Digital Brand Media and Marketing Group Inc (DBMM)

[Jetmek_03052]

That is SO totally incorrect!

It is the responsibility of the lawyers, the SEC lawyers to convince the judge that revocation was the right decision.

The responsibility of the DOE (Division of Enforcement) was to open an investigation into DBMM's record of late filings. They opened the OIP and performed that investigation. Their findings were that DBMM did indeed have filing transgressions. They were in violation of the SEC filing regulations.

The Judge (Foelak) came right out in her decision and said outright: The allegations stated in the OIP WERE PROVEN.

It was not the job of DOE to convince the judge to come to ANY specific ruling, other than the ones stipulated in the SEC regulations for delinquent filers!

The judge came right out and said the allegations of the OIP WERE PROVEN, and so DOE had every right to expect Foelak to adhere to the only two choices given to her: Revocation OR suspension. When Foelak basically MADE UP her OWN rules and let DBMM off the proverbial hook? They had every right to disagree with her ruling and file the Petition for Review.

No. The lawyers for DOE did not "screw up". They did what they set out to do - investigate DBMM's delinquent filing record and PROVE they were in violation of the filing statutes. Even Foelak agreed - the allegations in the OIP were PROVEN.

End of story.