The Commission has sought to combat fraud in the microcap realm by suing lawyers responsible for issuing opinion letters such as Christison's, which not only cause registration violations, but enable fraudsters to profit by dumping purportedly unrestricted shares into spam e-mail and blast fax-fueled artificial markets.
See SEC v. Integrated Services Group Inc., James L. Rowton and David M. Loev, Civ. Action No. 4:05CV04071 (S.D. Tex., final judgment entered Nov. 29, 2005) (attorney Loev consented to entry of an order permanently enjoining him from violating the Securities Act's registration provisions and directing him to disgorge over $25,000 in profits and pay a $25,000 civil penalty); and SEC v. Peter W. Fisher, N. Tyler Fisher, David B. Stocker, Phillip W. Offill, Jr., and Collective Thought Holdings, Inc., Civ. Action No. 2:07CV12552 (E.D. Mich., filed June 14, 2007).