Wednesday, October 15, 2014 8:28:12 PM
48. Upon information and belief, Hudson Bay participated, directly or indirectly, in the creation of a “death spiral” in the summer of 2013, causing significant decrease in the market price of Worlds common stock from $.54 to $.26 per share.
49. Upon information and belief, Hudson Bay has the propensity to engage in such conduct, having subsequently settled allegations of illegal short selling brought by the SEC by entering into a consent decree with the SEC as of September 16, 2013, in administrative proceeding file number 3-15478.
50. In an attempt to salvage shareholder value and to break free of the “death spiral,” the Company entered into an Amendment and Exchange Agreement, dated as of July 15,
2013 (attached as Exhibit B to the Complaint).
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