UNITED STATES OF AMERICA before the SECURITIES AND EXCHANGE COMMISSION Securities Act of 1933 Release No. 7632 / January 21, 1999 Administrative Proceeding File No. 3-9772 ___________________________________ In the matter of : ORDER MAKING FINDINGS : AND IMPOSING A CEASE- Global Information Services, Inc. : AND-DESIST ORDER d/b/a Investment Hotlines and : PURSUANT TO SECTION 8A James E. Grady, : OF THE SECURITIES : ACT OF 1933 Respondents. : __________________________________ : I. On October 27, 1998, the Securities and Exchange Commission ("Commission") entered an Order Instituting Public Administrative Cease-and-Desist Proceedings Pursuant to Section 8A of the Securities Act of 1933 ("Securities Act") against Global Information Services, Inc. d/b/a Investment Hotlines ("Investment Hotlines") and James E. Grady ("Grady") (collectively "Respondents"). II. Investment Hotlines and Grady have submitted an Offer of Settlement (the "Offer") for the purpose of resolving these proceedings, which Offer the Commission has determined to accept. Solely for the purpose of these proceedings and any other proceedings brought by or on behalf of the Commission or to which the Commission is a party, Respondents, by their Offer, consent to the entry of this Order Making Findings and Imposing a Cease-And-Desist Order Pursuant to Section 8A of the Securities Act of 1933 ("Order"), admit the jurisdiction of the Commission and, without admitting or denying the findings set forth herein, consent to the entry of the findings and remedial sanctions set forth below. 1 III. On the basis of this Order and Respondents’ Offer, the Commission finds that: THE WEB PUBLISHER: INVESTMENT HOTLINES A. Investment Hotlines was incorporated in Florida in December 1995 and is located in Clearwater, Florida. B. Since December 1995, Grady has been the sole director and president of Investment Hotlines. At all relevant times, Grady has directed and operated Investment Hotlines. C. Investment Hotlines is engaged in the direct marketing of a combination of investment opportunities, products and services by use of the mail and, principally, the Internet. THE WEB SITE: INVESTMENT HOTLINES ON LINE D. Investment Hotlines is the publisher of Investment Hotlines OnLine, a Web site that has appeared on the Internet since December 1995. E. Investment Hotlines OnLine contains information and links to other sites relating to securities and other investment opportunities such as commodities and mutual funds. F. The focus of Investment Hotlines OnLine site, however, is its "Featured Investment Opportunities" page.[1] This page offers short one-line descriptions of companies whose stock are or were quoted on the OTC Bulletin Board. These brief descriptions tout favorable investment information about each featured company. G. Investment Hotlines further provides those using its site with links to Web sites maintained by its featured companies from each of the brief touts appearing on the Investment Hotlines OnLine Featured Investment Opportunities Web page. The Web sites maintained by InvestmentHotlines’ featured companies contain more extensive information aboutthose companies, including, but not limited to, business and managementdescriptions, financial information, investment opportunities and outlooks, and/or links to other sites offering current or delayed stock quotes. H. Since December 1995, Investment Hotlines has featured fourteen companies on the Featured Investment Opportunities page of its Investment Hotlines OnLine site. I. In addition to featuring selected companies on its Web site and linking its site to sites maintained by those companies, Investment Hotlines publishes press releases issued by its featured companies on the Investment Hotlines OnLine site. Investment Hotlines received the press releases from thefeatured companies themselves or "cut and pasted" them from the newswires. CONSIDERATION RECEIVED FOR WEB PUBLICITY NOT FULLY DISCLOSED J. In exchange for the Internet publicity and other related services it provided to its featured companies, Investment Hotlines received freely tradable common stock and cash from the companies. K. From December 1995, through August 1998, Investment Hotlines received $6,000 and approximately 200,000 shares of freely tradable common stock from eleven of the companies featured on its Investment Hotlines OnLine site. L. From December 1995, through September 23, 1998, the only disclosure appearing on the Investment Hotlines OnLine site addressing the consideration Investment Hotlines received from its featured companies stated, "The publisher, its affiliates, officers, directors, subsidiaries, andagents of this advertisement have been compensated by the companiesherein." M. This disclosure appeared on a Web page apart from the Featured Investment Opportunities page and was accessible only by a link from the site’s home page highlighted as "IMPORTANT INFORMATION - Please Read". N. Investment Hotlines did not disclose anywhere on its Web site the nature (specifically the stock and cash) or amount of the consideration it received from each of its featured companies for the publicity it provided to them. GRADY O. As director and president of Investment Hotlines, Grady determined and directed what information, including any disclosures, and services, including any links, would be published on and offered through the Investment Hotlines OnLine Web site. P. As director and president of Investment Hotlines, Grady negotiated and set the amount of consideration received by Investment Hotlines from the companies featured on the Investment Hotlines OnLine Web site. VIOLATIONS Q. As a result of the conduct described above, Investment Hotlines and Grady committed or caused violations of Section 17(b) of the Securities Act by publishing or giving publicity to or circulating notices, advertisements, investment services or communications which, though notpurporting to offer securities for sale, describe such securities forconsideration received or to be received, directly or indirectly, from theissuers without fully disclosing the receipt, whether past or prospective, of such consideration and the amount thereof. IV. In view of the foregoing, the Commission deems it appropriate and in the public interest to impose the sanctions specified in Respondents’ Offer. ACCORDINGLY, IT IS ORDERED that: Investment Hotlines and Grady cease-and-desist from committing or causing violations or any future violations of Section 17(b) of the Securities Act. For the Commission, by its Secretary, pursuant to delegated authority. Jonathan G. Katz Secretary **FOOTNOTES** [1]: In September 1998, the name of this Web page was changed to "Featured Companies".