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Re: PennyHoper post# 18838

Monday, 10/30/2023 6:29:32 PM

Monday, October 30, 2023 6:29:32 PM

Post# of 22795
WCVC - Facebook and Twitter Advertisements


Two more Facebook updates (yesterday 10/29):

https://www.facebook.com/illegalburgerco/
https://www.facebook.com/KalakaMexicanKitchen/

These look like basic ads rather than announcements of specials.

The content of the Illegal Burger update
is the same as the now very stale Jan 9 Twitter update
(which was the last Twitter update).

But if Facebook updates generate notices to 'followers,' it serves a purpose.



https://investorshub.advfn.com/boards/read_msg.aspx?message_id=173120524

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October 30, 2019
WCVC Now Accepting Illegal Burger Franchise Applications Online


https://www.globenewswire.com/en/news-release/2019/10/30/1938120/0/en/WCVC-Now-Accepting-Illegal-Burger-Franchise-Applications-Online.html


Franchise Help Desk
844-372-6482

https://franchise.illegalburger.com/

https://www.facebook.com/illegalburgerco/

https://www.facebook.com/KalakaMexicanKitchen/

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Brenda Hamilton - to SEC on Facebook and Twitter Advertisements

Brenda Hamilton - Letter to Ms. Elizabeth M. Murphy - October 30, 2013

Comments on Proposed Rule:
Amendments to Regulation D, Form D
and Rule 156 under the Securities Act


https://www.sec.gov/comments/s7-06-13/s70613.shtml
https://www.sec.gov/comments/s7-06-13/s70613-454.pdf

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Two areas of concern are the requirement to file all “written materials provided to
investors” with the SEC, and the burden on companies to assure that all participants in a Rule
506(c) placement are accredited investors.

The first seems reasonable enough if the company has, for example, prepared a
presentation to be sent to prospective investors, or shown to them at a seminar or similar
function. But if the need to file extends to updates to a Facebook page, or even to very brief
Twitter notices intended to keep interested readers current with the company's activities, then
the requirement does not seem reasonable at all.
In order to stimulate interest, these kinds of
communications must be constant. To demand that every one be submitted to the SEC in
advance—with penalties if that is not done—appears to counter the intention of the new rules,
and place an inappropriate burden on the companies.

The requirement that companies using general solicitation and advertising must
themselves take “reasonable steps” to assure that participants in their offerings are genuine
accredited investors
is another burden that could make small companies shy away from using
Rule 506(c).



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