Subject: File No. S7-06-13
From: Gary J Brooks, Jr

August 7, 2013

I have some general questions about marketing a security under 506(c) using modern social networks. For instance, lets assume I want to send a Tweet of 240 characters (or less) via Twitter.

Lets also assume the following:

The 506 (c) is legal.
Our company has already filed a Form D and elected 506 (c).
The holding time after registration has passed.
We've decided its time to publicly solicit our legal implementation of our security under 506 (c) guidelines.

My questions:

1) Can I avoid the disclosures (legend context) in the Tweet?

2) Can we create a Tweet and link to a webpage with disclosures? (legend context)

An example Tweet:

"Offering Preferred Shares at 6% - come and go as you please - $10,000 minimum deposit - monthly dividend checks - Read our Disclosure: http://Link-To-Disclosure-or-picture-with-legend.html".

3) Can I use a linked photograph in a call to action for the legend?

4) Can you provide an example of how I can use Twitter, Facebook or other social media to legally solicit?

Gary Jay Brooks CEO
[email, phone number and address redacted]