Digital Brand Media and Marketing Group Inc (DBMM)

[Gotham Bay Group]

I get the precedent argument. I made it in the beginning when the DOE recommendation was filed and subsequently challenged. What you have pointed out, in length, is correct to the point of prior cases.
But, where it falls short, is the assumption the ALJ not agreeing with a DOE recommendation is rare or would affect ant SEC established rules. This process was setup as a check and balance in the system. These proceedings are not court proceedings, they are internal rule compliance governance based on the established rules within the SEC. Every company has a right to challenge them, just as DBMM has. Most do not because OTC is largely a scam wasteland. Some challenge SEC and some win. I am not just talking about revocation, as well. DOE has more purpose than revocation.
In addition, this process to establish a moderator(ALJ) to review the DOE and any information the company may want to present, is designed to allow for a case by case review. As many cases could have extenuating circumstances that are not in anyway related to other companies. You can't have a zero tolerance policy and maintain a working system with equality throughout. This is why, if both the ALJ and DOE come to the same unfavorable conclusion, it can be challenged in a court of law. What makes this DBMM case stand out, is almost nobody fights revocation, not any assumed precedent.