1
IN THE RIDGEWAY SUPERIOR COURT
STATE OF RIDGEWAY,
Plaintiff,
v.
C_RYP1C, an individual, AVENGER
REAL ESTATE, a limited liability
company, THEAVENGERNICK, an
individual,
Defendants.
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
CIVIL COMPLAINT
Civil Case No.
FACTUAL BACKGROUND
I. THE LAW
On June 26th, 2024, Governor Matrix_oc signed the Fair Housing Act of 20241 (hereinafter
“FHA”) into law. This landmark piece of legislation was written, in the words of its writer, to
“encourage free and open competition in the real estate market while ensuring housing market
integrity and maintaining appropriate standards of homeowner decency.” Prior to the FHA,
housing was nearly unattainable for most Ridgewayians. Prices for entry-level homes, even small
condos exceeded $50,000.00, not including the rent that must be paid to retain ownership of that
property. With housing so scarce within our State, homebuyers were practically forced into paying
astronomically large premiums to sellers. Thus, this landmark piece of legislation was introduced,
which capped the prices of housing, and established penalties for those who choose to ignore those
prices and other restrictions.
1 Read the Fair Housing Act of 2024 here:
https://drive.google.com/file/d/13khf4YXtapphDWDOIBM5GtTyxBCFXZCV/view
2
The FHA does many things, including but not limited to: (1) setting a price limit on homes for
sale, (2) prevent monopolization of the real-estate market, and (3) establish penalties for those who
violate the FHA.
What is applicable in this case, is the price limit, or “cap” on all home sales within the state.
This cap is established in Section 4 of the FHA, where it reads: “There shall be a sales cap of no
more than 20% above the current average home price (as determined by local sales data and state
reports) on all home sales. This includes private transactions between individuals and sales
conducted by real estate persons or entities.2” The current average home price is compiled by the
Ridgeway Department of State at the beginning of each month, and published, which sets the sales
price limit for the month to follow. A new average home price is calculated at the beginning of each
month, after reviewing the average home price throughout the State of Ridgeway.
The FHA alongside setting the price limit on homes, establishes penalties for those who violate
those limits. The FHA, in Section 3, allows the Department of Justice to initiate civil litigation
against businesses who violate the FHA. “If a business conducts or otherwise facilitates a sale that
exceeds more than twenty percent (20%) of the monthly price average, the business shall be subject
to civil liability, and liable for civil penalties, including equitable and declaratory relief by a court of
competent jurisdiction […].3” But in the cases of individuals, they can still be found in violation of
the FHA and be subjected to penalties. “If a court of competent jurisdiction finds that a person has
committed any transgression prohibited by section four, subsections (a) to (c), the court may require
such person to pay to the state a civil penalty […]4”
II. THE BEGINNINGS
On July 1st, 2024, at 8:31 PM EST, the Secretary of State published the first Monthly Home
Average Report5. In this report, the Secretary of State outlined that thirty-six (36) homes were sold,
with the median price being $23,810.00, thus, establishing the price cap for the month of July as
$28,572.00. This price cap was enforceable the day it was published.
2 Ibid.
3 Ibid.
4 Ibid.
5 Monthly Home Average Report: https://drive.google.com/file/d/1bRzltSOPPz3l2gLg_kz1Elwa5Q9fSnul/view
3
III. MISTRUST AND DECEPTION BY DEFENDANTS
Avenger Real Estate, a company owned by TheAvengerNick, is one of the primary facilitators
of unlawful and unfair real-estate practices in Ridgeway. Avenger Real Estate operates in a Discord
of roughly 300 members. Many real-estate deals have been conducted via this server since its
inception by TheAvengerNick in February of 2024. Within this server, individuals can find
information about the occupancy status of various properties, be reminded about upcoming
evictions, and see available housing.
Beyond these seemingly innocuous services, Avenger Real Estate goes further in offering a
forum for anyone to list their property for sale, this is within their “estate-exchange” channel.
Within this channel, Avenger Real Estate has allowed for multiple homes to be listed, some directly
in violation of the FHA.
This is where we find the listing of a user by the name of c_ryp1c, which exemplifies the
disregard of Avenger Real Estate and their want, or lack thereof, to follow the law. c_ryp1c, on July
9th, listed their home on 1325 Rodgers Lane, Oakland, Ridgeway, for a whopping $50,000.00, which
is $21,428.00 over the allowable price.
But the blame does not solely lie with the sellers, Avenger Real Estate has taken no action to
protect their members from unlawful conduct. Avenger Real Estate have a plethora of tools
available to them to moderate their Discord server. They could establish rules prohibiting unlawful
listings, delete unlawful listings, or remove members who post unlawful listings, but they choose
not to. As a result of their wanton disregard for the rights of the consumer, unlawful listings remain
viewable, and consumers are put in jeopardy.
Avenger Real Estate claims to be the consumers “trusted partner in navigating the world of
homeownership6”, yet they are facilitating anti-consumer and unlawful conduct in their business,
which their Discord acts as pursuant to their Articles of Organization7. Avenger Real Estate also
admits that the Discord, which is their “location of the organization”, is operated by
6 Avenger Real Estate Server Information: https://prnt.sc/2LUKYP32aWCX
7 Avenger Real Estate Articles of Organization: https://drive.google.com/file/d/1rkwPq3fL_-
of U8eFFeJlPGGbMcYbINgX/view
4
TheAvengerNick8. Avenger Real Estate also claims to “[provide] up-to-date information regarding
house availability and strive to provide you with accurate information so that you can make an
informed decision9.” Avenger Real Estate does nothing of the sort, they continue to act as an illegal
facilitator for unlawful real-estate deals, which directly harm the consumer, and make the members
who they pledge to “empower”, poorer. Instead of moderating listings and attempts to sell homes
which obviously violate the FHA, Avenger Real Estate through TheAvengerNick ignore these
listings, and let the consumers pay the price, literally and figuratively.
Although Avenger Real Estate is responsible for their wanton facilitation of unlawful business
practices, so is the seller, c_ryp1c. c_ryp1c is a member of both the Avenger Real Estate Discord,
which is where the unlawful listing was posted, and the main Ridgeway Discord, wherein he is an
active member, making it reasonable to assume c_ryp1c knew about the passage of the FHA, but
chose to ignore it to fatten his pockets at the expense of the consumer.
IV. STATEMENT OF FACTS
1. On June 26th, 2024, the FHA was signed into law, which established all the provisions listed
above.
2. The next month, on July 1st, 2024, at 8:31 PM EST, the Secretary of State published the
first Monthly Home Average Report10. In this report, the Secretary of State outlined that
thirty-six (36) homes were sold, with the median price being $23,810.00, thus, establishing
the price cap for the month of July as $28,572.00.
3. TheAvengerNick, since February 6th, 2024, has owned and operated a Discord Server by
the name of “Avenger Real Estate”.
4. TheAvengerNick promotes his Discord Server as being “your trusted partner in navigating
the world of homeownership11”
5. In this Discord Server, TheAvengerNick publishes various information, including
reminders regarding evictions, housing information, and a “estate-exchange”.
8 Ibid.
9 Ibid.
10 Monthly Home Average Report: https://drive.google.com/file/d/1bRzltSOPPz3l2gLg_kz1Elwa5Q9fSnul/view
11 See Avenger Real Estate “server-information” channel
5
6. In this channel titled “estate-exchange”, members of the Discord Server can list homes for
sale.
7. The channel serves as a place for serious sellers to advertise their homes to potential buyers.
8. The channel and its contents are moderated and controlled by TheAvengerNick.
9. On July 9th, 2024, a Discord user who is verified through RoVer, a Discord bot which links
a Discord account to a ROBLOX account, posted to the “estate-exchange” channel, listing
their home on 1325 Rogers Lane, Oakland, Ridgeway with a starting price of $50,000.00.
10. The Discord user who posted the listing, has verified, through the RoVer bot, that the
ROBLOX account bearing the name of “c_ryp1c” is theirs.
11. This Discord user is also verified, through RoVer, in four Ridgeway Discords, as “c_ryp1c”.
12. The Discord user who posted the listing, is the ROBLOX user and Ridgeway Resident
c_ryp1c.
13. Detective Lieutenant T4K3NW of the Palmer Police Department verified the post was
made by c_ryp1c, in the Avenger Real Estate Discord, and verified the message was offering
to sell a home on 1325 Rogers Lane, Oakland, Ridgeway for $50,000.00.
14. The FHA prohibits sellers from selling homes for more than 20% higher than the median
home price.
15. The FHA prohibits businesses from acting as facilitators to potentional unlawful real-estate
deals.
16. The Secretary of State, days before c_ryp1c listed the property, published the median home
price, which was and remains $23,810.00.
17. Thus, the limit for home prices, is set at $28,572.00.
18. Defendant c_rypl1c intentionally and knowingly listed their home for sale at a price higher
than allowable under state law.
19. Defendant c_rypl1c did intend to sell his home for a price higher than permitted under the
FHA.
20. Defendant Avenger Real Estate acted as a faciliatory to Defendant c_rypl1c and his
attempted unlawful sale.
21. Defendant Avenger Real Estate took no action to shield the members of the Discord server
from unlawful activity.
6
22. Defendant Avenger Real Estate violated their duty to care for the consumer through their
wanton disregard for the law and the FHA.
JURISDICTION AND VENUE
This court has original jurisdiction over this complaint under Article V, Section IV of the
Ridgeway Constitution. Furthermore, this court’s jurisdiction is invoked in equity. The venue is
proper in this court because the actions alleged in this complaint occurred in the State of
Ridgeway.
PARTIES
1. Plaintiff, The State of Ridgeway, is a State Government, tasked with, by statute, enforcing
all laws of the State of Ridgeway, and interest of the public.
2. Defendant, Avenger Real Estate, is a sole proprietorship, labled as a limited liability
company within the State of Ridgeway.
3. Defendant, TheAvengerNick, is a Resident of the State of Ridgeway, and the only
member and owner of Avenger Real Estate.
4. Defendant, c_rypl1c, is a Resident of the State of Ridgeway.
CAUSES OF ACTION
COUNT ONE
VIOLATING SECTION 4 OF THE FAIR HOUSING ACT OF 2024
1. Plaintiff incorporates all aforementioned facts and information to be true and pleads them
herein.
2. Section 4(a) of the Fair Housing Act establishes a sales cap of no more that 20% above the
current average home price.
3. Defendant c_rypl1c, on July 9th, 2024, intentionally and willingly listed a home for sale in
the Avenger Real Estate business for a price above 20% higher than the average home
price.
4. Defendant c_rypl1c, ignored the price caps on home established in the Fair Housing Act
of 2024 to illicitly enjoy unlawful financial gain, at the expense of the consumer.
COUNT TWO
VIOLATING SECTION 4 OF THE FAIR HOUSING ACT OF 2024
1. Plaintiff incorporates and pleads all aforementioned facts and information to be true and
pleads them herein.
2. Defendant Avenger Real Estate facilitated a sale that was unlawful, and in violation of
Section 4(a) of the Fair Housing Act of 2024.
7
3. Defendant Avenger Real Estate facilitated that sale knowingly, and in violation of the law.
4. Defendant Avenger Real Estate consistently allows for unlawful sales to occur in their
business.
5. Defendant Avenger Real Estate took no action to protect or shield their costumers from
unlawful real-estate deals, violating their duty to care to their customer.
6. Defendant Avenger Real Estate facilitated an unlawful business practice.
7. Defendant Avenger Real Estate deceived the consumer to directly benefit themselves.
COUNT THREE
VIOLATING SECTION 4 OF THE FAIR HOUSING ACT OF 2024
1. Plaintiff incorporates and pleads all aforementioned facts and information to be true and
pleads them herein.
2. Defendant TheAvengerNick, the sole owner of Avenger Real Estate, facilitated an
unlawful sale which was in direct violation of Section 4(a) of the Fair Housing Act of
2024.
3. Defendant TheAvengerNick facilitated this sale knowingly and intentionally.
4. Defendant TheAvengerNick should have known unlawful sales were being conducted in
his business but failed to act to protect his customers from unlawful real-estate practices.
5. Defendant TheAvengerNick is the sole owner and controlled of Defendant company
Avenger Real Estate, and thus, he manages the venue in which this violation occurred,
and could of prevented it.
PR AYERS FOR RELIEF
COUNT ONE
1. Plaintiff request a declaratory judgement that Defendant c_rypl1c violated the Fair
Housing Act of 2024.
2. Plaintiff request a permanent injunction, prohibiting Defendant c_rypl1c from conducting
any further unlawful real-estate deals or sales.
3. Plaintiff request a civil penalty be imposed against Defendant c_rypl1c for $2,500.00
pursuant to Section 7(b) of the Fair Housing Act of 2024.
4. Plaintiff request an addition civil penalty be imposed against Defendant c_rypl1c for
$500,000.00 pursuant to Section 7(b) of the Fair Housing Act of 2024.
5. Plaintiff request Defendant c_rypl1c pay Plaintiff attorney fees, to be calculated before
final judgement.
COUNT TWO
1. Plaintiff request a declaratory that Defendant Avenger Real Estate violated the Fair
Housing Act of 2024 by facilitating an unlawful real-estate sale.
2. Plaintiff request a permanent injunction, prohibiting Defendant Avenger Real Estate from
facilitating any further unlawful real-estate deals or sales.
8
3. Plaintiff request Defendant Avenger Real Estate pay Plaintiff attorney fees, to be
calculated before final judgement.
COUNT THREE
1. Plaintiff request a declaratory that Defendant TheAvengerNick violated the Fair Housing
Act of 2024 by facilitating an unlawful real-estate sale.
2. Plaintiff request a permanent injunction, prohibiting Defendant TheAvengerNick from
facilitating any further unlawful real-estate deals or sales.
3. Plaintiff request a civil penalty be imposed against Defendant TheAvengerNick for
$2,500.00 pursuant to Section 7(b) of the Fair Housing Act of 2024.
4. Plaintiff request an addition civil penalty be imposed against Defendant TheAvengerNick
for $500,000.00 pursuant to Section 7(b) of the Fair Housing Act of 2024.
5. Plaintiff request Defendant TheAvengerNick pay Plaintiff attorney fees, to be calculated
before final judgement.
Dated: July 10, 2024
Palmer, Ridgeway.
Respectfully submitted,
/s/ insertreality
insertreality
Deputy Solicitor General
Stickza
Solicitor General
Ridgeway Department of Justice
1 County Annex
Palmer, Ridgeway 33368
