Replies to post #254232 on Digital Brand Media and Marketing Group Inc (DBMM)

[Poo28]

MF wins her cases and I side with her, Judge Foelak and DBMM. 

Judge Foelak has judicial discretion as ALJ. https://dictionary.law.com/Default.aspx?selected=1063 Judges apply relative judgments on absolute regulations as part of their role as Judges, heeding the intent  or decisions could be made by robots. Enforcement often overreaches and is chastised for it on the record. 

The key here as shown in MF brief is the term “material.” The Super 10-K does not require (review) Q’s  as the 

Audit for the year provides more information . Companies determine is there is “material” Q info to be cited . DBMM Audit determinative, no material events.


Qs of “little value to shareholders” when 10-K Audit filed as stated in Dismissal.


Other ALJs, like Judge Grimes, took the same position as Judge Foelak regarding the Super 10-K. Those are in place with other Judge’s orders.