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cowtown jay

04/09/16 5:38 AM

#346105 RE: 236T568 #346100

It's hardly a point worth making. When there was an Original Issuance, who got paid for those shares? SpongeTech. The methodology of getting those shares into the market, through their affiliates, doesn't change that. You might just as well argue, then, that the affiliates didn't place those shares in the market, either. They went through clearing firms and brokerages, and through the accounts of members of the SpongeTech stock distribution network.

All of the above entities should be charged with getting those unregistered shares into the market, if the SEC's charges are correct. So far, the only example of comprehensive enforcement was by IIROC.