The DOJ indictment and SEC complaint allege that, ahead of multiple token listing announcements in 2021 and 2022, Ishan used phone calls and text messages to tip off Nikhil and Ramani about the upcoming listings. For example, on August 30, 2021, Ishan learned that Coinbase would be listing the XYO token. In the days thereafter, and prior to the Coinbase's public announcement, blockchain addresses associated with Ramani were allegedly used to purchase XYO tokens valued at $600,000. Following the public announcement by Coinbase that XYO tokens would be listed, those coins are alleged to have appreciated to approximately $1.5 million, representing a profit of approximately $900,000.