SEC Charges Eleven in Stock Manipulation Ring

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Canceli provided the accounts from which Dynkowski subsequently sold purportedly unrestricted shares received from the issuer through Defendant Gary Heath, who Bailey and Ternes arranged to act as a conduit for the shares.

SEC AMENDED COMPLAINT
http://sec.gov/litigation/complaints/2010/comp21463.pdf

3. The GH3 pump-and-dump scheme occurred between October and December 2006. Dynkowski orchestrated this fraud with Defendant Matthew Brown, who operates a penny stock website called InvestorsHub.com.

Brown introduced Dynkowski to Defendant Richard Bailey, an officer of GH3, and to Defendant Jake Canceli, a penny stock promoter who participated in the scheme.

Brown acted as a liaison between Dynkowski, Canceli, Bailey and Defendant Florian Ternes, the CEO of GH3.

Dynkowski and his associates used wash sales, matched orders, and other manipulative trading, timed to coincide with false, misleading, and touting press releases arranged by Bailey and Ternes at the company, to artificially inflate the price of GH3 stock.

Canceli provided the accounts from which Dynkowski subsequently sold purportedly unrestricted shares received from the issuer through Defendant Gary Heath, who Bailey and Ternes arranged to act as a conduit for the shares.

The scheme culminated in mid-December 2006, with Dynkowski dumping 312 million shares of GH3 stock for total proceeds of $747,609.

SEC AMENDED COMPLAINT
http://sec.gov/litigation/complaints/2010/comp21463.pdf