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Thursday, 09/10/2009 11:50:33 AM

Thursday, September 10, 2009 11:50:33 AM

Post# of 16569
SEC response to Complaint on Kamal


Dear Mr. Rudy,



Thank you for your email.



On August 14, 2009, the Commission filed an amended complaint naming Kamal Abdallah as a defendant in an action that was initially filed on July 21, 2009. The amended complaint alleges that Abdallah conspired to manipulate the prices of UPDV. You can view the amended complaint and the SEC release summarizing its contents at http://www.sec.gov/litigation/litreleases/2009/lr21179.htm.



We understand your concerns as a shareholder of UPDV, and we are taking your complaint seriously. We cannot, however, provide you with any information outside of the allegations detailed in the amended complaint referenced above. Please understand that the SEC conducts its investigations on a confidential basis both to preserve the integrity of the investigation and to protect the reputations of companies and individuals if we find no wrongdoing or decide that we cannot bring a successful action against them. It is therefore SEC policy not to confirm or deny the existence of an investigation unless, and until, it becomes a matter of public record as the result of a court action or administrative proceeding. Accordingly, we will also not be able to provide you with updates on the status of any pending SEC investigation.



Please feel free to contact me if you have any other questions. Thanks again!



-Liora

____________________________________
Liora Sukhatme, Esq.
U.S. Securities and Exchange Commission
3 World Financial Center, Suite 400
New York, NY 10281-1022
(212) 336-0136

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