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UNITED STATES DISTRICT COURT
COMPLAINT Plaintiff, the United States Securities and Exchange Commission (the "Commission"), for its Complaint alleges as follows: SUMMARY 1. Defendant, Douglas Norman, obtained illicit profits of at least $1.8 million through a "pump and dump scheme" that promoted the common stock of World Transport Authority ("WTA"), a company that purports to have a design for both a low-cost motor vehicle called the WorldStar and the facilities needed to manufacture it. During 2000 and 2001, from a position of authority in that company, Norman knew and approved of materially false or misleading statements about WTA, which appeared in press releases, Internet messages, and elsewhere. Norman also caused WTA to file materially false or misleading periodic reports with the Commission during those years. Norman's campaign of deception inflated the price of WTA's stock, thus generating illicit profits for him when he sold WTA shares. Norman's scheme also violated other registration and reporting provisions of federal securities laws. 2. Norman's conduct violated Sections 5(a), 5(c), and 17(a) of the Securities Act of 1933 (the "Securities Act") [15 U.S.C. §§ 77e(a) and (c), and 77q(a)]; Sections 10(b), 13(d) and 16(a) of the Securities Exchange Act of 1934 (the "Exchange Act") [15 U.S.C. §§ 78j(b), 78m(d) and 78p(a)], and Exchange Act Rules 10b-5, 13d-1 and 16a-3 [17 C.F.R. §§ 240.10b-5, 240.13d-1, and 240.16a-3]. Norman is also liable as a controlling person, pursuant to Section 20(a) of the Exchange Act [15 U.S.C. § 78t(a)], for WTA's violations of Sections 5(a) and 5(c) of the Securities Act [15 U.S.C. §§ 77e(a) and (c)], and for WTA's violations of Sections 10(b) and 13(a) of the Exchange Act [15 U.S.C. §§ 78j(b) and 78m(a)], and Exchange Act Rules 10b-5, 12b-20, 13a-1, and 13a-13 [17 C.F.R. §§ 240.10b-5, 240.12b-20, 240.13a-1, and 240.13a-13]. 3. By engaging in the conduct alleged herein, Norman directly or indirectly and as a controlling person of WTA, violated antifraud, reporting and registration provisions of the federal securities laws. Unless this Court enjoins Norman, he will continue to engage in conduct similar to that described in this Complaint. The Commission, therefore, requests that this Court issue an order permanently restraining and enjoining Norman from directly or indirectly violating the aforementioned provisions of the federal securities laws. 4. The Commission is also seeking: (a) an order that Norman disgorge, with prejudgment interest, all ill-gotten gains he obtained as a result of his illegal conduct; (b) an order directing an accounting from Norman of all WTA securities and options that he directly or indirectly, received, bought, or sold, all trading profits thereon, and all remuneration that he directly or indirectly received from WTA; and (c) an order that Norman pay civil penalties for his unlawful acts pursuant to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)], and Section 21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)]. 5. Norman's conduct shows that he is unfit to serve as an officer or director of a publicly-traded company. The Commission thus requests that this Court issue an order, pursuant to Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)] and Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)], permanently barring Norman from acting as an officer or director of any issuer that has a class of securities registered pursuant to Section 12 of the Exchange Act [15 U.S.C. § 78l] or that is required to file reports pursuant to Section 15(d) of the Exchange Act [15 U.S.C. § 78o(d)]. 6. Pursuant to Section 21(d) of the Exchange Act, [15 U.S.C. § 78u(d)], as amended by Section 603 of the Sarbanes Oxley Act [Public Law 107-204, 116 Stat. 745 (July 30, 2002)], and under the Court's equitable powers, the Commission further requests that this Court permanently bar Norman from participating in an offering of penny stock. JURISDICTION 7. This Court has jurisdiction over this action pursuant to Section 22(a) of the Securities Act [15 U.S.C. § 77v(a)] and Exchange Act Sections 21(d), 21(e), and 27 [15 U.S.C. §§ 78u(d), 78u(e), and 78aa]. 8. The Commission brings this action pursuant Section 20(b) of the Securities Act [15 U.S.C. § 77t(b)] and Sections 21(d) and (e) of the Exchange Act [15 U.S.C. §§ 78u(d) and (e)], to restrain and enjoin permanently Norman from engaging in the acts, practices, and transactions herein alleged. 9. Norman, directly or indirectly, has made use of the mails, or the means or instrumentalities of transportation or communication in interstate commerce, or of the facilities of a national securities exchange in connection with the acts, practices, and transactions alleged herein. THE DEFENDANT 10. Defendant Norman is the self-described "founder" of WTA, and he holds the title of WTA's Vice President for International Sales. At all relevant times, Norman was the de facto chief executive officer of WTA, and controlled, and was a "controlling person" of, WTA. Norman negotiated and signed license agreements for WTA; he beneficially owned or controlled more WTA stock than any other shareholder; he approved the issuance of stock for services; he was the final arbiter on, and set the terms of, all license agreements WTA entered; and he provided funds for WTA's survival. Norman, a Canadian citizen, is approximately 60 years old, and he resides in El Cajon, California. WTA 11. Until September 2000, WTA was known as Composite Automobile Research, Inc., a business incorporated under the laws of Alberta, Canada in 1996. Since about 1998, WTA's principal place of business has been San Diego, California. 12. Since 1998, WTA has registered its common stock with the Commission under Section 12(g) of the Exchange Act [15 U.S.C. § 78l(g)]. At all times relevant to this Complaint, the Over the Counter Bulletin Board ("OTCBB") of the National Association of Securities Dealers (NASDAQ) posted quotations for WTA's shares. SUBSTANTIVE ALLEGATIONS The WTA Scheme 13. WTA's core business was promoting the sale of the "WorldStar," a small motor vehicle, and a system to manufacture it. WTA's literature claimed that the WorldStar was uniquely suited to underdeveloped countries because its body resisted corrosion and because it used fewer than 500 moving parts. WTA literature also claimed that, in about 90 days, one could establish a "micro-factory" or "factory in a box" to manufacture the WorldStar. It also stated that one could establish such a factory with a small capital investment and that such a factory could produce one vehicle per day. 14. To carry out its business, WTA issued "Master Licenses" that gave a Master Licensee an exclusive marketing territory, typically covering one or two countries or a geographic region. The Master License granted the licensees "the right and responsibility" in their territory to promote the WorldStar and issue "Manufacturing and Distribution Licenses" to sub-licensees, who would actually build and sell the WorldStar vehicle. WTA based the price for a Master License on the population in the exclusive sales territory. The fee to obtain a Master License often exceeded $1 million. However, WTA typically did not require a Master Licensee to pay that fee upon issuing such a license. WTA permitted Master Licensees to make installment payments after they entered subordinate Manufacturing and Distribution Licenses. 15. WTA's Master Licenses typically required the Master Licensees to charge $372,000 for each Manufacturing and Distribution License and pay that amount back to WTA. Of the total $372,000, WTA treated $112,000 as an installment payment on the Master License, and the remaining $260,000 was to pay for establishing a "micro-factory" and manufacturing supplies. 16. WTA stated in quarterly and annual reports filed with the Commission, in press releases, on the Internet, and in other public communications that it would also receive revenue from the sale of vehicle parts and materials for manufacturing vehicles, and royalties on vehicle sales by licensees. 17. WTA's license program never succeeded. From 1998 forward, WTA made public statements and reported in its filings with the Commission that it had issued Master Licenses, entered letters of intent to issue Master Licenses, and conducted negotiations to issues license agreements for numerous countries. None of these licenses, letters of intent, or negotiations led to significant revenue for WTA. Most of WTA's licenses never went beyond the announcement stage. WTA and its licensees have sold only a handful of WorldStar vehicles since 1998, and WTA has always operated at a loss. Materially False or Misleading Press Releases 18. Beginning no later than March 2000, WTA issued numerous materially false or misleading press releases, some of which are described in ¶¶ 19-34, below. 19. On or about March 23, 2000, WTA issued a press release announcing that its Master Licensee in South America was expanding its license to all of South America and to 120 factories, increasing the licensee's "commitment" to WTA to $14.6 million, and resulting in "approximately US $45 million" in total revenues to WTA from factory sales. At that time, WTA had no reasonable basis to project that this reported agreement would result in 120 factories, $14.6 million in fees, or $45 million in revenue from factory sales. 20. On or about March 29, 2000, WTA issued a press release announcing that it had entered a license agreement with the African Electrification Foundation ("AEF"). The press release said that the agreement meant "cash for [WTA]." Contrary to this assertion, AEF paid nothing to WTA when it entered this agreement. Nor did the agreement unconditionally commit AEF to make any later payments to WTA, and AEF never made any such payment. 21. On or about April 27, 2000, WTA announced that it had placed an order for 1,000 engines to meet the "initial production requirements" for WTA's Master Licensees in the Philippines and Colombia. The same announcement stated that WTA intended to order an additional 1,000 engines over the next three months. In fact, at this time, WTA had actually ordered only 19 engines. 22. On or about April 29, 2000, WTA issued a press release headlined "[WTA] Opens WorldStar Production in the Far East," and further stating that the license was "expected to net WTA $10,000,000 in license fees over the life of the agreement." At that time, WTA had no reasonable basis to project that this reported agreement would result in $10,000,000 in revenue. 23. On or about May 9, 2000, WTA issued a press release announcing that WTA had entered a Master License agreement for Angola, with an estimated "initial value" of $1 million and estimated five-year value of $8 million. The press release also stated that the licensee had given WTA a "significant cash deposit." WTA had no reasonable basis for its valuations of the license, and it did not receive any cash deposit. 24. On or about July 18, 2000, WTA issued a press release announcing that it had entered a Master License agreement for Nigeria. The press release also stated that WTA estimated that its gross revenues would reach $11 million during the first two years of the license. WTA had no reasonable basis to support this revenue estimate. 25. On or about September 6, 2000, WTA announced expansion of its "factory to build factories" in the Philippines. It stated that, within fifty days, Phase One of this expansion project would result in building eight factories per month, and by May 2001, it would produce sixty factories per month. At that time, WTA had no orders for factories, and it had no reasonable basis to expect factories to be produced as projected. 26. On or about September 13, 2000, WTA issued a press release announcing the issuance of a Master License for China. The press release estimated that this license would lead to the sale of $900 million worth of factories and vehicle components. It also stated that the Master License would provide WTA with a fee of $40 million and that it would lead to construction of 358 factories. WTA did not have a reasonable basis to support these revenue and fee projections. 27. On or about September 18, 2000, WTA issued a press release announcing a Manufacturing and Distribution License for India, which "will generate" over $1.1 billion in revenue for WTA from the purchase of 315 factories and components for over 200,000 vehicles. WTA did not have a reasonable basis to expect that this license would generate $1.1 billion in revenue, or the sale of 315 factories and components for 200,000 cars. 28. On or about September 18, 2000, WTA announced that the Society Of Automotive Engineers (SAE) had selected WTA's WorldStar and its "Factory-in-a-Box" system as the current standard for advanced engineering. SAE never took this action or made this statement. 29. On or about September 22, 2000, WTA issued a press release stating that the Master License for Guinea "will generate" approximately $1.5 million in annual revenues for WTA. At the time, WTA did not have a reasonable basis to support this revenue projection. 30. On or about October 24, 2000, WTA issued a press release stating that the Master License for Senegal, Mali, and Gambia had a "potential value" of $110 million over the life of the license, resulting in "about $13 million in annual revenues for the company." At the time, WTA had no reasonable basis to expect that this license would generate such revenues either during the life of the license or on an annual basis. 31. On or about December 21, 2000, WTA issued a press release stating that it had entered new Master Licenses for Mexico and the Caribbean, which it "valued at" $2 million and $1 million, respectively. WTA had no reasonable basis for the valuation it placed on these licenses. 32. On or about January 8, 2001, WTA issued a press release to "update" the "$1.1 billion" India license. The press release stated that the India licensee had requested from WTA a total of 486 mini-factories over the next five-years, rather than the original order for 315. WTA had no reasonable basis to project delivery of 315 factories under the license, let alone 171 more. 33. On or about January 18, 2001, WTA issued a press release stating that WTA had entered a letter of intent to issue a Master License for Lebanon, Jordan, and Syria, resulting in an "initial fee" of $3 million to WTA. The press release failed to disclose that this agreement, even if concluded, might not generate any fee because the licensee did not commit to issue a Manufacturing and Distribution License and thus might never pay anything. 34. The revenue projections, estimates, and valuations in press releases concerning license agreements lacked any reasonable basis for several reasons. At a minimum, it was unlikely that sale of any Master License or Manufacturing and Distribution License, if it led to production and sale of any vehicles, would do so quickly enough to fulfill the revenue projections, estimates, and valuations in WTA's press releases. In addition, WTA's press releases were misleading because they described the Master License fee as a fixed amount although the Master Licenses did not unconditionally commit licensees to pay any fee at all. 35. Defendant Norman was the architect of WTA's program of press releases and promotion, and he knew and approved of WTA's press releases, described in ¶¶ 19 - 34 above. At all relevant times, Norman knew, or was reckless in not knowing, that the WTA press releases described in ¶¶ 19-34 above were false or misleading. Materially False or Misleading Statements on the Internet 36. Defendant Norman either made, or knowingly permitted the posting of, materially false or misleading statements about WTA on the Internet site "RagingBull." Norman authorized an individual, whom Norman hired as an Internet consultant ("WTA's Internet consultant") to post such statements on "RagingBull." 37. On or about October 6, 2000, WTA's Internet consultant posted on "RagingBull" a statement quoting Norman as saying that WTA would see revenues from its September 2000 China license agreement in "months, a few months." (See ¶ 26, above, quoting WTA's press release of September 13, 2000 valuing this Master License at $900 million.) WTA's "Internet consultant" also reported that Norman said, "The Q reports will soon reflect the dramatic increases in cash flowing into our company." Norman knew, or was reckless in not knowing, that these statements were false or misleading. Among other things, the China licensee had not yet placed an order for a factory. 38. On November 10, 2000, WTA's Internet consultant posted on "RagingBull" a statement quoting Norman as saying, "We [WTA] are averaging 1 micro-factory every 12 days" and that micro-factories in India would be producing WorldStar vehicles within six months. Norman knew, or was reckless in not knowing, that these statements were false or misleading. Among other things, WTA had no factory orders and lacked the resources to produce factories. 39. On December 13, 2000, WTA's Internet consultant posted a statement on "RagingBull" quoting Norman as saying that, "[the Philippine facility had] orders for cars to keep them busy for the next 6 months." Norman knew, or was reckless in not knowing, that this statement was false or misleading. Among other things, the Philippine government had not yet approved sale of the WorldStar in the Phillipines. 40. On December 13, 2000, WTA's Internet consultant posted a statement on RagingBull, which quoted Norman as saying that the factory to produce micro-factories "is in production now, and by the end of the month [WTA] hopes to produce 4-8 micros [micro-factories]. By the end of May, that should be 20 micros per month . . . ." On December 20, 2000, WTA's Internet consultant posted a statement quoting Norman as saying that WTA's operation to build micro-factories is "99% complete and operational now," and that he expected WTA would ship its first finished micro-factory in January 2001. Norman knew, or was reckless in not knowing, that these statements were false or misleading. Among other things, WTA had no orders for factories and lacked the resources to produce factories. Materially False or Misleading Statements in Quarterly and Annual Reports 41. At all relevant times, WTA has been subject to the periodic reporting requirements that the Exchange Act imposes on companies having securities registered with the Commission. 42. For the fiscal year ended June 30, 2000, WTA filed an annual report with the Commission on Form 10-KSB. That report omitted material information needed to make statements not misleading or otherwise materially inaccurate. The report described WTA's license program generally, including its installment payment plan, and it also mentioned the license agreements for the Philippines, Colombia, and Costa Rica, including the fee for them. However, the report failed to disclose substantial limitations of the WorldStar vehicle and the micro-factories for producing it. It also failed to discuss the significant obstacles and delays in obtaining governmental approvals that its licensees would face in the jurisdictions where they would operate. Finally, the report omitted discussion of events indicating that predictions in prior WTA press releases never came to pass or simply failed. In the fiscal year ended June 30, 2001, similar omissions were made in WTA's quarterly and annual reports filed with Commission. 43. Defendant Norman controlled and was a "controlling person" of WTA. He was the de facto chief executive officer of the company. He was aware of WTA's reports to the Commission, and he publicly commented on WTA's reports at least once. Norman permitted WTA to file inaccurate, materially false or misleading reports with the Commission. Norman knew, or was reckless in not knowing, that WTA's reports to the Commission were false or misleading. WTA's Stock Price 44. During 2000 and 2001, WTA's stock price increased substantially on several occasions after WTA, with Norman's knowledge, approval and participation, made materially false or misleading statements in press releases. WTA's stock price also was inflated throughout this time period as a result of WTA's and Norman's campaign of materially false or misleading statements in press releases, on the Internet, and in WTA reports to the Commission. Unregistered Sales of Securities 45. According to WTA's filings with the Commission, WTA issued Norman approximately 5.5 million WTA shares during the fiscal year ended June 30, 2000, adjusted for a August 31, 2000 4-for-1 forward split. In the fiscal year ended June 30, 2001, WTA issued to Norman approximately 750,000 more shares. WTA issued these shares purportedly to offset loans that Norman had made to WTA. In addition, in the fiscal year ended June 30, 2000, WTA issued at least 1,345,764 shares of stock to Norman for services he allegedly performed. For the fiscal year ended June 30, 2001, WTA issued an additional 2,916,000 shares to Norman for such alleged services. WTA's issuance of stock to Norman to offset loans and to compensate him for services were private sales of stock by WTA, an issuer, to Norman. WTA never filed a registration statement with respect to the transactions in which it sold these shares to Norman. No exemption to the registration requirement applied to these transactions. 46. Norman acquired the aforementioned shares from WTA with a view to distributing them. Norman's subsequent sales of the stock he acquired from WTA in private transactions were not registered, and no exemption from registration applies. From approximately January 2000 through May 2001, Norman realized at least $1.8 million by selling at least 5.5 million shares of WTA stock through Canadian brokerage accounts. Failure to File Required Reports 47. Defendant Norman never filed a Schedule 13D Form, or Forms 3, 4, or 5 related to his holding of shares in WTA. The Exchange Act required Norman to file such reports because, at various relevant times, he, directly or indirectly, beneficially owned or controlled at least five percent, and at times ten percent, of WTA's outstanding shares. In addition, irrespective of the percentage of WTA's outstanding shares that he owned, the securities laws imposed reporting obligations on Norman because he was the de facto chief executive officer of WTA and he performed policy-making functions similar to an officer. FIRST CLAIM (For Violation of Exchange Act Section 10(b) and Rule 10b-5) 48. The commission hereby re-alleges and incorporates ¶¶ 1 through 47 with the same force and effect as if set out here. 49. In the manner described in ¶¶ 10 through 44, Norman, directly or indirectly, singly or in concert with others, in connection with the purchase or sale of WTA securities, by use of the means or instrumentalities of interstate commerce or of the mails, or by use of any facility of any national securities exchange, (a) employed devices, schemes or artifices to defraud; (b) made untrue statements of material facts or omitted to state material facts necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading; or (c) engaged in acts, transactions, practices or courses of business which operated and would operate as a fraud or deceit upon a person or persons, in violation of Section 10(b) of the Exchange Act [15 U.S.C § 78j(b)] and Rule 10b-5 [17 C.F.R. § 240.10b-5] thereunder. SECOND CLAIM (For Violation of Securities Act Section 17(a)) 50. The commission hereby realleges and incorporates ¶¶ 1 through 47 with the same force and effect as if set out here. 51. In the manner described in ¶¶ 10 through 44, Norman, directly or indirectly, singly or in concert with others, in the offer or sale of WTA securities, by the use of means or instrumentalities of transportation or communication in interstate commerce or by use of the mails, (a) employed devices, schemes or artifices to defraud; (b) to obtain money or property, made untrue statements of material facts and omitted material facts necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading; or (c) engaged in acts, practices or courses of business which operated or would operate as a fraud or deceit upon a person or persons in violation of Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]. THIRD CLAIM (For Violation of the Sections 5(a) and 5(c) of the Securities Act) 52. The Commission hereby realleges and incorporates ¶¶ 1 through 47 with the same force and effect as if set out here. 53. Defendant Norman, in the conduct as described more fully in ¶¶ 45 and 46 set forth above, when no registration statement was filed or in effect, and no exemption applied to his sales, directly or indirectly, by the use of means or instruments of transportation or communication in interstate commerce or of the mails, offered to sell or sold such securities in violation of Sections 5(a) and 5(c) of the Securities Act [15 U.S.C. §§ 77e(a) and (c)]. FOURTH CLAIM (Controlling Person Liability for WTA's Violations of Securities Act Section 5(a) and 5(c), Exchange Act Sections 10(b) and 13(a), and Exchange Act Rules 10b-5, 12b-20, 13a-1, and 13a-13) 54. The Commission hereby realleges and incorporates ¶¶ 1 through 47 with the same force and effect as if set out here. 55. As set forth more fully above in ¶¶ 10 through 44, WTA issued materially false or misleading press releases, made or approved the making of materially false or misleading statements on the Internet, and filed materially false or inaccurate quarterly and annual reports with the Commission. As a result, WTA violated Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5 [17 C.F.R. § 240.10b-5] thereunder. 56. As set forth more fully above in ¶¶ 45 through 46, WTA engaged in a private sale of stock to Norman. WTA never filed a registration statement with respect to this transaction and no exemption from the registration provision applied. As a result, WTA violated Sections 5(a) and 5(c) of the Securities Act [15 U.S.C. §§ 77e(a) and (c)]. 57. During all relevant times, WTA had securities registered with the Commission pursuant to Section 12(g) of the Exchange Act [15 U.S.C. § 78l(g)]. As a result, WTA was required under Section 13(a) of the Exchange Act [15 U.S.C. § 78m(a)] and Exchange Act Rules 12b-20, 13a-1, and 13a-13 [17 C.F.R. §§ 240.12b-20, 240.13a-1, and 240.13a-13] to file quarterly and annual reports and statements with the Commission which did not contain untrue statements of material facts or omissions of material facts. As set forth more fully in ¶¶ 41 through 43, WTA filed periodic reports and annual reports with the Commission that contained materially false or misleading statements or omissions of material facts. By virtue of this conduct, WTA violated Section 13(a) of the Exchange Act [15 U.S.C. § 78m(a)] and Exchange Act Rules 12b-20, 13a-1, and 13a-13 [17 C.F.R. §§ 240.12b-20, 240.13a-1 and 240.13a-13]. 58. Norman was a controlling person of WTA and culpably participated in WTA's aforementioned violations. Norman, therefore, is liable, pursuant to Section 20(a) of the Exchange Act [15 U.S.C. § 78t(a)], for WTA's violations of Sections 5(a) and 5(c) of the Securities Act [15 U.S.C. §§ 77e(a) and (c)], and for WTA's violations of Section 10(b) and 13(a) of the Exchange Act [15 U.S.C. §§ 78j(b) and 78m(a)], and Exchange Act Rules 10b-5, 12b-20, 13a-1, and 13a-13 [17 C.F.R. §§ 240.10b-5, 240.12b-20, 240.13a-1, and 240.13a-13] as a controlling person. FIFTH CLAIM (Violation of Exchange Act Sections 13(d) and 16(a) and Exchange Act Rules 13d-1 and 16a-3) 59. The Commission hereby realleges and incorporates ¶¶ 1 through 47 with the same force and effect as if set out here. 60. Defendant Norman, as more fully described in ¶ 47 set forth above, never filed with the Commission a Schedule 13D Form, or SEC Forms 3, 4, or 5. Section 13(d) of the Exchange Act [15 U.S.C. § 78m(d)], and Rule 13d-1 thereunder [17 C.F.R. § 240.13d-1], require any person who acquires beneficial ownership of more than five percent of a company's stock to, within ten days, file with the Commission and send to the company a statement describing the purchases and other information required on Schedule 13D. Section 16(a) of the Exchange Act [15 U.S.C. § 78p(a)], and Rule 16a-3 thereunder [17 C.F.R. § 240.16a-3], require that officers, directors, and beneficial owners of more than ten percent of any class of any equity security registered pursuant to Section 12 of the Exchange Act file various reports on Forms 3, 4, and 5 relating to the acquisition and disposition of their holdings. Norman failed to file the aforementioned required reports, thus, he violated Sections 13(d) and 16(a) of the Exchange Act [15 U.S.C. §§ 78m(d) and 78p(a)], and Exchange Act Rules 13d-1 and 16a-3 [17 C.F.R. §§ 240.13d-1 and 240.16a-3]. PRAYER FOR RELIEF WHEREFORE, the Commission respectfully requests that this Court enter a judgment: (i) Permanently restraining and enjoining Defendant Norman from violating, directly or indirectly, Sections 5(a), 5(c), and 17(a) of the Securities Act, Sections 10(b), 13(a), 13(d), and 16(a) of the Exchange Act, and Exchange Act Rules 10b-5, 12b-20, 13a-1, 13a-13, 13d-1, and 16a-3; (ii) Ordering Defendant Norman (a) to disgorge, with prejudgment interest, all ill-gotten gains he obtained as a result of his illegal conduct; and (b) to make an accounting of all WTA securities and options he, directly or indirectly, received, bought, or sold, and all trading profits thereon, and all remuneration directly or indirectly received from WTA; (iii) Ordering Defendant Norman to pay a civil money penalty under Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)]; (iv) Ordering Defendant Norman permanently barred from acting as an officer or director of any issuer that has a class of securities registered pursuant to Section 12 of the Exchange Act [15 U.S.C. § 78l] or that is required to file reports pursuant to Section 15(d) of the Exchange Act [15 U.S.C. § 78u(d)] pursuant to Section 20(a) of the Securities Act [15 U.S.C. §77t (e)] and Section 21(d) of the Exchange Act [15 U.S.C. § 78u(d)]; (v) Ordering Defendant Norman permanently barred from participating in an offering of penny stock, pursuant to Section 21(d) of the Exchange Act, [15 U.S.C. § 78u(d)], as amended by Section 603 of the Sarbanes Oxley Act [Public Law 107-204, 116 Stat. 745 (July 30, 2002)], and pursuant to the Court's equitable powers; and (vi) Granting such other relief as this Court may deem just and appropriate.
Dated: February 19, 2003 http://www.sec.gov/litigation/complaints/comp17993.htm
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