Replies to post #234473 on Digital Brand Media and Marketing Group Inc (DBMM)

[Jetmek_03052]

"Wrong", eh?

I think not! From this legally published SEC document on the proceedings page found here:

https://www.sec.gov/litigation/apdocuments/3-17990-2021-02-24-divisions-appellate-brief.pdf


On page 24 and page 25;


5. Digital Brand Has Knowingly Failed To Cure Some Deficiencies.

Digital Brand also has a high degree of culpability for the quarterly report information
missing from the Comprehensive Form 10-K which it has never corrected, now over two years
after Corporation Finance noted the deficiency. The four uncured 2018-2019 Reports still state
that Digital Brand’s DCPs are effective “notwithstanding mitigating factors outside the Company’s
control,” two years after Corporation Finance notified Digital Brand that the qualifier was
unacceptable and more than a year after Corporation Finance reminded Digital Brand that the
reports were still not corrected.

From page 33:

[sic] Digital Brand was delinquent in its filings for two years, violations that were
serious, recurrent, and then filed deficient reports for another year and one month. Digital Brand
never cured some deficiencies, and its attempts at curing others were marked by delays,
recalcitrance in the face of repeated notices of deficiency, and a troubling tendency to elide the
reporting requirements through the use of improper qualifiers that blunted the utility of critical
disclosures about controls. Digital Brand’s violations were serious, recurrent, and committed with
a high degree of culpability. A sanction other than revocation would reward Digital Brand for
gaming the system, incentivize other registrants to do the same, and undermine the Exchange Act’s
reporting requirements.

CONCLUSION

For the foregoing reasons, the Commission should vacate the Initial Decision and enter an
order revoking the registration of Digital Brand’s securities.