Subject: Administrative Proceeding File Number 3-20537
From: Hong
Affiliation:

Feb. 28, 2022

To Whom It May Concern: 


First, I applaud your efforts in protecting harmed investors.   


I invested in both G-coins and GTV Media Group, Inc. (GTV) common stocks.  The G-coins were paid with my credit cards while the GTV common stocks were invested via Voice of Guo Media, Inc., owned and operated by Lihong Wei Lafrenz, a.k.a., Lihong Wei, a.k.a., Sara Wei.  The funds were remitted to Guo Media, Inc. via bank wire.   


For Item #68 under 'Distribution Tranches' on page 12 - I would suggest increasing the initial payment from 50% to no less than 90%.  It would, then, read "Eligible Claimants whose Recognized Loss as calculated in accordance with the Plan of Allocation exceeds fifty dollars ($50.00) will receive a payment representing at least ninety percent (90%) of their Recognized Loss in the Initial Tranche."  Many of us paid for G-coins and GTV common stocks with borrowed funds in support of the creation of a free speech platform and the recent democracy movement in Hong Kong. 



For 'Third-Party Filer' in Item 31 of Section III. Definitions on page 5 - I would suggest adding, at the end of Item 31, that: 
"Third-Party Filer" does not include Lihong Wei Lafrenz, Yanping Wang, Wengui Guo, a.k.a. Ho Wan Kwok, a.k.a. Miles, Kwok, a.k.a. Miles Guo and their associates, who have or had aided these individuals and their-controlled organizations in defrauding harmed investors, including Rule of Law Foundation III, Inc. (RoLF), Rule of Law Society IV, Inc. (RoLS), two fraudulent charities established by Guo, and entities owned and/or operated by Guo-appointed past and present leaders of all so-called Himalaya virtual farms.  These individuals have in their possessions or otherwise have access to all private and vital information of the harmed investors that would be sufficient for them to impersonate the harmed investors to file fraudulent claims with the Fund Administrator. 
"Third-Party Filer" must properly disclose any potential conflict of interests and file a conflict-of-interest affidavit. 
For Section III. Definitions, I would suggest reexamining "Relevant Period", as necessary, for below reasons: 
Some harmed investors might have sent funds for investing in GTV common stocks via third-party payers or to Lihong Wei LaFrenz's personal bank account(s) before or after June 2, 2020.  It's unknown if and how much of these funds were legitimate or could be traced back to the original senders/harmed investors, and how much of these funds, if any, was represented in the GTV Guo Media Fair Fund. 



 For 'Eligible Claimant' in Item 16 of Section III. Definitions on page 3 - I would suggest adding at the end of Item 16, that: 
“Eligible Claimant” means a Potential Claimant...who is not an Excluded Party and who has not received a full refund either directly from GTV, Saraca, or Voice of Guo Media, Inc. or indirectly via third-party payors, such as Maywind Trading, LLC, that were arranged or directed by Lihong Wei LaFrenz, owner of Voice of Guo Media, Inc., Wengui Guo and/or his personal assistant, Yanping Wang, who is also the President of GTV and Saraca Media Group, Inc. (Saraca).  
For “Excluded Party” in Item 17 of Section III. Definitions on page 3 - I would suggest adding/naming the following two fraudulent charities and their past and present board of directors and officers to the list explicitly, 

Rule of Law Foundation III Inc. (RoLF), and Rule of Law Society IV, Inc. (RoLS) 


as well as including past and present leaders that were appointed by Wengui Guo to run his various world-wide virtual Himalaya farms and their designees, who were involved in disseminating payment instructions, collecting or solicitating payments. 



For “Fair Fund” in Item 18 of Section III. Definitions on page 4, I would suggest modifying the last sentence to read "Any additional funds collected from the Respondents, including fines and penalties, pursuant to the Order will be added to the Fair Fund." 





For Item 32 of Section IV. Tax Compliance - I would suggest adding one sentence at the end that "reasonable fees and expenses from the Fair Fund in accordance with its 2019-2021 Engagement Letter Agreement with the Commission shall not include income taxes of the Fund Administrator", which shall be the responsibility of the Fund Administrator." 


For Item 39 of Section V. Fund Administrator - I would suggest adding one sentence at the end that "third-parties must properly file a disclosure of conflict of interests or a conflict-of-interest affidavit."  



For Item 40 of Section V. Fund Administrator - I would suggest adding at the end that " ...These fees and expenses are subject to audit." 



For Item  45 of Section VI. ADMINISTRATION OF THE FAIR FUND -  forty-five (45) days from the date of the initial mailing of the Plan Notice might not be enough for international recipients residing in China due to additional and unpredictive inbound mail processing requirements and procedures in China during the pandemic.  For outbound international mail, the U.S. post office might not even have estimated or guaranteed date of arrival. 



For Item 67 under "Distribution Tranches" - one hundred thirty-five (135) days of the date of the Claim Bar Date is too long.  Many harmed investors sent the funds for investing in GTV common stocks via bank wire.  Many invested with borrowed funds.  It would be ideal to distribute the funds as soon as possible.   



For Item 68 under "Distribution Tranches" - Could we increase the payment in the Initial Tranche to be at least 90% of Recognized Loss as many invested with borrowed funds? 



For the second paragraph of Exhibit A- PLAN OF ALLOCATION on page 19, for purposes of transparency, please disclose or make public the number of shares of GTV stocks and G-coins sold from April 20, 2020 through July 1, 2020.  If the GTV common stocks and G-coins were found illegal and Wengui Guo said publicly during this time period that sales or transfer of GTV stock shares among investors were not allowed, shouldn't the sales of such, if any, be voided?  About a month into the illegal GTV private offering, Wengui Guo announced in a public broadcast on gtv.org platform that the price of GTV stock went up to $20 a share, and then, he continued by saying that nobody was allowed to sell or transfer any shares.   


Additionally, shouldn't the Recognized Loss from GTV stock include the loss of interest income calculated at applicable prime rates?   


For "Prior Recovery' on page 20 - Some harmed investors (about 100) were said to have received full refund of their investments in GTV common stocks, via a third-party, Maywind Trading LLC, as directed and/or arranged by Lihong Wei LaFrenz (owner of Voice of Guo Media, Inc.) and/or Wengui Guo, who has effective control and influence over the activities at GTV and significant influence over Lihong Wei LaFrenz.  How will those payments be treated or factored into the proposed Plan of Allocation?  Has SEC been provided a full and detailed listing of those who have received such a full refund?  Will any of them meet the definition of "Excluded Party”? 


Again, thank you very much for protecting harmed investors.  The GTV common stock scam was proceeded by and built upon Guo's two fraudulent charities: Rule of Law Foundation III, Inc. (RoLF) and Rule of Law Society IV, Inc. (RoLS) and committed and/or aided by the same able hands.  They should be held responsible to the fullest extent. 


Respectfully, 


Hong