Below is an initial draft of the e-mail I prepared. I need everyone’s opinion whether it is appropriate for each one of us to send the email to the SEC contacts you have listed or should we try to follow up with PRMO management first on our list. The reason why I ask this is the nature of the questions might not be appropriate to request from an SEC enforcement office. Maybe it’s just me and I don’t have enough experience with this. Please let me know if anyone has any edits or if I am missing any details or questions.
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July XX, 2011
Dear SEC Enforcement Officer,
My name is XXXX and I am currently a shareholder of Prom Resources Inc. which is a pinksheet stock that trades under the symbol PRMO. I would like to file a complaint on the lack of updates and verifiable information from management about the company’s operations to substantiate the financial reports they have been filing and request your assistance to obtain this infromation since management is not responding to the information request.
Due to the lack of verifiable updates from management, I have witnessed the price per share drop to $0.0001 which does not reflect the true value of the company based on the information report in their financial statements, there is no longer any bid on the stock and there has been very little volume for over a month.
The transfer agent is currently gagged and the shareholders are not able to reach management who I believe is ultimately lead by Mr. Gerry Sklar. Listed below are a few quick facts about the company for your reference:
• Formerly known as American Benefits Group Inc.
• Incorporation Date: February 26, 1996
• Financial year-end: June 30
• Authorized Shares: 20,500,000,000 as of November 3, 2010
• Outstanding Shares: 8,418,197,564 as of September 30, 2010
• Federal ID No.65-0647122
• Transfer Agent: Transfer Online, Portland OR (Ph: 503-227-2950)
• Executive Management: Dror Moradov, President and Director; Shyam H. Vasnani, director, COO and CFO
• For Q1 June 30-Sept 30, 2010, sales were $4,115,124, which generated a net profit of $3,009,794
• For fiscal year ending June 30, 2010, sales were $6,172,876, which generated a net profit of $2,309,938
• For fiscal year ending June 30, 2009, sales were $3,027,000, which generated a net profit of $489,631
• For fiscal year ending June 30, 2008, sales were $1,250,000, which generated a net profit of $951,225
• Gold inventory as of September 30, 2010 was $15,315,872
I am requesting your assistance to investigate Prom Resources Inc. management on the following information requests which we have not been able to obtain from management:
1. Current authorized and outstanding share counts
2. Verification why management is not submitting updated filings to OTC Markets (pinksheets) and when do they plan on removing the current stop sign
3. Verification on how many employees are currently employed by Prom Resources Inc.
4. Why management is not responding to emails and phone calls from shareholders
5. Current value and cost of the company’s gold inventory
6. Name, location and interest attained by the company in the gold refinery they disclosed in the December 29, 2010 press release that they are negotiating an interest in
7. Listing of all properties they own and the related resource data for each
8. Location, ownership proof and condition of the $4.5 million in mining equipment disclosed in their financial statements
9. Substantiation of the sales and costs they are reporting in the financial statements
10. Since American Benefits Group Inc. mined in Madagascar 10 years ago, we are requesting proof of change of ownership of the Prom Resources shell from Mr. Gerry Sklar to Mr. Dror Moradov and of two mining properties in Madagascar named Saowani Development SARL and Stones and Woods which were reported in the Prom Resources Inc. financial statements.
I would greatly appreciate your answer to my assistance request by July 30, 2011. I am very concerned with the current share price, the lack of volume in PRMO stock and the lack of updates from management. Please don't hesitate to contact me if you need clarification on any of my questions. I have included my personal phone number below if you prefer to speak to me to discuss the requests listed above.
Thank you in advance for your time,
XXXXX
XXX-XXX-XXXX