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Georgia Bard

06/23/01 5:04 AM

#291 RE: DragonMaster #289

Dragon, I am in the process of pulling the historical and reviewing KB's posts now that we know there is part of a syndication where PR was given and of course support in the market through runs and financing. I now feel the more I read that possibly the syndication PR was the rhetorical manipulation of the internet message boards like the RB message board. I have not seen a 17b disclosure at who was compensated to provide PR.

It also appears that gaining control of this one was also attempted. The post Frank wanted removed and for the reasons he wanted it removed was very valid but the post had too much information and the TMI was in process.

My curiosity is who on RB is also part of this syndication. I am also curious at what financing was done and terms of the financing not to mention the approximate 15M or basically 33% (just to round it off approximately) owner of stock by this syndication. Even institutiona have to file quarterly reports when they take a position. Investment groups also.

This Financial Advisor, I am curious if they are the head financier of this syndication and responsible for the structuring of the the way it was done to accumulate around 15M shares. Is this legal to avoid the hassles and limitations of SEC regulations 13D just because it is an OTC?

This whole syndication (entity} revelation appears to me to have possibly violated several SEC regulations such as:

13d == Beneficial Ownership , http://www.law.uc.edu/CCL/34ActRls/reg13D.html
10b-3 -- Employment of Manipulative and Deceptive Devices by Brokers or Dealers, http://www.law.uc.edu/CCL/34ActRls/rule10b-3.html
10b-5 -- Employment of Manipulative and Deceptive Devices, http://www.law.uc.edu/CCL/34ActRls/rule10b-5.html
10b5-1 -- Trading "on the Basis of" Material Nonpublic Information in Insider Trading Cases, http://www.law.uc.edu/CCL/34ActRls/rule10b5-1.html
Section 15 -- Liability of Controlling Persons http://www.law.uc.edu/CCL/33Act/sec15.html
Section 17 -- Fraudulent Interstate Transactions http://www.law.uc.edu/CCL/33Act/sec17.html
E+Regulation FD (Fair Disclosure) -- http://www.law.uc.edu/CCL/regFD/index.html where in some paragraphs it states clearly "person associated with an investment adviser or institutional investment manager"

Now I do not know if it does or doesn't violate SEC regulations but I find it curious at this point and time that as long as KB has been on RB he is just now disclosing he is part of a financing, support, PR, stock runs, & syndication and wants to be a director here now.

I am also finding it very interesting that RB is not touching this. So yes Smouch, I think you may have been right all this time. There is a fox{es} in the henhouse.



:=) Gary Swancey