January 5, 2026
DISCLAIMER: THIS IS NOT LEGAL ADVICE AND THE FOLLOWING ARE NOT PROVEN FACTS, ONLY SUGGESTED ALLEGATIONS AT THE PLEADING STAGE THAT IF PROVEN MIGHT STATE A CLAIM AND BE CONSIDERED BY ATTORNEYS AS PART OF THE FOLLOWING PROPOSED CLASS ACTION. ALL READERS SHOULD CONSULT THEIR OWN ATTORNEYS.
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
WLBJ, et al.,
Plaintiffs,
v.
JPMORGAN CHASE & CO.; JPMORGAN SECURITIES LLC; CME GROUP INC.; CHICAGO MERCANTILE EXCHANGE INC.; PRESIDENT DONALD J. TRUMP, THE CENTRAL INTELLIGENCE AGENCY (CIA), UNITED STATES FEDERAL RESERVE, THE COMMODITIES FUTURES TRADING COMMISSION (CFTC) UNKNOWN COMMODITIES TRADERS (JOHN DOES 1–20); UNKNOWN REGULATORY OFFICIALS (DOE REGULATORS 1–10); UNKNOWN FEDERAL RESERVE OFFICIALS (DOE FED 1–10); UNITED STATES OF AMERICA; and DOES 1–50,
Defendants.
COMPLAINT FOR DAMAGES, DECLARATORY RELIEF, AND INJUNCTIVE RELIEF
(Jury Trial Demanded)
I. INTRODUCTION
1. This is a civil action arising from an alleged coordinated scheme involving major financial institutions, derivatives exchanges, federal regulators, and executive actors, to manipulate commodities markets, conceal systemic insolvency, override contractual delivery obligations, and use extraordinary governmental power—including alleged extraterritorial abduction—as a pretext to secure strategic natural resources, including silver and oil.
2. Plaintiffs allege that It has long been alleged that CME Group/the Comex and JP Morgan operate a paper casino Ponzi scheme called the silver futures market used to manipulate and suppress the physical price of silver, repeatedly driving the price down after allowing it to rise, shaking weak holders out of the market, only to allow JP Morgan and other big institutions to buy up much of the silver at the lowest prices. Attempts to defeat this scheme in the courts have failed largely due to poor pleading and framing of the complaints which have ended in dismissal.
3. Plaintiffs also allege upon information and belief that the nation of China (along with millions of Americans) has become fed up with the silver futures market manipulation and suppression of the price of physical silver and as a result China has recently frozen all exports of physical silver from its country. This was done specifically to expose the alleged fraud within JP Morgan and The LBMA as well as the Comex, who repeatedly claim to have the proper amount of silver on hand to cover all the silver futures contracts when in fact they have allegedly been lying about this.
4. Plaintiffs allege that Defendants formed an enterprise within the meaning of 18 U.S.C. § 1961(4) that engaged in racketeering activity, market manipulation, fraud, conspiracy, and obstruction, resulting in massive economic harm to market participants and the unlawful consolidation of financial and geopolitical power as a way to retaliate against China and secure the needed silver to compensate for China’s refusal to sell the united states any more silver.
5. Plaintiffs do not allege a single isolated act. Rather, they allege a pattern of conduct: repeated margin hikes, clustered emergency liquidity operations, rule changes during delivery periods, and extraordinary governmental intervention, all temporally aligned and allegedly designed to protect short-side institutional exposure while destroying long-side counterparties, and retaliate against China for exercising their rights to refuse to sell silver to the Comex and JP Morgan allegedly exposing their financial and commodity crimes.
6. Plaintiffs allege that the kidnapping of Venezuelan President Maduro and his wife and taking over Venezuela natural resources by the US defendants, effectively cripples or controls Venezuela, a major trading partner with China, putting the US in a position to refuse to sell oil to China in hopes to force China to resume the sale of silver to JP Morgan and the CME group and presumably the LBMA as well.
7. Plaintiffs allege the seizing of Venezuelan resources also benefits the US in other ways such as forcing China to abandon Russian oil contracts by also agreeing to sell oil to China at dirt cheap prices putting pressure on Russia to end the Ukraine war. If China refuses to cooperate The defendants are simultaneously attacking China’s oil supply effectively seizing that which Venezuela has been trading with China, in retaliation for China allegedly attacking the United States Silver supply, with many more possible advantages for the U.S.
8. Plaintiffs also allege that the alleged kidnapping of Venezuelan President Maduro and his wife and taking over Venezuela natural resources by the US defendants constitutes a violation of International law and U.S. Law, Inter alia, Rico as like him or not, Maduro and his wife are protected by Sovereign Immunity. Defendants engage in election interference of Venezuela’s closed and litigated elections by refusing to recognize that like him or not, Venezuela has accepted Maduro as their president and put the election in their past and what defendants are doing by refusing to recognize Maduro as the legal president of Venezuela is no more legal than any other country kidnapping George Bush Jr. at the time the Supreme Court declared him the winner over Al Gore. Venezuela had a sovereign right to decide their own election and the defendants do not have a right to suddenly declare that election illegitimate as a pretext for grounds to kidnap Maduro and somehow surmount Maduro's sovereign Immunity. That is wickedness and an abominable insult to common sense and the rule of law, especially waiting 12 years to take action and make such utterly ridiculous and offensive claims. Instead, the court will find plaintiff’s claims to be the real unlawful motives for defendants' reprehensible actions and plaintiffs demand immediate relief as defendants are so out of control, they have lost their minds and forgotten how to blush.
II. STANDING
9. Plaintiffs and those similarly situated are purchasers, holders, and investors in physical silver and silver-linked instruments who entered the market with the reasonable expectation that the price of silver would be determined by lawful supply and demand dynamics. Plaintiffs purchased and held silver in reliance on transparent price discovery, including rising industrial demand, constrained physical supply, and publicly reported inventory levels, all of which would have caused the price of silver to rise absent Defendants’ unlawful conduct.
10. Plaintiffs suffered concrete economic injury because Defendants’ coordinated manipulation artificially suppressed the price of silver below its natural market level, depriving Plaintiffs of the appreciation, returns, and investment gains they reasonably expected and would have realized but for Defendants’ actions. Plaintiffs paid distorted prices, received suppressed returns, and were denied the benefit of a free and lawful market.
11. As a direct result of Defendants’ extraordinary margin hikes, emergency rule changes, and liquidity interventions, Plaintiffs and similarly situated investors were forced to liquidate positions prematurely, exit the market at depressed prices, or forego additional purchases they otherwise would have made, causing further economic loss.
12. Plaintiffs’ injuries are fairly traceable to Defendants’ conduct, including coordinated margin increases, suppression of physical delivery, concealment of supply shortfalls, and regulatory actions favoring institutional short positions, all of which directly distorted silver prices and injured Plaintiffs in their capacity as market participants.
13. Plaintiffs’ injuries are redressable by this Court through damages, disgorgement, injunctive relief, and structural remedies restoring lawful price discovery, enjoining further manipulation, and compensating Plaintiffs for losses caused by Defendants’ unlawful scheme.
14. Plaintiffs bring this action on behalf of themselves and all similarly situated silver purchasers and holders who were injured by Defendants’ manipulation of the silver market, including individuals and entities who purchased silver or silver-linked instruments at artificially suppressed prices or were forced to liquidate positions due to Defendants’ conduct.
II. JURISDICTION AND VENUE
15. Jurisdiction is proper under 28 U.S.C. §§ 1331, 1337, and 1964, and supplemental jurisdiction under 28 U.S.C. § 1367.
16. Venue is proper in this District because substantial acts in furtherance of the alleged scheme occurred here, including commodities trading, clearing activity, regulatory decision-making, and alleged coordination involving entities subject to SDNY jurisdiction.
III. PARTIES
17. Plaintiffs are SILVER commodities market participants harmed by alleged manipulation, forced liquidation, deprivation of delivery rights, and fraudulent market practices.
18. Defendant JPMorgan Chase & Co. is a multinational banking institution with extensive commodities exposure.
19. Defendant CME Group Inc. owns and operates major U.S. derivatives exchanges, including COMEX. @CMEGroup
20. Defendant United States of America, @realDonaldTrump is named solely for declaratory and injunctive relief related to alleged ultra vires actions.
21. The Central Intelligence Agency (CIA), Unknown CIA Does. @CIADirector
22. The (Chicago) Federal Reserve, Unknown Fed Does
23. The Commodity Futures Trading Commission (CFTC), Unknown CFTC Does, @CFTC
24. Doe Defendants also include unidentified traders, regulators, central bank officials, and executive agents whose identities are presently unknown.
IV. FACTUAL ALLEGATIONS (ALLEGED)
25. During a compressed time window, specifically during the month of December, 2025, Defendants allegedly imposed four margin hikes within a single week on silver futures contracts—an event Plaintiffs allege is historically unprecedented.
26. Plaintiffs allege these margin hikes were implemented during periods of rising prices and approaching delivery windows, triggering forced liquidations and cascading sell-offs.
27. Plaintiffs further allege that these margin increases disproportionately harmed long-position holders while insulating or benefiting large institutional short positions.
28. Plaintiffs allege that multiple large-scale Federal Reserve repo operations were conducted in close temporal proximity to the margin hikes.
29. Plaintiffs allege that the timing and scale of these liquidity injections support an inference that certain financial institutions faced acute collateral stress linked to commodities exposure.
30. Plaintiffs allege that COMEX “registered” silver inventory was materially insufficient to meet outstanding delivery obligations.
31. Plaintiffs allege that Defendants relied on in-transit or unverified metal while continuing to sell futures contracts implying immediate deliverability.
32. Plaintiffs allege that on or about December 31, 2025, at approximately 2:14 PM EST, a Gulfstream aircraft departed JFK Airport carrying senior commodities personnel affiliated with JPMorgan, along with at least one individual alleged to be affiliated with the CFTC and one with the Chicago Federal Reserve.
33. Plaintiffs allege the aircraft traveled to Hong Kong, then onward to mainland China, where meetings were allegedly sought with Chinese officials to secure large quantities of physical silver.
34. Plaintiffs allege that these efforts were unsuccessful.
35. Plaintiffs allege that such joint travel, if proven, constitutes evidence of direct coordination between regulated entities and regulators for non-market purposes.
36. Plaintiffs allege that shortly thereafter, the United States engaged in an extraterritorial seizure of Venezuelan President Nicolás Maduro and his spouse.
37. Plaintiffs allege that U.S. officials publicly characterized the action as a law-enforcement operation, while simultaneously making statements indicating intent to assume control over Venezuela’s governance and resource infrastructure.
38. Plaintiffs allege that public statements attributed to President Donald J. Trump included assertions that the United States would “run” Venezuela, rebuild its oil infrastructure through U.S. companies, “we (meaning the United States) will sell oil to China”, and later “return” control. All said on National TV in his press conference in front of the entire world.
39. Plaintiffs allege that this conduct supports an inference that criminal charges were used as a pretext for regime control, resource access, and retaliation against China for refusing to sell oil to JP Morgan, The CME group/Comex, and other US affiliated partners such as the LBMA, in order to expose the defendants for their criminal activity.
40. Upon information and belief, and based on contemporaneous eyewitness reporting from Venezuelan journalist Andrea Nach Chavez, who stated she was physically present in Caracas beginning at approximately 2:00 a.m. local time on the morning of the alleged seizure of President Maduro, there were no массов public celebrations in the streets of Caracas following the alleged U.S. military action.
41. Chavez stated that she personally observed confusion, fear, civilian displacement, and denunciations, not celebration, and that the streets were largely calm, with residents focused on securing water, food, and safety rather than engaging in demonstrations of support for U.S. action.
42. Chavez further reported that U.S. strikes impacted mixed-use areas containing civilian residences, including but not limited to areas identified as Fortuna, which she stated is not solely a military complex but also a residential neighborhood, resulting in civilian harm.
43. Chavez stated that explosions and aircraft activity were audible throughout the night, beginning in the early morning hours, and that Venezuelan authorities subsequently confirmed multiple strike locations within Caracas.
44. Chavez reported that individuals gathered near Miraflores Palace publicly denounced the removal of President Maduro as a kidnapping, not an arrest or capture, stating that no Venezuelan judicial process had occurred and demanding proof of life and his return.
45. Chavez further reported that demonstrators asserted President Maduro remains the elected President of Venezuela and that his removal occurred without domestic legal authority.
46. Chavez explicitly disputed claims circulating in U.S. media depicting Venezuelans celebrating in the streets, stating that such portrayals do not reflect conditions on the ground, and warning Venezuelans against what she described as psychological operations and misinformation campaigns circulating on social media and foreign broadcasts. Evidence of fake A.I generated videos proving this can be seen here: https://x.com/Shayan86/status/2007878255135887709?s=20
47. Upon information and belief, following the alleged seizure/removal of Venezuela’s head of state, Defendants and/or persons acting in concert with them disseminated or caused to be disseminated misleading audiovisual media—including miscaptioned, recycled, and/or AI-generated video—portraying Venezuelans as celebrating the alleged U.S. action, in order to manufacture consent, suppress opposition, and provide political cover for the alleged regime-control and resource-seizure objectives.
48. Plaintiffs allege that such information operations are consistent with documented patterns of disinformation surrounding #Venezuela -related events and narratives reported in public sources.
49. Upon information and belief, one or more intelligence-affiliated Doe Defendants participated in, directed, or materially supported the foregoing information operations. Plaintiffs plead these facts on information and belief because the details of such activities are uniquely within Defendants’ possession and will require discovery, including subpoenas to social media platforms, contractors, and relevant government offices.
50. Plaintiffs further allege that U.S. intelligence agencies have historically maintained relationships with media actors and have engaged in covert influence operations, as documented by official investigations such as the Church Committee, supporting the plausibility that intelligence-linked actors could be involved in information operations in the present matter.
51. Plaintiffs further allege that allegations of intelligence-community awareness of, and failures to interdict, narcotics trafficking connected to foreign operations have been the subject of congressional inquiry and Inspector General review, demonstrating that illicit finance and covert operations have been publicly alleged and officially examined in prior eras.
52. Chavez further reported that Venezuela’s Vice President Delcy Rodríguez, along with senior civilian and military officials, held a press conference stating that the Venezuelan government and armed forces remained intact, unified, and operational, and that President Maduro ( @NicolasMaduro) continued to be recognized domestically as President.
53. Chavez stated that Venezuelan officials and civilians uniformly characterized the U.S. action as regime change, asserting that the stated justifications relating to narcotics trafficking were pretextual and unsupported by publicly presented evidence, and that the true motive was foreign control over Venezuela’s political and economic life, including its natural resources.
54. On information and belief, and based on testimony delivered to the United Nations Security Council by Professor Jeffrey Sachs on [date], Defendants’ conduct constitutes the threat or use of force against the territorial integrity and political independence of Venezuela, in violation of Article 2(4) of the United Nations Charter, absent authorization by the UN Security Council or lawful self-defense.
55. Professor Sachs testified that the United States has engaged in a documented pattern of regime-change operations since 1947, including covert action, economic coercion, and military force, and specifically identified Venezuela as a continuous target since at least 2002, supporting Plaintiffs’ allegations of motive, intent, and pretext underlying Defendants’ actions.
56. Professor Sachs testified that the United States unilaterally froze approximately $7 billion in Venezuelan sovereign assets and recognized an alternative political authority without Security Council authorization, actions he characterized as part of an unlawful regime-change effort.
F. Alleged Silver and Resource Motive
57. Plaintiffs allege that Venezuela possesses significant untapped mineral reserves, including silver, which has been significantly under reported in quantity and said silver reserves were allegedly sought as emergency supply to stabilize U.S. derivatives markets and to resupply the missing silver in the Comex and within JP Morgan supplies before defendants were exposed as having defaulted and committed fraud.
58. Plaintiffs allege however that prior to the seizure, upon information and belief, foreign actors, mainly China and Russia, allegedly removed substantial quantities of Venezuelan #Silver estimated at about 4 million ounces, before the US could get their hands on it.
59. Professor Sachs further testified that unilateral U.S. sanctions imposed on Venezuela, including sanctions on its state oil company, resulted in catastrophic economic collapse and constituted economic warfare not authorized by the UN Security Council, which he stated violates international law governing unilateral coercive measures.
V. RICO ALLEGATIONS (18 U.S.C. § 1962)
60. Defendants formed an association-in-fact enterprise.
61. The enterprise’s purpose was to prevent delivery failure, conceal insolvency risk, suppress prices, maintain institutional dominance, retaliate against China for attempting to expose defendants fraud by freezing Chinese silver exports, and to control China to also be able to Control Russia and leverage the entire world with dominant oil reserves.
62. Predicate acts include alleged wire fraud, commodities manipulation, obstruction, and interstate conspiracy.
63. Defendants’ conduct constitutes a pattern of racketeering activity.
64. Professor Sachs testified that recent U.S. military actions involving Venezuela were not authorized by the UN Security Council and were not undertaken in lawful self-defense, rendering such actions unlawful under the UN Charter.
VI. RICO ALLEGATIONS (18 U.S.C. § 1962(c) and (d))
65. Defendants JPMorgan Chase & Co., JPMorgan Securities LLC, CME Group Inc., Chicago Mercantile Exchange Inc., together with Doe Defendants, associated together for a common purpose and formed an association-in-fact enterprise within the meaning of 18 U.S.C. § 1961(4).
66. The enterprise had relationships among its members, longevity sufficient to pursue its purpose, and operated as a continuing unit.
67. The purpose of the enterprise was to suppress the market price of silver, prevent or delay physical delivery obligations, protect short-side institutional exposure, and unjustly enrich Defendants at the expense of Plaintiffs and similarly situated market participants.
68. Defendants conducted and participated, directly and indirectly, in the conduct of the enterprise’s affairs through a pattern of racketeering activity, in violation of 18 U.S.C. § 1962(c).
69. The pattern of racketeering activity included, but was not limited to wire fraud, commodities manipulation and fraud, and acts in furtherance of conspiracy.
70. These predicate acts were related, continuous, and posed a threat of continued criminal activity.
71. Plaintiffs were injured in their business or property by reason of Defendants’ RICO violations.
VII. ADDITIONAL CLAIMS
72. Commodity Exchange Act Violations (7 U.S.C. §§ 1 et seq.)
Defendants engaged in manipulation, attempted manipulation, and employed deceptive devices in connection with futures trading, causing artificial prices and market distortion.
73. Civil Conspiracy
Defendants knowingly agreed and acted in concert to carry out unlawful acts and lawful acts by unlawful means, resulting in harm to Plaintiffs.
74. Fraud and Misrepresentation
Defendants made material omissions and misrepresentations regarding deliverability, inventory sufficiency, and market integrity, upon which Plaintiffs reasonably relied.
75. Unjust Enrichment
Defendants were unjustly enriched by retaining profits obtained through market manipulation and price suppression at Plaintiffs’ expense.
76. Tortious Interference
Defendants intentionally interfered with Plaintiffs’ prospective economic advantage by distorting supply-and-demand pricing mechanisms.
77. Abuse of Process
Defendants misused regulatory and governmental processes for ulterior purposes unrelated to legitimate market regulation.
VIII. PRAYER FOR RELIEF
WHEREFORE, for the foregoing reasons, Plaintiffs respectfully request that this Court:
A. Declare that Defendants’ conduct violated the Commodity Exchange Act, RICO, and other applicable federal laws;
B. Enjoin Defendants from continuing any practices that artificially suppress silver prices or interfere with fair market operations;
C. Order Defendants to disgorge all ill-gotten gains obtained through the alleged misconduct;
D. Award Plaintiffs compensatory damages in an amount to be proven at trial;
E. Award treble damages and costs, including reasonable attorneys’ fees, pursuant to 18 U.S.C. § 1964(c);
F. Grant appropriate declaratory and injunctive relief to prevent future violations;
G. Grant such other and further relief as the Court deems just and proper.
Respectfully Submitted, January 5, 2026
Counsel For Plaintiff’s WLBJ Et. Al.