That was my first thought!
My second was Bro ;-)
Unregistered securities: In the Matter of Ironridge Global Partners, LLC, Adm. Proc. File No. 3-16649 (June 23, 2015) is a proceeding which names as Respondents Ironridge and Ironridge Global IV, Ltd. which was, until recently a wholly owned subsidiary of Ironridge Global Partners. Beginning in 2011, and continuing through early 2014, the two firms implemented a business model in which microcap issuers were solicited for a liabilities for equity financing program. Under the so-called LIFE program, Respondents acquired claims against microcap issuers which were then resolved through with unregistered shares under a state court order. Utilizing Securities Act Section 3(a)(10) , which exempts from registration shares acquired in a court approved exchange for bona fide outstanding claims, Respondents received and sold about 5.5 billon shares of stock, realizing about $22 million. The Order alleges violations of Exchange Act Section 15(a). The case will be set for hearing.