Case Number: CACE-18-000934 Division: 02
Filing # 66504265 E-Filed 01/12/2018 04:01:33 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
INTELLIGENT HIGHWAY CASE NO.
SOLUTIONS, INC., a Nevada
Corporation
Plaintiff,
v.
TCA GLOBAL CREDIT MASTER
FUND, LP, a limited partnership organized
and existing under the laws of the
Cayman Islands.
Defendants.
SOMPLAINT
COMES NOW Plaintiff, INTELLIGENT HIGHWAY SOLUTIONS, INC., a Nevada
Corporation (“Plaintif?”), by and through its undersigned counsel files this, its Complaint and sues
the Defendant TCA GLOBAL CREDIT MASTER FUND, LP, a limited partnership organized
and existing under the laws of the Cayman Islands (“Defendant”), and alleges as follows:
1 This is an action for damages in excess of $15,000, exclusive of interest,
atiomey’s fees, and costs,
2. Venue is proper as Defendant's principal place of business is located in Broward
County, Florida,
3. Plaintiff, INTELLIGENT HIGHWAY SOLUTIONS, INC. (hereinafter “IHSI”),
is a Nevada corporation that is publicly traded,
4. Defendant TCA GLOBAL CREDIT MASTER FUND, LP, (“TCA”) is a limited
partnership organized and existing under the laws of the Cayman Istands and their principal
offices are located in Broward County, Florida.
4 FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 1/12/2018 4:01:32 PM.**#*$. TCA is an investment banker and lender holding itself out as “a predominately
short-duration, absolute return fund specializing in senior secured lending and advisory services
to small-caps located mainly in the US, Canada, Western Europe and Australia, The investment
objective of the Fund is to seek to achieve superior risk-adjusted returns primarily by making
directly negotiated debt and equity-related investments in public and, to a lesser extent, private
companies.”
6. Oninformation and belief, TCA is not licensed or authorized to conduct,
investment banking or lending business in the State of California under the California Finance
Lenders Law.