Subject: File Number 265-27
From: Darrell Starr-Jude

February 16, 2016

I would like to add these thoughts:  The SEC realizes the Pump and Dump as a fraud and illegal scheme. The goal is to raise a price  and sell off at a higher level.

One must think outside of the box, if a scheme exist for driving price higher then can an individual receive gains at driving a price lower.  Who would benefit?

I call it a “Dump to Sump” and this must be recognized as a Creativity Manipulation obtaining value at the loss of monetary value in relinquishment of shares. Option trade could be one objective and causing hardship to a stock funded corporation. The tools are created by current Bid/ASK spread widening and placing a simple ASK to sell.

Any ASK order placed into a window of a spread: immediately lowers the current ASK PPS. Creativity Manipulation must be observed by data: (i.e.) the current monetary state of BID and ASK into which order was place, the changes occurred to Bid/ASK after trade, the trader (with a record of past transactions) and detection of a pattern.  This is a few details that may form the statistics for patterns use to determine abuse.

Thank You,


Darrell Starr-Jude