19. The Monk’s Den discussion board was open to the public. Williams used his position as moderator to promote securities by publicly identifying various stocks as his “picks” that he had previously told a core group of followers (Core Group) that he would be promoting.
22. In June 2009 and in order to create an artificial demand for Sungro shares, Williams provided the Sungro confidential information to the Core Group. Williams also told the Core Group:
· Sungro would be his next public stock pick; · They should each purchase 5,000 Sungro shares; and · Sungro’s share price would rise to at least $5.00 USD.
27. On or about June 17, 2009, the Core Group began to buy Sungro shares. Their buy orders began filling Virk’s sell orders. Williams and the Core Group also began to promote Sungro shares on the Monk’s Den and on another discussion board.
28. Between June 15 and June 22, 2009, Virk sold his remaining Sungro shares into the artificial demand created by Williams and the Core Group at escalating prices, ranging from $0.45 USD to $2.50 USD per share.
29. After Virk sold all of his remaining Sungro shares, Williams and the Core Group continued to buy Sungro shares and promote Sungro shares on the Monk’s Den and on another discussion board.
A casual stroll through the lunatic asylum shows that faith does not prove anything. Friedrich Nietzsche