On Tuesday, October 13, 2026, Ronald Gerald Wayne filed a second amended complaint in the US District Court for the District of Nevada against Joann Coffey, KGU International LLC, JC Coffey Foundation, Inc., and ten unnamed defendants, alleging fraud, exploitation of an older person, and eight other claims. Wayne, 92, is representing himself in the case.
Wayne, identified in the filing as a Nevada resident who holds historically significant materials related to the formation of Apple Computer Company, says he was 91 during the events described. The complaint states that Coffey presented herself as an artificial intelligence consultant and as the leader of KGU, a Wyoming limited liability company registered in Florida, and the Foundation, a Florida nonprofit.
According to the filing, Coffey met Wayne and his advisor at the Consumer Electronics Show in Las Vegas in January 2025 and showed them a basic AI avatar of Wayne generated from a single photograph. Wayne alleges she said the defendants could build a fully trained avatar and a digital-legacy platform, produce products based on non-fungible tokens, or NFTs, and secure investors, donors and media coverage. The complaint says Wayne and his advisor agreed to plan an AI-avatar project and an “NFT-based digital-legacy system” with the defendants in reliance on those statements.
Wayne alleges the promised NFT work was a recurring inducement. He says Coffey urged an early June 2025 trip to New York City and a Florida trip from about June 18 to July 3, 2025, on the strength of promises that included NFT products, along with awards, investors and donors. He says he paid the main costs of both trips. At a June 8 meeting in New York, the complaint says, he and his advisor were presented with broad power-of-attorney documents naming an agent introduced through Coffey. They rejected the documents, according to the filing.
The complaint says Wayne signed a Consulting Services Agreement with KGU and, with Coffey, KGU and Charles A. Stigger, a Digital Legacy Revenue Sharing Agreement on or about July 3, 2025. It states that the written agreements and related arrangements contemplated NFT and digital-legacy products, among other services. Wayne alleges KGU warranted in the consulting agreement that it had the expertise and resources to perform, and that both documents were procured by fraud and are voidable.
Wayne alleges the defendants delivered no NFT product, NFT assets, blockchain integrations, or NFT marketplace. He says he received only basic avatar demonstrations or web presentations, some generated through third-party technology. He alleges Coffey’s statements about NFT-production ability were false or materially misleading when made, and that the defendants lacked the personnel, infrastructure, and technical capability to carry them out. The complaint does not specify what the tokens would have depicted or sold, nor does it give a dollar figure tied to the NFT work.
The filing also alleges that Coffey used Wayne’s Pahrump address as a business address for herself, KGU, and the Foundation without written consent, including in Workforce Nevada registrations after a July 25, 2025, meeting. It further alleges, on information and belief, that she acquired or controlled the expired domain reliancelaw.net, formerly associated with Wayne’s then-counsel, the next day.
The complaint’s ten causes of action are fraud, fraud in the inducement, breach of contract, unjust enrichment, exploitation of an older person under Nevada Revised Statutes 41.1395, conversion, declaratory and injunctive relief, rescission, intentional infliction of emotional distress, and civil conspiracy.
Wayne seeks compensatory and punitive damages, double actual damages under the exploitation statute, restitution, rescission of the agreements, a declaration that the defendants lack authority to use his name or identity, and injunctions. He also seeks attorney’s fees, interest, and a jury trial.
Please contact BlockTribune for access to a copy of this filing.
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