Replies to post #19098 on MyDx Inc. (fka MYDX)

[Huggy Bear]

Phoenix and Rockwell are not acting as qualified investors. They are acting as broker dealers who are purchasing "debt" in exchange for discounted shares, thereby in violation of Section 15(a) if they are not registered with FINRA as broker dealers.

I cannot find either Phoenix Fund Management or Rockwell Capital Partners in the FINRA database, can you?

Can anyone? Anyone care to show how Phoenix and Rockwell are registered broker dealers, thus legally able to sell discounted shares of stock to the public?

https://brokercheck.finra.org/search/genericsearch/firmgrid

This is not their first rodeo with the selling of shares as unregistered broker dealers.

Silberstein, now Phoenix:

Allen Gabriel Silberstein, age 40, resides in Miami, Florida. Silberstein is AGS’s
99% owner, its chief executive officer and sole employee. Silberstein runs AGS’s day-to-day
operations as its only employee. Silberstein has never been registered with the Commission as a
broker-dealer, nor been an associated person of a registered broker-dealer, and does not hold any
securities licenses

https://www.sec.gov/litigation/admin/2015/34-74586.pdf


Oshana, now Rockwell:

This matter involves violations of the broker-dealer and securities registration
provisions by IBC, a financing company located in Miami Beach, Florida. Between June
2013 and March 2015, IBC entered into more than 50 separate financing transactions
through which IBC received securities from microcap issuers pursuant to an exemption
found in Section 3(a)(10) of the Securities Act. In relevant part, Section 3(a)(10) of the
Securities Act exempts from registration securities issued in court-approved exchanges for
“bona fide outstanding claims.” As part of its business model, IBC purchased outstanding
claims from creditors of microcap issuers and then settled those claims through Section
3(a)(10) exchanges. Under the resulting settlements, IBC received discounted shares, which
IBC subsequently liquidated, without registering as a broker-dealer as required by Section
15(a) of the Exchange Act.

https://www.sec.gov/litigation/admin/2016/33-10042.pdf