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05/11/15 5:02 PM

#88193 RE: janice shell #88191

Wow, and wow, how did they determine this?

The Registration Statement states that “t is our belief
[Respondent’s sole officer and director] had such knowledge and experience in financial
and business matters that he was capable of evaluating the merits and risks of the
investment and therefore did not need the protections offered their [sic] shares under
Securities and Act of 1933 [sic], as amended. [Respondent’s sole officer and director]
certified that he was purchasing the shares for their [sic] own accounts, with investment
intent.” These disclosures are untrue and misleading because Respondent’s sole officer
and director does not have the described knowledge or experience in financial or business
matters,
did not purchase the described shares, and did not make the described
certification.