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Santa Barbara Broker

02/14/11 10:56 AM

#90280 RE: venomen2002 #90276

Also..no shares have been sold by the management..No restrictions have been removed...veno


In my opinion, this can not be proven. Therefore it cannot be stated as if it is a fact as that could be interpreted as misleading. The purpose of share disposition by Expo management would be to exchange shares for cash or other valuable goods or services. The exchange of these shares for such goods or services would be identical to having sold them for cash and using that cash to buy said goods or services. Likewise the intent behind the pledge or swap of these equities for monetary benefit would be identical to having sold them directly on the open market, to a PIPE funder or to an accredited investor. The ONLY difference in using one of the other myriad of disposition methods than direct sale would be that the semantical "out" to mislead shareholders would be intact. Let's explore the statement and it's possible meanings:

The principals of the company have never sold a single restricted share.

-They have sold unrestricted shares.
-They have exchanged shares for goods.
-They have exchanged shares for services.
-They have pledged shares for cash loans which would default in the event of non-payment in which case the shares would be taken in lieu of cash repayment.
-1000 other possible ways to obtain value from the shares without "selling" them per se.

It is simply not prudent to accept that the principals of this company, individuals who have been proven to directly mislead their shareholders over and over again, would not consider using the same exact semantical methods to mislead them where it came to personal share sales. There is a reason common shareholders of Expo Holdings, Inc. do not have access to the management's Form 3 filings. That, IMHO, is it. All IMHO.

SBB