SEC Charges Eleven in Stock Manipulation Ring

[scion]

21. In furtherance of the conspiracy and to accomplish its objects, defendant MATTHEW W. BROWN, and P.D. and J.M., along with others known and unknown to the grand jury, committed the following overt acts, among others, in the District of Delaware and elsewhere:

a. On or about August 4, 2006, defendant BROWN communicated via the instant messaging function of America OnLine with P.D., regarding a scheme to raise money for Asia Global through liquidating shares registered pursuant to a January 6, 2006 SEC Form S-8 filing by Asia Global (then BonusAmerica) ("the January 2006 S-8"). To participate in the deal, P.D. explained that he needed both to control the price of the Asia Global stock and needed press releases to attract investors ("blow it up with news"), which he wanted to review in advance, explaining that "[w]hatever [sector] is hot we can put PR saying they are looking into expanding into that sector." BROWN explained that, while the shares could not go into an account in P.D.'s name, P.D. would have full control over where the Asia Global shares were, and their price.

b. Between in or about December 2005 and in or about August 2006, brokerage accounts were opened at Advantage Investment Strategies ("AIS") for the receipt of and trading in Asia Global shares.

c. Beginning on or about August 9 and continuing through at least December 21, 2006, P.D., through accounts in his name and in the name of Tetrix Financial, bought and sold, and directed the buying and selling, of Asia Global shares.

d. On or about August 14, 2006, defendant BROWN communicated via the instant messaging function of America OnLine with P.D. regarding the market manipulation of AAGH stock, including P.D.'s coordinated posting of messages on on-line message boards regarding Asia Global stock wherein P.D. stated: "I got the entire world on aagh, lol, willys room, panettas room, ihub."

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Matthew W. Brown: 04/16/2009 3 REDACTED VERSION of 2 Indictment by USA as to Defendant Sealed. (rpg) (rpg). (Entered: 04/22/2009)
Doc 3 OCR extract