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Santa Barbara Broker

01/14/11 8:42 AM

#88655 RE: AStTropaz #88621

AST...I strongly suspect there never was an ETC retailer as described in that PR release. I suspect that like all other aspects of business where PRs and public stock sales are concerned, our "new" salesman, unlisted Chairman/"Co-President" and ex-CEO considers any meeting where he approaches a retailer and isn't given a polite but direct "no way...get out and don't call us" as good as a written contract. Not in his mind of course as I believe the guy is anything but insane, just from the perspective of putting stock selling crapola under the protection of forward looking language guidelines. Yes, I know that non-reporting pink sheet companies don't have the legal protection of Safe Harbor, but using Safe Harbor guidelines would provide an attorney with a "prudent and reasonable care" defense should it ever come up. And, with any justice to the scores of people being ripped off, it will come up.

I approach any and all PRs released by EXPH in general and JD Brown in particular to be written under the following premises and with the following mindset:

1) If the event is conceivable, however unlikely and near impossible, as long as proper caution is used in the wording of any release, no one is being deceived.

2) "Proper caution" shall be defined as even the most causual of sit downs with a potential retailer being written up implying that the best of all possible "pre-contractual" discussions has taken place and that it is highly likely a large monetary windfall for the company is eminent. Where there is no chance whatsoever of this happening, the PR shall be written implying "potential" rather than a sure thing.

3) Where "sure thing" was implied, a semi-plausible excuse (i.e. router failure, weather, economy, ad nauseam) shall be fabricated to explain away why the last "sure thing" fell through and that excuse shall be included in the next PR release describing the next "sure thing". Where there was no chance whatsoever, it shall be ignored and forgotten with no explaination.

I believe one can apply this template to every PR ever released by Expo Holdings, Inc. concerning future business prospects and find, with the possible exception of the Lowes display contract, they all fit the model quite nicely. All IMHO.

SBB