76. On approximately June 15,2010, Capital Edge entered into a wrap around agreement involving Ingen Technologies. The wrap around agreement allowed Capital Edge to acquire purportedly unrestricted Ingen Technologies' stock at a specified price. Immediately upon signing the wrap around agreement, Capital Edge converted approximately $34,615 of the Ingen Technologies debt into approximately 192.3 million shares of stock. 77. Capital Edge procured an attorney opinion letter concluding that the transaction qualified for an exemption from the registration requirements of the federal securities laws and that Capital Edge could immediately sell the stock. Although not written by Linton, the letter was nearly identical in substance to the other letters Linton wrote for Protege and Capital Edge. 78. Beach caused Capital Edge to sell its Ingen Technologies stock into the market within 60 days of the issuance. Capital Edge's proceeds from its sales of Ingen Technologies stock were approximately $45,133. 79. Capital Edge's sales of Ingen Technologies stock were not registered and not exempt from the registration requirement. 80. Beach and Capital Edge's sales of Ingen Technologies stock violated Section 5 of the Securities Act.