Digital Brand Media and Marketing Group Inc (DBMM)

[Jetmek_03052]

Disagree. It’s VERY complicated.

You have an ALJ that is CLEARLY DEVIATING from precedent with her “no punishment fits the crime” routine.

She herself revoked MANY companies that did EXACTLY as DBMM did - not file for years on end!

Yet suddenly, she deviates from the precedent previously set.

You seldom have a branch of the SEC fighting the ruling of one of its OWN ALJ’s! Yet the Division of Enforcement has called into question whether Foelak erred when she called DBMM compliant in filing, which is DIRECTLY OPPOSITE what the Division of Finance has REPEATEDLY CLAIMED. The division of finance wants to see the 10Q financial numbers from previously delinquent 10Q’s INCLUDED IN THE “SUPER 10K”.

They haven’t been included yet. It is TOTALLY IRRELEVANT that Foelak thinks they don’t need to be included. The RULES say that they need to be included and the REGULATORY ARM of the SEC wants to see them included!

This case is VERY complicated and in the end, Foelak’s ruling will be overturned.