The only evidence presented to suggest that Rick Maike and Doyce Barnes intentionally set out to create a pyramid scheme was a compensation plan projection shared via email from Barnes to Maike. Creating a compensation plan and defining product packages is a crucial part of planning when establishing any multi-level marketing (MLM) company. The government emphasized that no products were mentioned in the projection, which listed package amounts of $100, $400, $600, and $5,000, but failed to specify the products. Their argument was that this omission indicated that products were not essential to the business model, implying it was a pyramid scheme from the outset.
The claim was misleading because the email included product attachments and long-term customer acquisition plans for an online casino model. One of the attachments was exhibit “503b,” an early I2G business plan that the government used as evidence to demonstrate the roles of Maike and Barnes within I2G. However, the government did not disclose that 503b outlined the strategy for attracting customers to an international online casino through a multi-level marketing (MLM) approach.
This point was supported by Reynolds, who discussed the System Integration Plan (SIP) provided by Maike, which focused on product sales requirements and instructed the system to track customer usage in the casino, directly tied to distributor rewards or commissions. The SIP emphasized the crucial role of product sales in activating, qualifying, and advancing through the I2G compensation plan without relying on recruitment. Reynolds established the entire system, allowing individuals to activate, qualify, and advance within it solely based on customer usage of digital products, which was determined by business volume, much like when a distributor purchased a product package. This was the excitement of the plan, and as Reynolds explained, driving people to play the casino was the whole point. Reynolds consistently corrected Sewell when he attempted to assert that the plan was centered on recruitment. Reynolds clarified that the plan was based on product sales, which accounted for 90% of I2G’s sales.
You be the judge. We have attached 503 B included with the compensation plan projections. You can read the plan and mission statement with its focus on customer acquisition in an online casino.
The arguments regarding Barnes or Hosseinipour’s knowledge or intent, written by Philip Cecil and Kenyon Meyer for the appeal, are compelling. I have attached the original broader arguments, which faced numerical constraints during the appeal, necessitating word reductions.