I bet one of the Treaty representatives the SEC is referring to here is Platon Petratos...
54. However, when certain investors refused to buy restricted shares and instead demanded free trading Treaty shares, the Treaty Defendants used Form S-8 to further their fraudulent trading scheme. Specifically, they illegally transferred at least 10.4 million Treaty shares purportedly registered under Form S-8 in exchange for cash payments or to pay commissions for stock sales.
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