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Monroe1

03/15/24 2:53 PM

#112304 RE: fung_derf #112299

Oh Kyle Alexander who was found guilty for promoting the other 5 companies of which our new CEO was one and who paid little fine and not included further


MGX
[27] MGX is a mining company incorporated in British Columbia. It was a reporting issuer in British
Columbia and its shares traded on the Canadian Securities Exchange during the relevant period.
[28] Stock Social and Johnston admitted that Stock Social provided investor relations services to
MGX from March to August 2017. Stock Social prepared and disseminated six different
advertorials about MGX on 14 newswires and websites. Most of those Records contained
disclaimers or disclosure:

• Two of the Records contained a section at the bottom about the websites or newswires
that published the advertorials. Those sections were titled “Third-Party Content” and said
the content came from third parties and any opinions stated were those of the third
parties. The websites and newswires disclaimed liability relating to the content;
• Two other Records contained links to disclaimers about content published or re-published
by the websites or newswires. Those links appeared at the end of the Records;
• One Record contained a section at the bottom about the newswire, titled “Disclaimer”.
That section stated “…. NNW’s compensation disclosure is incorporated herein and
appears in full at http://NNW.fm/Disclaimer”;
• In one case, Johnston sent an advertorial to a publisher for dissemination indicating Stock
Social as the source but he did not instruct the publisher to include a disclosure statement
to that effect and that Record did not contain such disclosure;
• Eight Records contained sections at the bottom. Those sections, titled “Disclaimer”, said
that the content should not be taken as investment advice.
They indicated a fee had been
paid for distribution but did not say by whom or on whose behalf;
o Three of those disclaimers stated “Source: MGX Minerals Inc.” at the bottom of
the Record following 20 paragraphs of content. They also stated that “… the
author of this editorial content is third-party and not the opinion of the
company…”;
o Three others indicated the source as Stock Social. They indicated that investors
should always consult an investment advisor before making any trading decision.
One of those had a link titled “Legal Notice”; and
6
o One indicated Baystreet as the source.
[29] None of the above Records indicated that they were issued on behalf of MGX. With respect to
the three that identified MGX as the source, Stock Social and Johnston admitted that the
disclosure was not clear and conspicuous.

[30] The investor relations services provided by Stock Social also included multiple promotional
posts about MGX by 17 social media influencers retained and paid by Stock Social on various
platforms including Twitter, Facebook and LinkedIn. A number of those posts linked to the six
advertorials. None of the posts indicated that they were issued on behalf of MGX.