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Re: stervc post# 13263

Tuesday, 03/22/2016 11:53:18 PM

Tuesday, March 22, 2016 11:53:18 PM

Post# of 68034
stervc, has your opinion of the Section 3(a)(10) exemption effected here, and for the other five related securities that also had unregistered free trading shares to sell to the market, changed?

To be specific, what about Goulding's creative use of the exemption as intended by the letter of the law, to be used for the relief of "bona fide" specific debt already legitimately owed by the company for goods and/or services provided? Provided in the past, which qualifies it as "bona fide" in the first place IMO.


I think it was communicated, but misunderstood regarding all the facts pertaining to the 3(a)(10) Exemption. It was a lesson learned by all I am sure.



Would you clarify on what facts were misunderstood regarding the exemption? Eligibility or applicability, things in this area?


Admittedly, I have not followed TWDL, GEAR or HALB as closely as IJJP, so are we to understand that TWDL did not sell any of the exemption shares into the market? I am unclear on this matter. Thanks for any input.