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RUBY1100

12/20/06 10:32 AM

#86174 RE: amj23 #86145

amj23 actually according to the ERHC web site under Goverance / FCPA

in additon to a Fine - there is a potential for Prison time

However our RIGHTS WILL NOT BE CHANGED

RECALL we had the Protected STP/JDZ RIGHTS PRIOR to SEO coming on board [SEO just re negotiated the deal]

Where the anti-bribery provisions of the FCPA are breached, the following penalties may be imposed:

§ Fines of up to US$2 million against the company

§ Prison terms of up to five years and fines of up to US$100,000 per violation for individuals involved

§ The Securities and Exchange Commission (“SEC”) may seek further civil penalties.

Where the record-keeping and accounting provisions of the FCPA are breached, SEC penalties for violation of securities laws may be invoked. Wilful violations of the record-keeping provisions may result in up to 20 years imprisonment and US$5 million fines for individuals and up to US$25 million for companies.