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RisknReturn

12/15/12 12:38 PM

#281005 RE: Poptech #280999

The fact is that YA has always selected the lowest single day out of 60, and NEOM accepts that interpretation.

The proof is in the subsequent event disclosure in the latest 10-Q: Subsequent to September 30, 2012, holders of convertible debentures have converted $469,940 of principal and accrued interest on those debentures into 96,835,097 shares of our common stock. That conversion price for October 2012 computes to $.0048 per share.

Prior to November 1, 2012, NEOM's stock never traded below $.0048 so you will need to explain how your formula could yield a price of $.0048 when the stock had never closed at a price that low in NEOM's history.

If your method had been used, that conversion price should have been about $.008.