CJ-2026-1458 - Itria Ventures LLC v. Integrity Construction and Roofing LLC

What's This Case About?

Let’s be real: nobody expects a high-stakes drama when someone sells a receivable. But buckle up, because in Oklahoma County, a financial company is suing a roofing contractor for nearly $100,000 over a deal that sounds less like a loan and more like a financial time bomb disguised as a business boost. Imagine this: you’re a construction company trying to keep the lights on, and some Wall Street-adjacent LLC in New York shows up offering cold hard cash in exchange for a slice of your future paychecks. Sounds great—until the slice turns into a full pie, and suddenly you owe more than you ever got. That’s the legal dumpster fire unfolding in Itria Ventures LLC v. Integrity Construction and Roofing LLC, where a supposedly simple funding agreement has blown up into a six-figure grudge match.

So who are these people? On one side, we’ve got Itria Ventures LLC—a Delaware-based financial outfit that operates in the shadowy, jargon-filled world of “merchant cash advances.” These aren’t banks. They don’t do traditional loans. Instead, they buy a piece of your future sales—like a vampire bat leasing your revenue stream. Itria’s office is in New York, but their tentacles stretch into small businesses across the country, including right here in Oklahoma. On the other side: Integrity Construction and Roofing LLC, a local roofing company trying to survive the brutal Oklahoma weather (both meteorological and economic). And then there’s Bobby Chris Johnson II—the name sounds like a backup quarterback for a minor college team, but in this story, he’s the man who signed his life away. Allegedly the owner of Integrity, Johnson didn’t just sign for the company. He guaranteed it. Which, in legal-speak, means: “If this goes south, we’re coming after you, Bobby. Your house, your car, your prized collection of vintage shingles—we want it all.”

Now, the plot thickens—like a bad gravy—on July 13, 2023. That’s when Integrity and Itria inked their first deal: the Receivables Sale Agreement, or RSA 1. Under the terms, Itria “bought” $125,000 worth of Integrity’s future customer payments—for only $100,000 in cold, upfront cash. Sounds like a sweet deal, right? But here’s the catch: Integrity didn’t just promise to pay back $125,000. They agreed to hand over 9.44% of their weekly sales—forever, or at least until the debt was cleared—with a minimum payment of $2,083.33 every single week. That’s like saying, “We’ll give you a bag of money, but every week you have to give us a cut of your paycheck, no excuses.” And if you miss a payment? Boom—entire balance becomes due immediately. No grace period. No “I had a slow month.” Just game over, pay up.

Fast forward a few months. November 17, 2023. Itria, apparently thrilled with how things are going (or maybe just smelling blood in the water), offers another deal: RSA 2. This time, they “buy” $37,500 in future receivables for $30,000 in cash. The weekly minimum? $937.50. The percentage? A seemingly manageable 1.98%. But again, the nuclear clause applies: miss a payment, and the whole thing comes due. And just to make sure Bobby Chris Johnson II can’t weasel out, he personally signs a Guaranty of Performance, swearing he’ll cover the debt if the company can’t. It’s the financial equivalent of cosigning your kid’s car loan—except the car is on fire, and the loan shark is a Delaware LLC.

Then, February 14, 2024—D-Day. According to the filing, Integrity stops making payments on both agreements. Not just late. Not partial. Stopped. And not just for a week—permanently. Now, under the terms of these RSAs, that’s not just a missed payment. That’s a Material Breach. And a Material Breach is like pressing the self-destruct button: the entire unpaid balance becomes due immediately. So Itria flips the switch. They’re not asking for next week’s payment. They’re demanding everything—right now.

And what’s everything? According to the lawsuit, $70,833.42 is still owed under RSA 1, and $29,062.50 under RSA 2. Add ‘em up, toss in some legal fees, and you get $99,895.92—just shy of a hundred grand. That’s what Itria wants. And they want it from both the company and Bobby Chris Johnson II, thanks to that fateful guarantee. It’s a joint and several liability situation, which means: Itria can go after the business, or Bobby personally, or both. And if Integrity’s bank account is emptier than a politician’s promise, guess who’s getting the garnishment notice?

Now, let’s talk about what $100,000 means in this context. For a roofing company in Oklahoma, that’s not just a bad quarter—it’s potentially game over. That could be six months of payroll. A full fleet of trucks. A lifetime supply of asphalt shingles. Meanwhile, Itria? They’re a financial firm that deals in these kinds of transactions all day. To them, this might be just another line item. But make no mistake: they’re not backing down. They’ve got attorneys from Lytle Soulé & Felty P.C.—a reputable Oklahoma City firm—on the case. They’ve filed in Oklahoma County, even though they’re based in New York, because the contracts say jurisdiction is here. They’ve dotted every i, crossed every t, and structured this case like a legal Rube Goldberg machine: one misstep, and boom, the debt explodes.

So what’s our take? Honestly, the most absurd part isn’t the money. It’s the language. This whole thing is built on the fiction that Itria “bought” receivables, when in reality, this is a loan with a fancy name and predatory terms. They didn’t buy anything. They fronted cash and are now demanding repayment with interest—except they’re calling it a “purchase price” and “remittance” to dodge usury laws. It’s financial cosplay. And the weekly percentage draws? 9.44% of revenue? For a roofing company that might have seasonal lulls, weather delays, or clients who don’t pay on time? That’s a recipe for disaster. One bad month, and the whole thing collapses.

Are we rooting for the little guy? Sure. Roofing is hard work. The industry is cutthroat. And Bobby Chris Johnson II probably thought he was getting a lifeline, not a noose. But let’s not pretend he didn’t sign the papers. He did. He even guaranteed it personally. So while we can side-eye the predatory nature of merchant cash advances, we can’t ignore that contracts—however shady—still mean something in court.

Bottom line: this isn’t a murder mystery. There’s no body. No hidden affair. Just cold, hard contracts and the brutal math of small business survival. But in the world of civil court drama, sometimes the most chilling thing isn’t a knife in the back—it’s a clause in fine print. And in this case, that clause just cost someone nearly a hundred grand.

Case Overview

$99,996 Demand Petition

Jurisdiction

District Court of Oklahoma County, Oklahoma

Filing Attorney

B. Gore Gaines, Matthew J. Becker

Lytle Soulé & Felty P.C.

Relief Sought

$99,996 Monetary

Plaintiffs

Itria Ventures LLC business
Rep: B. Gore Gaines, Matthew J. Becker

Defendants

Integrity Construction and Roofing LLC business
Bobby Chris Johnson II individual

Claims

#	Cause of Action	Description
1	Breach of Contract RSA 1	Plaintiff alleges Defendant Integrity failed to remit funds as per the terms of the RSA 1
2	Breach of Guaranty RSA 1	Plaintiff alleges Defendant Johnson is liable for Defendant Integrity's failure to remit funds
3	Breach of Contract RSA 2	Plaintiff alleges Defendant Integrity failed to remit funds as per the terms of the RSA 2
4	Breach of Guaranty RSA 2	Plaintiff alleges Defendant Johnson is liable for Defendant Integrity's failure to remit funds

Petition Text

1,076 words

IN THE DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA ITRIA VENTURES LLC, ) ) ) ) FEB 25 2026 ) ) Plaintiff, ) ) RICK WARREN v. ) COURT CLERK ) 37 ) INTEGRITY CONSTRUCTION ) CASE NO. CJ-2026-1458 AND ROOFING LLC ) and BOBBY CHRIS JOHNSON II, ) ) Defendants. PETITION COMES NOW Plaintiff Itria Ventures LLC ("Plaintiff"), a Delaware limited liability company, and for its causes of action against the Defendants, Integrity Construction and Roofing LLC ("Integrity") and Bobby Chris Johnson II ("Johnson"), states as follows: 1. Itria Ventures LLC is a Delaware limited liability company, with a principal place of business at One Penn Plaza, Suite 4915, New York, New York 10119. 2. Integrity is an Oklahoma limited liability company with its principal business location and registered agent address in Oklahoma County. 3. Johnson is an individual residing in Oklahoma County, Oklahoma. Johnson, upon information and belief, is the owner of Integrity. ALLEGATIONS COMMON TO EACH CLAIM FOR RELIEF 4. Plaintiff is engaged in the business of providing financial accommodations to its business customers through, among other things, the purchase of merchant accounts receivable. 5. On or about July 13, 2023, Plaintiff entered into a Receivable Sale Agreement ("RSA 1") with Defendant Integrity whereby Plaintiff purchased, and Defendant Integrity sold, accounts receivables of Defendant Integrity in the total amount of One Hundred Twenty Five Thousand Dollars ($125,000.00) (the "Amount Sold") for the purchase price of One Hundred Thousand Dollars ($100,000.00). 6. Pursuant to the RSA, Plaintiff agreed to receive the Amount Sold from Defendant Integrity by the latter's remittance of 9.44% of Integrity' accounts receivables, but no less than Two Thousand Eighty-Three Dollars and Thirty-Three Cents ($2,083.33) every week (the "Remittance Amount"). 7. On or about November 17, 2023, Plaintiff entered into another Receivable Sale Agreement ("RSA 2") with Defendant Integrity whereby Plaintiff purchased, and Defendant Integrity sold, accounts receivables of Defendant Integrity in the total amount of Thirty-Seven Thousand Five Hundred Dollars ($37,500.00) (the "Amount Sold") for the purchase price of Thirty Thousand Dollars ($30,000.00). 8. Pursuant to the RSA 2, Plaintiff agreed to receive the Amount Sold from Defendant Integrity by the latter's remittance of 1.98% of Integrity' accounts receivables, but no less than Nine Hundred Thirty-Seven Dollars and Fifty Cents ($937.50) every week (the "Remittance Amount") 9. RSA 1 and RSA 2 set forth certain actions which would result in a material breach of the RSAs. One material breach is Defendant Integrity' failure to timely remit to Plaintiff the Remittance Amount (the "Material Breach"). 10. Pursuant to the terms of RSA 1 and RSA 2, in the event of a Material Breach, Plaintiff has the immediate right to the balance of the Amount Sold, plus reasonable attorneys' fees and costs incurred by Plaintiff as a result of Defendant Integrity's Material Breach. 11. Contemporaneous with the execution of RSA 1 and RSA 2, Defendant Johnson, as Defendant Integrity’s Guarantor, executed a Guaranty of Performance whereby Johnson guaranteed the performance of Defendant Integrity’ duties and obligations pursuant to both of the RSA (the “Guaranty of Performance” and along with the RSA, the “Agreement”). 12. As set forth therein, Plaintiff and each of Defendants expressly consented to the jurisdiction of the courts located in the State of Oklahoma. FIRST CLAIM FOR RELIEF (Breach of Contract RSA 1) 13. Plaintiff repeats and realleges the allegations set forth above as if fully set forth at length herein. 14. Beginning on or about February 14, 2024, Defendant Integrity failed to remit to Plaintiff the Remittance Amount pursuant to the terms of the RSA 1. 15. Accordingly, Defendant Integrity is in Material Breach of the RSA 1. 16. Pursuant to the terms set forth in the RSA, Plaintiff is immediately entitled to the balance of the Amount Sold plus reasonable attorneys’ fees and costs incurred by Plaintiff as a result of Defendant Integrity’ Material Breach. 17. The balance of the Amount Sold that is due and owing is Seventy Thousand Eight Hundred Thirty-Three Dollars and Forty-Two Cents ($70,833.42). SECOND CLAIM FOR RELIEF (Breach of Guaranty RSA 1) 18. Plaintiff repeats and realleges the allegations set forth above as if fully set forth at length herein. 19. As a result of Defendant Integrity’ failure to remit to Plaintiff the balance of the Amount Sold plus reasonable attorneys’ fees and costs incurred by Plaintiff as a result of Defendant Integrity’s Material Breach, Defendant Johnson is liable for the same pursuant to the Guaranty of Performance. 20. Defendant Johnson has failed to remit to Plaintiff the balance of the Amount Sold plus reasonable attorneys’ fees and costs incurred by Plaintiff as a result of Defendant Integrity’s Material Breach and thus is in breach of the Guaranty of Performance. 21. The balance of the Amount Sold that is due and owing is Seventy Thousand Eight Hundred Thirty-Three Dollars and Forty-Two Cents ($70,833.42). THIRD CLAIM FOR RELIEF (Breach of Contract RSA 2) 22. Plaintiff repeats and realleges the allegations set forth above as if fully set forth at length herein. 23. Beginning on or about February 14, 2024, Defendant Integrity failed to remit to Plaintiff the Remittance Amount pursuant to the terms of the RSA 2. 24. Accordingly, Defendant Integrity is in Material Breach of the RSA 2. 25. Pursuant to the terms set forth in the RSA, Plaintiff is immediately entitled to the balance of the Amount Sold plus reasonable attorneys’ fees and costs incurred by Plaintiff as a result of Defendant Integrity’s Material Breach. 26. The balance of the Amount Sold that is due and owing is Twenty-Nine Thousand Sixty-Two Dollars and Fifty Cents ($29,062.50). FOURTH CLAIM FOR RELIEF (Breach of Guaranty RSA 2) 27. Plaintiff repeats and realleges the allegations set forth above as if fully set forth at length herein. 28. As a result of Defendant Integrity’s failure to remit to Plaintiff the balance of the Amount Sold plus reasonable attorneys’ fees and costs incurred by Plaintiff as a result of Defendant Integrity’s Material Breach, Defendant Johnson is liable for the same pursuant to the Guaranty of Performance. 29. Defendant Johnson has failed to remit to Plaintiff the balance of the Amount Sold plus reasonable attorneys’ fees and costs incurred by Plaintiff as a result of Defendant Integrity’s Material Breach and thus is in breach of the Guaranty of Performance. 30. The balance of the Amount Sold that is due and owing is Twenty-Nine Thousand Sixty-Two Dollars and Fifty Cents ($29,062.50). WHEREFORE, Plaintiff demands judgment against Defendants, jointly and severally, in the amount of Ninety-Nine Thousand Eight Hundred Ninety-Five Dollars and Ninety-Two Cents ($99,895.92), together with interest thereon from February 24, 2024, and reasonable attorneys’ fees and costs and further relief as the court may deem just and proper. Respectfully submitted, B. Gore Gaines, OBA No.16500 Matthew J. Becker, OBA No. 35057 Lytle Soulé & Felty P.C. 119 N. Robinson, Suite 1200 Oklahoma City, OK 73102 Tel: (405) 235-7471 Fax: (405) 232-3852 Email: [email protected] [email protected] Attorney for Plaintiff Itria Ventures LLC