Best part is on page 13 where the SEC states a VIPR officer signed TJM's term sheet and a subscription agreement 31 times. JC Barbeck and/or John Riccio had to sign off on these agreements. According to the chart, the first offering was on 5/20/09, and the first resale was on 5/22/09. We need to see the details of these agreements. Could be made available via the FOIA eventually. Might be where investors can pay JC back if SEC wins this thing.