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maddawg1

08/24/12 11:07 AM

#150893 RE: Isitreal #150863

I don't see HFBG listed as a defendant.

(Since at least August 2009, Defendants have engaged in a scheme to purchase billions of shares of stock from small companies and illegally resell those shares to the investing public, without complying with the registration requirements of the federal securities laws.)

(FACTS

Defendants

7.Bronson, age 46, resides in Ossining, New York. Bronson is the sole managing member ofE-Lionheart, an entity he used to facilitate his illegal stock sales.

8.E-Lionheart, formed in 2005 as a Delaware limited liability company, also does business as "Fairhills Capital." E-Lionheart is registered in the State ofNew York as a foreign limited liability company. Bronson is the sole managing member ofE-Lionheart. At all times relevant to this Complaint, E-Lionheart has maintained its sole physical office in White Plains, New York.

Relief Defendant

9. FCI was formed in 2010 as a Delaware corporation, and maintains a registered business address in White Plains, New York at the same location as E-Lionheart. Bronson is the President and owner ofFCI. FCI was unjustly enriched by Bronson's transfer to FCI ofat least $600,000 of the proceeds from the illegal stock sales described herein.)