It happens quite often in the Pinks, let me guess the SEC now has it all wrong and the promoter still has the right story about BEHL....lol.. ok.. Where did he go after the money was gone????BEHL, they enriched insiders during the 2009 pump and dump, and then they continued to sell cheap shares to whomever would hand over cash to them. That is a fact, and they were not exactly hiring top notch people.