SEC v. Juan Campo a/k/a John Campo, No. 1:24-CV-2198, District of Columbia (July 26, 2024) — Complaint

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UNITED STATES DISTRICT COURT
DISTRICT OF COLUMBIA

SECURITIES AND EXCHANGE COMMISSION
100 F Street NE
Wa s h i n
gton, D.C. 20549,

Plaintiff, Case No. 1:24-CV-2198

v.                                                                             JURY                                                                             TRIAL                                                                             DEMANDED

JUAN CAMPO a/k/a JOHN CAMPO,

Defendant.

COMPLAINT

 Plaintiff Securities and Exchange Commission (“SEC”) in its complaint against Juan
Campo, also known as John Campo, (“Campo” or “Defendant”), the former Chief Executive
Officer of View Systems, Inc. (“View Systems” or “the Company”), alleges as follows:
SUMMARY
1. From approximately July 2019 through July 2022 (the “Relevant Period”),
Campo, the then-CEO of View Systems, perpetrated three fraudulent schemes to create the false
impression that View Systems, a publicly traded penny stock company, was actively engaged in
potentially lucrative lines of business in order to make it attractive to investors.  Throughout the
Relevant Period, View Systems earned virtually no revenue, manufactured no products, and had
a stock price of less than a penny per share.
2. First, in 2019 and 2020, Campo repeatedly made and disseminated statements to
the public falsely representing that View Systems had acquired Sannabis S. A.S., a Colombian
cannabis company, when Campo knew that View Systems had not, and never did, complete this
acquisition.

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3. Second, in the fall of 2020—during the height of the Covid pandemic—Campo
made and disseminated statements falsely representing that View Systems had developed a
temperature screening device, when Campo knew that it had not.
4. And third, in July 2022, Campo signed and certified View Systems’ 2020 annual
report with the SEC, which contained a fake audit report that falsely represented that the
Company’s financial statements had been audited, when he knew the audit was never completed.
JURISDICTION AND VENUE
5. The Court has jurisdiction over this action pursuant to Sections 21(d) and 27(a) of
the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. §§ 78u(d) and 78aa(a)].
Campo, directly or indirectly, made use of the means or instrumentalities of interstate commerce,
of the mails, or of the facilities of a national securities exchange, in connection with the
transactions, acts, practices, and courses of business alleged in this Complaint.
6. Venue is proper in this District under Exchange Act Section 27 [15 U.S.C. § 78aa]
because violations of the securities laws alleged in this Complaint occurred within this District,
including (a) the filing with the SEC of false and misleading documents that Campo signed and
(b) purchases and sales of View Systems’ stock by residents of this District during the Relevant
Period.
DEFENDANT
7. Juan Campo a/k/a John Campo, age 53, is a resident of Colombia in South
America.  Since early July 2019 and through at least the end of the Relevant Period, Campo was
the President, CEO, and chairman of the board of directors of View Systems.

8. During the Relevant Period, Campo drafted and published nearly all View
Systems’ press releases through a newswire service headquartered in the United States.  He also

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drafted and posted all View Systems’ tweets, as he was the only individual with access to View
Systems’ Twitter account.  As CEO, Campo also signed View Systems’ quarterly and annual
reports filed with the SEC during the Relevant Period.
9. From approximately 2002 to 2018, before joining View Systems, Campo served
as an investor relations consultant to public companies, including View Systems.
OTHER RELEVANT ENTITY AND PERSON
10. View Systems is a Colorado corporation.  According to its SEC filings, View
Systems’ principal place of business was in Greenbelt, Maryland through at least July 13, 2022.
11. The Company became registered pursuant to Section 12(g) of the Exchange Act
beginning in August 1999.  During the Relevant Period, its stock traded on various over the
counter markets in the United States under the ticker symbol VSYM, including trading by U.S
investors.  On January 19, 2021, the SEC issued an order temporarily suspending trading of View
Systems’ stock through February 1, 2021 because of questions regarding the accuracy and
adequacy of information in the marketplace about the Company and its securities.  After the
trading suspension, the stock continued to be sold over the counter until the SEC revoked its
registration in December 2022 for failing to file required periodic reports.
12. During the Relevant Period, View Systems’ stock qualified as a “penny stock” as
defined under Exchange Act Section 3(a)(51) [15 U.S.C. § 78c(a)(51)] because it did not meet
any exemption from the definition under Exchange Act Rule 3a51-1 [17 C.F.R. § 240.3a51-1]
and was traded on the over-the-counter market for less than $5 per share.  View Systems’ annual
report on Form 10-K for 2019 (“2019 10-K”), signed by Campo and filed with the SEC on July
2, 2020, states that the Company’s stock was considered to be a penny stock.

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13. View Systems’ Founder is an individual residing in Arkansas who founded the
company that later became View Systems.  View Systems’ Founder was the Company’s CEO
from 1998 until Campo joined View Systems in July 2019.  During the Relevant Period, View
Systems’ Founder continued to serve on View Systems’ board of directors and remained involved
with the company.
FAC TS
A. Prior to the Relevant Period, View Systems Had a Real Business, but by 2019, It
Had Virtually No Operations.
14. Prior to the Relevant Period, View Systems had a real business that involved
manufacturing and selling security and surveillance products, with its primary product being a
concealed weapons detection device known as the ViewScan.  In 2016, however, the Company
stopped manufacturing products (except for special orders) and stopped soliciting sales of its
ViewScan.  By 2018, the Company had licensed the ViewScan to a third party and stopped
selling its products almost entirely.
15. In July 2019, Campo joined View Systems as President and CEO.  By that time,
View Systems had virtually no revenue generating business.

 View Systems’ 2019 10-K states
that its total revenue for 2019 was just $1,400.  View Systems’ annual report on Form 10-K for
2020 (the “2020 10-K”), although problematic for the reasons discussed below, still only claimed
total revenue of less than $3,000 for 2020.
B. The Sannabis Acquisition Scheme: Campo Falsely Represented That View Systems
Had Acquired Sannabis.

1. Campo Signed a Contingent Agreement for View Systems to Acquire
Sannabis in the Future.
16. On or about July 9, 2019, View Systems issued a press release announcing that it
had entered into a memorandum of understanding to acquire a Colombian company called

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Sannabis, S.A.S., a company that Campo had founded and co-owned.  View Systems touted
Sannabis as a “Medical Marijuana Pioneer” that had purportedly obtained “medical marijuana
licenses for seed propagation, cultivation, transformation, and export.”
17. At some point during the period from about July 29, 2019 to June 2021, View
Systems entered into a contingent merger commitment with Sannabis, written in Spanish and
titled “Compromiso de Fusion.”  That agreement was signed by Campo on behalf of View
Systems.  This merger commitment required View Systems to direct funding to Sannabis and
made the future merger contingent on that as well as approval by the shareholders of each entity.
As contemplated by the merger commitment, the acquisition would be completed by having
Sannabis be absorbed into View Systems and View Systems issuing shares in equal parts to
Campo and a Sannabis representative, who were both shareholders of Sannabis.
18. View Systems’ acquisition of Sannabis was never completed.  Sannabis was never
merged into View Systems and no shares of View Systems were issued to Sannabis shareholders.
As Campo was a founder and co-owner of Sannabis and was directly involved in the negotiations
between View Systems and Sannabis, he knew this.  In fact, Campo provided sworn testimony in
August 2021 during the SEC’s investigation in which he admitted that the merger still had not
been completed as of that date.  View Systems’ Founder also testified in the investigation that
View Systems’ planned acquisition of Sannabis was never completed.
2. Campo Made and Disseminated Numerous Materially False and Misleading
Statements Describing the Potential Future Sannabis Acquisition as
Something That Had Already Happened.
a. Campo Made Misstatements in 2019 Falsely Representing That the
Sannabis Acquisition Had Closed.

19. Despite knowing that View Systems had not actually acquired Sannabis, Campo
repeatedly made and disseminated false and misleading statements to the public suggesting that

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it had.  These false claims appeared in press releases, View Systems’ Twitter posts, and at least
one quarterly report filed with the SEC.  In these statements, Campo also touted Sannabis as an
international player in the “medical marijuana” industry that was poised to “Supply the World’s
$14 Billion Hemp Market.”  He also falsely represented that Sannabis was actively growing
cannabis, when it was not, and did not have the requisite licenses to do so.  In fact, contrary to
Campo’s public statements, during 2019 and 2020, Sannabis’ business was limited to making and
selling cosmetics and creams made from hemp seed oil.  And although Sannabis had applied for
licenses from the government of Colombia that would have allowed it to grow cannabis, it did
not actually obtain any such license until at least 2021.
20. For instance, beginning on or about July 31, 2019, Campo drafted and published a
press release that announced, falsely, that “View Systems Inc. Closes Acquisition of Colombia
Medical Marijuana and Hemp Products Company, Sannabis.”  The body of the press release
repeated the false statement that “View Systems, Inc. ... announced today the closing for the
acquisition of Sannabis S.A.S. (“Sannabis”), a Colombian medical marijuana and hemp
company.”  The press release also falsely stated that “View Systems acquired Sannabis to
diversify into the burgeoning Cannabis industry...”
21. These false statements had a material effect on View Systems’ stock price.  Later
that same day, an article was published in Emerging Growth.com, a company that reports on
small-cap companies.  The article cited to the July 31 press release and was titled “View
Systems, Inc. (OTC Pink: VYSM) up 31% after Closing Acquisition of Colombia Medical
Marijuana and Hemp Products Company, Sannabis.”
22. As of market close on July 31, 2019, the stock price for View Systems increased
over 25%, from $0.0029 to $0.0037 per share, compared to the prior day close.  And the trading

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volume for the day was over 16.5 million shares bought and sold, compared to fewer than 25,000
shares traded the day before.
23. Similarly, on or about August 19, 2019, Campo, as CEO of View Systems, signed
a quarterly report on Form 10-Q for the period ended June 30, 2019, falsely representing that
View Systems had “acquired a company called Sannabis that grows and ships Cannabis grown
for medical and industrial purposes.”

 This statement was false both because an acquisition with
Sannabis had not taken place,

and because Sannabis was not growing cannabis at all at that time.
24. Campo repeated the false representation that View Systems had acquired
Sannabis, in substantially verbatim form, in at least nine more View Systems press releases that
he drafted and published between August and December 2019, including on: August 6, 2019;
August 8, 2019; October 16, 2019; October 17, 2019; October 18, 2019; October 31, 2019;
November 15, 2019; November 22, 2019; and December 5, 2019.
25. In the August 6, 2019 press release, Campo also falsely referred to Sannabis as
belonging to View Systems by using the possessive form to describe the relationship between the
two companies, another way of falsely representing that the acquisition had been completed.
Specifically, Campo described Sannabis as “View Systems’ Medical Marijuana Company
Sannabis” while announcing a distribution agreement with a cannabis licensee in Uruguay.  The
body of that press release contained additional false statements claiming that Sannabis was
owned by View Systems by describing it as “their medical marijuana company in Colombia”
(emphasis added).
26. Campo repeated the false and misleading descriptions of Sannabis as “View
Systems’ Sannabis” or “View Systems’ subsidiary,” nearly verbatim, in at least seven more View
Systems press releases (of which six also contained the false “acquired” language, as listed

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above) between September and December 2019, including on: September 4, 2019; October 17,
2019; October 18, 2019; October 31, 2019; November 15, 2019; November 22, 2019; and
December 5, 2019.
27. At least some of the false statements about the Sannabis acquisition were
highlighted by third parties analyzing the stock.  For instance, on November 15, 2019, another
article appeared on Emerging Growth.com that cited to the November 15 View Systems press
release and was titled “View Systems, Inc. (OTC Pink: VYSM) up 37% after Sannabis imports
Hemp Seeds to Uruguay to Begin Planting Next Week to Supply the World’s $14 Billion Hemp
Market.”
28. As of market close on November 15, 2019, the stock price for View Systems had
increased 38%, from $0.0008 to $ 0.0011 compared to the prior day close, and the trading
volume for the day was over 9.4 million shares traded, compared to fewer than 1.4 million shares
traded the day before.
b. Campo Signed a Report Filed with the SEC in December 2019
Admitting That the Sannabis Acquisition Had Not Closed.
29. On or about December 9, 2019, Campo signed a View Systems quarterly report
(Form 10-Q) for the third quarter of 2019 that was filed with the SEC that same day.  In the Form
10-Q, View Systems acknowledged that “[t]he acquisition of Sannabis has not yet closed” and
added that “[w]e expect the [Sannabis] acquisition to be complete in the first quarter of 2020.”
This statement in the SEC filing essentially admits the falsity of all the prior press releases,
which described the acquisition as “closing,” View Systems having “acquired” Sannabis, or
representing Sannabis as belonging to View Systems.  Nevertheless, Campo began the fraud
anew the very next month.

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c. Campo Made and Disseminated Additional Misstatements About the
Sannabis Acquisition in 2020.
30. On January 13, 2020, for reasons not yet determined, View Systems experienced a
sudden increase in its stock price and trading volume.  Specifically, by the market close on that
day, View Systems’ stock price had increased by 83%, from $0.0006 to $0.0011, and the trading
volume increased from less than 30 million to more than 118 million, as compared to the prior
trading day of January 10.
31. Although the immediate cause of this increase in View Systems’ trading is
unknown, contemporaneous market sources suggest that it reflects the materiality of the planned
Sannabis acquisition.  For instance, after the market closed on January 13, 2020, an article was
published in Pennystockdream.com, an online newsletter service, with the headline: “View
Systems, Inc., (PINK:VYSM) closed up 83.33% Today, As Anticipation Grows Over Planned
Merger With Colombian Cannabis Company, ‘Sannabis’” and specifically noted that “[a]s per a
form 10-Q filed for the quarterly period ended on September 30
th
 2019, View Systems stated that
this merger is expected to be completed in the first quarter of 2020.”
32. On January 14, 2020, the next day, View Systems’ stock price closed another 55%
higher, at $0.0017, with more than double the trading volume at over 314 million.  After the
market closed, another article was published in Pennystockdream.com, with the headline: “After
Our Update On View Systems, Inc., (PINK:VSYM) Last Night It Gained As Much As 109.09%
Mid-Day Today, And Closed Up 54.55%.”  The article cited to View Systems’ December 2019
Form 10-Q and noted that “investors are currently anticipating the expected close of a planned
merger between View Systems, Inc. and the Colombian Cannabis company, ‘Sannabis.’”
33. Contrary to the claimed expectation in the December 9, 2019 Form 10-Q, which
was repeated in the press coverage described above, View Systems did not close the Sannabis

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acquisition during the first quarter of 2020 (or ever).  Yet, Campo continued to draft, publish, and
disseminate press releases falsely representing that the acquisition had been completed.
34. For example, on or about January 14, 2020, Campo drafted and published a press
release that falsely represented Sannabis as belonging to View Systems: “View Systems, Inc.’s
(VSYM) Sannabis is Only Company Planting Cannabis in Uruguay this Season, on Target for
250,000 POUNDS with Plants Growing Nicely to Supply the World with Hemp and CBD
Products from Uruguay and Colombia.”  Campo repeated this misrepresentation in the body of
the press release by referring to Sannabis, once again, as “View Systems, Inc.’s (VSYM),
medical marijuana and hemp subsidiary.”  He also repeated the specific representation that
“View Systems acquired Colombian Cannabis company, Sannabis, to diversify into the
burgeoning Cannabis industry...” (emphasis added).
35. Campo repeated his false and misleading descriptions of Sannabis as “View
Systems, Inc.’s Sannabis” or View Systems’ “subsidiary,” or as View Systems as having
acquired, or been merged with, Sannabis, in at least ten more press releases between January and
June 2020, including on: January 15, 2020;  January 17, 2020; January 28, 2020; January 31,
2020; February 4, 2020; February 12, 2020; February 21, 2020;  April 8, 2020; June 4, 2020; and
June 8, 2020.

36. Campo also disseminated the June 4 and 8, 2020 press releases by including links
to them in posts he made to View Systems’ Twitter account on the day of each of these press
releases.
37. Contrary to these representations, Campo eventually admitted—again—that no
merger or acquisition of Sannabis had actually been completed.  On or about July 2, 2020, View
Systems filed its 2019 10-K with the SEC, in which it acknowledged that no acquisitions were

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pending.  Included as an attachment to the 2019 10-K was an unsigned Memorandum of
Understanding that described a future plan of merger between Sannabis and View Systems if
“certain milestones” were met.  This annual report was signed and certified by Campo.

38. A November 20, 2020 press release that Campo drafted and published also
admitted that the acquisition had not been completed by that time, describing it as something that
View Systems was still “finalizing.”
39. In fact, View Systems never completed any acquisition of Sannabis.
40. Through the actions described above, Campo knowingly or recklessly deceived
investors and potential investors in View Systems with the false and misleading statements he
made and disseminated representing that View Systems actually acquired Sannabis.
C. The ViewScan II Scheme: Campo Falsely Represented That View Systems Had a
New Thermal Imaging Product That Could Provide “Real Time COVID
Temperature Results.”

1. Background on the COVID-19 Pandemic and View Systems’ Planned
ViewScan II.

41. In the fall of 2020, at the height of the global COVID-19 pandemic, there was a
sharp increase in the demand for thermal imaging devices, in the hope that such devices could
help detect people who had COVID-19 and thus mitigate the spread of the virus.  As a November
3, 2020 news article noted:
Since last spring, hundreds of merchants have begun selling telethermographic
systems—a category that includes dozens of devices such as cameras and kiosks
that use infrared scanning and thermal imaging to detect body heat from a
distance.
School administrators, managers of government office buildings and corporations
have been purchasing the technology and installing it at the entrances of schools,
hospitals and other buildings in the hope that it will mitigate the spread of Covid-
19 by screening out people with fevers, a key symptom of the virus.

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42. In November and December 2020, Campo repeatedly represented in press
releases, Tweets, and by sending links to the View Systems website that View Systems had a new
thermal imaging temperature screening product, sometimes referred to as the ViewScan II, that
could detect temperatures, including those associated with COVID.  He further claimed that
View Systems had already received orders for the new product.  These representations were
false.
43. As Campo knew, View Systems had no thermal imaging temperature screening
product.  Although View Systems had developed technical designs and other documentation for a
new version of the ViewScan that would be wider and more effective, none of these designs or
documentation provided for any thermal imaging capabilities.
44. Campo admitted in testimony in 2021 that he did not know whether View
Systems had even reached agreements with any suppliers to provide thermal imaging devices to
be incorporated into a future ViewScan system.  In fact, View Systems and at least one View
Systems customer, had attempted to find a thermal imaging system that might work with the
Company’s old ViewScan product, but had been unsuccessful.
45. Moreover, as Campo admitted in his testimony, at the time of the press releases
and other statements discussed below, no ViewScan II had been built.  Campo further admitted
that building the ViewScan II was not possible unless View Systems raised capital from
investors.  Campo attempted to defend the statements in testimony by asserting that “I still to this
day have every optimism that I’ll be able to get this done” and claiming that the press releases
were “forward-looking” statements.  Yet his false and misleading statements were not mere
expressions of optimism or “forward-looking” statements of some future event.  They were
factual representations that the product existed already, when he knew it did not.  The public

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statements regarding the ViewScan II were also not accompanied by any forward-looking
disclaimer languages.
46. Additionally, although records reflect that View Systems had provided price
quotes for “ViewScan II’s” to two potential customers in May and November 2020, it never
received any actual orders for the product.  Indeed, View Systems’ Founder testified that View
Systems did not take orders for the ViewScan II because no ViewScan II had been built.

2. Campo Made and Disseminated Numerous Materially False and Misleading
Statements About the ViewScan II and Its Thermal Imaging Capabilities.
47. Despite knowing that no ViewScan II had been built and no ViewScan product
had thermal imaging capabilities, Campo drafted and posted a message on View Systems’ Twitter
feed dated November 19, 2020, announcing: “ViewScan for Stadiums, now with Thermal
Imaging Real-Time Temperature Results ... More in Press Release tomorrow morning...”
48. The next day, the promised press release (drafted and published by Campo),

announced: “View Systems, Inc. (VSYM)...Launches New Website to Begin Marketing
ViewScan II with Real Time Thermal Imaging Temperature Results and other Enhanced
Features.” and included links to View Systems’ website (www.viewsystems.com), which
prominently featured the following banner of a thermal-like image of a person wearing a
facemask:

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Written over banner image were the words, “Introducing Thermal Imaging. Real-Time COVID
Temperature Results VIEW SCAN II.”
49. Campo also drafted and published a Twitter post with the same date of November
20, 2020 that contained the same representations about ViewScan II as the press release and a
link to the press release.
50. At the time he drafted and published the November 20 press release and the
Twitter post, Campo knew the View Systems website had the COVID temperature results banner
because he had seen it.  Additionally, although Campo had the authority to ask the Company’s
web page designer to change the content of the website, Campo did not ask to change the banner
before issuing the press release.  Thus, Campo knowingly disseminated the statement on the
website “Introducing Thermal Imaging Real-Time COVID Temperature Results VIEW SCAN
II” by linking to that website in his press release.
51. Once again, Campo’s false and misleading representations had an immediate and
material impact on the market.  By the close of the market on the day of the November 20 press
release and Twitter post, View Systems’ stock price increased 133%, from $0.0003 to $0.0007
per share.  And View Systems’ trading volume increased from more than 82.6 million on
November 19 to nearly 1.3 billion on November 20.
52. On or about December 11, 2020, Campo drafted and published another View
Systems press release that stated that the Company was “raising capital to build the new and
improved ViewScan II ... to fill existing international orders” (emphasis added).  In this press
release, Campo again included links to the View Systems website, which Campo knew still
displayed the same banner of a thermal-like image of a person wearing a facemask stating,
“Introducing Thermal Imaging Real-Time COVID Temperature Results VIEW SCAN II.”

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53. Campo also drafted and published a Twitter post dated December 11, 2020 that
contained the same representations about ViewScan II and linked to the press release.
54. And again, Campo’s false and misleading representations had a material impact
on the market.  By market close on December 11, 2020, View Systems’ stock price had increased
50%, from $0.0008 to $0.0012 per share, from the prior day.  And View Systems’ trading volume
increased from nearly 110 million on December 10 to more than 750 million on December 11.
55. At the time of these November and December 2020 statements, Campo knew that
View Systems had not built any ViewScan II devices and that View Systems had not received
any actual orders for the ViewScan II.  In fact, Campo admitted in testimony that the ViewScan
II did not physically exist, but that he had been attempting to raise capital from investors so that
View Systems could build it (though again, even the ViewScan II designs did not include thermal
capabilities).  As part of his fundraising efforts, Campo testified that he sent Private Placement
Memoranda to dozens of
 individuals, including existing View Systems shareholders.  View
Systems records reflect that it provided a Private Placement Memoranda with an offering
commencement date of March 15, 2021, to at least 26 potential investors from December 2020
through February 2021.  Campo testified that, as a result of his efforts, View Systems obtained at
least one $15,000 private placement investment from a U.S. investor, and that, as of August
2021, View Systems was still seeking to raise capital.
56. Through the actions described above, Campo knowingly or recklessly deceived
investors and potential investors in View Systems with the false and misleading statements he
made and disseminated regarding the ViewScan II.

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D. The Fake Audit Report Scheme: Campo Signed and Certified a Form 10-K Falsely
and Misleadingly Representing That View Systems’ 2020 Financial Statements Had
Been Audited.

1. Background on View Systems, Its SEC Filings, and Its Auditor.

57. As a company whose stock was publicly traded, View Systems was required to
file periodic reports with the SEC during the Relevant Period, consisting of quarterly reports on
Forms 10-Q and annual reports on Forms 10-K.  However, over time the Company fell
significantly behind in filing these reports.  By July 2022, View Systems had not filed its annual
reports on Form 10-K for the years ended December 31, 2020 or December 31, 2021, or any
quarterly reports on Form 10-Q for any quarter period in 2021 or 2022.  In June 2021, the
Company’s prior auditor resigned.
58. In August 2021, View Systems hired a new auditor (“Audit Firm”) to audit its
2020 financial statements.  The terms of the audit engagement were set forth in a seven-page
letter signed by the managing partner of the Audit Firm (“Audit Partner”) and Campo.  One of
the terms specified that before View Systems could make any SEC filing with which the Audit
Firm was associated, View Systems would notify the Audit Firm, which would then provide a
signed copy of its audit report and consent to including it in the filing.
59. By early July 2022, the audit of View Systems’ 2020 financial statements still had
not been completed.  In the SEC’s investigation, the Audit Partner testified that he had never
completed certain substantive audit steps, including completion of the engagement quality
review, obtaining a representation letter from management, and conducting a subsequent events
review.
60. On or about July 5, 2022, Campo emailed the Audit Partner requesting that the
Audit Firm “send us the 2020 financial statements so we can finish drafting the [Form] 10K.  We

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can’t file it until you sign off.”  The Audit Partner responded to Campo that he had not been paid
for his services, and he did not provide the financial statements.  Campo continued to press the
Audit Partner to provide the 2020 financial statements, noting that doing so would allow View
Systems “to begin preparing the [Form] 10K.”
61. On or about July 11, 2022, View Systems’ Founder informed Campo and the
Audit Partner that several investors were waiting for View Systems to become current on its SEC
filings, and that once View Systems did that, they would invest.  Later that morning, the Audit
Partner agreed to have an employee of the Audit Firm provide Campo with a draft set of
financial statements so that View Systems could finalize a draft of the 2020 10-K.  The Audit
Partner testified that, although the financials were provided to Campo, he never provided any
audit report (signed or unsigned) and did not consent to View Systems including an audit report
in the 2020 10-K filed with the SEC.
2. Campo Signed and Certified View Systems’ Form 10-K for 2020 Despite
Knowing It Included a Fake Audit Report.

62. On or about July 13, 2022, View Systems filed its 2020 10-K, which included
financial statements for 2020.  Campo signed the 2020 10-K and certified under SOX 302 that it
did “not contain any untrue statement of a material fact.”
63. Campo’s SOX 302 representation was false because the 2020 10-K described the
financial statements contained in the annual report as having been audited—referring to “[t]he
audited financial statements contained in this Annual Report”—when Campo knew that the audit
was not complete.  In fact, the Audit Partner testified that he had informed Campo on multiple
occasions that he had not completed the audit.
64. Not only did the 2020 10-K falsely claim that the financials had been audited, it
contained a fake audit report, purportedly by an independent auditor.  This fake audit report was

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titled “Report of Independent Registered Public Accounting Firm,” and falsely stated “[w]e have
audited the accompanying balance sheets of View Systems, Inc. (the “Company”) as of
December 31, 2020.”  The fake audit report then concluded that the financial statements “present
fairly, in all material respects, the financial position of the Company as of December 31, 2020,”
and that the results of View Systems’ “operations and its cash flows” were “in conformity” with
U.S. GAAP.
65. The language in this fake audit report appears to be nearly identical to the real
audit report that had been included in View Systems’ 2019 10-K.  However, unlike the 2019
audit report, the 2020 fake audit report contained no date, no logo, and no name or signature for
any audit firm.  When the Audit Partner was shown the fake audit report from the 2020 10-K, he
testified that he did not write it.
66. Although it is not clear who first created the fake audit report, Campo nonetheless
engaged in a fraudulent scheme to deceive investors by signing and certifying the Form 10-K
that included the fake audit report while knowing, or being reckless in not knowing, that the
Audit Firm (a) had not issued any such audit report, (b) had not completed the audit of View
Systems’ 2020 financial statements, and (c) did not consent to file an audit report with the
Company’s annual report.
3. Campo Later Admitted the Audit Had Not Been Completed and Tried to
Cover His Tracks.

67.   On or about July 25, 2022, Campo emailed the Audit Partner notifying him that
the 2020 10-K had been filed and requesting that the Audit Firm provide “an audit opinion”
(something that should have been received before the 2020 10-K was filed).  In that email,
Campo claimed that “it slipped my attention that it was missing” (in fact the report was not
“missing,” but rather fabricated).  The Audit Partner responded that same day by refusing to

19
provide the requested audit opinion without additional due diligence, noting “I was surprised that
after we discussed and agreed that you only want to review the Financials, you go ahead and file
it with SEC. That destroyed all the trust I had in your word. I have to proceed with caution.”
68. The Audit Firm never did complete the audit and Campo took no steps to correct
the false and misleading statements in the 2020 10-K regarding the audit.
69. On or about August 20, 2022 the Audit Firm resigned.

FIRST CLAIM FOR RELIEF
Violations of Exchange Act Section 10(b) and Rule 10b-5

70. The SEC realleges and incorporates by reference the forgoing paragraphs, as
though fully set forth herein.
71. By reason of the foregoing, Defendant, directly or indirectly, in connection with
the purchase or sale of securities, by the use of means or instrumentalities of interstate
commerce, of the mails, or of the facilities of a national securities exchange: (a) employed
devices, schemes, or artifices to defraud; (b) made untrue statements of a material fact and/or
omitted to state a material fact necessary in order to make the statements made, in the light of the
circumstances under which they were made, not misleading; and (c) engaged in acts, practices,
or courses of business which operated or would operate as a fraud or deceit upon any persons,
including purchasers of the securities.
72. While engaging in the conduct described above, Defendant acted with scienter.
73. By engaging in the conduct described above, Defendant violated, and, unless
enjoined, will continue to violate Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and
Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].

20
SECOND CLAIM FOR RELIEF
Violation of Exchange Act Rule 13a-14

74. The SEC realleges and incorporates by reference the foregoing paragraphs, as
though fully set forth herein.
75. On July 13, 2022, acting under Section 302 of the Sarbanes-Oxley Act of 2002
and Exchange Act Rule 13a-14 [17 C.F.R. § 240.13a-14], Defendant signed a certification
attesting to the accuracy and completeness of an annual report (Form 10-K) filed with the SEC
by View Systems.
76. By engaging in the acts and conduct alleged herein, Defendant filed or caused to
be filed on View Systems’ behalf an annual report on Form 10-K, which contained certifications
signed by Defendant as View Systems’ principal executive officer pursuant to Exchange Act
Rule 13a-14 [17 C.F.R. § 240.13a-14] and included untrue statements of material fact, or failed
to include, in addition to the information required to be stated in such certification, such further
material information as was necessary to make the required statements, in light of the
circumstances under which they were made, not misleading, or failed to disclose information
required to be disclosed therein.
77. By reason of the foregoing, Defendant violated, and, unless enjoined, will
continue to violate, Exchange Act Rule 13a-14 [17 C.F.R. § 240.13a-14].
THIRD CLAIM FOR RELIEF
Aiding and Abetting Violations of Exchange Act Section 13(a)
 and Exchange Act Rules 12b-20, 13a-1, and 13a-13

78. The SEC realleges and incorporates by reference the foregoing paragraphs, as
though fully set forth herein.
79. As alleged above, View Systems violated Exchange Act Section 13(a) and Rules
12b-20, 13a-1, and 13a-13, thereunder [17 C.F.R. §§ 240.12b-20, 240.13a-1, and 240.13a-13] by

21
filing Forms 10-K and 10-Q filed with the SEC that were untruthful, inaccurate, and/or failed to
disclose required material information.
80. As detailed above, Defendant knowingly or recklessly provided substantial
assistance to View Systems’ violations by signing and/or certifying those filings that violated
Exchange Act Section 13(a) and Rules 12b-20, 13a-1, and 13a-13, thereunder [17 C.F.R. §§
240.12b-20, 240.13a-1, and 240.13a-13].
81. By reason of the foregoing, and pursuant to Exchange Act Section 20(e) [15
U.S.C. § 78t], Defendant aided and abetted View Systems’ violations of Section 13(a) of the
Exchange Act [15 U.S.C. § 78m(a)] and Rules 12b-20, 13a-1, and 13a-13 thereunder [17 C.F.R.
§§ 240.12b-20, 240.13a-1 and 240.13a-13], and, unless enjoined, will continue to aid and abet
such violations.
RELIEF REQUESTED
WHEREFORE, the SEC respectfully requests that the Court enter a Final Judgment:
 A. Finding that Defendant violated the federal securities laws as alleged against him
in this Complaint;
B. Permanently restraining and enjoining Defendant and his agents, employees,
attorneys, and all persons in active concert or participation with them, who receive actual notice
of the injunction by personal service or otherwise from violating, directly or indirectly, Sections
10(b) and 13(a) of the Exchange Act and Rules 10b-5, 12b-20, 13a-1, 13a-13, and 13a-14
thereunder [15 U.S.C.§§ 78j(b); § 78m(a); 17 C.F.R. §§ 240.10b-5; 240.12b-20; 240.13a-1,
240.13a-13, and 240.13a-14];
C. Permanently barring Defendant 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. §

22
78l] and that is required to file reports under Section 15(d) of the Exchange Act [15 U.S.C. §
78o(d)], 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)];
D. Permanently restraining and enjoining Defendant from participating in the
offering of any penny stock, including by engaging in activities with a broker, dealer, or issuer
for purposes of issuing, trading, or inducing or attempting to induce the purchase or sale of any
penny stock, pursuant to Exchange Act Section 21(d)(6) [15 U.S.C. § 78u(d)(6)];
E. Ordering Defendant to pay appropriate civil money penalties pursuant to Section
21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)]; and
F. Granting such other further relief this Court deems just, equitable, appropriate, or
necessary in connection with the enforcement of the federal securities laws and for the protection
or benefit of investors.
JURY DEMAND
 Pursuant to Federal Rule of Civil Procedure 38, Plaintiff SEC demands a trial by jury on
all issues so triable.

Dated:  July 26, 2024    Respectfully submitted,

Of            Counsel:                                                U.S.            SECURITIES AND EXCHANGE COMMISSION
Christopher            Bruckmann
Ashley            Sprague                                    _/s/ Devon Staren_____________
                                                            Devon            L.            Staren
                                                            D.C.            Bar            No.            478619
                                                            Attorneys            for            Plaintiff
                                                            SECURITIES            AND EXCHANGE COMMISSION
                                                            100            F.            Street            NE
                                                            Washington,            D.C.            20549
                                                            (202)            551-5346            (Staren)
[email protected]

1 

UNITED STATES DISTRICT COURT 
DISTRICT OF COLUMBIA 

 
  
SECURITIES AND EXCHANGE COMMISSION 
100 F Street NE 
Washington, D.C. 20549, 

 

  
Plaintiff, Case No. 1:24-CV-2198 

  
v. JURY TRIAL DEMANDED 

  
JUAN CAMPO a/k/a JOHN CAMPO,  
  

Defendant.  
  

 

COMPLAINT  
 
 Plaintiff Securities and Exchange Commission (“SEC”) in its complaint against Juan 

Campo, also known as John Campo, (“Campo” or “Defendant”), the former Chief Executive 

Officer of View Systems, Inc. (“View Systems” or “the Company”), alleges as follows:  

SUMMARY 

1. From approximately July 2019 through July 2022 (the “Relevant Period”), 

Campo, the then-CEO of View Systems, perpetrated three fraudulent schemes to create the false 

impression that View Systems, a publicly traded penny stock company, was actively engaged in 

potentially lucrative lines of business in order to make it attractive to investors.  Throughout the 

Relevant Period, View Systems earned virtually no revenue, manufactured no products, and had 

a stock price of less than a penny per share. 

2. First, in 2019 and 2020, Campo repeatedly made and disseminated statements to 

the public falsely representing that View Systems had acquired Sannabis S. A.S., a Colombian 

cannabis company, when Campo knew that View Systems had not, and never did, complete this 

acquisition.  

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3. Second, in the fall of 2020—during the height of the Covid pandemic—Campo 

made and disseminated statements falsely representing that View Systems had developed a 

temperature screening device, when Campo knew that it had not. 

4. And third, in July 2022, Campo signed and certified View Systems’ 2020 annual 

report with the SEC, which contained a fake audit report that falsely represented that the 

Company’s financial statements had been audited, when he knew the audit was never completed. 

JURISDICTION AND VENUE 

5. The Court has jurisdiction over this action pursuant to Sections 21(d) and 27(a) of 

the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. §§ 78u(d) and 78aa(a)].  

Campo, directly or indirectly, made use of the means or instrumentalities of interstate commerce, 

of the mails, or of the facilities of a national securities exchange, in connection with the 

transactions, acts, practices, and courses of business alleged in this Complaint. 

6. Venue is proper in this District under Exchange Act Section 27 [15 U.S.C. § 78aa] 

because violations of the securities laws alleged in this Complaint occurred within this District, 

including (a) the filing with the SEC of false and misleading documents that Campo signed and 

(b) purchases and sales of View Systems’ stock by residents of this District during the Relevant 

Period. 

DEFENDANT 

7. Juan Campo a/k/a John Campo, age 53, is a resident of Colombia in South 

America.  Since early July 2019 and through at least the end of the Relevant Period, Campo was 

the President, CEO, and chairman of the board of directors of View Systems.  

8. During the Relevant Period, Campo drafted and published nearly all View 

Systems’ press releases through a newswire service headquartered in the United States.  He also 

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drafted and posted all View Systems’ tweets, as he was the only individual with access to View 

Systems’ Twitter account.  As CEO, Campo also signed View Systems’ quarterly and annual 

reports filed with the SEC during the Relevant Period. 

9. From approximately 2002 to 2018, before joining View Systems, Campo served 

as an investor relations consultant to public companies, including View Systems. 

OTHER RELEVANT ENTITY AND PERSON 

10. View Systems is a Colorado corporation.  According to its SEC filings, View 

Systems’ principal place of business was in Greenbelt, Maryland through at least July 13, 2022. 

11. The Company became registered pursuant to Section 12(g) of the Exchange Act 

beginning in August 1999.  During the Relevant Period, its stock traded on various over the 

counter markets in the United States under the ticker symbol VSYM, including trading by U.S 

investors.  On January 19, 2021, the SEC issued an order temporarily suspending trading of View 

Systems’ stock through February 1, 2021 because of questions regarding the accuracy and 

adequacy of information in the marketplace about the Company and its securities.  After the 

trading suspension, the stock continued to be sold over the counter until the SEC revoked its 

registration in December 2022 for failing to file required periodic reports. 

12. During the Relevant Period, View Systems’ stock qualified as a “penny stock” as 

defined under Exchange Act Section 3(a)(51) [15 U.S.C. § 78c(a)(51)] because it did not meet 

any exemption from the definition under Exchange Act Rule 3a51-1 [17 C.F.R. § 240.3a51-1] 

and was traded on the over-the-counter market for less than $5 per share.  View Systems’ annual 

report on Form 10-K for 2019 (“2019 10-K”), signed by Campo and filed with the SEC on July 

2, 2020, states that the Company’s stock was considered to be a penny stock.   

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13. View Systems’ Founder is an individual residing in Arkansas who founded the 

company that later became View Systems.  View Systems’ Founder was the Company’s CEO 

from 1998 until Campo joined View Systems in July 2019.  During the Relevant Period, View 

Systems’ Founder continued to serve on View Systems’ board of directors and remained involved 

with the company. 

FACTS 

A. Prior to the Relevant Period, View Systems Had a Real Business, but by 2019, It 
Had Virtually No Operations.  

14. Prior to the Relevant Period, View Systems had a real business that involved 

manufacturing and selling security and surveillance products, with its primary product being a 

concealed weapons detection device known as the ViewScan.  In 2016, however, the Company 

stopped manufacturing products (except for special orders) and stopped soliciting sales of its 

ViewScan.  By 2018, the Company had licensed the ViewScan to a third party and stopped 

selling its products almost entirely.   

15. In July 2019, Campo joined View Systems as President and CEO.  By that time, 

View Systems had virtually no revenue generating business.  View Systems’ 2019 10-K states 

that its total revenue for 2019 was just $1,400.  View Systems’ annual report on Form 10-K for 

2020 (the “2020 10-K”), although problematic for the reasons discussed below, still only claimed 

total revenue of less than $3,000 for 2020. 

B. The Sannabis Acquisition Scheme: Campo Falsely Represented That View Systems 
Had Acquired Sannabis.  

 
1. Campo Signed a Contingent Agreement for View Systems to Acquire 

Sannabis in the Future. 

16. On or about July 9, 2019, View Systems issued a press release announcing that it 

had entered into a memorandum of understanding to acquire a Colombian company called 

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Sannabis, S.A.S., a company that Campo had founded and co-owned.  View Systems touted 

Sannabis as a “Medical Marijuana Pioneer” that had purportedly obtained “medical marijuana 

licenses for seed propagation, cultivation, transformation, and export.”    

17. At some point during the period from about July 29, 2019 to June 2021, View 

Systems entered into a contingent merger commitment with Sannabis, written in Spanish and 

titled “Compromiso de Fusion.”  That agreement was signed by Campo on behalf of View 

Systems.  This merger commitment required View Systems to direct funding to Sannabis and 

made the future merger contingent on that as well as approval by the shareholders of each entity.   

As contemplated by the merger commitment, the acquisition would be completed by having 

Sannabis be absorbed into View Systems and View Systems issuing shares in equal parts to 

Campo and a Sannabis representative, who were both shareholders of Sannabis.    

18. View Systems’ acquisition of Sannabis was never completed.  Sannabis was never 

merged into View Systems and no shares of View Systems were issued to Sannabis shareholders.  

As Campo was a founder and co-owner of Sannabis and was directly involved in the negotiations 

between View Systems and Sannabis, he knew this.  In fact, Campo provided sworn testimony in 

August 2021 during the SEC’s investigation in which he admitted that the merger still had not 

been completed as of that date.  View Systems’ Founder also testified in the investigation that 

View Systems’ planned acquisition of Sannabis was never completed. 

2. Campo Made and Disseminated Numerous Materially False and Misleading 
Statements Describing the Potential Future Sannabis Acquisition as 
Something That Had Already Happened. 

a. Campo Made Misstatements in 2019 Falsely Representing That the 
Sannabis Acquisition Had Closed. 

 
19. Despite knowing that View Systems had not actually acquired Sannabis, Campo 

repeatedly made and disseminated false and misleading statements to the public suggesting that 

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it had.  These false claims appeared in press releases, View Systems’ Twitter posts, and at least 

one quarterly report filed with the SEC.  In these statements, Campo also touted Sannabis as an 

international player in the “medical marijuana” industry that was poised to “Supply the World’s 

$14 Billion Hemp Market.”  He also falsely represented that Sannabis was actively growing 

cannabis, when it was not, and did not have the requisite licenses to do so.  In fact, contrary to 

Campo’s public statements, during 2019 and 2020, Sannabis’ business was limited to making and 

selling cosmetics and creams made from hemp seed oil.  And although Sannabis had applied for 

licenses from the government of Colombia that would have allowed it to grow cannabis, it did 

not actually obtain any such license until at least 2021.  

20. For instance, beginning on or about July 31, 2019, Campo drafted and published a 

press release that announced, falsely, that “View Systems Inc. Closes Acquisition of Colombia 

Medical Marijuana and Hemp Products Company, Sannabis.”  The body of the press release 

repeated the false statement that “View Systems, Inc. … announced today the closing for the 

acquisition of Sannabis S.A.S. (“Sannabis”), a Colombian medical marijuana and hemp 

company.”  The press release also falsely stated that “View Systems acquired Sannabis to 

diversify into the burgeoning Cannabis industry…”  

21. These false statements had a material effect on View Systems’ stock price.  Later 

that same day, an article was published in Emerging Growth.com, a company that reports on 

small-cap companies.  The article cited to the July 31 press release and was titled “View 

Systems, Inc. (OTC Pink: VYSM) up 31% after Closing Acquisition of Colombia Medical 

Marijuana and Hemp Products Company, Sannabis.”   

22. As of market close on July 31, 2019, the stock price for View Systems increased 

over 25%, from $0.0029 to $0.0037 per share, compared to the prior day close.  And the trading 

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volume for the day was over 16.5 million shares bought and sold, compared to fewer than 25,000 

shares traded the day before. 

23. Similarly, on or about August 19, 2019, Campo, as CEO of View Systems, signed 

a quarterly report on Form 10-Q for the period ended June 30, 2019, falsely representing that 

View Systems had “acquired a company called Sannabis that grows and ships Cannabis grown 

for medical and industrial purposes.”  This statement was false both because an acquisition with 

Sannabis had not taken place, and because Sannabis was not growing cannabis at all at that time. 

24. Campo repeated the false representation that View Systems had acquired 

Sannabis, in substantially verbatim form, in at least nine more View Systems press releases that 

he drafted and published between August and December 2019, including on: August 6, 2019; 

August 8, 2019; October 16, 2019; October 17, 2019; October 18, 2019; October 31, 2019; 

November 15, 2019; November 22, 2019; and December 5, 2019. 

25. In the August 6, 2019 press release, Campo also falsely referred to Sannabis as 

belonging to View Systems by using the possessive form to describe the relationship between the 

two companies, another way of falsely representing that the acquisition had been completed. 

Specifically, Campo described Sannabis as “View Systems’ Medical Marijuana Company 

Sannabis” while announcing a distribution agreement with a cannabis licensee in Uruguay.  The 

body of that press release contained additional false statements claiming that Sannabis was 

owned by View Systems by describing it as “their medical marijuana company in Colombia” 

(emphasis added).   

26. Campo repeated the false and misleading descriptions of Sannabis as “View 

Systems’ Sannabis” or “View Systems’ subsidiary,” nearly verbatim, in at least seven more View 

Systems press releases (of which six also contained the false “acquired” language, as listed 

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above) between September and December 2019, including on: September 4, 2019; October 17, 

2019; October 18, 2019; October 31, 2019; November 15, 2019; November 22, 2019; and 

December 5, 2019. 

27. At least some of the false statements about the Sannabis acquisition were 

highlighted by third parties analyzing the stock.  For instance, on November 15, 2019, another 

article appeared on Emerging Growth.com that cited to the November 15 View Systems press 

release and was titled “View Systems, Inc. (OTC Pink: VYSM) up 37% after Sannabis imports 

Hemp Seeds to Uruguay to Begin Planting Next Week to Supply the World’s $14 Billion Hemp 

Market.” 

28. As of market close on November 15, 2019, the stock price for View Systems had 

increased 38%, from $0.0008 to $ 0.0011 compared to the prior day close, and the trading 

volume for the day was over 9.4 million shares traded, compared to fewer than 1.4 million shares 

traded the day before. 

b. Campo Signed a Report Filed with the SEC in December 2019 
Admitting That the Sannabis Acquisition Had Not Closed. 

29. On or about December 9, 2019, Campo signed a View Systems quarterly report 

(Form 10-Q) for the third quarter of 2019 that was filed with the SEC that same day.  In the Form 

10-Q, View Systems acknowledged that “[t]he acquisition of Sannabis has not yet closed” and 

added that “[w]e expect the [Sannabis] acquisition to be complete in the first quarter of 2020.”  

This statement in the SEC filing essentially admits the falsity of all the prior press releases, 

which described the acquisition as “closing,” View Systems having “acquired” Sannabis, or 

representing Sannabis as belonging to View Systems.  Nevertheless, Campo began the fraud 

anew the very next month. 

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9 

c. Campo Made and Disseminated Additional Misstatements About the 
Sannabis Acquisition in 2020. 

30. On January 13, 2020, for reasons not yet determined, View Systems experienced a 

sudden increase in its stock price and trading volume.  Specifically, by the market close on that 

day, View Systems’ stock price had increased by 83%, from $0.0006 to $0.0011, and the trading 

volume increased from less than 30 million to more than 118 million, as compared to the prior 

trading day of January 10.   

31. Although the immediate cause of this increase in View Systems’ trading is 

unknown, contemporaneous market sources suggest that it reflects the materiality of the planned 

Sannabis acquisition.  For instance, after the market closed on January 13, 2020, an article was 

published in Pennystockdream.com, an online newsletter service, with the headline: “View 

Systems, Inc., (PINK:VYSM) closed up 83.33% Today, As Anticipation Grows Over Planned 

Merger With Colombian Cannabis Company, ‘Sannabis’” and specifically noted that “[a]s per a 

form 10-Q filed for the quarterly period ended on September 30th 2019, View Systems stated that 

this merger is expected to be completed in the first quarter of 2020.”   

32. On January 14, 2020, the next day, View Systems’ stock price closed another 55% 

higher, at $0.0017, with more than double the trading volume at over 314 million.  After the 

market closed, another article was published in Pennystockdream.com, with the headline: “After 

Our Update On View Systems, Inc., (PINK:VSYM) Last Night It Gained As Much As 109.09% 

Mid-Day Today, And Closed Up 54.55%.”  The article cited to View Systems’ December 2019 

Form 10-Q and noted that “investors are currently anticipating the expected close of a planned 

merger between View Systems, Inc. and the Colombian Cannabis company, ‘Sannabis.’” 

33. Contrary to the claimed expectation in the December 9, 2019 Form 10-Q, which 

was repeated in the press coverage described above, View Systems did not close the Sannabis 

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10 

acquisition during the first quarter of 2020 (or ever).  Yet, Campo continued to draft, publish, and 

disseminate press releases falsely representing that the acquisition had been completed.    

34. For example, on or about January 14, 2020, Campo drafted and published a press 

release that falsely represented Sannabis as belonging to View Systems: “View Systems, Inc.’s 

(VSYM) Sannabis is Only Company Planting Cannabis in Uruguay this Season, on Target for 

250,000 POUNDS with Plants Growing Nicely to Supply the World with Hemp and CBD 

Products from Uruguay and Colombia.”  Campo repeated this misrepresentation in the body of 

the press release by referring to Sannabis, once again, as “View Systems, Inc.’s (VSYM), 

medical marijuana and hemp subsidiary.”  He also repeated the specific representation that 

“View Systems acquired Colombian Cannabis company, Sannabis, to diversify into the 

burgeoning Cannabis industry…” (emphasis added). 

35. Campo repeated his false and misleading descriptions of Sannabis as “View 

Systems, Inc.’s Sannabis” or View Systems’ “subsidiary,” or as View Systems as having 

acquired, or been merged with, Sannabis, in at least ten more press releases between January and 

June 2020, including on: January 15, 2020;  January 17, 2020; January 28, 2020; January 31, 

2020; February 4, 2020; February 12, 2020; February 21, 2020;  April 8, 2020; June 4, 2020; and 

June 8, 2020.  

36. Campo also disseminated the June 4 and 8, 2020 press releases by including links 

to them in posts he made to View Systems’ Twitter account on the day of each of these press 

releases. 

37. Contrary to these representations, Campo eventually admitted—again—that no 

merger or acquisition of Sannabis had actually been completed.  On or about July 2, 2020, View 

Systems filed its 2019 10-K with the SEC, in which it acknowledged that no acquisitions were 

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11 

pending.  Included as an attachment to the 2019 10-K was an unsigned Memorandum of 

Understanding that described a future plan of merger between Sannabis and View Systems if 

“certain milestones” were met.  This annual report was signed and certified by Campo.  

38. A November 20, 2020 press release that Campo drafted and published also 

admitted that the acquisition had not been completed by that time, describing it as something that 

View Systems was still “finalizing.” 

39. In fact, View Systems never completed any acquisition of Sannabis. 

40. Through the actions described above, Campo knowingly or recklessly deceived 

investors and potential investors in View Systems with the false and misleading statements he 

made and disseminated representing that View Systems actually acquired Sannabis. 

C. The ViewScan II Scheme: Campo Falsely Represented That View Systems Had a 
New Thermal Imaging Product That Could Provide “Real Time COVID 
Temperature Results.” 

 
1. Background on the COVID-19 Pandemic and View Systems’ Planned 

ViewScan II. 
 

41. In the fall of 2020, at the height of the global COVID-19 pandemic, there was a 

sharp increase in the demand for thermal imaging devices, in the hope that such devices could 

help detect people who had COVID-19 and thus mitigate the spread of the virus.  As a November 

3, 2020 news article noted: 

Since last spring, hundreds of merchants have begun selling telethermographic 
systems—a category that includes dozens of devices such as cameras and kiosks 
that use infrared scanning and thermal imaging to detect body heat from a 
distance.  

School administrators, managers of government office buildings and corporations 
have been purchasing the technology and installing it at the entrances of schools, 
hospitals and other buildings in the hope that it will mitigate the spread of Covid-
19 by screening out people with fevers, a key symptom of the virus. 

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42. In November and December 2020, Campo repeatedly represented in press 

releases, Tweets, and by sending links to the View Systems website that View Systems had a new 

thermal imaging temperature screening product, sometimes referred to as the ViewScan II, that 

could detect temperatures, including those associated with COVID.  He further claimed that 

View Systems had already received orders for the new product.  These representations were 

false. 

43. As Campo knew, View Systems had no thermal imaging temperature screening 

product.  Although View Systems had developed technical designs and other documentation for a 

new version of the ViewScan that would be wider and more effective, none of these designs or 

documentation provided for any thermal imaging capabilities.   

44. Campo admitted in testimony in 2021 that he did not know whether View 

Systems had even reached agreements with any suppliers to provide thermal imaging devices to 

be incorporated into a future ViewScan system.  In fact, View Systems and at least one View 

Systems customer, had attempted to find a thermal imaging system that might work with the 

Company’s old ViewScan product, but had been unsuccessful.    

45. Moreover, as Campo admitted in his testimony, at the time of the press releases 

and other statements discussed below, no ViewScan II had been built.  Campo further admitted 

that building the ViewScan II was not possible unless View Systems raised capital from 

investors.  Campo attempted to defend the statements in testimony by asserting that “I still to this 

day have every optimism that I’ll be able to get this done” and claiming that the press releases 

were “forward-looking” statements.  Yet his false and misleading statements were not mere 

expressions of optimism or “forward-looking” statements of some future event.  They were 

factual representations that the product existed already, when he knew it did not.  The public 

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13 

statements regarding the ViewScan II were also not accompanied by any forward-looking 

disclaimer languages. 

46. Additionally, although records reflect that View Systems had provided price 

quotes for “ViewScan II’s” to two potential customers in May and November 2020, it never 

received any actual orders for the product.  Indeed, View Systems’ Founder testified that View 

Systems did not take orders for the ViewScan II because no ViewScan II had been built.  

2. Campo Made and Disseminated Numerous Materially False and Misleading 
Statements About the ViewScan II and Its Thermal Imaging Capabilities.  

47. Despite knowing that no ViewScan II had been built and no ViewScan product 

had thermal imaging capabilities, Campo drafted and posted a message on View Systems’ Twitter 

feed dated November 19, 2020, announcing: “ViewScan for Stadiums, now with Thermal 

Imaging Real-Time Temperature Results … More in Press Release tomorrow morning…” 

48. The next day, the promised press release (drafted and published by Campo), 

announced: “View Systems, Inc. (VSYM)…Launches New Website to Begin Marketing 

ViewScan II with Real Time Thermal Imaging Temperature Results and other Enhanced 

Features.” and included links to View Systems’ website (www.viewsystems.com), which 

prominently featured the following banner of a thermal-like image of a person wearing a 

facemask: 

 

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Written over banner image were the words, “Introducing Thermal Imaging. Real-Time COVID 

Temperature Results VIEW SCAN II.” 

49. Campo also drafted and published a Twitter post with the same date of November 

20, 2020 that contained the same representations about ViewScan II as the press release and a 

link to the press release. 

50. At the time he drafted and published the November 20 press release and the 

Twitter post, Campo knew the View Systems website had the COVID temperature results banner 

because he had seen it.  Additionally, although Campo had the authority to ask the Company’s 

web page designer to change the content of the website, Campo did not ask to change the banner 

before issuing the press release.  Thus, Campo knowingly disseminated the statement on the 

website “Introducing Thermal Imaging Real-Time COVID Temperature Results VIEW SCAN 

II” by linking to that website in his press release. 

51. Once again, Campo’s false and misleading representations had an immediate and 

material impact on the market.  By the close of the market on the day of the November 20 press 

release and Twitter post, View Systems’ stock price increased 133%, from $0.0003 to $0.0007 

per share.  And View Systems’ trading volume increased from more than 82.6 million on 

November 19 to nearly 1.3 billion on November 20. 

52. On or about December 11, 2020, Campo drafted and published another View 

Systems press release that stated that the Company was “raising capital to build the new and 

improved ViewScan II … to fill existing international orders” (emphasis added).  In this press 

release, Campo again included links to the View Systems website, which Campo knew still 

displayed the same banner of a thermal-like image of a person wearing a facemask stating, 

“Introducing Thermal Imaging Real-Time COVID Temperature Results VIEW SCAN II.” 

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53. Campo also drafted and published a Twitter post dated December 11, 2020 that 

contained the same representations about ViewScan II and linked to the press release. 

54. And again, Campo’s false and misleading representations had a material impact 

on the market.  By market close on December 11, 2020, View Systems’ stock price had increased 

50%, from $0.0008 to $0.0012 per share, from the prior day.  And View Systems’ trading volume 

increased from nearly 110 million on December 10 to more than 750 million on December 11. 

55. At the time of these November and December 2020 statements, Campo knew that 

View Systems had not built any ViewScan II devices and that View Systems had not received 

any actual orders for the ViewScan II.  In fact, Campo admitted in testimony that the ViewScan 

II did not physically exist, but that he had been attempting to raise capital from investors so that 

View Systems could build it (though again, even the ViewScan II designs did not include thermal 

capabilities).  As part of his fundraising efforts, Campo testified that he sent Private Placement 

Memoranda to dozens of individuals, including existing View Systems shareholders.  View 

Systems records reflect that it provided a Private Placement Memoranda with an offering 

commencement date of March 15, 2021, to at least 26 potential investors from December 2020 

through February 2021.  Campo testified that, as a result of his efforts, View Systems obtained at 

least one $15,000 private placement investment from a U.S. investor, and that, as of August 

2021, View Systems was still seeking to raise capital. 

56. Through the actions described above, Campo knowingly or recklessly deceived 

investors and potential investors in View Systems with the false and misleading statements he 

made and disseminated regarding the ViewScan II. 

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D. The Fake Audit Report Scheme: Campo Signed and Certified a Form 10-K Falsely 
and Misleadingly Representing That View Systems’ 2020 Financial Statements Had 
Been Audited. 

 
1. Background on View Systems, Its SEC Filings, and Its Auditor. 

 
57. As a company whose stock was publicly traded, View Systems was required to 

file periodic reports with the SEC during the Relevant Period, consisting of quarterly reports on 

Forms 10-Q and annual reports on Forms 10-K.  However, over time the Company fell 

significantly behind in filing these reports.  By July 2022, View Systems had not filed its annual 

reports on Form 10-K for the years ended December 31, 2020 or December 31, 2021, or any 

quarterly reports on Form 10-Q for any quarter period in 2021 or 2022.  In June 2021, the 

Company’s prior auditor resigned. 

58. In August 2021, View Systems hired a new auditor (“Audit Firm”) to audit its 

2020 financial statements.  The terms of the audit engagement were set forth in a seven-page 

letter signed by the managing partner of the Audit Firm (“Audit Partner”) and Campo.  One of 

the terms specified that before View Systems could make any SEC filing with which the Audit 

Firm was associated, View Systems would notify the Audit Firm, which would then provide a 

signed copy of its audit report and consent to including it in the filing.  

59. By early July 2022, the audit of View Systems’ 2020 financial statements still had 

not been completed.  In the SEC’s investigation, the Audit Partner testified that he had never 

completed certain substantive audit steps, including completion of the engagement quality 

review, obtaining a representation letter from management, and conducting a subsequent events 

review. 

60. On or about July 5, 2022, Campo emailed the Audit Partner requesting that the 

Audit Firm “send us the 2020 financial statements so we can finish drafting the [Form] 10K.  We 

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can’t file it until you sign off.”  The Audit Partner responded to Campo that he had not been paid 

for his services, and he did not provide the financial statements.  Campo continued to press the 

Audit Partner to provide the 2020 financial statements, noting that doing so would allow View 

Systems “to begin preparing the [Form] 10K.”  

61. On or about July 11, 2022, View Systems’ Founder informed Campo and the 

Audit Partner that several investors were waiting for View Systems to become current on its SEC 

filings, and that once View Systems did that, they would invest.  Later that morning, the Audit 

Partner agreed to have an employee of the Audit Firm provide Campo with a draft set of 

financial statements so that View Systems could finalize a draft of the 2020 10-K.  The Audit 

Partner testified that, although the financials were provided to Campo, he never provided any 

audit report (signed or unsigned) and did not consent to View Systems including an audit report 

in the 2020 10-K filed with the SEC. 

2. Campo Signed and Certified View Systems’ Form 10-K for 2020 Despite 
Knowing It Included a Fake Audit Report. 

 
62. On or about July 13, 2022, View Systems filed its 2020 10-K, which included 

financial statements for 2020.  Campo signed the 2020 10-K and certified under SOX 302 that it 

did “not contain any untrue statement of a material fact.” 

63. Campo’s SOX 302 representation was false because the 2020 10-K described the 

financial statements contained in the annual report as having been audited—referring to “[t]he 

audited financial statements contained in this Annual Report”—when Campo knew that the audit 

was not complete.  In fact, the Audit Partner testified that he had informed Campo on multiple 

occasions that he had not completed the audit. 

64. Not only did the 2020 10-K falsely claim that the financials had been audited, it 

contained a fake audit report, purportedly by an independent auditor.  This fake audit report was 

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titled “Report of Independent Registered Public Accounting Firm,” and falsely stated “[w]e have 

audited the accompanying balance sheets of View Systems, Inc. (the “Company”) as of 

December 31, 2020.”  The fake audit report then concluded that the financial statements “present 

fairly, in all material respects, the financial position of the Company as of December 31, 2020,” 

and that the results of View Systems’ “operations and its cash flows” were “in conformity” with 

U.S. GAAP. 

65. The language in this fake audit report appears to be nearly identical to the real 

audit report that had been included in View Systems’ 2019 10-K.  However, unlike the 2019 

audit report, the 2020 fake audit report contained no date, no logo, and no name or signature for 

any audit firm.  When the Audit Partner was shown the fake audit report from the 2020 10-K, he 

testified that he did not write it. 

66. Although it is not clear who first created the fake audit report, Campo nonetheless 

engaged in a fraudulent scheme to deceive investors by signing and certifying the Form 10-K 

that included the fake audit report while knowing, or being reckless in not knowing, that the 

Audit Firm (a) had not issued any such audit report, (b) had not completed the audit of View 

Systems’ 2020 financial statements, and (c) did not consent to file an audit report with the 

Company’s annual report. 

3. Campo Later Admitted the Audit Had Not Been Completed and Tried to 
Cover His Tracks. 

 
67.   On or about July 25, 2022, Campo emailed the Audit Partner notifying him that 

the 2020 10-K had been filed and requesting that the Audit Firm provide “an audit opinion” 

(something that should have been received before the 2020 10-K was filed).  In that email, 

Campo claimed that “it slipped my attention that it was missing” (in fact the report was not 

“missing,” but rather fabricated).  The Audit Partner responded that same day by refusing to 

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provide the requested audit opinion without additional due diligence, noting “I was surprised that 

after we discussed and agreed that you only want to review the Financials, you go ahead and file 

it with SEC. That destroyed all the trust I had in your word. I have to proceed with caution.”   

68. The Audit Firm never did complete the audit and Campo took no steps to correct 

the false and misleading statements in the 2020 10-K regarding the audit. 

69. On or about August 20, 2022 the Audit Firm resigned.  

FIRST CLAIM FOR RELIEF 
Violations of Exchange Act Section 10(b) and Rule 10b-5  

 
70. The SEC realleges and incorporates by reference the forgoing paragraphs, as 

though fully set forth herein. 

71. By reason of the foregoing, Defendant, directly or indirectly, in connection with 

the purchase or sale of securities, by the use of means or instrumentalities of interstate 

commerce, of the mails, or of the facilities of a national securities exchange: (a) employed 

devices, schemes, or artifices to defraud; (b) made untrue statements of a material fact and/or 

omitted to state a material fact necessary in order to make the statements made, in the light of the 

circumstances under which they were made, not misleading; and (c) engaged in acts, practices, 

or courses of business which operated or would operate as a fraud or deceit upon any persons, 

including purchasers of the securities. 

72. While engaging in the conduct described above, Defendant acted with scienter. 

73. By engaging in the conduct described above, Defendant violated, and, unless 

enjoined, will continue to violate Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and 

Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]. 

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SECOND CLAIM FOR RELIEF 
Violation of Exchange Act Rule 13a-14 

 
74. The SEC realleges and incorporates by reference the foregoing paragraphs, as 

though fully set forth herein. 

75. On July 13, 2022, acting under Section 302 of the Sarbanes-Oxley Act of 2002 

and Exchange Act Rule 13a-14 [17 C.F.R. § 240.13a-14], Defendant signed a certification 

attesting to the accuracy and completeness of an annual report (Form 10-K) filed with the SEC 

by View Systems. 

76. By engaging in the acts and conduct alleged herein, Defendant filed or caused to 

be filed on View Systems’ behalf an annual report on Form 10-K, which contained certifications 

signed by Defendant as View Systems’ principal executive officer pursuant to Exchange Act 

Rule 13a-14 [17 C.F.R. § 240.13a-14] and included untrue statements of material fact, or failed 

to include, in addition to the information required to be stated in such certification, such further 

material information as was necessary to make the required statements, in light of the 

circumstances under which they were made, not misleading, or failed to disclose information 

required to be disclosed therein. 

77. By reason of the foregoing, Defendant violated, and, unless enjoined, will 

continue to violate, Exchange Act Rule 13a-14 [17 C.F.R. § 240.13a-14]. 

THIRD CLAIM FOR RELIEF 
Aiding and Abetting Violations of Exchange Act Section 13(a) 

 and Exchange Act Rules 12b-20, 13a-1, and 13a-13 
 

78. The SEC realleges and incorporates by reference the foregoing paragraphs, as 

though fully set forth herein. 

79. As alleged above, View Systems violated Exchange Act Section 13(a) and Rules 

12b-20, 13a-1, and 13a-13, thereunder [17 C.F.R. §§ 240.12b-20, 240.13a-1, and 240.13a-13] by 

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filing Forms 10-K and 10-Q filed with the SEC that were untruthful, inaccurate, and/or failed to 

disclose required material information. 

80. As detailed above, Defendant knowingly or recklessly provided substantial 

assistance to View Systems’ violations by signing and/or certifying those filings that violated 

Exchange Act Section 13(a) and Rules 12b-20, 13a-1, and 13a-13, thereunder [17 C.F.R. §§ 

240.12b-20, 240.13a-1, and 240.13a-13]. 

81. By reason of the foregoing, and pursuant to Exchange Act Section 20(e) [15 

U.S.C. § 78t], Defendant aided and abetted View Systems’ violations of Section 13(a) of the 

Exchange Act [15 U.S.C. § 78m(a)] and Rules 12b-20, 13a-1, and 13a-13 thereunder [17 C.F.R. 

§§ 240.12b-20, 240.13a-1 and 240.13a-13], and, unless enjoined, will continue to aid and abet 

such violations. 

RELIEF REQUESTED 

WHEREFORE, the SEC respectfully requests that the Court enter a Final Judgment: 

 A. Finding that Defendant violated the federal securities laws as alleged against him 

in this Complaint; 

B. Permanently restraining and enjoining Defendant and his agents, employees, 

attorneys, and all persons in active concert or participation with them, who receive actual notice 

of the injunction by personal service or otherwise from violating, directly or indirectly, Sections 

10(b) and 13(a) of the Exchange Act and Rules 10b-5, 12b-20, 13a-1, 13a-13, and 13a-14 

thereunder [15 U.S.C.§§ 78j(b); § 78m(a); 17 C.F.R. §§ 240.10b-5; 240.12b-20; 240.13a-1, 

240.13a-13, and 240.13a-14]; 

C. Permanently barring Defendant 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. § 

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78l] and that is required to file reports under Section 15(d) of the Exchange Act [15 U.S.C. § 

78o(d)], 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)]; 

D. Permanently restraining and enjoining Defendant from participating in the 

offering of any penny stock, including by engaging in activities with a broker, dealer, or issuer 

for purposes of issuing, trading, or inducing or attempting to induce the purchase or sale of any 

penny stock, pursuant to Exchange Act Section 21(d)(6) [15 U.S.C. § 78u(d)(6)]; 

E. Ordering Defendant to pay appropriate civil money penalties pursuant to Section 

21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)]; and 

F. Granting such other further relief this Court deems just, equitable, appropriate, or 

necessary in connection with the enforcement of the federal securities laws and for the protection 

or benefit of investors. 

JURY DEMAND 

 Pursuant to Federal Rule of Civil Procedure 38, Plaintiff SEC demands a trial by jury on 

all issues so triable. 

 
Dated:  July 26, 2024    Respectfully submitted, 
 
 
Of Counsel:    U.S. SECURITIES AND EXCHANGE COMMISSION  
Christopher Bruckmann    
Ashley Sprague   _/s/ Devon Staren_____________ 
     Devon L. Staren 
     D.C. Bar No. 478619 
     Attorneys for Plaintiff 
     SECURITIES AND EXCHANGE COMMISSION 
     100 F. Street NE 
     Washington, D.C. 20549 
     (202) 551-5346 (Staren) 

[email protected]  
 

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