Spongetech Delivery Systems, Inc. (fka SPNGQ)

[loanranger]

I've referred to the SEC Enforcement Manual a number of times and am aware of it's section on the Wells process, thanks.

Unfortunately it does not answer my questions directly:
1. Can we assume that the three notices vary in terms of the allegations and citings?
2. Does a typical Wells notice merely outline the alleged rules violations and not provide the actual acts that comprise the violation?
3. If the actual acts are not provided to the respondents in the notices and given that they haven't been made available to the public, would it be correct to assume that your connections of acts to violations are assumptions on your part, reasonability notwithstanding?

The third question can only be answered by patchman himself. But if you run across an ACTUAL Wells notice it might help with the second one and I would very much like to see it.