1 ACOM

Marquis & Aurbach

2 A VECE M. HIGBEE, ESQ.

Nevada Bar No.3 739

3 BRIAN R. HARDY, ESQ.

Nevada Bar No. 10068

4 10001 Park Run Drive Las Vegas, Nevada 89145

5 (702) 382-0711

(702) 382-5816 Facsimile

6 ahigbee@marguisaurbach.c01TI

bhardy@)n1arguisaurbach.cqn1

7 Attorneys for Plaintiffs

8 9 10 1 1

12 13 14 15 16

17 18 19 20 21 22 23 24 25 26 27 28

Electronically Filed 05/12/2010 11 :55:10 AM

CLERK OF THE COURT

DISTRICT COURT

CLARK COUNTY, NEVADA

Plaintiff,

AMENDED COMPLAINT EXEMPT FROM ARBITRATION (Damages In Excess of $50,000 and Requests Injunctive Relief)

GLOBAL VERGE, INC., a Nevada Corporation and ALL WIRELESS SERVICE, INC., a Florida Corporation,

Case No.:

Dept. No.

A-10-615937-B XIII

vs.

CI-IRISTOPFIEI~ GI~ECO, an individual; MAKE AMERICA SHINE PRODlJCTS, LLC dba PANTHER MOBILE; UNLIMITED WIZARD CELLULAR, INC. dba ACTIVATION KING WIRELESS, a South Carolina Corporation; and Roe Corporations I through X, and Does I through X, inclusive

Defendants.

Plaintiffs, Global verge, Inc. ("Global Verge") and All Wireless Service, Inc. ("All

Wireless"), by and through their counsel of record, Marquis & Aurbach, hereby claims against Defendants Christopher Greco ("Greco"), Make America Shine, LLC dba Panther Mobile ("Panther") and Unlimited Wizard Cellular, Inc. dba Activation King Wireless ("AKW")(collectively the "Defendants") and alleges as follows:

JURISDICTIONAL ALLEGATIONS

1.

Plaintiff Global Verge is and was at all times relevant, a Nevada corporation

authorized to do business in Clark County, Nevada.

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1

2.

Plaintiff All Wireless IS and was at all times relevant herein, a Florida

2 corporation.

3

3.

Upon information and belief, Defendant Greco is and was at all times relevant, a

4 resident of South Carolina, and a Manger of Panther and Director of AKW.

5

4.

Upon information and belief, Defendant Panther was is and was at all times

6 relevant, a corporation conducting business online at www.panthermobile.colll with its offices

7 located at 5454 Lena Road Suite 104, Bradenton, Florida 34211.

8

5.

Upon information and belief, Defendant Panther is owned and/or operated by

9 Defendant Greco and Kevin Sipe.

10

6.

Upon information and belief, Defendant Panther actively solicits customers and

11 conducts business in Clark County, Nevada.

12

13 14 15 16 17 18 19

7.

Defendant AK W is and was at all times relevant, a South Carolina corporation

conducting business online at www.activationkingwireless.colTI with its offices located at 1515

Cannon Road, Myrtle Beach, South Carolina 29577.

8. Upon information and belief, Defendant AKW is owned and/or operated solely by

Defendant Greco and is a technology provider to Panther.

9. Upon information and belief, Defendant AI(W actively solicits customers and

conducts business in Clark County, Nevada.

10.

The true names and capacities, whether individual, corporate, associate, or

20 otherwise of the Defendants named herein as Roe Corporations I through X, and Does I through

21 X, inclusive, are unknown to Plaintiff at this time, who therefore sues said Defendants by

22 fictitious names and will ask leave of the Court to amend this Complaint to show the true names

23 and capacities of Defendants when the same are ascertained. Said Doe and Roe Defendants are

24 responsible for damages suffered by Plaintiff; therefore, Plaintiff sues said Defendants by such

25 fictitious names.

26 INTRODUCTION

27

11.

Global Verge provides products and services through a unique business model

28 which allows individuals and companies to purchase products at wholesale and sell any or all of Page 2 of 17

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3

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1 the products from a retail store. One of the many products offered by Global Verge is pre-paid

2 wireless mobile telecommunication services.

12.

All Wireless is a service provider for pre-paid wireless mobile

4 telecommunication services.

5

13.

Defendant Greco is not nor has ever been an owner, agent or affiliate of All

6 Wireless.

7 THE FRAUDULENT AGREEMENT

8

14.

On or about November 15, 2009, Global Verge contracted with, what it believed

9 to be, All Wireless (the "Fraudulent Service Agreement"). A true and correct copy of the

10 Fraudulent Service Agreement is attached hereto as Exhibit 1.

1 1

15.

The Fraudulent Service Agreement was presented to Global Verge by Defendant

12 Greco who represented that he was an owner of All Wireless.

16. The Fraudulent Service Agreement was executed by Defendant Greco who

13 14 15 16 17 18 19

represented therein that he was an owner of All Wireless.

17. In reliance upon the Fraudulent Service Agreement, Global Verge made payments

in the sum of $123,000.00 into what it believed to be an All Wireless account at Southern

Commerce Bank and payments in the sum of $51,650.00 to an account Global Verge has since

learned was controlled by Defendant AKW.

18.

In reliance upon Section 13 of the Fraudulent Service Agreement, Global Verge

20 allowed Greco access to its confidential and proprietary information which included, among

21 other things, its client lists and contact information.

22

19.

Despite receipt of the foregoing payments, Defendant Greco failed to provide all

23 services under the Fraudulent Service Agreement.

24 THE FRAUDULENT ACCOUNT

25

20.

In or around November 2009, Defendant Greco individually and/or through

26 Defendant AK W opened an account at Southern Commerce Bank under the name All Wireless

27 Services Inc. without the approval or authorization of All Wireless (the "Fraudulent Account").

28

Page 3 of 17

1

21.

Defendant Greco directed Global Verge to deposit its payments under the

2 Fraudulent Service Agreement into the Fraudulent Account.

3

22.

Global Verge made payments to in the sum of $123,000.00 into the Fraudulent

4 Account.

5 6

23.

Defendant Greco withdrew all funds out of the Fraudulent Account.

24.

During the month of December 2009 alone, Greco wrote checks to himself or

7 made payable to "CASH" in the sum of $55,200.00.

8 ALLEGATIONS OF FRAUDULENT LITIGATION'

9

25.

When it was discovered that Greco had opened the Fraudulent Account and

10 entered into the Fraudulent Service Agreement, Global Verge demanded, among other things,

11 that he return its payments.

12 13 14 15 16 17 18

26.

Rather than return the ill-gotten funds, Greco used Global Verge's confidential

and proprietary information against it by sending out mass emails to Global Verge's clients with

allegations that a lawsuit had been filed by AK W against Global Verge for "full disclosure"

indicating that Global Verge was instable and unable to continue conducting business. In

support of his allegations, Greco attached a copy of a Civil Cover Sheet from the United States District Court for the Southern District of New York (the "Fraudulent Civil Cover Sheet"). A

true and correct copy of an email sent out by Greco with the enclosed Fraudulent Civil Cover

19 Sheet is attached hereto as Exhibit 2.

20

27.

Upon information and belief, Greco downloaded a form civil cover sheet

21 available to the public from the United States District Court for the Southern District of New

22 York's website and filled it in with false information. 1

23

28.

On the Fraudulent Civil Cover Sheet, Greco identified the attorney of record for

24 AKW as "Max Weinberg" of the law firm of "Weinberg Kohler and (sic) associates".

25

29.

A search of licensed attorneys in New York evidences that there is no Max

26 Weinberg nor law firm of Weinberg Kohler and Associates.

27 28

1 A civil cover sheet form can be obtained at http://www,nysd.uscourts.gov/cases/show.php?db=forms&id=l20.

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30.

A search of the United States District Court records shows that neither AKW nor

2 Global Verge are a party to any current federal litigation.

3 FORMATION OF COMPETING COMPANY

4

31.

Upon information and belief, following his departure with Global Verge's

5 confidential and proprietary information, Defendant Greco contacted Kevin Sipe at Defendant

6 Panther.

7

32.

Upon information and belief, through the use of Global Verge's confidential and

8 proprietary information, Defendant Greco and others at Defendant Panther contacted Global 9 Verge's clients and provided them false and misleading information about Global Verge in an 10 attempt to solicit Global Verge's clients to join Defendant Panther.

1 1

33.

Upon information and belief, Defendant Panther knowingly acquired and

12 appropriated Global Verge's confidential and proprietary information from Defendant Greco.

13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

FIRST CAUSE OF ACTION (Misappropriation of Trade Secrets, NRS 600A.O 1 0, Et Seq.v

34. Global Verge repeats, realleges and incorporates by this reference, each and every allegation contained above, inclusive, as if they were fully set forth herein.

35. Defendant Greco obtained Global Verge's confidential and proprietary trade

secret information through fraud, artifice or deception.

36. Upon information and belief, Defendant Greco misappropriated Global Verge's

confidential and proprietary trade secret information including, but not limited to, client lists and

contact information with the intent to injure Global Verge in violation ofNRS 600A.035.

37. Global Verge has incurred significant costs in the creation and development of its

confidential and proprietary trade secret information, derives independent economic value by

virtue of its not being generally known to, and not being readily ascertainable through proper

means by, others who can obtain economic value from its disclosure or use.

38. Upon information and belief, Defendants Greco and Panther have used and are

now using Global Verge's confidential and proprietary trade secret information without Global

Verge's consent.

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39.

As a direct and proximate result of the Defendants Greco and Panther's conduct,

2 Global Verge has suffered damages in excess of $1 0,000.00.

3

40.

As a direct and proximate result of the Defendants Greco and Panther's willful,

4 wanton and/or reckless misappropriation and disregard of Global Verge's rights as the owner of

5 the misappropriated trade secrets, pursuant to NRS 600A.050, Global Verge is also entitled to

6 exemplary damages in an amount to be determined at trial.

7

41.

As a result of Defendants Greco and Panther's willful and malicious

8 misappropriation of Global Verge's trade secrets, pursuant to NRS 600A.060, Global Verge is

9 further is entitled to an award of attorneys' fees and costs.

10 SECOND CAUSE OF ACTION

(Tortious Interference with Contractual Relations)

1 1 12 13 14

15 16 17 18 19 20 21 22 23 24

25 26 27 28

42. Global Verge repeats, realleges and incorporates by this reference, each and every

allegation contained above, inclusive, as if they were fully set forth herein.

43. Global Verge had valid and existing contractual relationships with its customers,

suppliers, and vendors.

44. Defendants Greco and Panther's knew of the existence of those contractual

relationships.

45. Upon information and belief, Defendants Greco and Panther directly and

indirectly solicited Global Verge's customers to terminate or curtail their existing contractual

relationships with Global Verge and, instead, enter into contractual relations for the performance of those contracts with Panther.

46. Defendants Greco and Panther's solicitation of Global Verge's customers,

suppliers and vendors was intentional, wrongful and designed to disrupt and/or terminate Global

Verge's contractual relationships with its customers, suppliers and vendors.

47. Defendants Greco and Panther's wrongful solicitations of Global Verge's

customers, suppliers and vendors actually disrupted and/or terminated Global Verge's

contractual relationships with its customers, suppliers and vendors.

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48.

As a direct and proximate result of Defendants Greco and Panther's conduct,

2 G 10 bal Verge's has suffered damages in excess of $1 0,000.00.

3

49.

It has been necessary for Global Verge to obtain the services of attorneys to

4 prosecute this action. Accordingly, Global Verge is entitled to an award of attorneys' fees and

5 costs.

6 THIRD CAIJSE OF ACTION

(Tortious Interference With Prospective Economic Advantage)

7 8 9

10 1 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

50. Global Verge repeats, realleges and incorporates by this reference, each and every

allegation contained above, inclusive, as if they were fully set forth herein.

51. Global Verge had prospective contractual relationships with its customers,

suppliers and vendors.

52. Defendants Greco and Panther knew or should have known of the existence of

those prospective contractual relationships.

53. Upon information and belief, Defendants Greco and Panther contacted one or

more of Global Verge's customers, suppliers andlor vendors providing them with false and

misleading information so that the customers, suppliers andlor vendors would no longer do

business with Global Verge and should shift their future business to Panther.

54. In soliciting Global Verge's customers, suppliers and vendors in this manner,

Defendants Greco and Panther's wrongfully intended to harm Global Verge by improperly

preventing its prospective contractual relationships.

55. Defendants Greco and Panther did not have a legal privilege or justification to

interfere with Global Verge's prospective contractual relationships.

56. As a direct and proximate result of Defendants Greco and Panther's conduct,

Global Verge has suffered damages in excess of $10,000.00.

57. It has been necessary for Global Verge to obtain the services of attorneys to

prosecute this action. Accordingly, Global Verge is entitled to an award of attorneys' fees and

costs.

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1 2

4 5 6 7 8 9

10 1 1

12

FOURTH CAUSE OF ACTION (Business Disparagement)

58. Global Verge repeats, realleges and incorporates by this reference, each and every

allegation contained above, inclusive, as if they were fully set forth herein.

59. Defendants Greco and Panther published false and disparaging statement about

Global Verge to third parties.

60. Defendants Greco and Panther's publication of false and disparaging statements

about Global Verge were unprivileged publications.

61. Defendants Greco and Panther's publication of false and disparaging statements

about G lobal Verge were made with malice in that Defendants Greco and Panther published the

disparaging statements with the intent to cause harm to Global Verge andlor published the

disparaging statements knowing the falsity of said statements or with a reckless disregard for the truth of said statements.

62. Defendants Greco and Panther's publication of false and disparaging statements

about Global Verge are the proximate cause of the special damages to Global Verge in an

amount in excess of $1 0,000.00.

63. It has been necessary for Global Verge to obtain the services of attorneys to

prosecute this action. Accordingly, Global Verge is entitled to an award of attorneys' fees and

costs.

FIFTH CAUSE OF ACTION (Injunctive Relief)

64.

Global Verge repeats, realleges and incorporates by this reference, each and every

22 allegation contained above, incl usi ve, as if they were fully set forth herein.

23

65.

Upon information and belief, Defendants Greco and Panther have reproduced and

24 republished false and disparaging statements regarding Global Verge and will continue to

25 publish the false and disparaging statements unless legally restrained.

26

66.

If Defendants Greco and Panther are not enjoined from continuing to publish,

27 reproduce andlor distribute false and disparaging statements causing Global Verger irreparable

28 harm.

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67.

Defendant Greco misappropriated protected confidential and proprietary trade

2 secret information from Global Verge in violation ofNRS 600A.035.

3

68.

Defendants Greco and Panther are benefiting from the confidential and

4 proprietary trade secret information stolen from Global Verge and are currently contacting

5 clients from the client lists taken from Global Verge.

6

69.

If Defendants Greco and Panther are not enjoined from using the confidential and

7 proprietary trade secret information stolen from Global Verge, Global Verge will suffer

8 irreparab I e harm

9

70.

Based upon the foregoing, this Court should issue a temporary restraining order,

10 preliminary injunction, and permanent injunction enjoining Defendants Greco and Panther from

11 continuing to publish, reproduce and/or distribute the false and defamatory statements and from

12 using the confidential and proprietary trade secret information stolen from Global Verge.

13 14 15 16 17 18 19 20 21

22 23 24 25 26 27 28

SIXTH CAUSE OF ACTION (Deceptive Trade Practices, NRS 598 eta al.)

7l. Global Verge and All Wireless repeats, realleges and incorporates by this

reference, each and every allegation contained above, inclusive, as if they were fully set forth

herein.

72. A person engages in a deceptive trade practice if they knowingly pass off goods

or services as those of another person; knowingly make a false representation as to the source,

sponsorship, approval or certification of goods or services; knowingly make a false

representation as to affiliation, connection or association with and another; knowingly makes a

false representation as to the sponsorship, approval, status, affiliation or connection of another;

knowingly disparage the goods, services or business of another by false or misleading

representations of fact; advertise goods or services with the intent not to provide such services;

fraudulently alters any contract or other document in connection with the sale or lease of goods

or services; and knowingly makes any other false representation in a transaction. (NRS

598.0915)

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73.

Defendants Greco and/or AKW knowingly engaged in the deceptive trade

2 practices set forth above.

3

74.

As a direct and proximate result of Defendants Greco and/or AKW's conduct,

4 Global Verge and All Wireless have suffered damages in excess of$10,000.00.

5 6 7 8 9

10 1 1 12

13

14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

75.

As a direct and proximate result of the aforementioned acts, it has become

necessary for Global Verge and All Wireless to secure the services of an attorney to prosecute

this action. Accordingly, Global Verge is entitled to an award of attorneys' fees and costs herein

as well as treble damages pursuant to NRS 598.0999(3).

SEVENTH CAUSE OF ACTION (Fraud)

76.

Global Verge and All Wireless repeats, realleges and incorporates by this

reference, each and every allegation contained above, inclusive, as if they were fully set forth

herein.

77. In or around November 2009, Defendant Greco individually and/or through

Defendant AKW opened the Fraudulent Account.

78. On or about November 15, 2009, Global Verge was presented with the Fraudulent

Service Agreement by Defendant Greco who represented that he was an owner of All Wireless.

79. In reliance upon the Fraudulent Service Agreement, Global Verge made payments

in the sum of $123,000.00 into the Fraudulent Account and payments in the sum of $51,650.00

to an account Global Verge since learned was controlled by Defendant AKW.

80.

In reliance upon Section 13 of the Fraudulent Service Agreement, Global Verge

allowed Greco access to its confidential and proprietary information which included, among other things, its client lists and contact information.

81.

In or around February 16, 2010, Greco sent out mass emails to Global Verge's

clients with allegations that a lawsuit had been filed by AKW against Global Verge with the Fraudulent Civil Cover Sheet attached thereto.

Page 10 of 17

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1

82.

Upon information and belief, the acts, conduct and behavior of the Defendants,

2 each of them, were performed knowingly, intentionally, oppressively, and maliciously, by reason

3 of which Global Verge and All Wireless are enti tled to punitive damages.

4

83.

As a direct and proximate result of Defendants Greco and/or AKW's conduct,

5 Global Verge and All Wireless have suffered damages in excess of $1 0,000.00.

6

84.

As a direct and proximate result of the aforementioned acts, it has become

7 necessary for Global Verge and All Wireless to secure the services of an attorney to prosecute

8 this action. Accordingly, Global Verge is entitled to an award of attorneys' fees and costs.

9 10 1 1

85.

EIGHTH CAUSE OF ACTION (Civil Conspiracy)

Global Verge and All Wireless repeat, reallege and incorporate by reference the

12 allegations identified above with the same force and effect as if herein set forth.

13 14 15 16 17 18

86. Upon information and belief, the Defendants Greco and AKW conspired to

accomplish an unlawful objective for the purpose of harming Global Verge and All Wireless.

87. Among other things, Defendants Greco and AKW conspired to use All Wireless'

name to defraud Global Verge and others within the mobile telecommunications industry.

88. Upon information and belief, Defendants Greco and Panther conspired to, among

other things, misappropriate Global Verge's confidential and proprietary trade secret

19 information.

20

89.

As a direct result of the conduct of Defendants Greco and AKW Global Verge

21 and All Wireless are entitled to compensatory damages.

22

90.

As a direct result of the conduct of Defendants Greco and Panther Global Verge is

23 entitled to compensatory damages.

24

91.

Upon information and belief, the acts, conduct and behavior of the Defendants,

25 each of them, were performed knowingly, intentionally, oppressively, and maliciously, by reason

26 of which Global Verge and All Wireless are entitled to punitive damages.

27 28

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92.

It has been necessary for Global Verge and All Wireless to obtain the services of

2 attorneys to prosecute this action. Accordingly, Global Verge and All Wireless are entitled to an

3 award of attorneys' fees and costs.

4 NINTH CAUSE OF ACTION

(Concert of Action)

5 6 7 8 9

10 1 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

93. Global Verge and All Wireless repeat, reallege and incorporate by reference the

allegations identified above with the same force and effect as if herein set forth.

94. Upon information and belief, the Defendants, each of them, conspired to

accomplish an unlawful objective for the purpose of harming the Global Verge and All Wireless.

95. Upon information and belief, the Defendants undertook a common plan to commit

tortious acts where the participants, each of them, took substantial affirmative steps to harm

Global Verge and/or All Wireless.

96. As a direct result of the conduct of the Defendants, each of them, Global Verge

and All Wireless are entitled to compensatory damages.

97. Upon information and belief, the acts, conduct and behavior of the Defendants,

each of them, were performed knowingly, intentionally, oppressively, and maliciously, by reason

of which Global Verge and All Wireless are entitled to punitive damages,

98. It has been necessary for Global Verge and All Wireless to obtain the services of

attorneys to prosecute this action. Accordingly, Global Verge and All Wireless are entitled to an

award of attorneys' fees and costs.

TENTH CAUSE OF ACTION (Unjust Enrichment)

99. Global Verge repeats, realleges and incorporates by reference the allegations

identified above with the same force and effect as if herein set forth.

100. Upon information and belief, Defendant Greco has retained and is continuing to

retain monies paid by Global Verge for under the Fraudulent Agreement.

101. Defendant Greco has enjoyed the benefit of the Global Verge's payments under

circumstances where it is inequitable for him to retain such benefit.

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102. As a direct and proximate result of the Defendant Greco's actions, Global Verge

2 has suffered damages in excess of $10,000.00.

103. It has been necessary for Global Verge to obtain the services of attorneys to

4 prosecute this action. Accordingly, Global Verge is entitled to an award of attorneys' fees and

5 costs of suit.

6

7 8

ELEVENTH CAUSE OF ACTION

(Trademark Infringement Under NRS 600.420 and 15 U.S.C. §1114)

104. Global Verge repeats, realleges, and incorporates each and every paragraph

9 contained above as though fully set forth herein.

10

105. The GLOBAL VERGE name and logo are marks owned by Global Verge and are

11 registered with the Nevada Secretary of State as follows:

~ \0

U ~ 13

-< ~

".,... "'00

~ v:!", 14

~ .2: 0'> ~

~ 1-<00'"

""",ClroR

-e §-g~ 15 _I-) 0::: ~ ><

~ ...:.:: Z <t

8 r- w.....

en 0.. s ., 16

~ _ OIJ_

~ 8>8 CY;:: Vl N

~ j ~ 17

< 8

:E t:. 18

19 20 21 22 23 24

12

25

26 27 28

GLOBAL VERGE: Trademark Registration for comprehensive telecommunication services.

106. Further, the Global Verge name and logo are currently pending before the United

States Patent & Trademark Office ("USPTO") under Serial Number 77818286 for the following

goods and services:

IC 035. US 100 101 102. G & S: Advisory services relating to business management and business operations; Multi-level marketing business services; On-line business networking services; Online retail store services featuring telecommunications service plans and telecommunications service activation; Online retail store services featuring a variety of merchandise and services, namely, power saving devices, water making devices, travel services, identity recovery services, video conferencing services, computers, electronics and telephones; Multi-level marketing services featuring a variety of merchandise and services, namely, power saving devices, water making devices, travel services, identity recovery services, video conferencing services, computers, electronics and telephones.

IC 038. US 100 101 104. G & S: Cellular telephone services; Computerised telephony services; Data transmission and reception services via telecommunication means; Fixed and mobile telephone services; Instant messaging services; Telecommunication services in the nature of providing telephone features, namely, call waiting, call identification, call forwarding, and message waiting; and Voice over internet protocol (VOIP) services.

I C 039. US 100 105. G & S: Travel agency services, namely, making reservations and bookings for transportation; Travel and tour information service; Travel and tour ticket reservation service; Travel information services; Providing an on-line computer database in the field of travel information services; and Providing an on-line searchable computer database featuring information on travel.

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1 2 3 4

Ie 041. US 100 101 107. G & S: Training courses in strategic planning relating to advertising, promotion, marketing and business; Education services, namely, providing online classes, seminars, and workshops in the fields of marketing, business development and business management; Educational services, namely, providing information to members of a multi-level marketing network in the fields of business development, marketing and business management.

5 (collectively with the Nevada Registered marks the "GLOBAL VERGE Marks").

6

107. The GLOBAL VERGE Marks have been in continuous use since 2008 and the

7 foregoing registrations have not been abandoned, canceled, or revoked.

8

108. Global Verge has spent substantial time and funds to advertise and promote the

9 GLOBAL VERGE Marks through, among other things, the Internet.

10

109. Global Verge owns and operates websites accessible throughout Nevada, the

11 United States, and around the world at globalverge.com, globalvergecompplan.com,

12 globalvergeonlinemarketing.corn.

13 14 15 16 17 18

110. Based upon its mark registrations, and extensive use, the Plaintiffs owns the

exclusive right to use the GLOBAL VERGE Marks in Nevada and within the United States.

111. On or about January 29, 2010, Defendant Greco, through his company AKW,

registered the globalverge.us Internet domain name with GoDaddy.com, Inc. (,'GoDaddy"), a

domain name registrar. The globalverge.us domain name contains the CiLOBAL VERCiE Marks.

112. Some time after registration, Defendants Greco andlor AKW placed links on the

19 globalverge.us domain name to competing websites including that of Defendant AKW.

20

113. Defendants Greco andlor AKW have not registered nor used the globalverge.us

21 domain name in good faith.

22

114. By registering and using a domain name containing the GLOBAL VERGE

23 Marks, Defendants Greco and/or AKW were and are attempting to trade on the goodwill of

24 GLOBAL VERGE.

25

115. By registering and using the globalverge.us domain name, Defendants Greco

26 and/or AKW are and were attempting to frustrate or divert internet traffic and patrons intended

27 for or seeking association with Global Verge.

28

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116. By registering and using the globalverge.us domain name, Defendants Greco

2 and/or AKW are and were attempting to confuse those individuals seeking to conduct business

3 with Global Verge.

4

117. Defendants Greco and/or AKW have used and/or are using the globalverge.us

5 domain name, which contains the GLOBAL VERGE Marks, without the Plaintiffs consent.

6

118. Defendants Greco and/or AKW's use in commerce of GLOBAL VERGE Marks

7 and/or marks confusingly similar to the GLOBAL VERGE Marks in the globalverge.us Internet

8 domain name constitutes a reproduction, copying, counterfeiting, and colorable imitation of the

9 GLOBAL VERGE Marks in a manner that is likely to cause confusion or mistake or that is

10 likely to deceive others.

1 1

119. By using the GLOBAL VERGE Marks and/or marks confusingly similar to the

12 GLOBAL VERGE Marks with the knowledge that Global Verge owns and has used, and

13 14 15 16 17 18

continues to use, its trademarks in, among other locations, Clark County, Nevada, the Defendants

Greco and/or AK W's have intended to cause confusion, mistake, or deceive others.

120. Defendants Greco and/or AKW are also using marks that are the same and/or

confusingly similar to the GLOBAL VERGE Marks in the globalverge.us domain name to cause

initial interest confusion and to divert Internet users away from the Global Verge's websites.

121. As a direct and proximate result of Defendants Greco and/or AKW's

19 infringement, Global Verge has suffered, and will continue to suffer, monetary loss and

20 irreparable injury to its business reputation and goodwill.

21

122. Based upon the foregoing, Global Verge has been forced to retain the services of

22 an attorney to prosecute this matter and is entitled to recover reasonable costs and attorneys fees

23 incurred herein as special damages.

24 TWELFTH CAUSE OF ACTION

(Trademark Dilution)

25 26 27 28

123. Global Verge repeats, realleges, and incorporates each and every paragraph

contained above as though fully set forth herein.

Page 15 of 17

M&A:11429-002 1046216 l.DOC 5/12/2010 11:55 AM

1

124. The GLOBAL VERGE Marks are inherently distinctive. Through their adoption

2 and consistent and extensive use, the GLOBAL VERGE Marks have acquired notoriety in,

3 among other locations, the State of Nevada.

4

125. Defendants Greco and/or AKW began using marks that are the same and/or

5 confusingly similar to the GLOBAL VERC}E Marks in connection with globalverge.us domain

6 name after the G LC) BAL VERGE Marks had acquired notoriety in, among other locations, the

7 State of Nevada.

8

126. Defendants Greco and/or AKW's use of the GLOBAL VERGE Marks andlor

9 marks confusingly similar thereto has and will cause dilution of the distinctive quality of the

10 GLOBAL VERGE Marks and will otherwise cause irreparable injury to Global Verge's business

11 reputation and goodwill.

12

13 14 15 16 17 18 19

127. Upon information and belief, Defendants Greco andlor AKW's use of the GLOBAL VERGE Marks andlor marks confusingly similar thereto was willful in nature, in that the named Defendants intended to cause dilution of the GLOBAL VERGE Marks or willfully intended to damage Global Verge's reputation.

128. As a direct and proximate result of Defendants Greco and/or AKW's dilution of

the GLOBAL VERC}E Marks, Global Verge has suffered, and will suffer, irreparable injury to its

business reputation and goodwill.

129. Global Verge has been forced to retain the services of an attorney to prosecute

20 this matter and is entitled to recover reasonable costs and attorneys fees incurred herein as

21 special damages.

22 WHEREFORE, Global Verge and All Wireless pray for judgment against the Defendants

23 as follows:

24

1.

For general, compensatory, punitive and special damages in an amount to be

25 determined at trial;

26

2.

F or reasonable attorneys fees and costs incurred herein pursuant to NRS

27 600A.060, NRS 600.430(3), 15 U.S.C. § 1117 and as special damages.

28

Page 16 of 17

M&A:J 1429-0021046216 I.DOC 51l2/2010 11:55 AM

1

M&A: l1429~002 l0462l6 lDOC 5/12/20 io u :55 AM

3.

For a temporary restraining order, preliminary injunction, and permanent

2 injunction enjoining Defendants Greco and Panther from continuing to publish, reproduce and/or

3 distribute the false and defamatory statements and from using the confidential and proprietary

4 trade secret information stolen from Global Verge~

For treble damages pursuant to NRS 598.0999(3);

5 6 7

4. 5. 6.

F or interest; and

For such other and further relief as this honorable Court may deem just and

8 proper.

\

9 Dated this' day of May, 2010.

,,)d ~"

10 1 1

12

13 14

Ave' e M. I-ligbee, ESQ\ Nev a Bar No. 3739 'J Brian R. Hardy, Esq. Nevada Bar No. 10068 10001 Park Run Drive

Las Vegas, Nevada 89145 Attorneys for Plaintiff

15

16 17 18 19 20

21 22 23 24 25 26 27 28

Page 17 of 17

,:

i

cC'C'_

:,:c", <:

This Agreement is made and entered into this ~1_~.~._. day of

.__tl9vernQ.~ .. r 2009, between All Wireless Service, Inc. (lIAWSIl) a company incorporated and

existing under the Laws of the State of Flortda, with its registered address at 6405103rd

Street, Jacksonville, FL 32210*7129 and Global Verge crCompanyll), a company incorporated

and existing under the Laws of Nevada with its principal offices located

at 200 NE Missouri Rd Suite 202, Lees Surnrnlt iVlO 64086 (collectively the "Parties' and individually a "Party").

\~HeRlEA§( AWS and Company are interested in providing of Domestic pre-paid mobile telecommunications Services; and

WHEREAS, AWS desires to sell certain mobile telecommunications Services provided by Company and Company desires to procure certain telecommunications Services provided by AWS.

NOVllv Tliire~iElFOR~F in consideration of the mutual covenants and Agreements contained herein and other good and valuable consideration, the receipt and sufficiency of which is liereby acknowledqed, the Parties 'agree as follows:

"Effective Date" shall mean the date of execution of this Agreement.

"Service" or "Sel~v[ce5" shall mean those telecommunication Services described in the attached relevant Annex (es) incorporated herein by reference.

"Service Date" shail mean the date of completion of provtsioninq and testing of Service(s), and each Party shall notify the other Party of the respective Service Date

of Services It is providing hereunder,

"Customer" shal: mean the Party purchasing Service(s).

"Provider" shall mean the Party of the Ag reernent who is providing the Service/tenrlinatlon to the Customer. Rates are based on SImple Mobile and Page Plus service network programs.

Tile Partiesr directly or through their affiliates or underlying carriers, shall provide, procure; and utillze the Services per the terms and conditions of this Aqreement,

This /,l,greement shall commence on the Effective Date and shall continue to be in force unless and unttl terminated in accordance with the terms hereof. The Parties

may terminate this Agreement, and/or terminate or suspend any Service provided to Customer under ftrat any time wttnout liabilitv upon thirty (30) days prior written notice. The Parties may terminate this Agreement without liability on three (3) days

t.,p!~!~r written notice to CL:stomer f~r any ,breaCh ~f ~rl!S A~"!-eerne~t I~CI~dtl,:_~: b,u~.n~;~ ., lL ['0 ~\ 01·'\_."

'~J( 11 iJ--J> A l" ~. l...:>.,S ·--h) C i I.JT;._. G t'!.A~, \ I \ ~,.j., \ t . ../-. ! G f,._, yy(;.,~ c ~~<.. ( (3~. /' ,'"

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f\ WS, Inc

Confidential

limited to, a failure by Customer to pay in E! timely manner any charges for Services

rendered. In addition: either Party may termlnate this Aqreernent immediately

without notice 01" liability in the event that either Party deems such actions necessary clue to Customer's use of the Services for unlawful purposes or in an unlawful manner, or tn order to protect or preserve either Party's network. In the event of any termination of this Agreement each Party shall pay the other Paliy for all Service rendered through and including the date of termination.

Where applicable, each Party shall be responsible to connect to the other Party's network at one of the other Party's network mterconnectlon locations, and the Parties shall be responsible to procure, at their own expense,the necessary facilities

01" equipment required to interconnect to such locations. The Parties shall endeavor

to provide the Services on the Service Date and they shall be solely responsible to coordinate the provisioning of their respective matching facilities and/or equipment

(where applicable) by the Service Date. The Parties shall coordinate the

management of their respective network facilities. The Parties also shall interface on

a 24 hours/? clays a week basis to assist each other with the isolation and repair of any facility faults in their respective networks,

a) Durjng the term of this Aqreement.. j\VvS shall charge for the telecommunication Servlces,and Company shall pay for such telecommunication Services, the amount determined by using the rates set forth in Annex A.

b) DurIng the term of this Agreernent,. Cornpanv shall charqe for the

telecommurucatlon Services, and AWS shaH pay for such telecommunication Services, the. amount determtned by using the rates set forth in Annex B,

c) AVVS shall have the right to modify the rates and conditions set forth in

Annex "/-\11 at any time, but shall give t~e other Party at l~a5t "trdrty~ (30) days prior written notice, <fo;i:- A<,,:'~ \j~" \ \ '\ 0(,,~(\/1·b'" tc..:\~i'.· .. q:')r- '{' ~¥\O.-,'\'h,.S k. i"'<i> ·v\ <:hv\-':;;_ 0 $'

,. . ...,.. ..

;'\ (1->;" {_.:.:... (,,'-", '-<.r \

d) Company shall have the right to modify the rates and conditions set forth

in Annex "B'' at any time, but shall qlve theother Party at least five (5) days prior written notice.

p,S a condition of the Parties obliqations hereunder, and to ensure the prompt payment of sums due from Customer, Customer may be requested bv the other Party to turnlsn upon the execution of this Agreement either a cash deposit In an amount satisfactory to the Provider, or an irrevocable and unconditional letter of credit in an amount satisfactory to the Provide!'. The Provider shall have tile right to require Customer to increase the amount 01" institute a requirement for a cash deposit, letter of credit, or other security whenever It deems such increase to be necessary, Customer shall provide such Increased security to the Provider within three (3) days of request,

2

PLEASE INI'(lAL

AINS,In<.:

Confidentiat

§tariidard' Terms: The Parties hereby acknowledge that charges for the Services shall be bi1!ed on a Week!v basis; every seven (7) days and that payment for such servtces is due and payable in US dollars due upon receipt of the

invoice.

Late payments shall be assessed a late charge of 1.5% per month or the maximum amount permitted by law, whichever IS less.

Tile Parties acknowledge and understand that aU charges stated in the attached Annexes are computed exclusive of any applicable use, excise, gross receipts, sales

and pnvileqe taxes! duties, fees; or other taxes or similar liabilities (other than general income or property taxes). Such Additional Char"ges shall be paid by the Customer In addition to al! other charges provided herein.

Should either Party dispute any of the charqes on the invoice, It shall notify the other Party of thedfsputed charges not later than seven (14) days from the date of invoice. Said dispute shall set forth in writing all details concernlnq the disputed charges. In the event ora dlspute: the entire invoice shall be paid in accordance with the payment terms set forth herein. Disputes shall be reviewed and resolved within fifteen (1.5) days of receipt of written dispute. However, the Provider shall have no obligation to review disputed charges until the disputed invoice is paid in full. In the event such dispute is resolved in favor of Customei'l Provider shall provide Customer with a credit against future billing in the amount of the disputed

hi Iling. In the event that Customer fails to pay an invoice ill fulf because of a billing disputer Provider shall have the right! after giving Customer five (5) days prior written notice, to suspend all or anv portion of the Services until such time as the dispute is resolved or to require Customer to provide additional security deposit. Some disputed [tern may remain open for 30 days or more with mutual agreement if

3

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PL.EASE INITIAl

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AWS, Inc

Confidential

data is not provided on time but in case of non aqreement tile defaulted party must process the payments in full or settled amount.

The Pa rtles shall use reasonable efforts under the circumstances to maintain overall network quality. The quality of Service provided hereunder shall be consistent with other common carrier tndustrv : standards, government regulations and sound business practices.

THE PARTIES· MAKE \\10 OTHER WARRANTIES ABOUT THE SERVICE PROVIDED HEREUNDER, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO ANY WARRANTY OF fVlAR!<ETABIUTI OR FITNESS FOR (~ PARTICULAR PURPOSE OR USE.

a) The Provider shall not be responsible 01- Hable for any lnterruptlon,

diminution, or failure of service, in whole or in part! and in no event shall the Provide,r be responsible or liable for any Incidental or conseouential darnaqes incurred by Customer or any user of Customer'S service.

b) Customer shall Indemnify and hold the Provider harmless front and against

a!1 costs, expenses, losses! damages; claims and actions of any kind arisIng from 01" related to fraudulent calls of any nature which may comprise a portion of the Service to the extent that the Party claiming the call(s)in question to be fraudulent is (or was at the time of the call) a Customer or end-user of the Service. Customer shall not be excused from paying the Provider for Service provided to Customer, or any portion thereof, on the basis that fraudulent calls comprised a corresponding portion of tile Service.

c) The network is based on multi-vendor environment and calls made

througll the networks will be charged Or! standard bil\lng and customer is responsible to make adjustment in routing; quality of service and maintain its own Call Records on any Federal Issues and would not be excused on damages and responsible on all payments per billing standards.

1[\1 NO EVENT SHALL EITHER PARTY HERETO BE LIABLE TO THE OTHER PARTY FOR f.\i\JY INDIRECT, SPECIAL, INCIDEl\JTAL OR CONSEQUENTIAL L.OSSES OR DAMAGES, INCLUDING WITHOUT L1(v(ITATIONr LOSS OF REVENUEr LOSS OF CLIENTSr LOSS OF GOODWILL OR LOSS OF PROFITS ARISING IN ANY ~~ANl\JER FROM THIS AGREEl\iENT AND THE PERFORMANCE OR NONPERFORMfJJ\!CE OF OBLIGATION HEREUNDER.

No failure or omission by either Party to carry out or observe any of the terms and conditions of this Agl-eement, other than any payment obligation shall give rise to any claim against such Party or be deemed a breach of this Agreement if such failure or orntsston arises from an act of God, and act or omission of Government, insurrection of civil dlsorder, war or military operations, natlonal or local ernercencv. acts or omissions of Government, highway authority or other competent authority, industrial disputes of any kInd (whether or not involving the PaI-ty's employees), fire,

4-

Pl.E/~SE INITIAL

1\W5, Inc

Confidential

lighting1 explosion, flood, subsidence, inclement weather, acts or omissions of persons or bodies for whom the Party is not responsible.or any other cause whether strnllarordlsstmllar outside such Party's control.

Shall commence on the Effective Date and shall terminate either: 1) two years immediately following the termination of this Agl'eement, 01' 2) two years after the

term: nation or explretlon of any other Agreement between the Parties, whichever

occurs later, f\Jotwithstandingsuch expiration or termination, confidentiality

pursuant to this Agreement shall survive with respect to any Proprietary Information received prior to such expiration or termination for as long as the Proprietary Information remains confidential.

If any provision, subsection or sentence contained fn this Agreement is found to be. unenforceable in any respect, such unenforceabilttv shall not affect the other provisions of this Agreement, and this Agreement shall be construed as if such enforceable provision had never been contained herein.

Neither Party is authorized to act as an agent for, O( legal representative of, the other Party and neither Party shall nave the authority to assume or create any obllgation on behalf ot, in the name of', or" binding upon the other Party, Customer

shall not represent or intimate that Provider is responsible for the type or quality of

Customer's services to a third party customer. .

In the event payment In full is not received from either Party when duel the other Party shalt have the riqht, after gIving the defaulting Party one (1) day prior written notice, to suspend all or any portion of the. Service to the defaulting Party until such

tlrne as such Party has paid in full all charqes then due, IncludIng any late fees, interest and future value of the Dollar with inflation value may be asked including tile

rd

resources time reimbursement in such cases or a service acquired by 3 party on

behalf of rWI/S,

This Agreement and the Parties' described obllqatlons shall be binding on the representatives, assigns and successors of the Parties and shall Inure to the benefit of the assiqns and the successors of the Parties,

This Agreement 1I12Y not be modified, except by a written document Signed by authorized officers of the Parties hereto.

5

PLEASE INtTIAI,

AWS, Inc

Confidential

All notices, requests or other communications hereunder shall be in writing, addressed to the Parties at the address indicated In this Agreement or as otherwise stated In the relevant Annex hereto in respect of any parttcular Service. Notices mailed by registered or certified mail shall be deemed to have been received by the addressee on the fifth business day following the maIling or sending thereof. Notices sent by facsimile shall be deemed to have received when the delivery confirmation is received. Any notices of change of address shall be deemed to have been received onrv when actually received.

a)

In the case ofAWS Commurucettons, INC:

6405 103rd Street

Jacksonville, FL 32210-7129

b)

In the case of the Company:

200 NE Missouri Rd Suite 202, Lees Summit MO 64086

The failure to enforce or to require the performance at any time of any of tile provisions of this Agreement sna II not be construed to be a waiver of any other provision and shall not affect either the vaudttv of this I\greement or any part hereof

or the right of any Party thereafter to enforce each and every provision of this Agreement.

The headings in this Agreement are for reference purposes only and shat: not affect the meaning or interpretation of this Agreement

This Agreement shaH be interpreted, construed and governed tn accordance with the

federal laws of the United States of America and the laws of the state of f"lichiganj without regards to the choice of law principles thereof.

Any civil action or other legal proceeding arjsing out of or relatIng to this Agreement or any dealings between theParties' officers, directors; ernployees, or agents on the other nand, whether brought before or after any termination of this Agreement, shall be brought and heard only in a state or federal court located in Collin County r Texas and the Parties hereto expressly waive any rights under any law or rule to cause any such proceeding to be brought and heard III any other location. The Parties consent 'co jurisdiction in any state or federal court located in Collin County I Texas in any civil action or other Jega! proceeding arising out of or relating to this Agreement.

6

(:

AWS/_/"" Company ;"1,/"

'- .,'. '- .. ".

PLEASE IhHT!Al

AWS, inc

Confidential

This Agreement and the Schedules attached hereto set forth the full Agreement of the Parties with respect to the subject matter hereof, and supersede any prior Agreement or understanding.

ll\! WITf';lESS WHEREOF, each of tile Parties have executed this Agreement in duplicate, or caused this Agreement to be executed in duplicate by a duly authorized officer, as of the effective date above written.

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Page 2 of2

Delivery to the following recipients failed.

tOll1n1y.price@bdhhi.con1

F inal- Recipient; rfG822;JQmrnY.PIjG~.@bdhhLGQIn Action: failed

Status: 5.1.1

---------- Forwarded message ----------

From: chris greeo <chris@actiy_ationking_\Yi.reless.com>

To: ~Qsse.@tral1ZQJL.C_Om, s.h.~I.Q_Dbrown~c(}rolina.rr.com, shawn@tealnbuige.com, shebebrand@pappasprpoertiessllc.com, shilohfarms@ctc.net, shovelheadsrfun@yahoo.com, silk-=fun~lb~@att. blackberrY-.!Ilet, skg@_Skgoodman.! com, smithr@231~.81L!JDlb.~. CQffi, sQunY!.Grater@gmfl.il.!.QQIU, srQvbin.s@bellsQlJth.net, $l~.Y~~Ia.y@.rb.Q.~QQnl., steven@logicaladvantage.colTI, stevens7773@bellsouth.net, steveterpak@aoI.com,

susan. wolf@regions.coln, susan.wolfe@regions.coln, sweetoldbob56@yahoo.com, sy.dn~y'_bll~h@bel1s.QlJth!n.e_t, tb.il~k@a.Ql~~QJJJ, t_QhrisJ~nbJJIY1@QQmQ.as.t.n~t, tQ_Q~Y_@InihQ_m.e_$.!_.Q.Q_m., ted@gIobalverge.cOlTI, terribias@kw.con1, thesteingrou_, tina.wiggins@regions.com, tnboo@ctc.net, tom hapeman@yahoo.con1, tommeeler@sc.rr.com, tommy.price@bdhhi.com, .tQny.@sc.d.sinc~n_~t, tp_~Ikins@ha.let..rf1ilt;LQQm, tpt:.Ikin$@haletrai1~rs.~.QQm, tpl_186.@b~11sQ.1Jth!_n~J, traceyhowell@n1inds;Rring_!_Q_Qnl, troy@ervgordon.conl, t~~mll:els@nvrinc.coln, tw(q; 1 asmc.com, twhorton@vnet.net, ty(g),tyhensley.com, uniqlift@aol.com, usaprovidence@yahoo.com, wat~rlQ.rd@l1ibloG.khomes~Q_om, wbui@~gstoversurvey.com, wcukjb@aol.com,

~:u-rl1eyj r@aoI.conl" wbi t.nico le@hotlnail.con1, wjjliamlatta@ bellsouth.net

Date: Tue, 16 Feb 2010 17:20:00 -0600

Subject: Activation King Sues Global Verge for full disclosure

Due to the fact that corporate continues to lie about the stability of the company I want you to see this, This is filed for AKW to Sue GLOBAL VERGE INC. a Nevada S-Corp in Federal Court For full Disclosure, I know you will get a copy so let me say HI TED AND RUTH, how is it going over there, Well I can state that we just broke 3000 members and we have also signed members of the holy advisory board, So have a great day, OH WAIT CAN YOU HEAR THAT, THE TITANIC JUST HIT THE ICE BERG

Sincerely

Chris Greco

Who actually sells and meets deadlines in wireless.

4/12/2010