Tyler Brandon Davis owned 49% of something he could not control. That was the arrangement from the beginning — a manager-managed LLC where the Manager held all authority and the minority member held none. Davis could not sign contracts. He could not hire employees. He could not open bank accounts or bind the company to anything. He was, on paper, a passive investor watching someone else build a technology company worth tens of millions of dollars.

According to a 185-page federal civil RICO complaint filed January 6, 2026, Davis decided that arrangement was unacceptable. And so, the plaintiffs allege, he spent eight years building a parallel infrastructure — shell companies, corrupted attorneys, stolen databases, forged documents, a weaponized bankruptcy — to take what was never his to take. Not through negotiation. Not through a buyout. Through what the complaint describes as a criminal enterprise spanning more than 750 predicate acts and approximately $75 million in fraudulent transactions.

A 185-page federal civil RICO action (Case 3:26-cv-00080-GPC-BJW), filed January 6, 2026, names fifteen defendants. And at the center of all of it, identified in language reserved for the worst actors the federal racketeering statute contemplates, is Davis. The filing calls him “the principal organizer and leader of the criminal enterprise alleged herein.”

He lived at 149 Parkshore Drive in Folsom, California. Folsom is a quiet suburb northeast of Sacramento — tract homes, good schools, strip malls anchored by a Raley’s. It is not the kind of place you associate with allegations of wire fraud, money laundering, identity theft, and obstruction of justice. But the complaint paints Davis as a man who understood how to operate from a distance, assembling a network of co-conspirators across Southern California while running his end of the operation from the Sacramento suburbs. The company he allegedly targeted was 400 miles south. The attorneys he allegedly recruited were in Newport Beach, Irvine, and Beverly Hills. The shell companies were scattered across Northern California. The stolen data ended up in Wyoming and Ohio. It was, the plaintiffs argue, a geographically distributed criminal enterprise orchestrated by one man who held no formal power over the thing he was allegedly stealing.

The Company That Became a Target

TopDevz, LLC operated out of 7460 Girard Avenue in La Jolla, California. Its founder had previously scaled a software company from $6 million to $60 million in revenue in under three years, and TopDevz was the American expansion of that track record. The company placed elite contract software developers with enterprise clients — HBO, DriveTime Automotive Group, Procore Technologies, Becton Dickinson. By 2021, total earned revenue had reached nearly $30 million, with a $1.4 million net profit. Independent analyses valued the company between $18 million and $30 million.

The operating agreement, signed May 9, 2017, established TopDevz as a manager-managed LLC. The structure was intentional: only the designated Manager could direct operations, execute agreements, or represent the company in any binding capacity. Davis came in as the 49% minority member. The founder held 51% and the Manager designation. It was a firewall — designed to prevent exactly the kind of unilateral power grab the complaint alleges Davis spent nearly a decade executing.

The company’s Canadian parent, Mobile Monster, Inc., maintained a contractual relationship with TopDevz, sourcing clients and leads in exchange for a 7% commission on revenues. That arrangement generated roughly $1.4 million per year, with Mobile Monster invoicing TopDevz approximately $3.3 million between 2017 and 2021 for lead generation, expense reimbursements, and staffing support. Both companies were functioning, profitable, and growing. Neither, the complaint argues, was in any kind of distress that would justify what came next.

Tainted Money from Day One

The complaint traces Davis’s alleged fraud to the very foundation of his ownership stake. His 49% membership interest was premised on a capital contribution of $787,240. According to the filing, a witness named Todd Belluomini — who owned between 10% and 20% of Porter Consulting, LLC, one of Davis’s entities based in Paradise, California — provided sworn testimony and documentary evidence in August 2023 establishing that this capital contribution was itself the product of criminal activity.

The breakdown, as alleged: $750,000 of the contribution was embezzled from the Porter Consulting partnership. The remaining $37,240 was laundered through Mason Building & Design, LLC — another Davis entity — from a fraudulent $328,300 Paycheck Protection Program loan obtained from the Small Business Administration via Tri Counties Bank. The $37,240 arrived at TopDevz as a check from Mason Building & Design labeled “capital call,” then was reimbursed by wire from Porter’s PPP account. The complaint describes this as a classic layering transaction: money from a fraudulent federal loan, routed through a shell company, relabeled, and injected into a legitimate business to establish an ownership claim that would anchor every legal maneuver Davis made for the next eight years.

If the allegation holds, the entire premise of Davis’s ownership was built on fraud. Every arbitration claim, every court filing, every assertion of membership rights traces back to a capital contribution the complaint characterizes as stolen money washed through a shell company network.

The Shell Company Architecture

Porter Consulting was not an isolated entity. The complaint identifies a constellation of companies allegedly controlled by Davis that functioned less as independent businesses than as instruments: Porter Consulting, LLC (Paradise, California). Mason Building & Design, LLC. Grigio LLC. Humble Provisions LLC. Riley’s Doggie Day Care.

A doggie daycare. The complaint does not treat this as comic relief. It alleges Davis “engaged in a systematic pattern and practice of using shell companies to commit racketeering activity for the purpose of obtaining and maintaining control of business enterprises.” Each entity, the plaintiffs argue, served a specific function in the larger architecture — moving money, obscuring origins, creating paper trails that appeared legitimate from the outside while concealing the mechanics of fraud underneath. The PPP loan that partially funded Davis’s TopDevz stake, for instance, was obtained by Mason Building & Design. The embezzled funds came through Porter Consulting. The complaint presents this network not as a collection of small businesses but as the financial plumbing of a criminal enterprise.

Recruiting the Lawyers

Every sophisticated fraud needs legal infrastructure, and the complaint alleges Davis built his methodically.

Scott Carpenter, a California attorney who practiced with Cummins & White, LLP in Newport Beach, is accused of serving as the enterprise’s primary litigation weapon. The complaint alleges Carpenter fraudulently seized control of TopDevz’s Wells Fargo bank account through false representations transmitted via interstate wire, forged stock certificates for a company that had no stock (TopDevz was an LLC), filed hundreds of fraudulent court pleadings, assembled perjured declarations, and threatened the founder with criminal prosecution and deportation consequences to coerce a settlement. Carpenter allegedly received $196,768 in fees from what the complaint characterizes as criminally derived funds held in a JPMorgan Chase account.

A second attorney, J. Douglas Kirk of Kirk & Toberty in Irvine, was allegedly recruited by Carpenter through their shared attendance at Grace Fellowship Church in Corona del Mar. The complaint presents this as part of a broader pattern: Davis building his support network not through open recruitment but through personal relationships, professional connections, and shared affiliations.

The legal campaign produced an arbitration award of $9,373,566.64 against the founder personally, plus $3.0 million against Mobile Monster. The complaint alleges the entire arbitration was corrupted — tainted by perjury, concealed conflicts of interest, and fraudulent evidence. Through these proceedings, the founder’s ownership was diluted from 51% to 4.692%. A majority stake in a company valued at up to $30 million, effectively erased through what the complaint describes as a coordinated fraud on the tribunal.

Converting the Employees

Davis did not just recruit lawyers. The complaint alleges he turned the company’s own employees into instruments of its destruction.

In March 2020, the founder hired Joshua Paul Lintz as TopDevz’s Chief Operating Officer at an annual salary of $200,000. Within twenty-two months, the complaint alleges, Lintz had been turned. Amanda Frye, TopDevz’s Director of Accounts, and Melissa Garcia, the company’s accounts payable manager, were also allegedly recruited into the scheme.

What followed was an eight-day data extraction operation in January 2022 that the complaint describes in forensic detail. On January 14, 2022, Frye downloaded the company’s entire Zoho Recruit database — a contractor and candidate repository containing approximately 2.5 million records representing years of sourcing, vetting, and relationship-building. Between January 6 and January 14, Garcia downloaded 3,784 confidential files from TopDevz email accounts: client lists, financial records, contractor databases, sourcing methodology, project histories.

Davis did not deny ordering the theft. Under oath, he testified: “I instructed her to download as much information as humanly possible at that time.”

The extraction was not the end. Over 130 TopDevz client projects were permanently deleted from the company’s Jira project management system. Years of operational history, client deliverables, project documentation — wiped. The complaint characterizes this as scorched earth: take everything portable, destroy what you leave behind.

TalentCrowd: Three Weeks from Theft to Incorporation

Three weeks after the January data extraction, on February 8, 2022, Josh Lintz incorporated a new company in Wyoming. He called it TalentCrowd, LLC.

TalentCrowd set up operations at 125 S Highway 101, Suite 1060, in Solana Beach, California — a few miles north of TopDevz’s La Jolla headquarters. Frye, the woman who had downloaded the entire Zoho Recruit database, became TalentCrowd’s CEO. The same people. The same data. The same clients. A different name above the door.

The complaint alleges TalentCrowd generated over $12 million in revenue in its first year of operation — built entirely, the plaintiffs contend, on stolen TopDevz assets, methodology, and client relationships. By March 2023, Frye was publicly claiming that TalentCrowd had “logged almost 90,000 hours of service” in its inaugural year. The complaint connects those hours directly to the stolen database, arguing that TalentCrowd’s explosive growth was not entrepreneurial innovation but the predictable result of transplanting a proven operation — database, clients, methodology, and all — into a new corporate shell.

The 33-day gap between the January 6 data extraction and the February 8 incorporation tells its own story. You do not build a $12 million company from scratch in thirty-three days. You do it by stealing one.

The Bankruptcy Endgame

When the founder filed for Chapter 11 bankruptcy protection on February 26, 2024, the complaint alleges Davis treated it not as an obstacle but as the final mechanism for completing the takeover.

D. Edward Hays, an attorney at Marshack Hays LLP in Beverly Hills, allegedly joined the enterprise between August and December 2023. The complaint calls him “the architect of the bankruptcy fraud schemes.” Hays is accused of filing false declarations under penalty of perjury — including sworn statements that Davis was “the managing member of TopDevz” — a claim directly contradicted by the operating agreement that reserved managerial authority exclusively for the Manager.

The bankruptcy proceedings produced a court-appointed Chapter 7 trustee: Christopher R. Barclay. What happened next, the complaint alleges, represents the most audacious phase of the entire scheme. Barclay settled approximately $75 million in claims — claims belonging to the bankruptcy estate, claims that included allegations of fraud committed by Davis himself — for a total of $200,000. Then the remaining estate claims were sold to Davis for $100,000.

Consider the mathematics. A man accused of orchestrating an eight-year criminal enterprise purchased, for $100,000, the legal right to pursue claims arising from his own alleged crimes. The complaint argues this transaction is void as a matter of law: a racketeer cannot legally acquire claims alleging his own criminal conduct. The California Court of Appeal apparently saw a problem. On October 6, 2025, the appellate court issued a stay order halting the sale. Two related appeals — Case Nos. C100954 and C101423 — remain pending.

The $50,000-a-Day Aftermath

In February 2025, TalentCrowd was acquired by GBQ Partners LLC, an Ohio-based professional services firm. The complaint alleges GBQ knew — or should have known — exactly what it was buying. At the time of the acquisition, multiple pending lawsuits named TalentCrowd and its principals, alleging trade secret theft, wire fraud, and identity theft. The timeline was publicly available. The claims were a matter of record.

GBQ retained Lintz and Frye in their leadership positions. The complaint alleges the combined operation now generates $50,000 or more per day — between $15 million and $20 million annually — from the 2.5-million-record database the plaintiffs say was stolen from TopDevz. Each day of continued exploitation, the complaint argues, constitutes a fresh predicate act under the federal trade secrets statute. The machine Davis allegedly built does not require his daily involvement anymore. It runs on its own, generating revenue from stolen assets, under new ownership, in a different state.

The Damage Calculation

The complaint quantifies the financial destruction with clinical precision.

Mobile Monster’s direct losses exceed $8.6 million — the termination of commission revenue, the destruction of the contractual relationship, the theft of the business it had built over years.

The founder’s personal losses are staggering in their scope. A 51% ownership interest, valued at $9 million to $15 million, diluted to near-nothing through allegedly fraudulent arbitration. Personal salary losses of $2.0 million to $2.5 million. A $9.3 million judgment entered against him personally through what the complaint characterizes as identity theft and perjury. The loss of his immigration status in the United States. And over $2.5 million to $5.0 million in legal fees spent fighting across multiple courts for nearly a decade.

Under RICO’s treble damages provision, the numbers escalate. Mobile Monster’s $8.6 million becomes $25.8 million. The founder’s damages, estimated between $22.8 million and $31.8 million, treble to between $68.4 million and $95.4 million. Total potential exposure exceeds $121 million before injunctive relief, attorney’s fees, and costs.

The Enterprise Theory

What elevates this case from a collection of civil disputes to a federal RICO action is the complaint’s central argument: that these were not isolated acts by independent people making independent decisions. This was, the plaintiffs allege, a single criminal enterprise with a single architect.

The complaint identifies the enterprise as operating from 2017 through the present day. Wire fraud. Bank fraud. Bankruptcy fraud. Tax fraud. Identity theft. Money laundering. Trade secret theft. Obstruction of justice. More than 750 predicate acts. Fifteen defendants. Six attorneys. A network of shell companies. A stolen database generating eight figures annually under new corporate ownership in Ohio.

And at the center of the web, according to the plaintiffs, the man who allegedly assembled every piece: Tyler Brandon Davis of Folsom, California. The 49% minority member who held no managerial authority. The man who could not sign a contract on behalf of TopDevz but who, the complaint alleges, spent eight years building the machinery to take everything the company was worth — and then purchase the legal claims against himself for a hundred thousand dollars.

The case remains pending in the Southern District of California.

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The full court filing referenced in this article is available for download: View complaint (PDF). Additional source documentation: sites.google.com. All allegations are civil claims in a filed complaint; no findings have been made by any court.