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Non-Tech : The SJI Group, Inc. (SJIG)

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To: Francois Goelo who wrote (38)1/15/1999 7:19:00 PM
From: Bob Davis  Read Replies (1) of 217
 
Francois,

Regarding your comment that, "I suggest you call him and ask him to confirm what I have reported, so that, if he lied, we have independent confirmation of it. I am just as interested as you are to get to the bottom of this matter."

I sense that you are making this comment in good faith. However, I have no interest whatsoever in any type of conversation with this gentleman. SJIG is a non-reporting Company, and as a result, the only information that would be deemed public is that contained in its press releases. In fact, it could be interpreted that you now possess inside information and have just traded on the basis of such information.

In fact, if you publish inside information, and someone else trades on the basis of this information, you can be held liable for his trade, and can be subject to prosecution by the SEC. About a year ago, I wrote about this in The Napeague Letter; go to napeague.com, click on "Feature Articles", and then on "Insider Trading".

Now, just to add to your concerns, "if he lied" and if you have published his "lies", then you can be whacked by the SEC for violating Rule 10b-5. "Employment of Manipulative and Deceptive Devices" of the Securities Exchange Act of 1934.

Now, I don't want to scare you - it is very unlikely that you would be discussing these issues with the SEC. But I can assure you that, since I am an Internet newsletter publisher, the SEC is more interested in my activities. In fact, the statistics page for the TNL web site contains "453 | gov.sec", which means that the SEC has visited 453 pages on the web site in the last year and a half.

Net-net...I don't want to talk to him until his company begins making full public disclosure by filing financial reports with the SEC. Reportedly, the food is not very good in the SEC jails.

Bob Davis
The Napeague Letter
napeague.com
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