Digital Brand Media and Marketing Group Inc (DBMM)

[Jetmek_03052]

There is NO problem with the SEC and the way this has been handled.

The facts of the case are these:

1. DBMM INTENTIONALLY CHOSE to not file the legally required quarterly and yearly financial filings.

2. After enough complaints, the SEC became aware of DBMM's filing deficiencies. They contacted DBMM and asked for information on WHY DBMM was not filing (had not filed for THREE YEARS).

3. DBMM refused to answer the SEC requests for information. They ignored the SEC requests for information for OVER A YEAR.

4. The SEC had no option other to instigate OIP proceedings against DBMM.

5. This got DBMM's (Linda's) attention. They finally answered the SEC and filed a "Super 10K", which supposedly included all information and numbers for all the delinquent filings.

6. The SEC outlined at least two major issues with the "Super 10K" filing. The first was language regarding DBMM's responsibility for the filings. The second was the LACK of 10Q financial numbers.

7. For almost another year, instead of simply complying with the SEC requested changes, Linda and her wonderful lawyer simply argued with the SEC that the SEC was wrong and that the "super 10K" was sufficient the way it was filed. After another several months, DBMM relented and filed an amendment to the "Super 10K", correcting ONLY THE LANGUAGE that the SEC flagged. They NEVER HAVE included the delinquent 10Q financial numbers in ANY amended filing.

8. Foelak came out with her RIDICULOUS ruling, never assessing ANY penalty to DBMM for not filing for THREE YEARS.

9. In the specified time period, the SEC filed the Petition For Review, citing the fact that Foelak erroneously called DBMM compliant in her Initial Decision, when the Division of Corporate finance EXPLICITLY called them MATERIALLY DEFICIENT due to the lack of delinquent 10Q financial numbers in the "Super 10K".

10. In accordance with General Rule 900, the SEC can take 7-11 Months to rule on a case, after a Petition For Review is filed. That timeline is for simple cases, not complicated ones (as this case against DBMM definitely is). At the moment, the SEC is well within that timeline.

The SEC is NOT being vindictive. This case is complicated. The fact that Foelak obviously was either given inaccurate information by the DBMM lawyer, or has wrongly interpreted what WAS given to her is plain.

DBMM should be given a severe penalty for INTENTIONALLY CHOOSING to not file FOR THREE YEARS. Foelak has given them ZERO penalty in her dismissal of the OIP.

THE SEC Board of Commissioners has this case now and you can expect SOME sort of punishment for DBMM.

Given DBMM's record of filing on time for the last several periods, revocation probably has been taken off the table. But SOME sort of punishment should be levied.