Digital Brand Media and Marketing Group Inc (DBMM)

[Jetmek_03052]

Rubbish. The very first line of the filing (petition for review) states it a a review of the INITIAL DECISION.

It IS also a review OF THE ALJ. A review of whether or not SHE ERRED in her initial decision.

You seem to intimate that this decision can’t be in question because it would put her OTHER decisions in doubt.

That is ludicrous position.

I don’t know how many decisions Foelak has rendered. But I think that if one were to look at them, most are probably rendered using the same set of “yardsticks”. I don’t believe any of her other decisions using that criteria have been remanded or overturned.

The position of Enforcement is that she didn’t use the same “yardsticks” when giving judgement in the DBMM case.

DBMM committed the same EXACT transgressions that other registered companies committed. She revoked the stocks of THOSE companies, yet let DBMM off the hook.

Her “DBMM differs” statement is not a valid argument. She stated that the findings of the OIP were proven. DBMM violated the rules of the SEC when they intentionally failed to file the required financial documents for almost THREE YEARS.

Other companies cited for exactly the same transgressions had their stock revoked.

So should DBMM.