DISTRICT COURT OF THE STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
ALEXANDERLUTHORJR and 0XSYNS,
on behalf of themselves and all others
similarly situated,,
-against-
AB_BAE, in her official capacity as
Secretary of State of Ridgeway,
Defendant.
Case No. tbd
COMPLAINT
Plaintiffs, AlexanderLuthorJr and 0xSyns, on behalf of themselves and all others
similarly situated, bring this action for damages and injunctive relief against Defendant,
ab_bae, in her official capacity as Secretary of State, and allege as follows
JURISDICTION AND VENUE
1. This court has original jurisdiction over “all civil and criminal cases or
controversies.” Rid. Const. art. 5, § 4.
2. Venue is proper in this Court as the events giving rise to this Complaint occurred
within the State of Ridgeway.
PARTIES
3. Plaintiff AlexanderLuthorJr is an individual and citizen of Ridgeway who has
submitted a business registration request to the Department of State and has
suffered financial harm due to the Defendant's failure to act upon it.
4. Plaintiff 0xSyns is an individual and citizen of Ridgeway who has submitted a
business registration request to the Department of State and has suffered financial
harm due to the Defendant's failure to act upon it.
5. Defendant ab_bae is the Secretary of State of Ridgeway. A primary and inherent
duty of her office is the administration and timely processing of business
registration applications for the State. She is sued in her official capacity pursuant to
1 R. Stat. § 3114.
CLASS ACTION ALLEGATIONS
6. Plaintiffs Plaintiffs bring this action on behalf of a class of all persons and entities
who have submitted a business registration application to the Ridgeway
Department of State on or after July 11, 2025, and have not received approval or
denial of said application.
7. This action is properly maintained as a class action because:
A. The class is so numerous that joinder of all members is impracticable. Upon
information and belief, there is a “huge backlog” affecting a large number of
aspiring business owners.
B. There are questions of law and fact common to the class, namely whether the
Defendant's failure to process applications constitutes official misconduct and
what remedies are appropriate.
C. The claims of the named Plaintiffs are typical of the claims of the class members.
All members have been harmed by the same wrongful inaction.
D. The named Plaintiffs will fairly and adequately protect the interests of the class.
FACTUAL ALLEGATIONS
8. The laws of Ridgeway require individuals to register their businesses with the
Department of State before they can legally operate.
9. A fundamental and non-discretionary duty inherent in the office of the Secretary of
State is to review and render decisions on such applications in a timely manner.
10. Defendant ab_bae officially took office as Secretary of State on July 7, 2025.
11. On July 11, 2025, the Department of State, under the direction of the Defendant,
opened the business registration process to the public.
12. On that same day, July 11, 2025, both Plaintiff AlexanderLuthorJr and Plaintiff
0xSyns submitted complete and accurate business registration requests to the
Department of State.
13. As of the filing of this complaint on July 24, 2025, thirteen (13) days have passed
since the Plaintiffs submitted their applications. During this time, Defendant ab_bae
has failed to approve or deny any applications.
14. Upon information and belief, Defendant has failed to approve or deny any
applications since the registration process opened, creating a massive and harmful
backlog.
15. This inaction is not the result of a complex review but is a wholesale failure to
perform a core duty of the office.
16. As a direct result of Defendant’s failure to act, Plaintiffs and all class members are
legally barred from operating their businesses, causing concrete and ongoing
financial injury, including lost profits, lost opportunities, and or a general inability
to enter the marketplace.
FIRST CAUSE OF ACTION (Official Misconduct - 1 R. Stat. § 3114) (Against
Defendant ab_bae in her Official Capacity)
17. Plaintiffs reallege and incorporate by reference the preceding paragraphs.
18. Defendant ab_bae is a public servant, and the timely processing of business
applications is a duty “clearly inherent in the nature of [her] office.”
19. By failing to process any applications and allowing a huge backlog to accumulate,
Defendant has refrained from performing this duty.
20. This failure constitutes an unauthorized exercise—or non-exercise—of her official
functions, for which she is liable under 1 R. Stat. § 3114.
21. As a direct result of this official misconduct, Plaintiffs and the class have suffered
concrete injury in the form of lost income and the inability to lawfully conduct
business.
WHEREFORE, Plaintiffs respectfully request that this Court enter judgment in their
favor and against Defendant ab_bae as follows:
A. Certifying this case as a class action;
B. Issuing a declaratory judgment that the Defendant's failure to process business
applications in a timely manner constitutes official misconduct in violation of 1
R. Stat. § 3114;
C. Issuing a permanent injunction and writ of mandamus ordering Defendant and
her officers, agents, and employees to immediately resume processing all
pending and future business applications in a timely fashion;
D. Awarding compensatory damages to the Plaintiffs and all class members for
their financial losses, to be paid by the government as required by 1 R. Stat. §
3114(iii);
E. Awarding punitive damages against Defendant ab_bae personally for her willful
disregard of her official duties, in an amount up to the statutory maximum of
$6,000 per violation, pursuant to 1 R. Stat. § 3114(ii)-(iii);
F. Awarding the costs of this action, including reasonable attorneys’ fees; and
G. Granting any and all other relief that this Court deems just and proper.
Respectfully submitted,
Dated: July 24, 2025
/s/0xSyns
0xSyns
