I interpret that he has done three things inappropriate and evidence, when presented may prove those actions to be illegal: 1. he failed to disclose his paid promotional role, 2. he (is accused of selling) stock as he was promoting it (although he has denied it) and 3. he maneuvered an investment fund with the manipulated help of a New Zealand bank (USHPF) as a promoter without disclosure. This is jurisdictionally iffy and I don't know how it works. The involvement of Green Oasis also seems vague. As it stands in the complaint, it could just as easily involve any share holder.