117. A. Hawatmeh, Galas and Mrowca began accumulating HEMP common stock through market purchases on January 23, 2014. Between January 23, 2014 and February 12, 2014, A. Hawatmeh, Galas, and Mrowca bought and sold approximately 41.7 million shares of HEMP common stock.
118. During the period from January 24 through February 12, 2014, HEMP was actively promoted on the Internet.
119. For example, on February 6, 2014, one Internet tout claimed that HEMP could reach “a REAL Possible Gain of OVER 2900%.”
120. During the promotion, A. Hawatmeh, Mrowca and Galas engaged in manipulative wash trades and matched orders of HEMP common stock.
121. The total trading volume for HEMP common stock in the A. Hawatmeh, Mrowca, and Galas accounts during this period was approximately 83 million shares.
122. Mrowca engaged in wash trades of HEMP common stock using two accounts in his name at B-D 1 (the “Mrowca #1” and “Mrowca #2” accounts).
123. For each wash trade of HEMP common stock, Mrowca entered a limit order to sell that had a lower limit price than the corresponding limit order to buy. The purpose of Mrowca’s sell low/buy high strategy was to increase the stock price.
124. Mrowca also engaged in matched orders of HEMP common stock with Galas, A. Hawatmeh, and a third party identified herein as “Trader B.”
125. From January 24, 2014 through February 12, 2014, while these manipulative trades were taking place, HEMP’s stock price increased by 573%.
126. Mrowca entered matched orders for HEMP common stock knowing that matching orders had been placed or would be placed by Galas or A. Hawatmeh.
127. Galas entered matched orders for HEMP common stock knowing that matching orders had been placed or would be placed by Mrowca.
128. A. Hawatmeh entered matched orders for HEMP common stock knowing that matching orders had been placed or would be placed by Mrowca.
129. Mrowca entered the matched orders and wash trades for HEMP common stock with the intention of creating a false or misleading appearance of active trading in HEMP common stock or a false and misleading appearance with respect to the market for HEMP 7 common stock.
130. Galas entered the matched orders for HEMP common stock with the intention of creating a false or misleading appearance of active trading in HEMP common stock or a false and misleading appearance with respect to the market for HEMP common stock.
131. A. Hawatmeh entered the matched order for HEMP common stock with the intention of creating a false or misleading appearance of active trading in HEMP common stock or a false and misleading appearance with respect to the market for HEMP common stock.
132. A. Hawatmeh’s, Mrowca’s and Galas’s matched orders and wash trades affected the market price and volume of HEMP common stock.
133. The price and volume of HEMP has collapsed since February 12, 2014. On June 17 24, 2014, the volume was approximately 7.4 million shares and the closing price was $.0590 per share.
134. During the period of the manipulative trading, from January 24 through February 12, 2014, sales of HEMP common stock in the Mrowca account generated gross profits of approximately $106,000; sales of HEMP common stock in the A. Hawatmeh account generated gross profits of approximately $229,000; and sales of HEMP common stock in the Galas account generated gross profits of approximately $12,500.
Extract - 08/05/2014 3 AMENDED COMPLAINT against defendant(s) All Defendants with JURY DEMAND, filed by Securities and Exchange Commission.(Stoelting, David) (Entered: 08/05/2014) Doc 3 PDF file http://www.sec.gov/litigation/complaints/2014/comp-pr2014-159.pdf
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