I said JMHO. Technically he may not be committing fraud as he is investing some money in this shell game and is "trying" to put this deal together like so many other pinks. Almost all of these pinks have some underlying business activity to suck in newbies and they have to show something to puff up. The more legitimate LOOKING the better. In the end he will slowly fold up shop on this "Division" of SYNJ as the grant denial will be his excuse and after all, he tried