Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA916734
`08/20/2018
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`ESTTA Tracking number:
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`Filing date:
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Proceeding
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`91243046
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`Party
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`Correspondence
`Address
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`Plaintiff
`Telegram Messenger Inc
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`BRUCE GOLDNER
`SKADDEN ARPS SLATE MEAGHER & FLOM LLP
`FOUR TIMES SQUARE
`NEW YORK, NY 10036-6522
`UNITED STATES
`bgoldner@skadden.com, jneukom@skadden.com, kplevan@skadden.com,
`dlamb@skadden.com, smarquez@skadden.com
`212-735-2972
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`Submission
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`Filer's Name
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`Filer's email
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`Signature
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`Date
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`Attachments
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`Other Motions/Papers
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`Bruce Goldner
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`bgoldner@skadden.com, jneukom@skadden.com, kplevan@skadden.com,
`dlamb@skadden.com, smarquez@skadden.com
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`/Bruce Goldner/
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`08/20/2018
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`Attachment For Suspension Motion opp. no. 91243046.pdf(82121 bytes )
`Telegram v. Lantah Complaint USDC SF Division.pdf(3139453 bytes )
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`

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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Serial No. 87810181
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`Opposition No. 91243046
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`Opposer,
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`TELEGRAM MESSENGER INC,
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`LANTAH LLC,
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`Applicant.
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`Opposer, Telegram Messenger Inc (“Opposer”) inadvertently omitted a copy of the Telegram Messenger Inc v.
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`Attachment For Motion For Suspension of Proceedings
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`Lantah LLC, Case No. 18-cv-2811 United States District Court for the Northern District of California, Complaint in
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`support of its Motion For Suspension of Proceedings. Opposer submits a copy of the Complaint.
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`Dated: August 20, 2018
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`Bruce Goldner
`Kenneth A. Plevan
`David M. Lamb
`SKADDEN, ARPS, SLATE,
` MEAGHER & FLOM LLP
`Four Times Square
`New York, NY 10036
`(212) 735-3000 (telephone)
`(212) 735-2000 (facsimile)
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`Attorneys for Opposer Telegram Messenger Inc
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`By: /Bruce Goldner/
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`Certificate of Service
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`I hereby certify that a true and complete copy of the foregoing Attachment For Motion For Suspension of
`Proceedings has been served on Donald A. Thompson by forwarding said copy on August 20, 2018, via email to:
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`Donald A. Thompson, Esq.
`Thompson & Co.
`One Embarcadero Center, Suite 500
`San Francisco, CA 94111
`don@tco.law
`don@thompsonandco.com
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` /Sylvia Marquez/
` Sylvia Marquez
` Trademark Specialist
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`

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`Case 3:18-cv-02811-CRB Document 1 Filed 05/11/18 Page 1 of 11
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`
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`
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`JOHN NEUKOM (SBN 275887)
`john.neukom@skadden.com
`PATRICK HAMMON (255047)
`patrick.hammon@skadden.com
`SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP
`525 University Avenue
`Palo Alto, California 94301
`Telephone: (650) 470-4500
`Facsimile: (650) 470-4570
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`Attorney for Plaintiff
`TELEGRAM MESSENGER INC
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`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
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`SAN FRANCISCO DIVISION
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`TELEGRAM MESSENGER INC,
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`CASE NO. 18-cv-2811
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`PLAINTIFF TELEGRAM MESSENGER
`INC’S COMPLAINT FOR:
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`1. FALSE DESIGNATION OF
`ORIGIN;
`2. TRADEMARK INFRINGEMENT;
`AND
`3. UNFAIR COMPETITION
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`JURY TRIAL DEMANDED
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`Plaintiff,
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`vs.
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`LANTAH, LLC,
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`Defendant.
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`
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`COMPLAINT 18-cv-2811
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`

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`Case 3:18-cv-02811-CRB Document 1 Filed 05/11/18 Page 2 of 11
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`Plaintiff Telegram Messenger Inc (“Telegram Messenger”) by its attorneys, for its
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`Complaint against Defendant Lantah LLC (“Defendant” or “Lantah”), upon personal knowledge
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`as to its own facts and conduct and on information and belief as to all other matters, states and
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`alleges as follows:
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`1.
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`This is an action alleging false designation of origin under 15 U.S.C. § 1125,
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`INTRODUCTION
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`common law trademark infringement, and unfair competition under Cal. Bus. & Prof. Code
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`§ 17200.
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`2.
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`This action concerns service mark rights used in connection with cryptocurrencies,
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`digital assets designed to work as a medium of exchange that use cryptography to secure
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`transactions, control the creation of additional units, and verify the transfer of assets.
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`3.
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`Cryptocurrencies allow users to transact business from anywhere in the world with
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`an internet connection, without requiring a centralized third party such as a bank or government to
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`verify or clear transactions.
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`4.
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`Telegram Messenger, including with affiliated companies (collectively,
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`“Telegram”) previously adopted the service mark GRAM, and has used that mark in connection
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`with financial products and services it intends to offer to customers, namely providing a
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`cryptocurrency (or virtual currency) for use by members of the Telegram Open Network (“TON”),
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`which network Telegram is working to launch in the fourth quarter of 2018.
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`5.
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`As a consequence of its extensive activities in commerce in support of its
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`cryptocurrency and TON, including successfully executing purchase agreements for GRAMs (the
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`“Purchase Agreements”), Telegram has established service mark rights in the mark GRAM for
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`financial products and services relating to cryptocurrency. The named plaintiff Telegram
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`Messenger is the owner and/or assignee of all rights to the GRAM mark, and other companies
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`affiliated with Telegram Messenger (such as Telegram Messenger’s parent corporation, Telegram
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`Group Inc.) use the GRAM mark with the permission of Telegram Messenger.
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`6.
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`Defendant Lantah has indicated in a recent governmental filing that it intends to use
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`the mark GRAM at some point in the future for a virtual currency for use by members of an on-
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`1
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`COMPLAINT 18-cv-2811
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`Case 3:18-cv-02811-CRB Document 1 Filed 05/11/18 Page 3 of 11
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`line community it apparently wants to create.
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`7.
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`While Lantah has recently indicated that it intends to use the GRAM mark at some
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`point in the future in relation to cryptocurrency, Telegram has already been doing so in the past, in
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`commerce, with substantial success, and with priority over Lantah. Telegram Messenger thus has
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`prior rights in the mark GRAM as used in connection with cryptocurrency and related financial
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`products and services, and brings this lawsuit seeking preliminary and permanent injunctive relief
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`to ensure that Lantah does not deceive or confuse consumers, or potential consumers, or otherwise
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`cause harm to Telegram.
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`8.
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`If Lantah’s infringing activities are not enjoined, such actions will cause significant
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`confusion among consumers and cause significant harm to Telegram.
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`9.
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`Plaintiff Telegram Messenger Inc is an entity organized under the laws of the
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`PARTIES
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`British Virgin Islands with registered offices at Vistra Corporate Services Centre, Wickhams Cay
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`II, Road Town, Tortola, British Virgin Islands, VG 1110 and is a wholly owned subsidiary of
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`Telegram Group Inc. Telegram Group Inc. is an entity organized under the laws of the British
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`Virgin Islands with its registered office at Vistra Corporate Services Centre, Wickhams Cay II,
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`Road Town, Tortola, British Virgin Islands, VG 1110.
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`10.
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`Defendant Lantah is a limited liability company organized under the laws of
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`Florida, maintaining its principal place of business at 7010 Potomac Drive, Port Richey, Florida
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`34668.
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`JURISDICTION AND VENUE
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`11.
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`This Court has subject matter jurisdiction over the Lanham Act claims asserted
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`herein pursuant to 28 U.S.C. §§ 1331 and 1338(a). This Court has subject matter jurisdiction over
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`the related state law claims raised in this action pursuant to 28 U.S.C. §§ 1338(b) and 1367.
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`12.
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`This Court also has subject matter jurisdiction under 28 U.S.C. § 1332(b), as this
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`dispute is between a party (Lantah) incorporated and having its principal place of business in
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`Florida and a subject (Telegram Messenger) of a foreign state, and the amount in controversy
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`exceeds $75,000, exclusive of interest and costs.
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`-2-
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`COMPLAINT 18-cv-2811
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`

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`Case 3:18-cv-02811-CRB Document 1 Filed 05/11/18 Page 4 of 11
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`13.
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`Venue is proper in this District pursuant to 28 U.S.C. § 1391(b)(1), (2) and/or (3).
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`As to § 1391(b)(1), this is a District “in which any defendant [Lantah] resides” and “all defendants
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`[Lantah] are residents of the State in which the district is located.” That is the case because Lantah
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`is subject to this Court’s personal jurisdiction with respect to this action. See 28 U.S.C.
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`§ 1391(c)(2).
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`14.
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`As to § 1391(b)(2), a “substantial part of the events . . . giving rise to the claim[s]
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`occurred” in this District given that, inter alia, Telegram has successfully executed numerous
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`Purchase Agreements with purchasers in this District using the GRAM service mark, establishing
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`Telegram Messenger’s priority in the mark, and Lantah’s recent trademark filing (claiming an
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`intent to use the mark) would undermine and damage Telegram Messenger’s mark, including by
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`giving rise to confusion among consumers (including those purchasers in this District with whom
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`Telegram has successfully executed Purchase Agreements using the GRAM mark).
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`15.
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`Personal jurisdiction is proper for numerous reasons. First, Lantah has been
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`attempting and/or is planning to transact business in the State of California, has engaged in or
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`plans to engage in tortious acts within the State of California, and has other contacts with the State
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`of California, as evidenced by Lantah’s recent actions to register the mark. Second, Lantah has
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`unlawfully claimed Telegram Messenger’s service mark while knowing (actually or
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`constructively) that Telegram has been using the mark to successfully execute Purchase
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`Agreements with purchasers inside California. (By way of example, publicly available news
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`reports published before Lantah’s trademark registration filing disclosed that Telegram executed
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`Purchase Agreements with notable venture capital firms located in Silicon Valley.) Third,
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`Lantah’s improper use of Telegram Messenger’s mark is likely to confuse consumers located
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`inside this District, which is especially important given that Telegram has already executed
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`Purchase Agreements using the GRAM service mark with purchasers located in this District.
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`BACKGROUND FACTS
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`History of Telegram
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`16.
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`The “Telegram Group” was founded in 2013 with the primary mission of
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`developing online products and services using encrypted technology.
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`-3-
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`COMPLAINT 18-cv-2811
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`Case 3:18-cv-02811-CRB Document 1 Filed 05/11/18 Page 5 of 11
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`17.
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`Telegram’s first project was a messaging application with a particular focus on
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`speed and security (“Telegram Messenger App”).
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`18. Within a few months after its launch, the Telegram Messenger App had attracted
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`millions of users, and received positive reviews from both users and the press.
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`19.
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`In early 2018, the Telegram Messenger App had 200 million monthly users
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`worldwide, with 500,000 new users joining daily, and was delivering 70 billion messages every
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`day.
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`The Telegram Open Network and the Gram Cryptocurrency
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`20.
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`The architecture of existing “general distributed ledgers,” also known as
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`“blockchains,” that support the development and exchange of most cryptocurrencies today
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`presents a number of limitations that prevent these cryptocurrencies from gaining widespread use
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`and adoption.
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`21. Most significantly, such blockchains are not fully scalable, resulting in slow
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`transaction speeds as the network grows. This means that cryptocurrencies built on such networks
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`cannot realistically be used as a medium of exchange in lieu of fiat currencies or credit cards.
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`22.
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`As a result, the current market of goods and services that can be purchased using
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`cryptocurrencies is limited.
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`23.
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`The user interfaces associated with existing blockchain networks and
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`cryptocurrencies also tend to be confusing or overwhelming for the average consumer.
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`24. Most cryptocurrencies also need to develop a large network of users to be viable.
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`25.
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`Telegram’s core development team recognized these limitations, and given its
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`strong experience in cryptography and distributed computing, embarked in 2017 to develop the
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`Telegram Open Network (“TON”), a new blockchain that will be fully scalable, and able to
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`support a robust cryptocurrency.
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`26.
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`The over 200 million member Telegram Messenger App user base would also
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`facilitate the network effect that is important for the adoption of a new cryptocurrency.
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`27.
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`In developing TON, Telegram recognized that it could take advantage of the
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`significant goodwill in its existing brand, and large customer base, to create a widely adopted
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`-4-
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`COMPLAINT 18-cv-2811
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`

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`Case 3:18-cv-02811-CRB Document 1 Filed 05/11/18 Page 6 of 11
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`blockchain network and cryptocurrency.
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`TON Purchase Agreements
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`28.
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`Telegram is, in part, funding the development and creation of TON through the
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`offering of Purchase Agreements to certain individuals and entities, including those in the United
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`States and those specifically in this District.
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`29.
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`Although GRAMs will not be released to purchasers until such time that the
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`development team determines that TON is ready to be launched, purchasers will receive a set
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`amount of GRAMs (determined based on a pricing formula) from TON Issuer Inc. (a wholly
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`owned subsidiary of Telegram Group Inc.) when the GRAMs are released, subject to satisfaction
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`of the conditions set forth in their respective Purchase Agreements with Telegram and TON Issuer
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`Inc.
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`30.
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`Throughout December 2017, Telegram’s offering of Purchase Agreements was
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`widely reported on by many financial and industry publications. Attached hereto as Exhibit A are
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`examples of such articles, including:
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`(a) a December 22, 2017, article from cryptocurrency publication
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`Cointelegraph;
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`(b) a December 22, 2017, article in the International Business Times
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`News; and
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`(c) a December 27, 2017, article from ICO publication ICO Watch List.
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`31.
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`On or around January 29, 2018, the first Purchase Agreement was executed by
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`Telegram and TON Issuer Inc.
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`32.
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`By February 25, 2018, Telegram had executed Purchase Agreements with 35
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`purchasers in the U.S., including 30 California-based purchasers, many of whom are based inside
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`this District.
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`33.
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`As a consequence of Telegram’s widely reported on and highly successful offering
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`of Purchase Agreements, it has used the mark GRAM in interstate commerce in the United States,
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`and in this District, and has established common law service mark rights in the mark GRAM in
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`connection with the offering of virtual currency to be used with TON.
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`-5-
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`COMPLAINT 18-cv-2811
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`

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`Case 3:18-cv-02811-CRB Document 1 Filed 05/11/18 Page 7 of 11
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`34.
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`Not only has it been widely reported since late 2017 that Telegram’s offering of
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`Purchase Agreements (using the GRAM mark) has been successful, it has also been the case that it
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`has been widely reported that such successful offering has included executing Purchase
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`Agreements with purchasers located inside the Northern District of California. For example, by
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`February 21, 2018, it was being reported publicly that Telegram had executed Purchase
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`Agreements with Sequoia Capital and Benchmark, both headquartered here in this District.
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`Defendant’s Infringing and Unfair Conduct
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`35.
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`After it was publicly reported that Telegram’s offering of Purchase Agreements to
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`Silicon Valley investors had been successful, namely on or about February 25, 2018, Lantah filed
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`an intent to use trademark application (Application No. 87/810,181) at the U.S. Patent and
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`Trademark office covering the mark GRAM for “financial services, namely, providing a virtual
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`currency for use by members of an on-line community via a global computer network” (the “ITU
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`Application”). A copy of the ITU Application is attached hereto as Exhibit B.
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`36.
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`On or about March 9, 2018, Lantah initiated a so-called initial coin offering
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`(“ICO”) using the mark “gram.”
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`37.
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`Both the filing of the ITU Application and the initiation of Lantah’s ICO post-date
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`Telegram’s date of first use of its GRAM service mark in interstate commerce and Telegram
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`Messenger’s rights in the GRAM mark accordingly predate those of Lantah.
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`38.
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`Lantah’s use of “gram” for a cryptocurrency will inevitably cause a likelihood of
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`consumer confusion, harm the goodwill in Telegram’s service mark, and cause confusion as to the
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`source, origin, and/or sponsorship of Telegram’s cryptocurrency services.
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`39.
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`Because of the nature of cryptocurrencies, Lantah’s use of “gram” will further
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`cause confusion among consumers as to which cryptocurrency is being used in any particular
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`transaction, thereby causing harm to consumers and to Telegram.
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`FIRST CLAIM
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`(False Designation of Origin Under 15 U.S.C. § 1125)
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`40.
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`Telegram Messenger incorporates by reference the allegations in the preceding
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`paragraphs of the Complaint.
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`-6-
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`COMPLAINT 18-cv-2811
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`

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`Case 3:18-cv-02811-CRB Document 1 Filed 05/11/18 Page 8 of 11
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`41.
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`By virtue of having used and continuing to use the GRAM mark in commerce,
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`including in California, Telegram Messenger has acquired common law trademark rights in the
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`GRAM mark.
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`42.
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`Lantah has used and continues to use a service mark that is confusingly similar to
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`Telegram’s GRAM mark without Telegram Messenger’s consent.
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`43.
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`Lantah’s unauthorized use in commerce of a service mark that is confusingly
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`similar to Telegram Messenger’s GRAM mark has caused and is likely to continue to cause
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`confusion or mistake, or to deceive consumers and potential consumers, the public, and the trade
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`concerning an affiliation, connection, or association between Lantah and Telegram when there is
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`no such affiliation, connection, or association.
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`44.
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`Lantah’s activities, alleged herein, have a substantial economic effect on interstate
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`commerce.
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`45.
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`Lantah’s activities, alleged herein, constitute false designation of origin within the
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`meaning of 15 U.S.C. § 1125(a).
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`46.
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`Telegram Messenger has been irreparably injured by Lantah’s false and misleading
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`conduct in violation of 15 U.S.C. § 1125(a).
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`47.
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`Lantah acted willfully, with knowledge of Telegram Messenger’s rights in the
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`GRAM mark, and those acts constitute a willful violation of the Lanham Act.
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`48.
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`As a result of this false designation of origin, Telegram Messenger has suffered
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`irreparable injury and, unless Lantah’s infringement is enjoined by the Court, Telegram Messenger
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`will continue to suffer irreparable harm. There is no adequate remedy at law for the harm caused
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`by Lantah’s infringing conduct.
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`SECOND CLAIM
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`(Common Law Trademark Infringement)
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`49.
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`Telegram Messenger incorporates by reference the allegations in the preceding
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`paragraphs of the Complaint.
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`50.
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`By virtue of having used and continuing to use the GRAM mark in commerce,
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`including in California, Telegram Messenger has acquired common law trademark rights in the
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`-7-
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`COMPLAINT 18-cv-2811
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`

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`Case 3:18-cv-02811-CRB Document 1 Filed 05/11/18 Page 9 of 11
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`1
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`GRAM mark.
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`2
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`51.
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`Lantah’s stated intent to use and use of a mark that is confusingly similar to the
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`GRAM mark infringes Telegram Messenger’s common law trademark rights in the GRAM mark
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`4
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`and is likely to cause confusion, mistake, or deception among consumers, who will believe that
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`Lantah’s services originate from, or are affiliated with, or are endorsed by Telegram, including
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`Telegram Messenger, when, in fact, they are not.
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`52.
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`By virtue of acts complained of herein, Lantah has intentionally caused a likelihood
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`8
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`of confusion among the public and has unfairly competed with Telegram Messenger in violation
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`9
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`of the common law of the State of California.
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`53.
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`As a direct and proximate result of Lantah’s common law trademark infringement
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`11
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`and unfair competition, Telegram Messenger has suffered, and unless Lantah is enjoined by this
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`12
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`Court will continue to suffer, irreparable injury to Telegram Messenger’s business, reputation, and
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`13
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`goodwill in the GRAM mark for which Telegram Messenger has no adequate remedy at law.
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`14
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`54.
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`As a direct and proximate result of Lantah’s common law trademark infringement
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`15
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`and unfair competition, Telegram Messenger has been forced to retain counsel to prosecute this
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`16
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`claim and is entitled to recover its attorneys’ fees and costs incurred herein.
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`17
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`18
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`19
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`THIRD CLAIM
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`(Unfair Competition Under Cal. Bus. & Prof. Code § 17200)
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`55.
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`Telegram Messenger incorporates by reference the allegations in the preceding
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`20
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`paragraphs of the Complaint.
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`21
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`56.
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`In the course of conducting its business, Lantah’s conduct—specifically, its use of
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`22
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`a service mark confusingly similar to Telegram Messenger’s GRAM mark in a manner that is
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`23
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`likely to cause consumer confusion—constitutes unfair competition and unfair business practice in
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`violation of California Business and Professions Code § 17200.
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`25
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`57.
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`As a result of this unfair competition and unfair business practice, Telegram
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`26
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`Messenger has suffered irreparable injury to its business, reputation, and goodwill in its GRAM
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`27
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`mark. Telegram Messenger will continue to suffer irreparable injury unless Lantah’s misconduct
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`28
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`is enjoined.
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`-8-
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`COMPLAINT 18-cv-2811
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`

`

`Case 3:18-cv-02811-CRB Document 1 Filed 05/11/18 Page 10 of 11
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`1
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`2
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`PRAYER FOR RELIEF
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`WHEREFORE, Telegram Messenger respectfully requests that this Court enter
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`3
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`judgment in its favor on each and every claim for relief set forth above and award it relief
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`4
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`including, but not limited to an Order:
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`5
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`1.
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`Finding that: (i) Lantah has violated Section 43(a) of the Lanham Act (15 U.S.C.
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`6
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`§ 1125(a)); (ii) Lantah has committed trademark infringement under California common law; and
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`7
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`(iii) Lantah has committed unfair competition under California state law;
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`8
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`2.
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`Entering a preliminary and permanent injunction enjoining and restraining Lantah
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`9
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`from using in commerce or in connection with any goods or services any mark, name, or design
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`10
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`that creates a likelihood of confusion with Telegram’s GRAM service mark and from engaging in
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`11
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`any other acts of unfair competition and in engaging in false designation of origin;
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`12
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`3.
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`Awarding Telegram Messenger its actual costs and attorneys’ fees incurred in
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`13
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`bringing this action pursuant to 15 U.S.C. § 1125(c) and California Business and Professions Code
`
`14
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`§ 17200; and
`
`Granting such other relief the Court deems just and proper.
`
`4.
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`
`
`
`Dated: May 11, 2018
`
`
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`SKADDEN, ARPS, SLATE MEAGHER & FLOM LLP
`
`
`/s/ John M. Neukom________
`
`Attorney for Plaintiff
`TELEGRAM MESSENGER INC
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`COMPLAINT 18-cv-2811
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`

`

`Case 3:18-cv-02811-CRB Document 1 Filed 05/11/18 Page 11 of 11
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`JURY TRIAL DEMANDED
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`2
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`Pursuant to Rule 38(a) of the Federal Rules of Civil Procedure, Plaintiff hereby demands trial by
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`3
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`jury of all issues properly triable of right by a jury.
`
`4
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`
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`SKADDEN, ARPS, SLATE MEAGHER & FLOM LLP
`
`
`/s/ John M. Neukom________
`
`Attorney for Plaintiff
`TELEGRAM MESSENGER INC
`
`5
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`Dated: May 11, 2018
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`-10-
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`COMPLAINT 18-cv-2811
`
`
`
`
`

`

`Case 3:18-cv-02811-CRB Document 1-1 Filed 05/11/18 Page 1 of 14
`Case 3:18—cv-02811-CRB Document 1-1 Filed 05/11/18 Page 1 of 14
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`EXHIBIT A
`EXHIBIT A
`
`
`
`

`

`Case 3:18-cv-02811-CRB Document 1-1 Filed 05/11/18 Page 2 of 14
`Case 3:18—cv-02811—CRB Document 1-1 Filed 05/11/18 Page 2 of 14
`
`
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`
`
`
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`

`

`4/10/2018
`
`Exclusive: Telegram to Release Blockchain Platform, Native Cryptocurrency
`Case 3:18-cv-02811-CRB Document 1-1 Filed 05/11/18 Page 3 of 14
`
`(https://servedbyadbutler.com/redirect.spark?
`MID=169476&plid=742691&setID=289765&channelID=0&CID=0&banID=519554613&PID=0&textadID=0&tc=1&mt=1523382667514919&
`
`BTC $ 6,865 (/bitcoin-price-index)
`
`ETH $ 413 (/ethereum-price-index)
`
`LTC $ 114 (/ltc-price-index)
`
`XRP $ 0.49 (/xrp-price-index)
`
`XMR $ 168 (/xmr-pric
`
` By David
`Dinkins
`Exclusive: Telegram to Release Blockchain Platform, Native Cryptocurrency
`
`DEC 22, 2017
`
`155076 Total views
`
`1455 Total shares
`
`EXCLUSIVE
`
`The popular encrypted messaging app Telegram (https://cointelegraph.com/tags/telegram) will launch its own Blockchain platform
`and cryptocurrency, according to sources familiar with the matter. The new platform will be dubbed either “The Open Network” or
`“Telegram Open Network” (TON) and is supposed to be based on an improved version of Blockchain technology.
`
`Initial reports of the new platform surfaced today from Anton Rozenberg, a former employee of Telegram’s publishing division
`Telegraph. Rozenberg posted on Facebook what he claims is an advertorial video for the new platform (he did not disclose the
`source of the video). He also pointed out that TON would aid those under oppressive governments, since they would be able to
`transfer money natively through the messaging app. This could serve to break the state’s control over citizens’ money, added
`Rozenberg.
`
`Leaked TON Platform Teaser
`
`
` 
`
`(https://twitter.com/intent/tweet?text=Exclusive: Telegram
`
`(https://plus.google.com/share?(https://www.linkedin.com/shareArticle?
`(https://www.facebook.com/sharer/sharer.php?
`
`to Release Blockchain Platform Native Cryptocurrency(https://www reddit com/submit?url=https%3A%2F%2Fcointelegraph com%2Fnews%2Fexclusive-telegram-to
`
`https://cointelegraph.com/news/exclusive-telegram-to-release-blockchain-platform-native-cryptocurrency
`
`1/4
`
`

`

`4/10/2018
`
`(cid:212)
`
`Exclusive: Telegram to Release Blockchain Platform, Native Cryptocurrency
`Case 3:18-cv-02811-CRB Document 1-1 Filed 05/11/18 Page 4 of 14
`(https://www.reddit.com/submit?url=https%3A%2F%2Fcointelegraph.com%2Fnews%2Fexclusive-telegram-to
`to Release Blockchain Platform, Native Cryptocurrency
`mini=true&url=https%3A%2F%2Fcointelegraph.com%2Fnews%2Fexclusive-telegram-to-release-blockchain-
`url=https%3A%2F%2Fcointelegraph.com%2Fnews%2Fexclusive-
`u=https%3A%2F%2Fcointelegraph.com%2Fnews%2Fexclusive-
`release-blockchain-platform-native-
`https%3A%2F%2Fcointelegraph.com%2Fnews%2Fexclusive-
`(cid:602)
`(cid:157)
`(cid:158)
`(cid:201)
`platform-native-
`telegram-to-release-blockchain-platform-native-
`telegram-to-release-blockchain-platform-native-
`cryptocurrency&title=Exclusive%3A+Telegram+to+Release+Blockchain+Platform%2C+Native+Cryptocurrency
`telegram-to-release-blockchain-platform-native-
`cryptocurrency&title=Exclusive%3A+Telegram+to+Release+Blockchain+Platform%2C+Native+Cryptocurrency)
`cryptocurrency)
`cryptocurrency)
`cryptocurrency via @Cointelegraph)
`
`
`Cointelegraph learned that the currency of TON will be called “Gram” and the platform will be natively integrated with many of the
`most popular messaging apps (it’s not yet certain which ones). The platform will utilize light wallets, making it unnecessary for users
`to download a large and unwieldy Blockchain.
`
`The TON platform also won’t have to go through a multi-year bootstrap period like most new platforms, since the Telegram app
`already boasts 180 mln users (https://www.bloomberg.com/news/articles/2017-12-12/cryptic-russian-crusader-says-his-5-billion-app-
`can-t-be-bought), according to Bloomberg.
`
`Telegram is already immensely popular with the Blockchain community, as cofounder Pavel Durov proclaimed:
`
`“Like right now, the entire Blockchain and cryptocurrency community just switched to Telegram.”
`
`Cointelegraph has reached out to Durov, but has not yet received a reply. While still not o(cid:213)cially con(cid:210)rmed, the creation of TON is
`compatible with an earlier article from Bloomberg, which said (https://www.bloomberg.com/news/articles/2017-12-12/cryptic-
`russian-crusader-says-his-5-billion-app-can-t-be-bought):
`
`“[Durov] sees Telegram as a charity that he’ll start to monetize early next year, but only enough to fund expansion.”
`
`The Mark Zuckerberg of Russia
`
`The enigmatic Pavel Durov teamed up with his brother to launch Telegram in 2013. The app boasts end-to-end encryption
`(https://cointelegraph.com/news/war-against-encryption-german-intelligence-agency-targets-whatsapp-telegram),
`making
`it
`extremely useful for dissidents and ordinary citizens living under oppressive regimes. In fact, according to Bloomberg, Telegram
`accounts for 40% of Iran’s internet tra(cid:213)c. The Iranian government is so aggrieved by the app’s privacy features that they have
`charged Durov, in absentia, of terrorism.
`
`Durov isn’t terribly bothered; he’s used to standing up to national governments. He and his brother cofounded Russia’s largest social
`network, VK, building a company worth over $3 bln. VK was in fact quite similar to Facebook, but whereas Zuckerberg was able to
`maintain control (and a massive ownership stake), Durov was not.
`
`https://cointelegraph.com/news/exclusive-telegram-to-release-blockchain-platform-native-cryptocurrency
`
`2/4
`
`

`

`4/10/2018
`
`Exclusive: Telegram to Release Blockchain Platform, Native Cryptocurrency
`Case 3:18-cv-02811-CRB Document 1-1 Filed 05/11/18 Page 5 of 14
`
`(//cointelegraph.com/storage/uploads/view/15132a05b07e2fb5ce4dfb0087ab255a.png)
`
`When he refused to hand over personal user information to Russian authorities, he was forced to sell his stake in the company to
`one of Putin’s allies. Thus, while Zuckerberg had the option of an IPO, Durov is using an ICO to monetize his creation