To: scion who wrote (22062 ) 4/8/2012 2:17:10 PM From: scion Read Replies (1) | Respond to of 53574 7. The first sentence of paragraph 7 is a description of the statutory basis for the SEC’s authority to which no response is required. The allegation of jurisdiction in this Court is admitted, but Baldwin denies any characterization of his alleged conduct as unlawful. 8. The allegation of proper venue in this District is admitted. Baldwin further admits that Defendant JBI had a principal executive office in the District of Massachusetts from approximately 2009 until the summer of 2010, but denies any characterization of his alleged conduct as unlawful. 9. Baldwin states that paragraph 9 contains legal conclusions to which no response is required. To the extent a response is required, Baldwin denies the allegations contained in paragraph 9. 10. Baldwin denies the allegations in paragraph 10. Ronald Baldwin, Jr.'s ANSWER to 1 Complaint Doc 13 PDF file viewer.zoho.com or tinyurl.com SEC COMPLAINT JURISDICTION AND VENUE 7. The Commission brings this action pursuant to the enforcement authority conferred upon it by Section 20(b) of the Securities Act [15 U.S.C. §77t(b)] and Section 21(d) of the Exchange Act [15 U.S.C. §§78u(d)]. This Court has jurisdiction over this action pursuant to 28 U.S.C. §1331, Section 22(a) of the Securities Act [15 U.S.C. §77v(a)], and Sections 21(e) and 27 of the Exchange Act [15 U.S.C. §§78u(e) and 78aa]. 8. Venue is proper in this district pursuant to 28 U.S.C. §1391(b)(2), Section 22(a) of the Securities Act [15 U.S.C. §77v(a)], and Section 27 of the Exchange Act [15 U.S.C. §78aa] because at all relevant times the Defendants transacted business in the District of Massachusetts, which also was the principal place of business of JBI for a portion of the relevant period set out in this Complaint, and because a substantial part of the acts constituting the alleged violations occurred in the District of Massachusetts. 9. In connection with the conduct alleged in this Complaint, Defendants directly or indirectly made use of the means or instruments of transportation or communication in interstate commerce, the facilities of a national securities exchange, or the mails. 10. Unless enjoined, Defendants will continue to engage in the securities law violations alleged herein, or in similar conduct that would violate the federal securities laws. Doc 1 PDF file SEC COMPLAINT sec.gov