Yes, in part. The SEC contends that the supposed Belize strike was pumped by the company with misleading information, and that when the pump was over, the purported project was abandoned without notice. It also alleges that Blackburn and others sold quite a lot of stock illegally.
That last will be easy to prove. The SEC offers very precise information about stock sales. And if all or some of it was, as they say, freed up using S-8 registration statements, that will just make it worse.
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