RemSleep Holdings Inc (RMSL)

[janice shell]

C. The REMSleep Holdings, Inc. (“RMSL”) Stock Promotion Scheme

102. On December 13, 2019, Costello acquired over 4.5 million shares of RMSL, and its stock closed at $0.02 that day. Costello purchased an additional 121,000 shares of RMSL on the morning of December 16.

103. Also on the morning of December 16, Costello messaged Ferraro to share his position: “RMSL. In for 4 mil total.” Ferraro replied that he would “start researching for noon so I have a story to tell.”

104. At 10:57 a.m. on December 16, Ferraro tweeted: “T minus 1 hour and 4 minutes....”

105. At noon, referencing a predicted 1,000 percent gain, Ferraro tweeted: “And the huge 10 bagger is....... $RMSL !!!!!!!!!!!!!!!!!!!!!!! $RMSL has entered the VERY LUCRATIVE Sleep apnea medical device market!!! They put out PR’s regularly. They should have a market cap over $10M!!! The chart is screaming for a massive run up!!!!”

106. Ferraro ultimately posted at least 100 tweets on December 16 and over 200 additional tweets over the next two weeks promoting RMSL. RMSL’s stock price reached an intraday high of $0.0368 on December 16 and closed at $0.031 that day, a 55 percent increase over the prior day’s close.

107. At no point did Costello or Ferraro disclose that Costello was selling RMSL stocks during this time period or that Ferraro would receive a share of Costello’s profits.

108. Costello began selling his shares of RMSL shortly after Ferraro began tweeting about RMSL on December 16, and sold his entire position by December 19 for profits of approximately $64,000. Costello shared $9,100 of those profits with Ferraro.

https://www.sec.gov/litigation/complaints/2022/comp-pr2022-178.pdf