Digital Brand Media and Marketing Group Inc (DBMM)

[Gusher405]

All arguments, proposed findings and conclusions>WERE CONSIDERED AND REJECTED

Below right from Initial Decision issued by Judge Foelak

https://www.sec.gov/alj/aljdec/2019/id1389cff.pdf

Key points: (which counter Division’s Petition points, directly from Judge’s Initial Decision)

1. Pg 2. “The Initial Decision is based on the existing record and the Commission’s public official records concerning Digital Brand, of which official notice has been taken pursuant to 17 CFR, Section 201.323. All arguments and proposed findings and conclusions that are inconsistent with this decision WERE CONSIDERED AND REJECTED.”

2.Pg 7 Para 3. The Judge addressed why Absolute is neither appropriate precedent, nor on point. ”Thus the company’s situation DIFFERS from cases in which the Commission determined that revocation was necessary or appropriate.”