Court File Nos. CV-26-00015305-0000 · CV-20-00645492-0000 · CV-21-00654929-0000
Sources: Shareholder and counsel email correspondence, July to October 2025 · Recording of the Equibit emergency shareholder meeting, August 2025 · Statement of Claim v. Marc Godard, issued July 31, 2026 · Chris Horlacher’s published account
In the summer of 2025, Equibit Group Ltd. was weeks away from examinations for discovery in its lawsuit against the Canadian Security Intelligence Service. That is when Marc Godard, Equibit’s former CEO and a co-plaintiff in Equibit’s defamation suit against Christian Saucier, tried to take control of the company. Over three months he and Brent Kievit-Kylar called meeting after meeting and sent “resolutions” to Equibit’s lawyers. Their stated aims were to end the case against Saucier and to make Godard the only channel between the company and its counsel.
Each attempt failed. In Chris Horlacher’s account, the takeover was the final act of roughly five years of counterintelligence work. He prepared the share register and waited for the moment to act. What follows is the email trail.
The Statement of Claim referred to below contains allegations that have not been proven in court. Statements of Equibit’s position and Chris Horlacher’s account are identified as such.
What Was at Stake
Equibit is the plaintiff in two lawsuits: the CSIS action (CV-20-00645492-0000) and the defamation action against Christian Saucier, David McFadzean and others (CV-21-00654929-0000). Godard asked to join the second suit as a co-plaintiff. Chris Horlacher is the only person who has paid for either lawsuit. The Statement of Claim against Godard pleads that this financing exceeds $230,000 and that Godard never contributed any money to the lawsuits or to Equibit’s operations.
Godard’s stated aim was to end the suit against Saucier, not the CSIS suit. He also tried to make himself Equibit’s sole legal liaison, which would have given him control of the information flowing out of the CSIS action. If he had pushed Chris out, nobody would have been paying counsel, and the CSIS suit would have died. As Chris put it to a fellow shareholder at the time: “Would he be able to count on my continued funding even if he had grounds to carry out this coup?”
Background: A Dissolved Company, Revived to Sue
Equibit was dissolved in 2019. It came out with no assets and no liabilities. Chris later revived it for one purpose: to be a plaintiff. He wrote on August 22, 2025: “I revived the company for the sole purpose of filing the lawsuits. It has no assets and no income of any kind.” The company’s Swiss parent, Equibit Group AG, was liquidated and deleted from the Swiss commercial register on September 5, 2023.
The tool for removing hostile shareholders was no accident. Chris added the share repurchase clause, the company’s call option, to the 2018 shareholders’ agreement after Sergei’s revelation about CSIS. He needed an orderly, contractual way to eject hostile shareholders. Under the agreement, effective July 20, 2018, a shareholder’s breach lets the company buy back that shareholder’s shares.
Nathan Wosnack did not leave through that clause. He sold his shares. In Chris Horlacher’s account, the sale was Marc Godard’s idea. Under a share purchase agreement effective December 5, 2018, Wosnack sold all 8,500,000 of his shares to Equibit Group AG “for repurchase and cancellation.” He was paid 40,000 Equibits, which the agreement valued at an offering price of 20 Swiss francs each. Wosnack expressly waived his rights under the shareholders’ agreement, including its “buy/sell option,” and confirmed that he relied on no statement about “the prospects for Equibits.” The same day, he signed a deed in Santiago, Chile, transferring the shares to the company. Chris signed both documents for Equibit Group AG. The unanimous shareholder resolution approving the purchase lists 2394790 Ontario Inc., per Marc Godard, first among the shareholders asked to consent.
Godard also tried to get Christian Saucier to take the same deal. Saucier refused. His shares were taken later, in January 2021, when Equibit sued him and exercised its call option. In effect, Godard laid the groundwork for his own demise. Every shareholder who left made Mario Malt’s proxy more decisive, and the call option was later used against Godard himself.
The share register had already been shrinking. According to the Statement of Claim:
- On December 5, 2018, Nathan Wosnack sold all 8,500,000 of his shares to Equibit Group AG for 40,000 Equibits, the negotiated sale described above, not an exercise of the call option.
- On January 15, 2021, when Equibit sued Christian Saucier, the company exercised its call option over Saucier’s 8,500,000 shares at a fair market value of nil. That left 68,000,000 shares outstanding.
- Of those, Chris held 29,750,000, Godard’s holding company 2394790 Ontario Inc. held 16,745,000, Brent Kievit-Kylar held 17,000,000, Mario Malt held 4,250,000, and Ilya Fadeev held 255,000. Ilya’s shares came out of Godard’s original 17,000,000. Together, Godard’s holding company and Brent held 33,745,000 of the 68,000,000 shares, a hair under half the register. In Chris’s account, that was exactly where he wanted them.
Chris did the arithmetic. With Wosnack’s and Saucier’s shares gone, he needed only Mario Malt’s proxy to control 50% of the voting shares. Chris and Mario together outvoted Godard and Brent: Chris’s 29,750,000 plus Mario’s 4,250,000 made 34,000,000 shares, against 33,745,000 for Godard’s holding company (16,745,000) and Brent (17,000,000). That was enough to block any hostile action by Godard. Chris’s position is that Godard’s actions were plainly meant to prejudice the other shareholders, Mario and himself, and that this would justify an injunction even if Chris had been in the minority. Mario’s response to Godard’s July 29 meeting, described below, gave Chris his opening: secure the proxy first, then remove Godard and Brent from the shareholder list.
Coup Attempt One: A Meeting of a Company That No Longer Existed
On July 17, 2025, Godard emailed the shareholders to call a “Shareholders’ Meeting of Equibit Group AG, the sole shareholder of Equibit Group Ltd.” for July 29 on Zoom. He signed as 2394790 Ontario Inc., “20% shareholder,” and claimed that “This meeting is supported by shareholders representing a majority of issued shares.” The second agenda item was “Issuance of binding instructions to the board of Equibit Group Ltd. regarding legal strategy and counsel.”
Brent Kievit-Kylar replied, “Sounds good. See you all then.” Christian Saucier, a defendant in Equibit’s own lawsuit, said he would be on the call. Mario Malt declined. For Chris, that refusal was the signal that Mario was not adverse to the company. Chris told counsel the date had been chosen to fall before the Attorney General’s examination and that the agenda was a request for privileged litigation strategy.
Counsel had already noticed that Brent was “suddenly” emailing the firm. According to Equibit counsel, Godard also contacted Equibit’s counsel directly about the Equibit case at around the time the Court scheduled the examinations for discovery. Around the same time, Chris says, his VPN began experiencing severe instability.
The meeting went ahead on July 29 with Godard, Brent and Saucier. That night Godard told Equibit’s lawyers that a “duly convened” meeting had passed resolutions “binding on Equibit Group Ltd.” He asked them to “confirm once the defamation claims have been withdrawn.” According to counsel’s summary, the resolutions did two things:
- They appointed Godard the sole authorized liaison between Equibit and its lawyers and barred counsel from discussing the litigation with anyone else without the holding company’s written consent.
- They instructed counsel to withdraw the defamation claims against Saucier and McFadzean in exchange for a full and final release of Equibit and Godard, and prohibited any new defamation claims without the holding company’s approval.
Counsel confirmed that Equibit Group AG had been deleted from the register in 2023, so its former shareholders could not call a meeting or pass resolutions. Counsel also noted that Saucier, as a defendant, was in a conflict of interest and could not vote to end the case against himself. In counsel’s view, Godard was “seeking to obtain information concerning the CSIS litigation and to prevent Equibit from pursuing the defamation action.”
In Equibit’s position, joining with a defendant to end the company’s lawsuit against him was a breach of the shareholders’ agreement that triggered the company’s call option. That first attempt cost Godard and Brent their shares. According to the Statement of Claim, on July 31, 2025, two days after the meeting, a shareholder resolution confirmed the earlier repurchase of Saucier’s shares and directed Equibit to repurchase the shares of Godard’s holding company and of Brent at their fair market value of nil.
Securing the Proxy
Chris contacted Mario as soon as he declined the July 29 meeting and explained the situation. Mario asked what the company’s purchase option allowed and guessed that, “since the company has failed,” any purchase would be for a nominal amount. On August 8 he wrote: “I think that am comfortable to allow you the proxy.” Chris sent the proxy assignment on August 11, and Mario returned it countersigned on August 12.
Two days later, Brent proposed a new meeting “focused on re-aligning and restoring trust.” He wrote, “This is not a power grab or a challenge to anyone’s position.” Mario answered by naming Chris his proxy. Godard wrote that he “would love Chris to join. We are mostly looking for explanations.” Saucier added: “Would love to hear why Equibit, my own company, is suing me.” He already knew. Saucier had filed a notice of intent to defend in the case (CV-21-00654929-0000) in 2023, and to date he has never served a defence. The question was part of the act they were putting on for the meeting.
The Emergency Meeting With Ilya, and the DNS Disclosure
On Monday, August 18, 2025, with Mario’s proxy in hand, Chris held an emergency shareholder meeting with Ilya Fadeev. The meeting was recorded:
The meeting had a second purpose. Chris used Ilya for what he describes as a controlled disclosure. Earlier, Chris had told Ilya, and only Ilya, that he had identified the DNS man-in-the-middle servers intercepting his DNS queries, which let whoever ran them see Chris’s web browsing as it happened. At the start of the recording Chris tells him: “You were the only person I told that to. And within 48 hours of me telling you, those servers are now gone.” Ilya confirms that he is in contact with Godard. He says he did not raise hacking with him and that they discussed only the case against Saucier. In that conversation, Ilya says, Godard told him he had changed his mind about suing Saucier.
The Statement of Claim pleads the same sequence as an allegation: within 48 hours of Chris disclosing the DNS interception to a single third party who was in communication with Godard, the false domain name servers were removed. It also pleads that this establishes Godard as the operator.
Chris then explains the call option on the recording. Article 6 gives the option to the company, not the shareholders, and “It’s up to the board to decide whether or not to use the option.” He says Godard and Brent “are having their shares called in effective August 1st, which is basically the day after they threw that fake order at the lawyers.” Ilya declines to sell his shares, vote on the resolution, or give his proxy. He is recorded as abstaining. Chris notes that, with Mario, more than 99% of the shares eligible to vote had already voted yes. Godard and Brent were excluded from the vote for the same reason Saucier cannot vote on the lawsuit against him.
The repurchase rests on the July 31, 2025 resolution pleaded in the Statement of Claim. Formal notice followed on the evening of August 18, when Chris wrote to Godard and Brent. He said their acts on July 29 and 30 were a “triggering event” under Section 6 of the shareholders’ agreement and that “your shares have been repurchased effective August 1, 2025, for their fair market value of $0.”
The Valuation Fight
Godard answered the same night. He disputed that any breach had occurred and rejected a $0 value as “unsupported, arbitrary, and implausible.” His reasoning gave the game away: “the value of the company and its shares is materially impacted by ongoing legal proceedings.” He went on to demand “immediate disclosure of the current status of those proceedings.” The valuation dispute became his next route to privileged litigation information.
The valuation argument does not survive contact with accounting. Equibit has no assets and no revenues that any accepted method could capitalize. Speculative, extraordinary future gains such as lawsuit winnings are excluded under every valuation methodology, including discounted cash flow and capitalized earnings. Chris’s September 19 reply said the $0 price was set under the Exit Price formula in Annex 5.2, and that “there is no valuation model in use anywhere by anyone that allows you to capitalize any portion of speculative, extraordinary future legal winnings.” In Chris’s account, he cited Annex 5.2 because it is the same method any independent valuator would use: a blend of net asset value and discounted cash flows.
Godard can disagree all he likes. If the question ever went to PricewaterhouseCoopers (as is stipulated in the Shareholder Agreement), Chris, a Deloitte alumnus and fellow accountant, expects them to side with him over what he calls “the ravings of a self-interested crook.” Equibit’s position is that Godard has no standing to contest the valuation and that any challenge would fail on the merits immediately, so the company went ahead with the repurchase. The Statement of Claim pleads the related point that ongoing litigation is not recorded as an asset.
Equibit’s position is that the real value is below zero. The company carries an accumulated deficit of about $230,000, owed to Chris as the financier of the lawsuits. Strictly speaking, if the call option is valued on the company’s actual books, Godard would owe the company his share of that deficit, not the other way around.
Saucier weighed in on August 19. He complained that he had never received notice of any breach and called the claim that he had “gone into hiding” false. The fact of the matter is, Equibit’s process servers had been hunting Saucier for months, to no avail.
Coup Attempt Two: The “Equibit Group Ltd.” Meeting
Having learned that the Swiss company no longer existed, Godard changed the target. On August 22 he added Nathan Wosnack to the thread, “now that I have his email address,” even though Wosnack sold his shares back in 2018. He then purported to requisition a meeting of Equibit Group Ltd. under section 143 of the CBCA for August 26, four days later. The agenda included confirming Saucier’s “shareholder status,” “confirmation that such [call option] mechanisms do not exist,” and, once again, “disclosure of the current status of ongoing legal proceedings.”
Chris declined to attend. Adding Wosnack, he wrote, was “proof this is not actually a meeting of shareholders.” Brent moved the meeting to Google Meet, held it, and on August 26 circulated minutes: “Marc will forward to the Equibit lawyers.”
On August 28, Wosnack claimed he still owned 10% of the company. The same evening, Godard dropped him from the thread (“Nathan does not appear to be considered a shareholder”) and sent round his own version of the share register. That register still counted Saucier, whose shares Godard had previously agreed were gone, and it still counted Godard and Brent.
Turning on Equibit’s Lawyer
Godard did not go to court. He went after Equibit’s counsel instead. On August 28 he emailed Sara Erskine and her partner Hilary Book, copying Brent, under the subject “Follow-Up: Shareholder Resolution Confirming Authorized Legal Representation – Urgent Response Requested.” He demanded that the firm confirm whom it recognized as its client, failing which “I will have no alternative but to file a formal complaint with the Law Society of Ontario.”
Counsel replied the same day. No resolution had been attached. Proper notice had not been given. The requisition was not signed by any shareholder. The agenda said nothing about appointing Godard to manage Equibit’s litigation. Four days’ notice fell far short of the 21 days the CBCA gives directors to call a requisitioned meeting.
Coup Attempts Three and Four: Requisitions, Records Demands, and a Paper Board
On September 19, Chris told Godard in writing that he, Brent and Saucier were not shareholders. The remaining holders were Chris with 29,750,000 shares, Mario Malt with 4,250,000, and Ilya Fadeev with 255,000. Chris added that even if Godard and Brent were still shareholders, they lacked the votes to pass anything.
On September 21, Godard replied that he “categorically dispute[s]” the redemption and that his holding company “continues to be a shareholder.” He then called a meeting himself under section 143(4) of the CBCA, citing the shareholders’ power to remove a director. Chris’s reaction to counsel: “This reply is delusional. Or, he’s a spy and can’t give up the act, no matter how blown his cover is.”
Next came a records demand. On September 24, Godard demanded access under CBCA section 21 to the securities register, the minutes, and every record of “the alleged exercise of call options.” He copied every shareholder, Saucier and Equibit’s lawyers. On October 9 he threatened counsel a second time. A “Formal Notice of Concern” accused the firm of “facilitating or acquiescing” in non-compliance and gave it five business days to comply or step aside. Otherwise, he would refer the firm to the Law Society of Ontario’s Professional Regulation Department.
On October 14, Brent wrote to Equibit’s counsel “On behalf of the majority shareholders.” He also copied counsel for Saucier and McFadzean, the defendants. He reported that an October 13 meeting had passed resolutions that:
- declared Saucier’s shares “remain intact”;
- directed counsel to withdraw the defamation claims against Saucier and McFadzean;
- appointed Godard sole liaison with counsel;
- removed Chris Horlacher as officer and director; and
- appointed Godard director in his place.
Brent invited the defendants’ lawyers to “confirm the required steps to finalize the withdrawal and execute a full and final release.” Equibit’s counsel declined to act on any of it. She stated that she takes no corporate instructions from individuals “asserting to be shareholders” and that the dispute would have to be resolved by a court.
The Statement of Claim pleads that none of the people who attended or voted at the August 2025 or October 2025 meetings held any share of Equibit. It also pleads that the matters they voted on were reserved to the board, and that the October 13 resolutions are void.
The Pattern: Retreat, Then Return With New Lies
Chris sees the same pattern he has documented in CSIS’s conduct toward Equibit for years. Godard retreated at every sign of resistance and came back with a new story:
- When the Swiss company turned out not to exist, he switched to the Canadian one.
- When Wosnack was challenged, Godard dropped him within hours.
- Brent’s tone kept changing to suit the moment: a “duly convened” meeting, then a meeting to restore “trust,” then “not a power grab,” then resolutions removing the director.
The first coup cost Godard his shares. He carried on as if he still held them and tried twice more to call meetings. He had a remedy available if he believed the redemption was wrong: an application to the court. He never filed one. Instead he threatened Chris’s lawyer with the Law Society unless she did as he said.
For Chris, this was the dramatic finish of his campaign against CSIS: in his words, the public meltdown of an undercover CSIS agent who had completely lost the plot. The allegation that Godard acted for CSIS is Equibit’s position. It is pleaded and argued in the Marc Godard Revelation.
Where This Fits in the Equibit Lawsuit
On July 31, 2026, Equibit and Chris Horlacher issued a Statement of Claim against Marc Godard (CV-26-00015305-0000). It seeks declarations that the July, August and October 2025 meetings and resolutions are void, that the shares of 2394790 Ontario Inc. and Brent Kievit-Kylar were validly repurchased at nil, and a permanent injunction. It also pleads the DNS interception and related intrusions into Chris’s home network and accounts. Process servers have been unable to locate Marc Godard and family members at his address claim to not know who he is.
