I do agree with Hulk man. Future looking revenues from MJ facilities do not constitute a legitimate bona fide debt owed, which is the requirement to effect a Section 3(a)(10) exemption. I see public funding being elicited for future MJ endeavors (sic) - not the relief of bona fide existing debt.
This exemption allows for the selling of unregistered shares directly to the public for debt relief.
If IJJP or any of the other five companies in the exemption hijacking consortium wanted to raise money legitimately and legally for any forward looking revenue stream to be put into action there are a whole host of legal options. Private placements, S-1 registrations with complete prospectus disclosure, 504 offerings, 506 offerings, etc.
The Section 3(a)(10) exemption IS NOT intended to fund forward looking statements and the pockets of insiders such as Pope, Goulding, and who knows who all else.
I don't think this exemption is legitimate in any fashion.
But I do see the angle being taken here by Goulding, and have reviewed the discourse provided by stervc regarding from Goulding. The whole scheme is multi-layered, and intriguing in many aspects. Could be a precedent setter.
I think it is a clever attempt to skate around the intent of Section 3(a)(10) utilizing the legal venues within the exemption.
Goulding details communique with someone from the SEC, but I do not see any "green light" to proceed as is his interpretation from the rapport between the parties. There is no substitution for requesting a "no-action" review by the SEC before effecting Section 3(a)(10) thru the proper legal channels.
I see clever usage of the venues available and the consortium's interpretation of the exemption, but I also see a clear circumventing of the intent of Section 3(a)(10) in the first place.
Momentum trading, the Elliot Wave, pump and dump, pump while dumping, all these elements are clearly in play. And that is all part of the game of the OTC, understood.
The bottom line is for those who do not understand that IJJP is a trading vehicle, NOT a legitimate investment.
