LZ Northern LLC has filed a lawsuit against Shoo Loong Kan Richardson LLC and David Cheng, accusing them of fraudulent misrepresentation to secure a $280,000 investment. The complaint was lodged in the United States District Court for the Eastern District of New York on December 18, 2025.
The plaintiff, LZ Northern LLC, claims that they were fraudulently induced into investing in Shoo Loong Kan Richardson LLC based on false representations about the company's anticipated revenue and profits. According to the lawsuit, the defendants promised that the company would generate $450,000 in monthly revenue with a profit margin of 26% per year. These assertions led LZ Northern to enter an investment agreement on August 23, 2024. However, after making the investment, LZ Northern discovered discrepancies between these promises and the actual financial performance of Shoo Loong Kan Richardson LLC.
The complaint details how LZ Northern was assured a ten percent share of net profits as part of their investment agreement. Yet, since entering into this agreement, they have only received one payment amounting to $8,492.79 for the fourth quarter of 2024. Further compounding their grievances is a communication from July 23, 2025, where Shoo Loong Kan Richardson LLC informed them that no distributions would be made for Q1 and Q2 due to cash flow constraints. This communication contradicted earlier assurances and highlighted significant differences between expected and actual financial outcomes.
In addition to allegations of fraudulent inducement, LZ Northern accuses Shoo Loong Kan Richardson LLC of breaching their contract by failing to provide access to company books and records as stipulated in their agreement. Despite sending a notice of default on November 12, 2025—demanding both repayment and access to financial documentation—the plaintiff received no satisfactory response or compliance from the defendants.
LZ Northern seeks several forms of relief from the court: recovery of their initial $280,000 investment plus interest; compensation for damages not less than $200,000 due to breach of contract; declaratory judgment compelling Shoo Loong Kan Richardson LLC to produce relevant financial documents; and reimbursement for legal fees incurred during this process.
Representing LZ Northern are attorneys Simon I. Malinowski, Matthew C. Schwartz, and Jonathan L. Fertig from Peraino Malinowski LLP based in New York City. The case has been assigned Case ID: 1:25-cv-06973.
Source: 125cv06973_LZ_Northern_LLC_v_Shoo_Loong_Kan_Richardson_LLC_Complaint_Eastern_District_New_York.pdf