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To: rrufff who wrote (219)	4/14/2000 9:00:00 PM
From: PartyTime	Read Replies (1) \| Respond to of 428

rrufff--Very, very interesting. >>>There may be front running and scalping involved. It is my contention that selective leaking to associates of a "report" no matter how ridiculous that "report" may be by a purported "ANALyst", which "report" is intended to manipulate a stock price may be actionable under Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder. The fact that one individual or entity that publishes the "report" does not have a position in that stock would not, IMO, insulate that individual or entity when there is concerted action.<<< Indeed. An unregistered agent who knowingly prepares a biased report and delivers same, in however manner, to parties who are certain to promulgate an act that is demonstrably negative and harmful to a company and its investors would seem to fit within the criteria of language you cite. >>>The fact that one individual or entity that publishes the "report" does not have a position in that stock would not, IMO, insulate that individual or entity when there is concerted action.<<< However if the report writer pre-alerts family and/or friends and/or business colleagues to the likelihood that there will become a decline in a company's share price value, expressly due to the existence and targeted dissemination of the report, then that individual, unless a registered agent, should be held liable. Again, it's a fair up and a fair down market principle. Investors have a right and protections to a fair market. Rruff, you might be interested in a new thread I began on SI: Non-OTC Conspiracy Theories. Perhaps the collusion between shorters could become a topic. As you continue your research on this issue, please report your findings to that thread. Thanks. Subject 34257