Someone brought the whole matter of the media credits to the attention of the SEC. At some point the SEC told this person that they were proceeding with the investigation.
This whole notion of a Wells Notice has been floating around for months. The suggestion to the SEC that a Wells Notice was appropriate was no doubt made long ago.
The Wells Notice may be appropriate. It was a bad mistake by the company to misrepresent the value of the media credits.
No doubt, the company will argue that the value of the media credits was misrepresented to them when the deal was made. There may be a grain of truth to that, but it demonstrates, at best, poor judgement by the company.
Whomever brought this to the attention of the SEC is either directly, or indirectly through friends, benefiting from the action. That seems like its own problem.