"so when was the media credits first shown on a quarterly report, I think you will find that that was on the 11/15/2009, so for 3/4 of the money raised in these two placements in question, the media credits were not even on a SEC filing"
The SEC isn't restricted to a company's filings as a source for misrepresentations. The fact that the improper valuation was offered up in the Pipe Memorandum supports securities law violations all by itself.