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Friday, December 06, 2019 4:45:52 PM
If ANYTHING, the letter asking for review proves that Foelak IGNORED the norms and came up with her own WARPED reasons why she thought DBMM should be spared revocation.
The reasoning she used is not based on prior rulings. It’s almost like she just picked them out of thin air.
The facts stated in the request for review are logical and based on what many other companies did that caused THEIR stock revocation. To abandon those norms and basically just state that “The SEC’s case is proven, but I don’t see a sanction that is appropriate” is not logical.
If the appropriate sanction for other companies that did the same as what DBMM did was revocation of stock, than that sanction should certainly be more than appropriate for DBMM.
I keep telling myself....deep breath....count to ten....try to answer without personal attack...if available, always try to present fact to back up your opinion.
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