Digital Brand Media and Marketing Group Inc (DBMM)

[Jetmek_03052]

I completely disagree.

1. We won ID

Good Lord. I hear this all the time. Unfortunately it is NOT TRUE. The “ID” is called “initial” becomes it means ABSOLUTELY NOTHING until FINALIZED! The ID came out and was LEGITIMATELY CHALLENGED. It has decided nothing. It means nothing. It is not final.

2. SEC hasn't sided with the Review

What does this mean EXACTLY?? It’s being reviewed. If the SEC wasn’t going to review it, they already would have ruled AGAINST the review LONG AGO! What....does it seem possible they been sitting around for going on 14 MONTHS hemming and hawing, saying “Geez, should we review or shouldn’t we review....let’s toss it around for another year shall we”????

3. SEC hasn't said no to DBMM wanting a drop of the Review.

Irrelevant. I guess the opposite side of that argument is that, since the SEC didn’t file any motion to quash the DBMM motion to dismiss, that they WELCOME the dropping of their own PFR???

4. No penalty is warranted.

Of course a penalty is deserved. DBMM broke the filing statutes for THREE YEARS! Foelak admits it right in the ID. Companies are sanctioned for doing so. DBMM has faced NO SANCTION to date. Of COURSE they will be sanctioned.

5. DBMM is current for past two years.

No. This has been discussed as nauseam.

Corp finance has said over and over again that DBMM became materially deficient when they failed to publish the REQUIRED FINANCIAL NUMBERS from previously delinquent 10Q’s in the “Super 10K” filing. Because of that deficiency, DBMM is NOT COMPLIANT to this day!