Spongetech Delivery Systems, Inc. (fka SPNGQ)

[cowtown jay]

re: Dennis Ringer and SpongeTech.

I looked a little more into the Administrative Proceeding filed against Mr. Ringer by the SEC. That Admin Proceeding reads, in part, as follows:

"4. Ringer purchased the 78 million shares from RM Enterprises in fifteen transactions,
and at discounts from market prices...

8. Ringer purchased the shares at a discount to the then current market price. On May
12, 2008, Ringer paid RM Enterprises $80,000 for the four million shares, or $.02 per share. The
market price of Spongetech stock on that day ranged from $0.037 to $0.047 per share.

9. On May 14, 2008, RM Enterprises transferred four million Spongetech shares to
Ringer’s brokerage account. The shares were transferred to Ringer’s account without an
appropriate restrictive legend. On May 16, 2008, after holding the Spongetech shares for only two
days, Ringer began selling the shares in the public market at prevailing market prices. Ringer sold
the four million shares at prices ranging from $0.03764 to $0.05300 per share, resulting in profits of
$93,867.31. These transactions were not registered with the Commission, and no exemption from
the registration requirements applied.

10. Between June 2008 and July 2009, Ringer continued to obtain Spongetech shares
from RM Enterprises at significant market discounts."

I cannot reconcile what the SEC said in the preceding paragraphs with the information available in the TA Transaction Journals. For instance, I only see 12 issuances made to Ringer, not the 15 claimed above. I don't see any issuances made prior to Sept 5, 2008. None were showing in May or June 2008, as the SEC claimed. Finally, I only see 65+ million shares issued, instead of 78 million shares.

I balanced with the number of issued shares the TA's and the SEC reported in the original SEC Complaint. That total did not include all of the 78 million shares the SEC has now claimed were issued to Ringer.

Another outsider named separately for selling unregistered shares of SPNG was Curt Kramer and his entity, Hope Capital.

https://www.sec.gov/litigation/admin/2016/33-10239.pdf

Kramer's Hope Capital received shares of SPNG from the same transaction in which Ringer received 10 million shares on Jan 13, 2009.

Kramer was also charged in a subsequent case with purchasing misappropriated shares of Bederra from the owner of that company's Transfer Agent.

"According to the SEC’s order, Kramer and Mazuma Holding Corporation acquired more than one billion shares of Bederra in 2009 and 2010 through 21 separate transactions from the principal of Bederra’s transfer agent, who had misappropriated the Bederra share certificates. Again they purchased the shares at a significant discount from prevailing market prices. Kramer and Mazuma Holding Corporation re-sold the misappropriated Bederra shares to the public without any registration statement for a profit of $934,404."

https://www.sec.gov/News/PressRelease/Detail/PressRelease/1370540410863

I don't see how Ringer received almost 13 million more shares than the Transfer Agent reported. But, as we see from Kramer's purchase of Bederra shares, anything is possible.