8. As set forth further below, from at least August 2013 through February 2014, MICHAEL AFFA, ANDREW AFFA, and BROWN participated in a "pump-and-dump" scheme pursuant to which they conspired to fraudulently manipulate the publicly traded shares of Amogear for their own benefit (the "Amogear Scheme").
9. A pump-and-dump scheme typically involves the artificial inflation of the stock price of a publicly traded company by, among other things, issuing news releases and/or promotional materials - often containing false or exaggerated information - and/or by engaging in undisclosed coordinated trading of the stock to inflate its price and generate the appearance of demand for the shares (the "pump"), followed by the sale of those shares at artificially high prices to other investors (the "dump").
10. As part of the Amogear Scheme, MICHAEL AFFA, ANDREW AFFA, and BROWN conspired to "pump" Amogear's stock price - and attempted to do so - by, among other things, ( 1) engaging in secret, coordinated trading designed to artificially increase the price of the stock, while also creating the false appearance of demand, and (2) sending "blast" e-mails, and hiring others to send such e-mails, containing false and misleading statements touting the company, with the intent of increasing demand for the stock. MICHAEL AFFA, ANDREW AFFA, and BROWN also conspired to "dump" Amogear's stock by selling it to other investors at the artificially high prices they themselves had created, with the intent to share the proceeds of those sales amongst themselves.
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