT Tokens. The
BCT Tokens alone represented approximately $30,000,000 in contributions to develop the BCT
product.
17. After Cermak had published the article, Dettman emailed an associate of Cermak
at The Block, providing written evidence of the ill will and untrustworthiness of Neu-Ner, who
was one of Cermak’s sources. Cermak nonetheless has refused to delete the article.

5. 18. The publication of the article with false information has defamed the Plaintiffs
19. The defamatory actions of Cermak have caused significant damage to the
Plaintiffs. Accordingly, the Plaintiffs are seeking damages from Cermak in the amount of
$40,000,000.
AS AND FOR A SECOND CAUSE OF ACTION
20. Plaintiff repeats and realleges each and every allegation set forth in
Paragraphs “1” through “19” hereof as if fully set forth at length herein.
21. The publication of the article with false information has libeled the Plaintiffs.
22. The libelous actions of Cermak have caused significant damage to the Plaintiffs.
Accordingly, the Plaintiffs are seeking damages from Cermak in the amount $40,000,000.
WHEREFORE, Plaintiffs demand judgment against the Defendant, Cermak, as follows:
23. On the first and second causes of action, judgment in the sum of $40,000,000.
24. The costs and disbursements, including reasonable attorney’s fees, incurred by the
Plaintiffs in connection with this action.
25. Immediate deletion and retraction of the Cermak article.
26. An Order requiring the Defendant to meet with the Plaintiff, take into account
corrections and explanations (as applicable) as provided by the Plaintiff, and issue a
public statement of correction.
25. Such other and further relief as the Court may deem just and proper.
Dated: New York, New York
December 13, 2018
Edith Pardo Mehler, Esq.
Attorney for the Plaintiff
Address: 77 Water Street, Suite 700
New York, NY 10005
Tel: (212) 390-8368