Spongetech Delivery Systems, Inc. (fka SPNGQ)

[Risicare]

the general nature of the investigation, including the indicated violations as they pertain to them,

I think it is quite clear they put the premise for the charges in the notice. It would be impossible to respond to anything with no idea what the charges are based on. I think what you have bolded is quite clear that they provide a basic outline of why they are recommending the charges.

Something like we have examined these brokerage records and have found wash trading which contravenes Section blah, blahh....

opposed to specifics like

On July 12th brokerage account #foo sold 150000
shares while the same beneficial owner of account #bar purchased 150000 shares contravening Section Blah, Blah.....


http://www.seclaw.com/docs/wellsnotice.htm
While there is no rule or regulation that requires that a prospective defendant be given the opportunity to address the decision maker prior to the filing of an action, in 1972, SEC Chairman William J. Casey appointed a committee (chaired by John Wells and commonly referred to as the “Wells Committee”) to review and evaluate the Commission’s enforcement policies and practices. Among the recommendations made by the Wells Committee was the following:

Except where the nature of the case precludes, a prospective defendant or respondent should be notified of the substance of the staff’s charges and probable recommendations in advance of the submission of the staff memorandum to the Commission recommending the commencement of an enforcement action and be accorded an opportunity to submit a written statement to the staff to be forwarded to the Commission together with the staff memorandum.