Titanium Blockchain Infrastructure Services Inc.

As alleged by the United States Securities and Exchange Commission, Titanium President Michael Alan Stollery, a/k/a Michael Stollaire, lied about business relationships with the Federal Reserve and dozens of well-known firms for purposes of promoting an Initial Coin Offering (“ICO”). Titanium’s website contained fabricated testimonials from these supposed corporate customers. These fraudulent statements were used to promote the ICO, which Stollaire advertised through videos and social media. The SEC's complaint charged Stollaire and Titanium with violating Sections 5(a), 5(c), and 17(a) of the Securities Act of 1933 and Section 10(b) of the Securities Exchange Act of 1934 and Rules 10b-5(a) and 10b-5(c) thereunder. The complaint charged another Stollaire company, EHI Internetwork and Systems Management Inc., with violating Section 17(a) of the Securities Act and Section 10(b) of the Exchange Act and Rules 10b-5(a) and 10b-5(c) thereunder.

You may be eligible to submit a claim if you:

(i) are a creditor of Titanium;

(ii) directly purchased Titanium Bar (“BAR”) or TBAR from Titanium;

(iii) purchased BAR from a third party (other than Titanium) prior to February 22, 2018, held such BAR through February 22, 2018, received TBAR from Titanium by virtue of your BAR holdings, and held such TBAR through May 29, 2018; or

(iv) purchased TBAR from a third party (other than Titanium) prior to May 29, 2018 and held such TBAR through May 29, 2018.

How Do I Submit a Claim?

The deadline for submitting a claim to the TBIS Estate was 11:59 p.m. (Pacific Time) on August 11, 2021. The online claim filing system is now closed. Individuals or entities with further questions should direct their correspondence to the Receiver at tbis@hklaw.com.

Deadline for Submitting Claims

NOTICE IS HEREBY GIVEN that all people with potential claims for recovery from the TBIS Estate should file their claim with the Receiver so that it is actually submitted on the Receiver’s online claim system, by 11:59 p.m. (Pacific Time) on August 11, 2021 (the “Bar Date”). Claims should be filed electronically through this online claim system.

Individuals or entities that believe they have good cause to either extend the Bar Date or to submit their claim by other means should request this from the Receiver at tbis@hklaw.com no later than the Bar Date. Unless a claim is subject to a Receiver-granted exception, all claims against TBIS Estate assets that are not received by the Bar Date are barred.

Frequently Asked Questions

A link to FAQ’s with respect to the Claim Process can be found here.

A link to step-by-step instructions for setting up MetaMask for the token validation process can be found here.

Except for a small number of claims, all validated claimants should have received a notice of determination. If you have not received a notice, we will be contacting you directly by email to obtain additional information about one or more transactions that affect the calculation of your claim. If you have not received a notice of determination and we do not contact you for additional information before the close of business on Friday, January 21, 2022, then please email tbis@hklaw.com. Please make sure to include “Notice of Determination Pending” and you claim number in the subject line of the e-mail.

Objections to Initial Determinations

If you already filed an objection to your initial notice of determination, we expect to provide an initial response to your objection on or before January 28, 2022. Please disregard the 60-day requirement to file an objection with the court set out in your notice of determination. We are extending that deadline to the date that is thirty (30) days after the date we notify you of our decision to accept or deny (in whole or in part) your objection.

Payment of Claims in ETH

A number of claimants have communicated to us a desire to receive their awards in the form of ETH, and as a result, we have incorporated a mechanism in our proposed plan of distribution to permit payment of claim awards to token purchasers in ETH. Please note that the plan of distribution must still be approved by the court (see below on status).

We have completed a draft plan of distribution, which we will be transmitting to the SEC on Tuesday (as today is a U.S. holiday) for review and comment. Our goal is to incorporate any feedback from the SEC by the end of next week and file the plan with the court immediately thereafter. Once filed, we will upload a copy of the submitted plan of distribution to the tbis.io website. We expect that it will take the court at least a few weeks to consider and rule on the proposed plan of distribution. During this period of time, we expect to finish resolving any outstanding claims. For those who wish to receive their award in ETH, you do not need to do anything at this time. Prior to any distributions, we will set up a procedure for individual claimants to choose how they wish to receive their award; and for those who elect to receive ETH (again, assuming our plan of distribution is approved by the court), a secure means for those claimants to communicate a wallet address to receive their award.