That's an interesting complaint. One that raises a lot of questions.
Check out a five year chart. All this began in spring 2009? SMEV tanked bigtime in 2007. Had it been pumped and dumped before? Licht signed the contract with Watson on 3 August 2009. The stock price did pick up eventually, but not until DECEMBER 2009 into early 2010.
Another oddity: Licht says that in June 2009, the "Watson's insiders (the insiders) are beginning to purchase Simulated's stock on the open market at discounted price in an anticipation of sale when the investor relations campaign will cause the stock price to go up."
Huh?? How do you get a discounted price on the open market??
And then they say the defendants sold the stock they'd received between September 2009 and August 2011. That's a LONG time for a pumpadump.
Footnote 6: At this time, Plaintiff is not aware if Gersten, Savage produced any opinion letters for Simulated's stock issuance.
Again, huh? Why not?? After all, it was the company that issued the stock, and it's the company that gives orders to the TA to remove restrictive legends. Licht didn't know that? Or didn't pay attention? Or didn't care? That information is in the TA logs.
Wasn't there any contract detailing the "promises and representations" of the defendants? Who'd be crazy enough to issue stock without one?
If at any time, Defendants initiated any public awareness campaigns, these were designed to pump-up the price, maintain street-level interest, and to assist the Defendants in dumping the shares.
Really? What was Licht expecting? And why did he keep on issuing stock to the defendants through August 2011?? That's nearly TWO YEARS.
These false, misleading, inaccurate and/or fraudulent statements and/or documents and/or representations did cause Plaintiff to approve issuance of shares of Simulated's stock to the Defendants.
Really? He didn't ask any real questions? He didn't just say NO and call the SEC??
However, none of the Defendants were ever registered with the SEC as brokers or dealers.
What?? Of course they weren't. Hasn't Licht ever heard of FINRA? I'm not gonna check to see whether any of them WAS registered with FINRA.
Just out of curiosity, why don't he go on to implicate the TA directly, given that he claims Watson induced him to fire his old TA and hire American?
If he didn't figure all this out till January 2012, why not? Pumpadumps and how they work aren't exactly a secret in Pennyland. Did he ever, then or at any time, report what happened to the SEC, FINRA (if any of the defendants actually was a broker during the relevant period), or the Florida Securities Division?
While interesting, this isn't a very convincing complaint, which is probably explained by the fact that Licht is action pro se.
