On May 11, 2004, an administrative law judge found that Respondent Harold Engel, Jr. violated Sections 5(a) and 5(c) of the Securities Act of 1933 when he offered and sold shares of stock to the public without a registration statement.1 On June 10, 2004, the Commission made final the Initial Decision in this proceeding as to Respondent Engel.2 Engel was ordered to disgorge $8,167.50 plus prejudgment interest