SEC v. MICHAEL M. BECK; and HELEN P. ROBINSON, No. 2:22-cv-00812, Central District of California (Feb. 7, 2022) — Complaint
raw: 20(d)(1) and 22(a) of the Securities Act of 1933 (“Securities Act”), 15 U.S.C.
20(d)(1) and 22(a) of the Securities Act of 1933 (“Securities Act”), 15 U.S.C., No. 2:22-cv-00812 (Feb. 7, 2022)
The SEC sued Michael M. Beck and Helen P. Robinson for an $870,000 scalping scheme involving the undisclosed sale of microcap stocks promoted on Twitter.
The SEC charged Michael M. Beck with violating antifraud provisions of the Securities Act and Exchange Act through a 'scalping' scheme involving eight microcap stocks. Between 2017 and 2019, Beck used his Twitter platform and 'TeamBillionaire' email group to promote stocks while secretly selling his own holdings for approximately $870,000 in gains. The agency is seeking permanent injunctions, disgorgement of ill-gotten gains, civil penalties, and a penny stock bar against Beck.
The Securities and Exchange Commission filed a complaint against Michael M. Beck and relief defendant Helen P. Robinson for a fraudulent 'scalping' scheme occurring between February 2017 and May 2019. Using his Twitter handle @BigMoneyMike6 and his 'TeamBillionaire' email group, Beck promoted eight microcap stocks to millions of followers without disclosing his intent to sell his own holdings. To artificially inflate prices, Beck also utilized third-party paid commentary on investor message boards. The scheme generated approximately $870,000 in pecuniary gains as Beck sold into the inflated market. Beck is charged with violating antifraud provisions of the Securities Act and the Exchange Act. The SEC seeks permanent injunctions, disgorgement of profits with interest, civil penalties, and a penny stock bar against Beck.
Extracted insights
- $900K $900,000 $100K–$1M
- $870K $870,000 $100K–$1M
- $870K $870,000 $100K–$1M
- $512K $512,000 $100K–$1M
- $358K $358,000 $100K–$1M
- $254K $254,000 $100K–$1M
- $254K $254,000 $100K–$1M
- $218K $218,000 $100K–$1M
- $218K $218,000 $100K–$1M
- $150K $150,000 $100K–$1M
- $110K $110,000 $100K–$1M
- $110K $110,000 $100K–$1M
- person amy j. longo
- person antifraud provisions
- agency attorney for plaintiff securities and exchange commission
- person helen p. robinson
- person michael m. beck
- person microcap stocks
- agency plaintiff securities and exchange commission
- person relief defendant
- person robert tercero
- agency Securities and Exchange Commission
- person third parties
- person twitter platform
- Amy J. Longo is an attorney for Securities and Exchange Commission
- Robert Tercero is an attorney for Securities and Exchange Commission
- Securities and Exchange Commission alleges jurisdiction and venue
- Defendants have used means or instrumentalities of interstate commerce
- Defendants have used mails
- Defendants have used facilities of a national securities exchange
- Michael M. Beck used Twitter platform
- Michael M. Beck promoted people to buy eight microcap stocks
- Michael M. Beck failed to disclose plans to sell
- Michael M. Beck sold stocks he was promoting
- Michael M. Beck earned pecuniary gains totaling about $870,000
- Michael M. Beck violated antifraud provisions of Section 10(b) of the Exchange Act
- Michael M. Beck violated antifraud provisions of Section 17(a) of the Securities Act
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy eight microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck earned pecuniary gains totaling about $870,000 by selling into artificially inflated stock prices
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Amy J. Longo is Attorney for Plaintiff Securities and Exchange Commission
- Robert Tercero is Attorney for Plaintiff Securities and Exchange Commission
- Securities and Exchange Commission alleges jurisdiction and venue
- Defendants used means or instrumentalities of interstate commerce
- Defendants made use of mails
- Defendants made use of facilities of a national securities exchange
- Michael M. Beck used Twitter platform
- Michael M. Beck promoted people to buy eight microcap stocks
- Michael M. Beck failed to disclose plans to sell
- Michael M. Beck earned pecuniary gains totaling about $870,000
- Michael M. Beck violated antifraud provisions of Section 10(b) of the Exchange Act
- Michael M. Beck violated antifraud provisions of Section 17(a) of the Securities Act
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plans to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck earned pecuniary gains totaling about $870,000 by selling into artificially inflated stock prices
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck paid third parties to post favorable commentary about the stocks on investor message boards
- Michael M. Beck sold stocks into the artificially inflated market, earning about $870,000 in pecuniary gains
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of penny stocks directly and/or through his nominee Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy eight microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold into the market and earned pecuniary gains totaling about $870,000
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold stocks into an artificially inflated market, earning about $870,000 in pecuniary gains
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plans to sell his own holdings
- Michael M. Beck purchased a block of shares of penny stocks directly and/or through his nominee Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy eight microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold into the market and earned pecuniary gains totaling about $870,000
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plans to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his nominee Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy eight microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold the promoted stocks into the artificially inflated market, earning about $870,000 in pecuniary gains
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck violated the antifraud provisions of Section 17(a) of the Securities Act
- Helen P. Robinson acted as a nominee for Michael M. Beck in purchasing penny stocks
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of penny stocks directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck paid third parties to post favorable commentary about the stocks on investor message boards
- Michael M. Beck sold stocks into the artificially inflated market, earning about $870,000 in pecuniary gains
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold microcap stocks into an artificially inflated market, earning about $870,000 in pecuniary gains
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plans to sell his own holdings
- Michael M. Beck purchased a block of shares of penny stocks directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy eight microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold into the market and earned pecuniary gains totaling about $870,000
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck paid third parties to post favorable commentary about the stocks on investor message boards
- Michael M. Beck sold stocks into the artificially inflated market, earning about $870,000 in pecuniary gains
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck violated the antifraud provisions of Section 17(a) of the Securities Act
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plans to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold microcap stocks into artificially inflated markets, earning about $870,000 in pecuniary gains
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck earned pecuniary gains totaling about $870,000 by selling into artificially inflated stock prices
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold stocks into the artificially inflated market, earning about $870,000 in pecuniary gains
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy eight microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck earned pecuniary gains totaling about $870,000 by selling into artificially inflated stock prices
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck violated the antifraud provisions of Section 17(a) of the Securities Act
- Helen P. Robinson acted as a nominee for Michael M. Beck in purchasing penny stocks
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold stocks into the artificially inflated market, earning about $870,000 in pecuniary gains
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy eight microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold stocks into an artificially inflated market, earning about $870,000 in pecuniary gains
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold stocks into the artificially inflated market, earning about $870,000 in pecuniary gains
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plans to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his nominee Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy eight microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold into the market and earned pecuniary gains totaling about $870,000
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy eight microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold stocks into the artificially inflated market, earning about $870,000 in pecuniary gains
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plans to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold stocks into the artificially inflated market, earning about $870,000 in pecuniary gains
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plans to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his nominee Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy eight microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold into the market and earned pecuniary gains totaling about $870,000
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck paid third parties to post favorable commentary about the stocks on investor message boards
- Michael M. Beck sold stocks into the artificially inflated market, earning about $870,000 in pecuniary gains
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of penny stocks directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy eight microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold into the market and earned pecuniary gains totaling about $870,000
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of penny stocks directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck paid third parties to post favorable commentary about the stocks on investor message boards
- Michael M. Beck sold into the market and earned pecuniary gains totaling about $870,000
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plans to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy eight microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold stocks into the artificially inflated market, earning about $870,000 in pecuniary gains
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plans to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy eight microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold stocks into the artificially inflated market, earning about $870,000 in pecuniary gains
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plans to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold stocks into the artificially inflated market, earning about $870,000 in pecuniary gains
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of penny stocks directly and/or through his mother, Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy eight microcap stocks to his millions of Twitter followers
- Michael M. Beck failed to disclose his plans to sell or ongoing selling of the stocks he was promoting
- Michael M. Beck earned pecuniary gains totaling about $870,000 by selling into artificially inflated stock prices
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plans to sell his own holdings
- Michael M. Beck purchased a block of shares of penny stocks directly and/or through his nominee Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy eight microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold into the market and earned pecuniary gains totaling about $870,000
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Michael M. Beck used his Twitter platform to promote and encourage people to buy eight microcap stocks without disclosing his plan to sell his own holdings
- Michael M. Beck purchased a block of shares of a penny stock directly and/or through his nominee Helen P. Robinson
- Michael M. Beck tweeted recommendations to buy eight microcap stocks to his millions of Twitter followers without disclosing his intent to sell
- Michael M. Beck sold stocks into the artificially inflated market, earning about $870,000 in pecuniary gains
- Michael M. Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5
- Securities and Exchange Commission alleges Michael M. Beck
- Michael M. Beck used Twitter platform
- Michael M. Beck promoted microcap stocks
- Michael M. Beck purchased shares of a penny stock
- Helen P. Robinson is Relief Defendant
- Michael M. Beck sold stocks
- Michael M. Beck earned $870,000
- Michael M. Beck violated antifraud provisions
- Michael M. Beck promoted eight microcap stocks
1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 AMY J. LONGO (Cal. Bar No. 198304) Email: [email protected] ROBERTO TERCERO (Cal. Bar No. 143760) Email: [email protected] Attorneys for Plaintiff Securities and Exchange Commission Michele Wein Layne, Regional Director Katharine Zoladz, Associate Regional Director 444 S. Flower Street, Suite 900 Los Angeles, California 90071 Telephone: (323) 965-3998 Facsimile: (213) 443-1904 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA SECURITIES AND EXCHANGE COMMISSION, Plaintiff, vs. MICHAEL M. BECK, Defendant, AND HELEN P. ROBINSON, Relief Defendant. Case No. 2:22-cv-00812 COMPLAINT Plaintiff Securities and Exchange Commission (“SEC”) alleges: JURISDICTION AND VENUE 1. The Court has jurisdiction over this action pursuant to Sections 20(b), 20(d)(1) and 22(a) of the Securities Act of 1933 (“Securities Act”), 15 U.S.C. §§ 77t(b), 77t(d)(1) & 77v(a), and Sections 21(d)(1), 21(d)(3)(A), 21(e) and 27(a) of 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 the Securities Exchange Act of 1934 (“Exchange Act”), 15 U.S.C. §§ 78u(d)(1), 78u(d)(3)(A), 78u(e) & 78aa(a). 2. Defendants have, 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. 3. Venue is proper in this district pursuant to Section 22(a) of the Securities Act, 15 U.S.C. § 77v(a), Section 27(a) of the Exchange Act, 15 U.S.C. § 78aa(a), because certain of the transactions, acts, practices and courses of conduct constituting violations of the federal securities laws occurred within this district. SUMMARY 4. Between February 2017 and May 2019, Defendant Michael M. Beck, aka @BigMoneyMike6 (“Beck”), used his Twitter platform, where he had as many as 3 million followers, to promote and encourage people to buy eight microcap stocks— all without disclosing that he planned to sell, or in some instances was personally selling, his own holdings of the same stocks (a practice known as “scalping”). 5. Beck’s scalping scheme involved the following pattern. First, Beck purchased a block of shares of a penny stock, directly and/or through his nominee (his mother), Relief Defendant Helen P. Robinson (“Robinson”). Next, he tweeted to his millions of followers and the public that he would soon be issuing a new stock recommendation, or an “alert.” In many instances, Beck then notified members of his email group, TeamBillionaire, to encourage them to buy the stock ahead of his upcoming recommendation to the public. At times, he also paid third parties to post favorable commentary about the stock on investor message boards, ahead of his recommendation. 6. Having purchased the stock, Beck then tweeted out recommendations to buy the stock to his millions of Twitter followers and the public. Throughout his promotional campaigns for the stocks, he failed to disclose his plans to sell, or his 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ongoing selling of, the very stocks he was promoting. 7. As the issuers’ stock price and trading volume increased, Beck sold into the artificially inflated market, earning pecuniary gains totaling about $870,000. 8. Through his conduct, defendant Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder, 15 U.S.C. § 78j(b) and 17 C.F.R. § 240.10b-5(a)-(c), as well as the antifraud provisions of Section 17(a) of the Securities Act, 15 U.S.C. § 77q(a)(1)-(3). 9. The SEC seeks permanent injunctions against future violations of Exchange Act Section 10(b) and Rule 10b-5 thereunder and Securities Act Section 17(a); an order requiring defendant Beck and relief defendant Robinson to disgorge their ill-gotten gains with prejudgment interest; civil penalties against defendant Beck; and a penny stock bar against defendant Beck. THE DEFENDANT AND THE RELIEF DEFENDANT 10. Michael M. Beck (“Beck”) resides in San Pedro, California. During the relevant time period, Beck used the Twitter handle “@BigMoneyMike6.” He also founded the email group TeamBillionaire. 11. Beck had at least one brokerage account at one financial institution in which he traded stock in 2017-2019. 12. During 2017-2019, Beck used the email addresses [email protected], [email protected], [email protected], and [email protected]. 13. Helen P. Robinson (“Robinson”) resides in San Pedro, California. She is Beck’s mother. 14. Robinson had at least five brokerage accounts at five financial institutions in which she and/or Beck traded stock in 2017-2019. 15. Robinson allowed Beck to use her account to trade stocks. RELATED ENTITIES 16. Pick-Ups Plus, Inc. (“Pick-Ups”) is a defunct Delaware corporation, 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 previously located in Newport Beach, California, which sold and installed accessories for sports utility vehicles. On June 18, 2018, the company filed a Form 15-12G with the SEC to terminate the registration of its common stock under Section 12(g) of the Exchange Act. Its common stock was quoted publicly under the ticker symbol “PUPS” on OTC Link (previously “Pink Sheets”), whose parent company is OTC Markets Group, Inc. (“OTC Markets Group”). PUPS is now quoted on OTC Markets Group’s Expert Market, where quotations are unsolicited and distribution of the quotations is limited to broker-dealers and other market professionals. 17. MK Automotive, Inc. is a Nevada corporation which engaged in retail and commercial automotive diagnostic, maintenance, and repair services. It was quoted on OTC Link under the ticker symbol “MKAU” until July 2017, when it was renamed Clikia Corp. and quoted under the ticker symbol “CLKA.” From December 15, 2017 to September 10, 2020, the company became qualified on six occasions to conduct a Tier 1 offering in reliance on Regulation A. In May 2020, the company was renamed Maison Luxe, Inc. and since April 2021 has been quoted on OTC Link under the ticker symbol “MASN.” 18. Zann Corp. (“Zann”) is a Nevada corporation located in Las Vegas which purports to be in the early stages of numerous business lines including block chain, information technology, and transportation logistics. Zann is a non-reporting company, and its common stock was quoted on OTC Link under the ticker symbol “ZNNC” but is now quoted on the Expert Market. 19. Vidaroo Corp. (“Vidaroo”) is a defunct Nevada corporation, which had its principal place of business in Orlando, Florida. It claimed to be in the video streaming and software distribution businesses, but it has no operations. Vidaroo’s common stock is registered with the SEC under Section 12(g) of the Exchange Act, but it has made no filings since March 17, 2014. Its common stock was quoted on OTC Link under the ticker symbol “VIDA” but is now quoted on the Expert Market. 20. Canadian Aerospace Group International, Inc. (“CASG”) is a 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 defunct Florida corporation, which had its principal place of business in Herriman, Utah and was a developer of aviation products and services. On September 23, 2016, the Florida Secretary of State put the company on inactive status for failing to make required filings. It is a non-reporting company, and its common stock was quoted under the ticker symbol “CASG” on OTC Link. On May 10, 2019, the SEC suspended trading in its securities for ten business days because the company was no longer in operation and had not posted any information to OTC Markets Group or filed any information with the Commission. Exchange Act Rel. No. 85835 (May 10, 2019). The stock is now quoted on the Expert Market. 21. Music for Your Life (“MYLY”) is a Florida corporation with its principal place of business in Las Vegas, Nevada, which operates a network of radio stations. It is a voluntary filer with the SEC, but filed a Form 12b-25 on August 31, 2021, stating that it was unable to file its Form 10-K. Its stock was quoted on OTC Link under the ticker symbol “TMGI,” but it is now quoted on the Expert Market. It was formerly known as Music for Your Life Inc. (OTC Link “MYLY”) until August 16, 2018. 22. Peoplesway.com, Inc. (“Peoplesway”) is a defunct Nevada corporation formerly located in North Carolina, that was a multi-level marketer of wellness products. Its corporate status was revoked in 2014. On October 20, 2005, the company filed a Form 15-12G with the SEC to terminate the registration of its common stock under Section 12(g) of the Exchange Act. Its common stock was quoted on OTC Link under the ticker symbol “PLWY” but is now quoted on the Expert Market. 23. United Consortium Ltd. (“UCSO”) is a defunct Nevada corporation formerly located in Tampa, Florida, which claimed to have four business lines: legal digital services; blockchain; palm oil; and cannabinoids. Its corporate status was revoked in 2019. It is a non-reporting company whose common stock was quoted on OTC Link under the ticker symbol “UCSO” but is now quoted on the Expert Market. 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 24. The eight companies whose stock Beck scalped (Pick-Ups, MK Automotive, Zann, Vidaroo, CASG, Marquie, Peoplesway, and UCSO) are collectively referred to as the “Issuers.” 25. The Issuers’ securities are commonly known as “microcap stocks” or “penny stocks,” which typically trade over OTC Link for pennies or even fractions of a penny per share. THE ALLEGATIONS A. Summary of Beck’s Scalping Scheme 26. As alleged below, Beck engaged in a fraudulent scheme to promote and manipulate penny stocks, using his Twitter account with the handle @BigMoneyMike6, by encouraging investors to buy the Issuers’ securities while at the same time — contrary to his advice to his millions of Twitter followers, as well as to the viewing public who read his Twitter posts — selling his own holdings of those securities into the inflated price and liquidity that his tweets helped create. 27. Beck’s Twitter handle during 2017 to 2019 was @BigMoneyMike6. 28. @BigMoneyMike6 had as many as many as 3 million Twitter followers between 2017 and 2019. 29. Beck was also the founder of an email group, TeamBillionaire. 30. Beck used his Twitter handle to invite his followers to join TeamBillionaire. (a) For example, on or about September 13, 2017, Beck tweeted, “GOT #PENNYSTOCKS? WANNA TURN A $5,000 INVESTMENT INTO $50,000+? JOIN #TEAMBILLIONAIRE ASAP.” 1 (b) As another example, on or about October 3, 2017, Beck tweeted, “JOIN #TEAMBILLONAIRE NOW !!!!!!! CHANGE UR FINANCIAL LIFE 1 Beck’s emails and tweets, which often contain typographical and grammatical errors, are quoted verbatim in this complaint. 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 FOREVER.” 31. In emails to members of his group, Beck described TeamBillionaire as a “NETWORK of the TRADER for the TRADER,” describing TeamBillionaire’s mission as “to make EVERY SINGLE TRADER in our NETWORK a minimum of 200% in profits every month for the rest of their TRADING LIVES from #TEAMBILLIONAIRE ALERTS/PICKS!!!!” 32. According to Beck, his TeamBillionaire email group had more than 740,000 members in 2017. 33. Between 2017 and 2019, Beck’s scalping scheme followed a repeated pattern. 34. First, Beck purchased shares of a microcap issuer directly and/or in Robinson’s accounts in advance of his promotional campaign. 35. Next, Beck tweeted to his followers and the public that a stock pick alert would be forthcoming. 36. Then, a few days before Beck tweeted his stock pick alert, he typically emailed his TeamBillionaire followers, identifying the stock recommendation he planned to promote through Twitter, enabling TeamBillionaire to purchase the stock prior to his Twitter promotions. This preview of the stock recommendation generally increased the stock’s trading volume and price, making the stock look more attractive to potential investors when Beck issued his public recommendation. 37. In some instances, Beck paid two third parties to post favorable messages about the stock on Investorshub.com. Like the previews to TeamBillionaire members, the posts generally increased the stock’s trading volume and price, making the stock look more attractive to potential investors when Beck issued his public recommendation. 38. Beck then tweeted his stock pick alert, and frequently emailed it to Team Billionaire members, to buy the stock, forecasting high growth and returns. Beck often repeated his stock pick in numerous subsequent tweets and emails. 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 39. As the stock price rose—whether following a preview email to TeamBillionaire, message board posts, or the actual stock pick alert—Beck simultaneously sold the Issuer’s stock in his accounts and/or Robinson’s. 40. None of Beck’s recommendations disclosed that Beck was either planning to sell or actually selling the stock while he was recommending that others buy it. Nor did Beck disclose that he had in some cases previewed his alert to his TeamBillionaire group, or secretly paid others to post favorably about the Issuers on investor message boards. 41. With respect to each of the Issuers, as detailed below, Beck profited by selling his stock while the market price was artificially inflated during his promotional campaign. B. Beck’s Scheme to Scalp the Issuers’ Stocks 1. Beck’s Pick-Ups scalping scheme 42. Pick-Ups is a now-defunct auto accessory company whose stock was trading under the ticker PUPS at around $0.0035 per share in April 2017. 43. Beck began purchasing Pick-Ups stock on or about February 7, 2017, in his own and Robinson’s accounts, when the prevailing market price of Pick-Ups stock was $0.0004 per share. He continued to purchase shares within the range of $0.0004 to $0.0039 per share with the vast majority at prices at $0.0018 per share or lower. 44. On or about April 19, 2017, Beck tweeted that a stock pick was imminent, stating among other things that, “THE APRIL 25TH MEGA ALERT IS LESS THAN A WEEK AWAY” and that, “NEXT TUESDAY COULD NOT ONLY BE MY BIGGEST ALERT EVER BUT COULD BE.. THEE BIGGEST ALERT EVER.” 45. In emails between April 23-24, 2017, Beck emailed his TeamBillionaire followers recommending they buy Pick-Ups stock in advance of his planned alert. (a) For example, on or about April 23, 2017, Beck wrote to one 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 follower: “The stock I’m going to get you into is currently trading at $.005 and will be trading $.05+ by Tuesday the 25TH . . . The stock that is going to make you a ‘minimum’ of 500% on your investment is................. $PUPS.” 46. Beginning on April 25, 2017 through May 9, 2017, Beck tweeted recommendations to purchase Pick-Ups stock. (a) For example, on or about April 25, 2017, Beck tweeted, “I'VE BOUGHT 27,000,000 SHARES OF $PUPS TODAY! IM STILL LOADING.. LETS SQUEEZE THE SHORTERS !!!” (b) As another example, on or about May 1, 2017, Beck tweeted, “$PUPS WILL BE GREEN EVERYDAY TILL CHRISTMAS !!!!!! $PUPS WILL BE AMERICAS #1 STOCK !!!” 47. In none of Beck’s tweets or emails recommending that others buy Pick- Ups stock did he disclose that he or his nominee were selling or planning to sell Pick- Ups stock. 48. Beck’s statements were materially false and misleading, as he was at that time planning to sell, and was already selling, his holdings of Pick-Ups’ stock. A reasonable investor would want to know, in assessing the quality of a recommendation to buy a stock, whether the person making the recommendation was selling contrary to the recommendation. 49. Beck knew that his statements were materially false and misleading because he was aware of his own trading activity. 50. During Beck’s promotional campaign, Pick-Ups’ stock price rose from $0.0050 to $0.0085 per share, between April 21, 2017 (the last trading day before the first TeamBillionaire email) and April 24, 2017 (the first day of TeamBillionaire emails). 51. Trading volume in Pick-Ups stock increased over ten-fold from April 21 and April 24, 2017. 52. Between April 24, 2017 and May 18, 2017, Beck’s and Robinson’s 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 accounts sold about 45.4 million shares of Pick-Ups stock, for combined sales proceeds of $218,000. 2. Beck’s MK Automotive scalping scheme 53. MK Automotive, now known as Maison Luxe, was previously an automotive maintenance and repair company whose stock was trading under the ticker MKAU, in the range of $0.0105 to $0.0135 per share in June 2017. 54. Beck had purchased and sold MK Automotive stock since at least 2016, but he began purchasing MK Automotive stock again on or about May 26, 2017, in his own and Robinson’s accounts. 55. On or about June 27, 2017, Beck tweeted that a new stock pick was imminent, stating, “WHOS READY FOR MY BIGGEST #PENNYSTOCKS ALERT EVER? ON JULY 17TH, 2017 I WILL BE UNLEASHING AN ABSOLUTE MONSTER.” 56. Between July 17, 2017 and July 27, 2017, Beck tweeted recommendations to buy MK Automotive’s stock. (a) For example, on July 17, 2017, Beck tweeted: “$MKAU IS CURRENTLY TRADING $.017 ... WITHIN 60 DAYS EXPECT $1.00+... My LAST MEGA ALERT RAN 4,000% !!! $MKAU WILL BE MUCH MUCH BIGGER !!!!” (b) As another example, on July 18, 2017, Beck tweeted, “$MKAU IS GOING TO $1.00+ WEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEE LOAD THE BOAT !!!!!! CHOOOOOOOOOO CHOOOOOOOOOOO.” 57. In none of Beck’s tweets recommending that others buy MK Automotive’s stock did he disclose that he or his nominee were selling or planning to sell MK Automotive’s stock. 58. Beck’s statements were materially false and misleading, as he was at that time planning to sell, and was even selling, his holdings of MK Automotive’s stock. A reasonable investor would want to know, in assessing the quality of a 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 recommendation to buy a stock, whether the person making the recommendation was selling contrary to the recommendation. 59. Beck knew that his statements were materially false and misleading because he was aware of his own trading activity. 60. During Beck’s promotional campaign, MK Automotive’s stock price rose from $0.017 per share on July 16, 2017 (the trading day before Beck’s first recommendation tweet) to $0.024 per share on July 24, 2017. 61. Between July 17, 2017 and August 22, 2017, Beck’s and Robinson’s accounts sold about 13.1 million shares of MK Automotive’s stock, for combined sales proceeds of $254,000. 3. Beck’s Zann scalping scheme 62. Zann is a Nevada corporation purportedly in blockchain, information technology and transportation logistics, whose stock was trading under the ticker ZNNC around $0.009 to $0.039 per share in September 2017. 63. Beck began purchasing Zann stock on or about July 26, 2017, in his own and Robinson’s accounts. 64. On or about September 13, 2017, Beck tweeted that a stock pick was imminent, stating, “#TEAMBILLIONAIRE ANNOUNCEMENT: I WILL BE RELEASING MY BIGGEST #PENNYSTOCKS ALERT EVER ON SEPT. 26 TH .” 65. Beck paid two third parties to post favorable commentary about Zann on investor message boards on or about September 24-25, 2017. (a) For example, one such message stated, as to Zann, “This holding Co. has lots going for itself and with this share structure it's worth having a long term outlook.” 66. Between September 26-27, 2017, Beck made recommendations to purchase Zann’s stock. (a) For example, on September 26, 2017, Beck tweeted, “LOAD UP ALL THE $ZNNC U CAN!!!!!!!!!!!!!!!!!!!!!!!!!!!” and “$ZNNC IS BEIN LOADED 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BY ....... SMART MONEY.” 67. In none of Beck’s tweets, or the message board posts he procured recommending that others buy Zann’s stock, did he disclose that he or his nominee were selling or planning to sell Zann’s stock. 68. Beck’s statements were materially false and misleading, as he was at that time planning to sell, and was even selling, his holdings of Zann’s stock. A reasonable investor would want to know, in assessing the quality of a recommendation to buy a stock, whether the person making the recommendation was selling contrary to the recommendation. 69. Beck knew that his statements were materially false and misleading because he was aware of his own trading activity. 70. During Beck’s promotional campaign, Zann’s stock price rose from $0.039 per share on September 22, 2017 (the day before the message board posts began) to $0.069 per share on September 25, 2017 (the first trading day following the message board posts) on trading volume that was ten times higher than on September 22, 2017. 71. Between September 25, 2017 and September 26, 2017, Beck’s and Robinson’s accounts sold about 1.39 million shares of Zann’s stock, for combined sales proceeds of $82,000. 4. Beck’s Vidaroo scalping scheme 72. Vidaroo is a now-defunct video streaming and software distribution company, whose stock was trading under the ticker VIDA in the range of $0.0011 to $0.0038 per share in October 2017. 73. Beck had purchased and sold Vidaroo stock beginning by at least 2016, and he began purchasing Vidaroo stock on or about May 26, 2017, in his own and Robinson’s accounts. 74. On or about October 3, 2017, Beck tweeted that a stock pick was imminent, stating, “ON OCTOBER 31ST, IM ALERTING THE MEGA 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 #PENNYSTOCKS...‘CHANGE-UR_LIFE ALERT’ SIGN UP NOW 2 GET IN EARLY.” 75. Between October 30, 2017 and December 11, 2017, Beck tweeted recommendations to purchase Vidaroo’s stock. (a) For example, on October 30, 2017, Beck tweeted, “$VIDA IS CURRENTLY TRADING AT $.0045 & WILL CLOSE TOMORROW AT $.005+ ...ITS GUARANTEED 2 GO UP 10% A DAY (EZ PROFITS).” (b) As another example, on November 3, 2017, Beck tweeted, “$VIDA WILL GO UP EVERYDAY TILL CHRISTMAS !!! ITS GOING TO $.05+ ( CURRENT PRICE $.0053 ).” 76. In none of Beck’s tweets recommending that others buy Vidaroo stock did he disclose that he or his nominee were selling or planning to sell Vidaroo stock. 77. Beck’s statements were materially false and misleading, as he was at that time he planning to sell, and was even selling, his holdings of Vidaroo’s stock. A reasonable investor would want to know, in assessing the quality of a recommendation to buy a stock, whether the person making the recommendation was selling contrary to the recommendation. 78. Beck knew that his statements were materially false and misleading because he was aware of his own trading activity. 79. During Beck’s promotional campaign, Vidaroo’s stock price rose from $0.0038 per share on October 27, 2017 (the trading day before Beck tweeted his recommendation) to $0.0049 per share between on October 30, 2017 (the day he began to recommend purchasing Vidaroo). 80. Between October 30, 2017 and December 11, 2017, Beck’s and Robinson’s accounts sold about 17.2 million shares of Vidaroo’s stock, for combined sales proceeds of $110,000. 5. Beck’s CASG scalping scheme 81. CASG is a now-defunct aviation company whose stock was trading 14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 under the ticker CASG in the range of $.0018 to $0.0035 per share in April 2018. 82. Beck began purchasing CASG stock on or about January 2, 2018, in his own and Robinson’s accounts. 83. On or about April 20, 2018, Beck tweeted that a stock pick was imminent, stating, “ON MAY 1ST, I WILL BE ALERTING THE MOST PROFITABLE #PENNYSTOCK ALERT IN HISTORY!!!!!” 84. Beck paid two third parties to post favorable commentary about CASG on investor message boards between April 25, 2018 and May 1, 2018. (a) For example, on April 28, 2018, one such post stated, as to CASG, “It looks like something big is going on here. Check out the volume on Friday.” 85. Beck issued his stock alert recommending CASG on May 1, 2018, tweeting: “TURN UR $1,000 INVESTMENT INTO $20,000.00+ WITH $CASG THE #1 #PENNYSTOCK IN THE WORLD !!!” 86. In none of Beck’s tweets or the message board posts he procured recommending that others buy CASG stock did he disclose that he or his nominee were selling or planning to sell CASG stock. 87. Beck’s statements were materially false and misleading, as he was at that time selling his holdings of CASG’s stock. A reasonable investor would want to know, in assessing the quality of a recommendation to buy a stock, whether the person making the recommendation was selling contrary to the recommendation. 88. Beck knew that his statements were materially false and misleading because he was aware of his own trading activity. 89. CASG’s stock price rose from $0.0035 per share on April 24, 2018 (the day before the message board posts that Beck paid for first appeared) to $0.0048 per share on April 25, 2018. 90. On April 30, 2018 (the first trading day after Beck emailed TeamBillionaire members about his CASG stock recommendation) the stock price rose from a previous day’s closing price of $0.0082 to $0.0138 per share on about 15 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 322% higher trading volume. 91. Between April 26, 2018 and May 1, 2018, Beck’s and Robinson’s accounts sold about 8.5 million shares of CASG stock, for combined sales proceeds of $218,000. 6. Beck’s Marquie scalping scheme 92. Marquie is a radio station company whose stock was trading under the ticker TMGI in the range of $0.041 to $0.096 per share in November 2018. 93. Beck began purchasing Marquie stock on or about November 27, 2018, in Robinson’s accounts. 94. On or about November 5, 2018, Beck tweeted that a stock pick was imminent, stating, “MY NEXT MEGA ALERT IS DECEMBER 18TH.” 95. Beck then emailed his TeamBillionaire group in advance of issuing his stock alert for Marquie, to encourage them to buy ahead of his public alert. 96. For example, on or about December 15, 2018, Beck emailed his TeamBillionare group: The MEGA December 18th alert will be released to the masses at 9:00 am est on the 18th of DECEMBER. There will be a GLOBAL release to every TRADER on the planet via all platforms on SOCIAL MEDIA . When I tweet that I will be releasing the BIGGEST PROFIT RUNNER in pennystock history, I'm not joking, I'm dead serious....December 18th will be HISTORIC and many traders will either quit their 9-5 jobs, buy a business, buy property all around the world, RETIRE, become Philanthropists, take a 5-STAR CRUISE around the world, buy a minor league baseball team etc etc.... I will be getting you in on the 17TH ( You will be able to 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 buy a day early before I alert the world on the 18th) . You will be receiving the alert Sunday morning the 16th so you can figure out how much stock you want to buy so you can ACHIEVE your FINANCIAL DREAMS........” 97. On December 18, 2018, Beck tweeted his recommendations to purchase Marquie’s stock, stating: “THIS YEARS MEGA MAGICAL CHRISTMAS ALERT IS GOING TO BE..........................$MYLI !!!!!!!BUY EVERYTHING YOU CAN UNDER $1.00+ BEFORE THE HERBALIFE MERGER NEWS DROPS!!! $MYLI IS GOING TO $10+ ( CURRENT PRICE $.44 ). TURN UR $5,000 INVESTMENT INTO $100,000+.” 98. In none of Beck’s tweets, emails or message board posts recommending that others buy Marquie stock did he disclose that he or his nominee were selling or planning to sell Marquie stock. 99. Beck’s statements were materially false and misleading, as he had already begun selling his holdings of Marquie’s stock on December 17, 2018. A reasonable investor would want to know, in assessing the quality of a recommendation to buy a stock, whether the person making the recommendation was selling contrary to the recommendation. 100. Beck knew that his statements about Marquie were materially false and misleading, because he was aware of his own trading activity. 101. Marquie’s stock price rose from $0.29 per share on December 14, 2018 (the trading day before Beck’s first TeamBillionaire email) to $0.40 per share on December 17, 2018 (the first trading day following Beck’s first Team Billionaire email). 102. Between December 17, 2018 and December 20, 2018, Robinson’s accounts sold about 343,000 shares of Marquie’s stock, for sales proceeds of $41,000. 7. Beck’s Peoplesway scalping scheme 103. Peoplesway is a now-defunct wellness company whose stock was 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 trading under the ticker PLWY in the range of $0.0027 to $0.0060 per share in February 2019. 104. Beck began purchasing Peoplesway stock on or about September 5, 2018, in Robinson’s accounts. 105. On or about February 28, 2019, Beck tweeted that a stock pick was imminent, stating, “ON MARCH 12TH, I WILL BE ALERTING THE ‘MEGA GODZILLA ALERT!!! THIS WILL BE THE BIGGEST RUNNER IN #PENNYSTOCKS HISTORY !!! EXPECT TO TURN UR $10,000 INVESTMENT INTO $150,000+.” 106. On or about March 11, 2019, Beck emailed his TeamBillionaire group to give them a preview that he would be recommending PLWY stock, stating: Guess what FAM? I'm getting you in EARLY March the 11th so you can avoid the STRESS of buying a stock that will keep going up and up and up on March the 12th. I dont want you to chase the stock to $.25+ on Tuesday March 12th. I want to get you in under $.05 Tomorrow so you can lock in your profits and enjoy the EASIEST profits you have ever made in your life... I'm so excited for you, me and the #MONEYGANG because we are all GOING to EAT FIRST and PROFIT FIRST before the major announcement to the WORLD on March the 12th. Drum roll please.........The BIGGEST RUNNER IN PENNY STOCK HISTORY IS GOING TO BE .....PLWY!” 107. Peoplesway’s stock price rose from $0.011 to $0.027 per share from March 8, 2019 (the trading date before Beck’s first Team Billionaire email) and March 11, 2019 (the first trading date after Beck’s Team Billionaire email) on trading 18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 volume about 1,760% higher trading volume. 108. On March 11, 2019, Robinson’s accounts sold about 3.56 million shares of Peoplesway stock, for sales proceeds of $78,000. 109. Between March 12-14, 2019, Beck tweeted his recommendations to purchase Peoplesway stock. 110. For example, on or about March 12, 2019, Beck tweeted: “IM GOING TO PERSONALLY PUNISH EVERY SINGLE SHORT SELLER ON $PLWY !!!! I WILL FORCE THOSE B*TCHES TO COVER OVER $.10 !!! SH*T JUST GOT REAL !!!!” 111. As another example, on or about March 14, 2019, Beck tweeted: “IM LOADING $PLWY ON THE BIDS .....ITS GOING BACK UP..........I BUY ‘PANIC’............NO NEED TO WORRY WHEN #BMM IS ON BIDS.” 112. In none of Beck’s tweets, emails or message board posts recommending that others buy Peoplesway stock did he disclose that he or his nominee were selling or planning to sell Peoplesway stock. 113. Beck’s statements were materially false and misleading, given that as of March 11, 2019, he had sold his entire position of PLWY and was not buying the stock. A reasonable investor would want to know, in assessing the quality of a recommendation to buy a stock, whether the person making the recommendation was selling contrary to the recommendation. 114. Beck knew that his statements were materially false and misleading because he was aware of his own trading activity. 8. Beck’s UCSO scalping scheme 115. Pick-Ups is a now-defunct company purportedly in the business of digital services, blockchain, palm oil and cannabis, whose stock was trading under the ticker UCSO in the range of $0.0055 to $0.0099 per share in March 2019. 116. Beck began purchasing UCSO’s stock on or about April 9, 2019, in Robinson’s accounts. 19 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 117. On or about March 31, 2019, Beck tweeted that a stock pick was imminent, stating, “ARE U READY FOR THE BIGGEST #PENNYSTOCKS ALERT IN HISTORY? GET READY TO TURN UR $5,000 INVESTMENT INTO $100,000+ ON MAY 1ST!” 118. On or about April 29, 2019, Beck emailed his TeamBillionaire group to preview that UCSO would be the stock pick, stating: I will be getting you...... there first with the release of the MEGA May 1st alert ! ! Here’s the good news........... I am not going to make you wait till May 1st to get the GAME- CHANGING SUPER MEGA ALERT. I'm giving you the alert April 29th which is 48 hours before the WORLD ( general public) receives it. 119. On or about May 1, 2019, Beck tweeted his alert recommending the purchase of UCSO, writing: #MONEYGANG, NO NEED FOR $UCSO TO RUN CRAZY TO $.10 TODAY...LOAD UP EVERYTHING U CAN UNDER $.06!!! TOMORROW WE LOAD EVERYTHING UNDER $.07...SLOW & STEADY ALWAYS WINS THE RACE. BUYING $UCSO WILL BE THE BEST FINANCIAL DECISION U HAVE EVER MADE IN UR LIFE !!! 120. In none of Beck’s tweets or emails recommending that others buy UCSO’s stock did he disclose that he or his nominee were selling or planning to sell UCSO’s stock. 121. Beck’s statements were materially false and misleading, as he was at that time selling his holdings of UCSO’s stock. A reasonable investor would want to know, in assessing the quality of a recommendation to buy a stock, whether the person making the recommendation was selling contrary to the recommendation. 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 122. Beck knew that his statements were materially false and misleading because he was aware of his own trading activity. 123. During Beck’s promotional campaign, UCSO’s stock price rose from $0.065 per share on April 26, 2019 (the trading day before Beck’s Team Billionaire email) to an intraday high of $0.08 per share on April 29, 2019 (the day of Beck’s Team Billionaire email) on about 232% increased trading volume. 124. Between April 29, 2019 and May 2, 2019, Robinson’s accounts sold about 228,000 shares of UCSO stock, for sales proceeds of $15,000. C. Beck’s Scienter and/or Negligence 125. Beck intentionally, knowingly and/or recklessly carried out his scalping scheme in the Issuers’ stocks. 126. Beck knew that he did not disclose to his Twitter or TeamBillionaire followers his intentions to sell, nor his actual sales, of the Issuers’ stock, when recommending they purchase the same stocks. 127. Beck conducted his trades in part through his nominee, Robinson, concealing the amount of his own trading. 128. Beck covertly paid third parties to post favorable commentary about more than one of the Issuers, concealing his role in promoting the Issuers’ stock. 129. Beck’s scheme showed a repeated pattern of conduct occurring over a period of years as to the eight Issuers. 130. In the alternative, Beck was negligent in recommending the Issuers’ stocks without revealing that he was selling, or intended to sell, the Issuers’ stocks. 131. Beck enjoyed illicit profits from his scheme. In total, between February 2017 and May 2019, Beck, through his and his nominee’s account, earned $870,000 in sales proceeds: 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 No. Issuer Sales Proceeds 1. Pick-Ups $218,000 2. MK Automotive $254,000 3. Zann $82,000 4. Vidaroo $110,000 5. CASG $72,000 6. Marquie $41,000 7. Peoplesway $78,000 8. UCSO $15,000 TOTAL $870,000 132. Of the sales proceeds, approximately $358,000 were from trades in Beck’s account and approximately $512,000 were from trades in Robinson’s accounts. D. Beck Concealed Material Information About His Trading 133. It would have been important to a reasonable investor to know that Beck was selling, or intended to sell, the Issuers’ stocks, at the time that he was recommending others purchase the stocks. 134. That Beck was selling the Issuers’ stocks, or intended to sell their stock, and profit from a run-up in the stocks’ price generated by his own recommendations, would have been important to a reasonable investor in evaluating Beck’s recommendation that the investor purchase the Issuers’ stocks. FIRST CLAIM FOR RELIEF Fraud in the Connection with the Purchase and Sale of Securities Violations of Section 10(b) of the Exchange Act and Rule 10b-5 (against Defendant Beck) 135. The SEC realleges and incorporates by reference paragraphs 1 through 134 above. 136. Defendant Beck intentionally and/or recklessly engaged in a scheme to 22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 scalp the Issuers’ stock. Through his promotional campaign, consisting of his tweeted stock alerts, emails to his TeamBillionaire group, and message board posts he procured in others’ names, Beck manipulated the Issuers’ stock price so he could sell at inflated prices. Beck failed to disclose that he was simultaneously selling or intended to sell the very stock he recommended that others purchase. Beck’s deceitful pattern persisted over the eight Issuers’ stocks, over a period of years, garnering him over $900,000 in illicit profits in his account and that of his nominee. 137. By engaging in the conduct described above, Defendant Beck, acting with scienter, directly or indirectly, in connection with the purchase or sale of a security, 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 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 other persons. 138. By engaging in the conduct described above, Defendant Beck violated, and unless restrained and enjoined will continue to violate, Section 10(b) of the Exchange Act, 15 U.S.C. § 78j(b), and Rules 10b-5(a), 10b-5(b), and 10b-5(c) thereunder, 17 C.F.R. §§ 240.10b-5(a), 240.10b-5(b) & 240.10b-5(c). SECOND CLAIM FOR RELIEF Fraud in the Offer or Sale of Securities Violations of Section 17(a) of the Securities Act (against Defendant Beck) 139. The SEC realleges and incorporates by reference paragraphs 1 through 134 above. 140. Defendant Beck Defendant Beck intentionally, recklessly, and/or negligently engaged in a scheme to scalp the Issuers’ stock. Through his promotional 23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 campaign, consisting of his tweeted stock alerts, emails to his TeamBillionaire group, and message board posts he procured in others’ names, Beck manipulated the Issuers’ stock price so he could sell at inflated prices. Beck failed to disclose that he was simultaneously selling or intended to sell the very stock he recommended that others purchase. Beck’s deceitful pattern persisted over the eight Issuers’ stocks, over a period of years. By means of his materially false and misleading statements, Beck obtained over $900,000 in illicit profits in his account and that of his nominee. 141. By engaging in the conduct described above, Defendant Beck has, directly or indirectly, in the offer or sale of securities, and by the use of means or instruments of transportation or communication in interstate commerce or by use of the mails directly or indirectly: (a) employed devices, schemes, or artifices to defraud; (b) obtained money or property by means of untrue statements of a material fact or by omitting to state a material fact necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading; and (c) engaged in transactions, practices, or courses of business which operated or would operate as a fraud or deceit upon the purchaser. 142. Defendant Beck, with scienter, employed devices, schemes and artifices to defraud; with scienter or negligence, obtained money or property by means of untrue statements of a material fact or by omitting to state a material fact necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading; and, with scienter or negligence, engaged in transactions, practices, or courses of business which operated or would operate as a fraud or deceit upon the purchaser. 143. By engaging in the conduct described above, Defendant Beck has violated, and unless restrained and enjoined will continue to violate, Sections 17(a)(1), 17(a)(2), and 17(a)(3) of the Securities Act, 15 U.S.C. §§ 77q(a)(1), 77q(a)(2), & 77q(a)(3). 24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PRAYER FOR RELIEF WHEREFORE, the SEC respectfully requests that the Court: I. Issue findings of fact and conclusions of law that Defendant committed the alleged violations. II. Issue judgment, in a form consistent with Rule 65(d) of the Federal Rules of Civil Procedure, permanently enjoining Defendant Beck and his officers, agents, servants, employees and attorneys, and those persons in active concert or participation with him, who receive actual notice of the judgment by personal service or otherwise, and each of them, from violating 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] and Securities Act Section 17(a) [15 U.S.C. §77q(a)]. III. Order Defendant Beck and Relief Defendant Robinson to disgorge all funds received from their illegal conduct, together with prejudgment interest thereon, pursuant to Securities Exchange Act of 1934, Sections 21(d)(5) and 21(d)(7) [15 U.S.C. §§ 78u(d)(5) and 78u(d)(7)]. IV. Order Defendant Beck to pay civil penalties under Section 21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)] and Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)]. V. Enter an order against Defendant Beck, pursuant to Section 20(g) of the Securities Act, 15 U.S.C. § 77t(g), prohibiting him from participating in an offering of penny stock. VI. Retain jurisdiction of this action in accordance with the principles of equity and 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 the Federal Rules of Civil Procedure in order to implement and carry out the terms of all orders and decrees that may be entered, or to entertain any suitable application or motion for additional relief within the jurisdiction of this Court. VII. Grant such other and further relief as this Court may determine to be just and necessary. Dated: February 7, 2022 /s/Amy Jane Longo Amy Jane Longo Roberto Tercero Attorneys for Plaintiff Securities and Exchange Commission
1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 AMY J. LONGO (Cal. Bar No. 198304) Email: [email protected] ROBERTO TERCERO (Cal. Bar No. 143760) Email: [email protected] Attorneys for Plaintiff Securities and Exchange Commission Michele Wein Layne, Regional Director Katharine Zoladz, Associate Regional Director 444 S. Flower Street, Suite 900 Los Angeles, California 90071 Telephone: (323) 965-3998 Facsimile: (213) 443-1904 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA SECURITIES AND EXCHANGE COMMISSION, Plaintiff, vs. MICHAEL M. BECK, Defendant, AND HELEN P. ROBINSON, Relief Defendant. Case No. 2:22-cv-00812 COMPLAINT Plaintiff Securities and Exchange Commission (“SEC”) alleges: JURISDICTION AND VENUE 1. The Court has jurisdiction over this action pursuant to Sections 20(b), 20(d)(1) and 22(a) of the Securities Act of 1933 (“Securities Act”), 15 U.S.C. §§ 77t(b), 77t(d)(1) & 77v(a), and Sections 21(d)(1), 21(d)(3)(A), 21(e) and 27(a) of Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 1 of 25 Page ID #:1 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 the Securities Exchange Act of 1934 (“Exchange Act”), 15 U.S.C. §§ 78u(d)(1), 78u(d)(3)(A), 78u(e) & 78aa(a). 2. Defendants have, 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. 3. Venue is proper in this district pursuant to Section 22(a) of the Securities Act, 15 U.S.C. § 77v(a), Section 27(a) of the Exchange Act, 15 U.S.C. § 78aa(a), because certain of the transactions, acts, practices and courses of conduct constituting violations of the federal securities laws occurred within this district. SUMMARY 4. Between February 2017 and May 2019, Defendant Michael M. Beck, aka @BigMoneyMike6 (“Beck”), used his Twitter platform, where he had as many as 3 million followers, to promote and encourage people to buy eight microcap stocks— all without disclosing that he planned to sell, or in some instances was personally selling, his own holdings of the same stocks (a practice known as “scalping”). 5. Beck’s scalping scheme involved the following pattern. First, Beck purchased a block of shares of a penny stock, directly and/or through his nominee (his mother), Relief Defendant Helen P. Robinson (“Robinson”). Next, he tweeted to his millions of followers and the public that he would soon be issuing a new stock recommendation, or an “alert.” In many instances, Beck then notified members of his email group, TeamBillionaire, to encourage them to buy the stock ahead of his upcoming recommendation to the public. At times, he also paid third parties to post favorable commentary about the stock on investor message boards, ahead of his recommendation. 6. Having purchased the stock, Beck then tweeted out recommendations to buy the stock to his millions of Twitter followers and the public. Throughout his promotional campaigns for the stocks, he failed to disclose his plans to sell, or his Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 2 of 25 Page ID #:2 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ongoing selling of, the very stocks he was promoting. 7. As the issuers’ stock price and trading volume increased, Beck sold into the artificially inflated market, earning pecuniary gains totaling about $870,000. 8. Through his conduct, defendant Beck violated the antifraud provisions of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder, 15 U.S.C. § 78j(b) and 17 C.F.R. § 240.10b-5(a)-(c), as well as the antifraud provisions of Section 17(a) of the Securities Act, 15 U.S.C. § 77q(a)(1)-(3). 9. The SEC seeks permanent injunctions against future violations of Exchange Act Section 10(b) and Rule 10b-5 thereunder and Securities Act Section 17(a); an order requiring defendant Beck and relief defendant Robinson to disgorge their ill-gotten gains with prejudgment interest; civil penalties against defendant Beck; and a penny stock bar against defendant Beck. THE DEFENDANT AND THE RELIEF DEFENDANT 10. Michael M. Beck (“Beck”) resides in San Pedro, California. During the relevant time period, Beck used the Twitter handle “@BigMoneyMike6.” He also founded the email group TeamBillionaire. 11. Beck had at least one brokerage account at one financial institution in which he traded stock in 2017-2019. 12. During 2017-2019, Beck used the email addresses [email protected], [email protected], [email protected], and [email protected]. 13. Helen P. Robinson (“Robinson”) resides in San Pedro, California. She is Beck’s mother. 14. Robinson had at least five brokerage accounts at five financial institutions in which she and/or Beck traded stock in 2017-2019. 15. Robinson allowed Beck to use her account to trade stocks. RELATED ENTITIES 16. Pick-Ups Plus, Inc. (“Pick-Ups”) is a defunct Delaware corporation, Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 3 of 25 Page ID #:3 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 previously located in Newport Beach, California, which sold and installed accessories for sports utility vehicles. On June 18, 2018, the company filed a Form 15-12G with the SEC to terminate the registration of its common stock under Section 12(g) of the Exchange Act. Its common stock was quoted publicly under the ticker symbol “PUPS” on OTC Link (previously “Pink Sheets”), whose parent company is OTC Markets Group, Inc. (“OTC Markets Group”). PUPS is now quoted on OTC Markets Group’s Expert Market, where quotations are unsolicited and distribution of the quotations is limited to broker-dealers and other market professionals. 17. MK Automotive, Inc. is a Nevada corporation which engaged in retail and commercial automotive diagnostic, maintenance, and repair services. It was quoted on OTC Link under the ticker symbol “MKAU” until July 2017, when it was renamed Clikia Corp. and quoted under the ticker symbol “CLKA.” From December 15, 2017 to September 10, 2020, the company became qualified on six occasions to conduct a Tier 1 offering in reliance on Regulation A. In May 2020, the company was renamed Maison Luxe, Inc. and since April 2021 has been quoted on OTC Link under the ticker symbol “MASN.” 18. Zann Corp. (“Zann”) is a Nevada corporation located in Las Vegas which purports to be in the early stages of numerous business lines including block chain, information technology, and transportation logistics. Zann is a non-reporting company, and its common stock was quoted on OTC Link under the ticker symbol “ZNNC” but is now quoted on the Expert Market. 19. Vidaroo Corp. (“Vidaroo”) is a defunct Nevada corporation, which had its principal place of business in Orlando, Florida. It claimed to be in the video streaming and software distribution businesses, but it has no operations. Vidaroo’s common stock is registered with the SEC under Section 12(g) of the Exchange Act, but it has made no filings since March 17, 2014. Its common stock was quoted on OTC Link under the ticker symbol “VIDA” but is now quoted on the Expert Market. 20. Canadian Aerospace Group International, Inc. (“CASG”) is a Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 4 of 25 Page ID #:4 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 defunct Florida corporation, which had its principal place of business in Herriman, Utah and was a developer of aviation products and services. On September 23, 2016, the Florida Secretary of State put the company on inactive status for failing to make required filings. It is a non-reporting company, and its common stock was quoted under the ticker symbol “CASG” on OTC Link. On May 10, 2019, the SEC suspended trading in its securities for ten business days because the company was no longer in operation and had not posted any information to OTC Markets Group or filed any information with the Commission. Exchange Act Rel. No. 85835 (May 10, 2019). The stock is now quoted on the Expert Market. 21. Music for Your Life (“MYLY”) is a Florida corporation with its principal place of business in Las Vegas, Nevada, which operates a network of radio stations. It is a voluntary filer with the SEC, but filed a Form 12b-25 on August 31, 2021, stating that it was unable to file its Form 10-K. Its stock was quoted on OTC Link under the ticker symbol “TMGI,” but it is now quoted on the Expert Market. It was formerly known as Music for Your Life Inc. (OTC Link “MYLY”) until August 16, 2018. 22. Peoplesway.com, Inc. (“Peoplesway”) is a defunct Nevada corporation formerly located in North Carolina, that was a multi-level marketer of wellness products. Its corporate status was revoked in 2014. On October 20, 2005, the company filed a Form 15-12G with the SEC to terminate the registration of its common stock under Section 12(g) of the Exchange Act. Its common stock was quoted on OTC Link under the ticker symbol “PLWY” but is now quoted on the Expert Market. 23. United Consortium Ltd. (“UCSO”) is a defunct Nevada corporation formerly located in Tampa, Florida, which claimed to have four business lines: legal digital services; blockchain; palm oil; and cannabinoids. Its corporate status was revoked in 2019. It is a non-reporting company whose common stock was quoted on OTC Link under the ticker symbol “UCSO” but is now quoted on the Expert Market. Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 5 of 25 Page ID #:5 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 24. The eight companies whose stock Beck scalped (Pick-Ups, MK Automotive, Zann, Vidaroo, CASG, Marquie, Peoplesway, and UCSO) are collectively referred to as the “Issuers.” 25. The Issuers’ securities are commonly known as “microcap stocks” or “penny stocks,” which typically trade over OTC Link for pennies or even fractions of a penny per share. THE ALLEGATIONS A. Summary of Beck’s Scalping Scheme 26. As alleged below, Beck engaged in a fraudulent scheme to promote and manipulate penny stocks, using his Twitter account with the handle @BigMoneyMike6, by encouraging investors to buy the Issuers’ securities while at the same time — contrary to his advice to his millions of Twitter followers, as well as to the viewing public who read his Twitter posts — selling his own holdings of those securities into the inflated price and liquidity that his tweets helped create. 27. Beck’s Twitter handle during 2017 to 2019 was @BigMoneyMike6. 28. @BigMoneyMike6 had as many as many as 3 million Twitter followers between 2017 and 2019. 29. Beck was also the founder of an email group, TeamBillionaire. 30. Beck used his Twitter handle to invite his followers to join TeamBillionaire. (a) For example, on or about September 13, 2017, Beck tweeted, “GOT #PENNYSTOCKS? WANNA TURN A $5,000 INVESTMENT INTO $50,000+? JOIN #TEAMBILLIONAIRE ASAP.”1 (b) As another example, on or about October 3, 2017, Beck tweeted, “JOIN #TEAMBILLONAIRE NOW !!!!!!! CHANGE UR FINANCIAL LIFE 1 Beck’s emails and tweets, which often contain typographical and grammatical errors, are quoted verbatim in this complaint. Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 6 of 25 Page ID #:6 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 FOREVER.” 31. In emails to members of his group, Beck described TeamBillionaire as a “NETWORK of the TRADER for the TRADER,” describing TeamBillionaire’s mission as “to make EVERY SINGLE TRADER in our NETWORK a minimum of 200% in profits every month for the rest of their TRADING LIVES from #TEAMBILLIONAIRE ALERTS/PICKS!!!!” 32. According to Beck, his TeamBillionaire email group had more than 740,000 members in 2017. 33. Between 2017 and 2019, Beck’s scalping scheme followed a repeated pattern. 34. First, Beck purchased shares of a microcap issuer directly and/or in Robinson’s accounts in advance of his promotional campaign. 35. Next, Beck tweeted to his followers and the public that a stock pick alert would be forthcoming. 36. Then, a few days before Beck tweeted his stock pick alert, he typically emailed his TeamBillionaire followers, identifying the stock recommendation he planned to promote through Twitter, enabling TeamBillionaire to purchase the stock prior to his Twitter promotions. This preview of the stock recommendation generally increased the stock’s trading volume and price, making the stock look more attractive to potential investors when Beck issued his public recommendation. 37. In some instances, Beck paid two third parties to post favorable messages about the stock on Investorshub.com. Like the previews to TeamBillionaire members, the posts generally increased the stock’s trading volume and price, making the stock look more attractive to potential investors when Beck issued his public recommendation. 38. Beck then tweeted his stock pick alert, and frequently emailed it to Team Billionaire members, to buy the stock, forecasting high growth and returns. Beck often repeated his stock pick in numerous subsequent tweets and emails. Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 7 of 25 Page ID #:7 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 39. As the stock price rose—whether following a preview email to TeamBillionaire, message board posts, or the actual stock pick alert—Beck simultaneously sold the Issuer’s stock in his accounts and/or Robinson’s. 40. None of Beck’s recommendations disclosed that Beck was either planning to sell or actually selling the stock while he was recommending that others buy it. Nor did Beck disclose that he had in some cases previewed his alert to his TeamBillionaire group, or secretly paid others to post favorably about the Issuers on investor message boards. 41. With respect to each of the Issuers, as detailed below, Beck profited by selling his stock while the market price was artificially inflated during his promotional campaign. B. Beck’s Scheme to Scalp the Issuers’ Stocks 1. Beck’s Pick-Ups scalping scheme 42. Pick-Ups is a now-defunct auto accessory company whose stock was trading under the ticker PUPS at around $0.0035 per share in April 2017. 43. Beck began purchasing Pick-Ups stock on or about February 7, 2017, in his own and Robinson’s accounts, when the prevailing market price of Pick-Ups stock was $0.0004 per share. He continued to purchase shares within the range of $0.0004 to $0.0039 per share with the vast majority at prices at $0.0018 per share or lower. 44. On or about April 19, 2017, Beck tweeted that a stock pick was imminent, stating among other things that, “THE APRIL 25TH MEGA ALERT IS LESS THAN A WEEK AWAY” and that, “NEXT TUESDAY COULD NOT ONLY BE MY BIGGEST ALERT EVER BUT COULD BE.. THEE BIGGEST ALERT EVER.” 45. In emails between April 23-24, 2017, Beck emailed his TeamBillionaire followers recommending they buy Pick-Ups stock in advance of his planned alert. (a) For example, on or about April 23, 2017, Beck wrote to one Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 8 of 25 Page ID #:8 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 follower: “The stock I’m going to get you into is currently trading at $.005 and will be trading $.05+ by Tuesday the 25TH . . . The stock that is going to make you a ‘minimum’ of 500% on your investment is…………….. $PUPS.” 46. Beginning on April 25, 2017 through May 9, 2017, Beck tweeted recommendations to purchase Pick-Ups stock. (a) For example, on or about April 25, 2017, Beck tweeted, “I'VE BOUGHT 27,000,000 SHARES OF $PUPS TODAY! IM STILL LOADING.. LETS SQUEEZE THE SHORTERS !!!” (b) As another example, on or about May 1, 2017, Beck tweeted, “$PUPS WILL BE GREEN EVERYDAY TILL CHRISTMAS !!!!!! $PUPS WILL BE AMERICAS #1 STOCK !!!” 47. In none of Beck’s tweets or emails recommending that others buy Pick- Ups stock did he disclose that he or his nominee were selling or planning to sell Pick- Ups stock. 48. Beck’s statements were materially false and misleading, as he was at that time planning to sell, and was already selling, his holdings of Pick-Ups’ stock. A reasonable investor would want to know, in assessing the quality of a recommendation to buy a stock, whether the person making the recommendation was selling contrary to the recommendation. 49. Beck knew that his statements were materially false and misleading because he was aware of his own trading activity. 50. During Beck’s promotional campaign, Pick-Ups’ stock price rose from $0.0050 to $0.0085 per share, between April 21, 2017 (the last trading day before the first TeamBillionaire email) and April 24, 2017 (the first day of TeamBillionaire emails). 51. Trading volume in Pick-Ups stock increased over ten-fold from April 21 and April 24, 2017. 52. Between April 24, 2017 and May 18, 2017, Beck’s and Robinson’s Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 9 of 25 Page ID #:9 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 accounts sold about 45.4 million shares of Pick-Ups stock, for combined sales proceeds of $218,000. 2. Beck’s MK Automotive scalping scheme 53. MK Automotive, now known as Maison Luxe, was previously an automotive maintenance and repair company whose stock was trading under the ticker MKAU, in the range of $0.0105 to $0.0135 per share in June 2017. 54. Beck had purchased and sold MK Automotive stock since at least 2016, but he began purchasing MK Automotive stock again on or about May 26, 2017, in his own and Robinson’s accounts. 55. On or about June 27, 2017, Beck tweeted that a new stock pick was imminent, stating, “WHOS READY FOR MY BIGGEST #PENNYSTOCKS ALERT EVER? ON JULY 17TH, 2017 I WILL BE UNLEASHING AN ABSOLUTE MONSTER.” 56. Between July 17, 2017 and July 27, 2017, Beck tweeted recommendations to buy MK Automotive’s stock. (a) For example, on July 17, 2017, Beck tweeted: “$MKAU IS CURRENTLY TRADING $.017 … WITHIN 60 DAYS EXPECT $1.00+... My LAST MEGA ALERT RAN 4,000% !!! $MKAU WILL BE MUCH MUCH BIGGER !!!!” (b) As another example, on July 18, 2017, Beck tweeted, “$MKAU IS GOING TO $1.00+ WEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEE LOAD THE BOAT !!!!!! CHOOOOOOOOOO CHOOOOOOOOOOO.” 57. In none of Beck’s tweets recommending that others buy MK Automotive’s stock did he disclose that he or his nominee were selling or planning to sell MK Automotive’s stock. 58. Beck’s statements were materially false and misleading, as he was at that time planning to sell, and was even selling, his holdings of MK Automotive’s stock. A reasonable investor would want to know, in assessing the quality of a Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 10 of 25 Page ID #:10 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 recommendation to buy a stock, whether the person making the recommendation was selling contrary to the recommendation. 59. Beck knew that his statements were materially false and misleading because he was aware of his own trading activity. 60. During Beck’s promotional campaign, MK Automotive’s stock price rose from $0.017 per share on July 16, 2017 (the trading day before Beck’s first recommendation tweet) to $0.024 per share on July 24, 2017. 61. Between July 17, 2017 and August 22, 2017, Beck’s and Robinson’s accounts sold about 13.1 million shares of MK Automotive’s stock, for combined sales proceeds of $254,000. 3. Beck’s Zann scalping scheme 62. Zann is a Nevada corporation purportedly in blockchain, information technology and transportation logistics, whose stock was trading under the ticker ZNNC around $0.009 to $0.039 per share in September 2017. 63. Beck began purchasing Zann stock on or about July 26, 2017, in his own and Robinson’s accounts. 64. On or about September 13, 2017, Beck tweeted that a stock pick was imminent, stating, “#TEAMBILLIONAIRE ANNOUNCEMENT: I WILL BE RELEASING MY BIGGEST #PENNYSTOCKS ALERT EVER ON SEPT. 26TH.” 65. Beck paid two third parties to post favorable commentary about Zann on investor message boards on or about September 24-25, 2017. (a) For example, one such message stated, as to Zann, “This holding Co. has lots going for itself and with this share structure it's worth having a long term outlook.” 66. Between September 26-27, 2017, Beck made recommendations to purchase Zann’s stock. (a) For example, on September 26, 2017, Beck tweeted, “LOAD UP ALL THE $ZNNC U CAN!!!!!!!!!!!!!!!!!!!!!!!!!!!” and “$ZNNC IS BEIN LOADED Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 11 of 25 Page ID #:11 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BY ....... SMART MONEY.” 67. In none of Beck’s tweets, or the message board posts he procured recommending that others buy Zann’s stock, did he disclose that he or his nominee were selling or planning to sell Zann’s stock. 68. Beck’s statements were materially false and misleading, as he was at that time planning to sell, and was even selling, his holdings of Zann’s stock. A reasonable investor would want to know, in assessing the quality of a recommendation to buy a stock, whether the person making the recommendation was selling contrary to the recommendation. 69. Beck knew that his statements were materially false and misleading because he was aware of his own trading activity. 70. During Beck’s promotional campaign, Zann’s stock price rose from $0.039 per share on September 22, 2017 (the day before the message board posts began) to $0.069 per share on September 25, 2017 (the first trading day following the message board posts) on trading volume that was ten times higher than on September 22, 2017. 71. Between September 25, 2017 and September 26, 2017, Beck’s and Robinson’s accounts sold about 1.39 million shares of Zann’s stock, for combined sales proceeds of $82,000. 4. Beck’s Vidaroo scalping scheme 72. Vidaroo is a now-defunct video streaming and software distribution company, whose stock was trading under the ticker VIDA in the range of $0.0011 to $0.0038 per share in October 2017. 73. Beck had purchased and sold Vidaroo stock beginning by at least 2016, and he began purchasing Vidaroo stock on or about May 26, 2017, in his own and Robinson’s accounts. 74. On or about October 3, 2017, Beck tweeted that a stock pick was imminent, stating, “ON OCTOBER 31ST, IM ALERTING THE MEGA Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 12 of 25 Page ID #:12 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 #PENNYSTOCKS...‘CHANGE-UR_LIFE ALERT’ SIGN UP NOW 2 GET IN EARLY.” 75. Between October 30, 2017 and December 11, 2017, Beck tweeted recommendations to purchase Vidaroo’s stock. (a) For example, on October 30, 2017, Beck tweeted, “$VIDA IS CURRENTLY TRADING AT $.0045 & WILL CLOSE TOMORROW AT $.005+ …ITS GUARANTEED 2 GO UP 10% A DAY (EZ PROFITS).” (b) As another example, on November 3, 2017, Beck tweeted, “$VIDA WILL GO UP EVERYDAY TILL CHRISTMAS !!! ITS GOING TO $.05+ ( CURRENT PRICE $.0053 ).” 76. In none of Beck’s tweets recommending that others buy Vidaroo stock did he disclose that he or his nominee were selling or planning to sell Vidaroo stock. 77. Beck’s statements were materially false and misleading, as he was at that time he planning to sell, and was even selling, his holdings of Vidaroo’s stock. A reasonable investor would want to know, in assessing the quality of a recommendation to buy a stock, whether the person making the recommendation was selling contrary to the recommendation. 78. Beck knew that his statements were materially false and misleading because he was aware of his own trading activity. 79. During Beck’s promotional campaign, Vidaroo’s stock price rose from $0.0038 per share on October 27, 2017 (the trading day before Beck tweeted his recommendation) to $0.0049 per share between on October 30, 2017 (the day he began to recommend purchasing Vidaroo). 80. Between October 30, 2017 and December 11, 2017, Beck’s and Robinson’s accounts sold about 17.2 million shares of Vidaroo’s stock, for combined sales proceeds of $110,000. 5. Beck’s CASG scalping scheme 81. CASG is a now-defunct aviation company whose stock was trading Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 13 of 25 Page ID #:13 14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 under the ticker CASG in the range of $.0018 to $0.0035 per share in April 2018. 82. Beck began purchasing CASG stock on or about January 2, 2018, in his own and Robinson’s accounts. 83. On or about April 20, 2018, Beck tweeted that a stock pick was imminent, stating, “ON MAY 1ST, I WILL BE ALERTING THE MOST PROFITABLE #PENNYSTOCK ALERT IN HISTORY!!!!!” 84. Beck paid two third parties to post favorable commentary about CASG on investor message boards between April 25, 2018 and May 1, 2018. (a) For example, on April 28, 2018, one such post stated, as to CASG, “It looks like something big is going on here. Check out the volume on Friday.” 85. Beck issued his stock alert recommending CASG on May 1, 2018, tweeting: “TURN UR $1,000 INVESTMENT INTO $20,000.00+ WITH $CASG THE #1 #PENNYSTOCK IN THE WORLD !!!” 86. In none of Beck’s tweets or the message board posts he procured recommending that others buy CASG stock did he disclose that he or his nominee were selling or planning to sell CASG stock. 87. Beck’s statements were materially false and misleading, as he was at that time selling his holdings of CASG’s stock. A reasonable investor would want to know, in assessing the quality of a recommendation to buy a stock, whether the person making the recommendation was selling contrary to the recommendation. 88. Beck knew that his statements were materially false and misleading because he was aware of his own trading activity. 89. CASG’s stock price rose from $0.0035 per share on April 24, 2018 (the day before the message board posts that Beck paid for first appeared) to $0.0048 per share on April 25, 2018. 90. On April 30, 2018 (the first trading day after Beck emailed TeamBillionaire members about his CASG stock recommendation) the stock price rose from a previous day’s closing price of $0.0082 to $0.0138 per share on about Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 14 of 25 Page ID #:14 15 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 322% higher trading volume. 91. Between April 26, 2018 and May 1, 2018, Beck’s and Robinson’s accounts sold about 8.5 million shares of CASG stock, for combined sales proceeds of $218,000. 6. Beck’s Marquie scalping scheme 92. Marquie is a radio station company whose stock was trading under the ticker TMGI in the range of $0.041 to $0.096 per share in November 2018. 93. Beck began purchasing Marquie stock on or about November 27, 2018, in Robinson’s accounts. 94. On or about November 5, 2018, Beck tweeted that a stock pick was imminent, stating, “MY NEXT MEGA ALERT IS DECEMBER 18TH.” 95. Beck then emailed his TeamBillionaire group in advance of issuing his stock alert for Marquie, to encourage them to buy ahead of his public alert. 96. For example, on or about December 15, 2018, Beck emailed his TeamBillionare group: The MEGA December 18th alert will be released to the masses at 9:00 am est on the 18th of DECEMBER. There will be a GLOBAL release to every TRADER on the planet via all platforms on SOCIAL MEDIA . When I tweet that I will be releasing the BIGGEST PROFIT RUNNER in pennystock history, I'm not joking, I'm dead serious….December 18th will be HISTORIC and many traders will either quit their 9-5 jobs, buy a business, buy property all around the world, RETIRE, become Philanthropists, take a 5-STAR CRUISE around the world, buy a minor league baseball team etc etc.... I will be getting you in on the 17TH ( You will be able to Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 15 of 25 Page ID #:15 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 buy a day early before I alert the world on the 18th) . You will be receiving the alert Sunday morning the 16th so you can figure out how much stock you want to buy so you can ACHIEVE your FINANCIAL DREAMS........” 97. On December 18, 2018, Beck tweeted his recommendations to purchase Marquie’s stock, stating: “THIS YEARS MEGA MAGICAL CHRISTMAS ALERT IS GOING TO BE..........................$MYLI !!!!!!!BUY EVERYTHING YOU CAN UNDER $1.00+ BEFORE THE HERBALIFE MERGER NEWS DROPS!!! $MYLI IS GOING TO $10+ ( CURRENT PRICE $.44 ). TURN UR $5,000 INVESTMENT INTO $100,000+.” 98. In none of Beck’s tweets, emails or message board posts recommending that others buy Marquie stock did he disclose that he or his nominee were selling or planning to sell Marquie stock. 99. Beck’s statements were materially false and misleading, as he had already begun selling his holdings of Marquie’s stock on December 17, 2018. A reasonable investor would want to know, in assessing the quality of a recommendation to buy a stock, whether the person making the recommendation was selling contrary to the recommendation. 100. Beck knew that his statements about Marquie were materially false and misleading, because he was aware of his own trading activity. 101. Marquie’s stock price rose from $0.29 per share on December 14, 2018 (the trading day before Beck’s first TeamBillionaire email) to $0.40 per share on December 17, 2018 (the first trading day following Beck’s first Team Billionaire email). 102. Between December 17, 2018 and December 20, 2018, Robinson’s accounts sold about 343,000 shares of Marquie’s stock, for sales proceeds of $41,000. 7. Beck’s Peoplesway scalping scheme 103. Peoplesway is a now-defunct wellness company whose stock was Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 16 of 25 Page ID #:16 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 trading under the ticker PLWY in the range of $0.0027 to $0.0060 per share in February 2019. 104. Beck began purchasing Peoplesway stock on or about September 5, 2018, in Robinson’s accounts. 105. On or about February 28, 2019, Beck tweeted that a stock pick was imminent, stating, “ON MARCH 12TH, I WILL BE ALERTING THE ‘MEGA GODZILLA ALERT!!! THIS WILL BE THE BIGGEST RUNNER IN #PENNYSTOCKS HISTORY !!! EXPECT TO TURN UR $10,000 INVESTMENT INTO $150,000+.” 106. On or about March 11, 2019, Beck emailed his TeamBillionaire group to give them a preview that he would be recommending PLWY stock, stating: Guess what FAM? I'm getting you in EARLY March the 11th so you can avoid the STRESS of buying a stock that will keep going up and up and up on March the 12th. I dont want you to chase the stock to $.25+ on Tuesday March 12th. I want to get you in under $.05 Tomorrow so you can lock in your profits and enjoy the EASIEST profits you have ever made in your life… I'm so excited for you, me and the #MONEYGANG because we are all GOING to EAT FIRST and PROFIT FIRST before the major announcement to the WORLD on March the 12th. Drum roll please.........The BIGGEST RUNNER IN PENNY STOCK HISTORY IS GOING TO BE …..PLWY!” 107. Peoplesway’s stock price rose from $0.011 to $0.027 per share from March 8, 2019 (the trading date before Beck’s first Team Billionaire email) and March 11, 2019 (the first trading date after Beck’s Team Billionaire email) on trading Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 17 of 25 Page ID #:17 18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 volume about 1,760% higher trading volume. 108. On March 11, 2019, Robinson’s accounts sold about 3.56 million shares of Peoplesway stock, for sales proceeds of $78,000. 109. Between March 12-14, 2019, Beck tweeted his recommendations to purchase Peoplesway stock. 110. For example, on or about March 12, 2019, Beck tweeted: “IM GOING TO PERSONALLY PUNISH EVERY SINGLE SHORT SELLER ON $PLWY !!!! I WILL FORCE THOSE B*TCHES TO COVER OVER $.10 !!! SH*T JUST GOT REAL !!!!” 111. As another example, on or about March 14, 2019, Beck tweeted: “IM LOADING $PLWY ON THE BIDS .....ITS GOING BACK UP..........I BUY ‘PANIC’............NO NEED TO WORRY WHEN #BMM IS ON BIDS.” 112. In none of Beck’s tweets, emails or message board posts recommending that others buy Peoplesway stock did he disclose that he or his nominee were selling or planning to sell Peoplesway stock. 113. Beck’s statements were materially false and misleading, given that as of March 11, 2019, he had sold his entire position of PLWY and was not buying the stock. A reasonable investor would want to know, in assessing the quality of a recommendation to buy a stock, whether the person making the recommendation was selling contrary to the recommendation. 114. Beck knew that his statements were materially false and misleading because he was aware of his own trading activity. 8. Beck’s UCSO scalping scheme 115. Pick-Ups is a now-defunct company purportedly in the business of digital services, blockchain, palm oil and cannabis, whose stock was trading under the ticker UCSO in the range of $0.0055 to $0.0099 per share in March 2019. 116. Beck began purchasing UCSO’s stock on or about April 9, 2019, in Robinson’s accounts. Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 18 of 25 Page ID #:18 19 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 117. On or about March 31, 2019, Beck tweeted that a stock pick was imminent, stating, “ARE U READY FOR THE BIGGEST #PENNYSTOCKS ALERT IN HISTORY? GET READY TO TURN UR $5,000 INVESTMENT INTO $100,000+ ON MAY 1ST!” 118. On or about April 29, 2019, Beck emailed his TeamBillionaire group to preview that UCSO would be the stock pick, stating: I will be getting you...... there first with the release of the MEGA May 1st alert ! ! Here’s the good news........... I am not going to make you wait till May 1st to get the GAME- CHANGING SUPER MEGA ALERT. I'm giving you the alert April 29th which is 48 hours before the WORLD ( general public) receives it. 119. On or about May 1, 2019, Beck tweeted his alert recommending the purchase of UCSO, writing: #MONEYGANG, NO NEED FOR $UCSO TO RUN CRAZY TO $.10 TODAY...LOAD UP EVERYTHING U CAN UNDER $.06!!! TOMORROW WE LOAD EVERYTHING UNDER $.07…SLOW & STEADY ALWAYS WINS THE RACE. BUYING $UCSO WILL BE THE BEST FINANCIAL DECISION U HAVE EVER MADE IN UR LIFE !!! 120. In none of Beck’s tweets or emails recommending that others buy UCSO’s stock did he disclose that he or his nominee were selling or planning to sell UCSO’s stock. 121. Beck’s statements were materially false and misleading, as he was at that time selling his holdings of UCSO’s stock. A reasonable investor would want to know, in assessing the quality of a recommendation to buy a stock, whether the person making the recommendation was selling contrary to the recommendation. Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 19 of 25 Page ID #:19 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 122. Beck knew that his statements were materially false and misleading because he was aware of his own trading activity. 123. During Beck’s promotional campaign, UCSO’s stock price rose from $0.065 per share on April 26, 2019 (the trading day before Beck’s Team Billionaire email) to an intraday high of $0.08 per share on April 29, 2019 (the day of Beck’s Team Billionaire email) on about 232% increased trading volume. 124. Between April 29, 2019 and May 2, 2019, Robinson’s accounts sold about 228,000 shares of UCSO stock, for sales proceeds of $15,000. C. Beck’s Scienter and/or Negligence 125. Beck intentionally, knowingly and/or recklessly carried out his scalping scheme in the Issuers’ stocks. 126. Beck knew that he did not disclose to his Twitter or TeamBillionaire followers his intentions to sell, nor his actual sales, of the Issuers’ stock, when recommending they purchase the same stocks. 127. Beck conducted his trades in part through his nominee, Robinson, concealing the amount of his own trading. 128. Beck covertly paid third parties to post favorable commentary about more than one of the Issuers, concealing his role in promoting the Issuers’ stock. 129. Beck’s scheme showed a repeated pattern of conduct occurring over a period of years as to the eight Issuers. 130. In the alternative, Beck was negligent in recommending the Issuers’ stocks without revealing that he was selling, or intended to sell, the Issuers’ stocks. 131. Beck enjoyed illicit profits from his scheme. In total, between February 2017 and May 2019, Beck, through his and his nominee’s account, earned $870,000 in sales proceeds: Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 20 of 25 Page ID #:20 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 No. Issuer Sales Proceeds 1. Pick-Ups $218,000 2. MK Automotive $254,000 3. Zann $82,000 4. Vidaroo $110,000 5. CASG $72,000 6. Marquie $41,000 7. Peoplesway $78,000 8. UCSO $15,000 TOTAL $870,000 132. Of the sales proceeds, approximately $358,000 were from trades in Beck’s account and approximately $512,000 were from trades in Robinson’s accounts. D. Beck Concealed Material Information About His Trading 133. It would have been important to a reasonable investor to know that Beck was selling, or intended to sell, the Issuers’ stocks, at the time that he was recommending others purchase the stocks. 134. That Beck was selling the Issuers’ stocks, or intended to sell their stock, and profit from a run-up in the stocks’ price generated by his own recommendations, would have been important to a reasonable investor in evaluating Beck’s recommendation that the investor purchase the Issuers’ stocks. FIRST CLAIM FOR RELIEF Fraud in the Connection with the Purchase and Sale of Securities Violations of Section 10(b) of the Exchange Act and Rule 10b-5 (against Defendant Beck) 135. The SEC realleges and incorporates by reference paragraphs 1 through 134 above. 136. Defendant Beck intentionally and/or recklessly engaged in a scheme to Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 21 of 25 Page ID #:21 22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 scalp the Issuers’ stock. Through his promotional campaign, consisting of his tweeted stock alerts, emails to his TeamBillionaire group, and message board posts he procured in others’ names, Beck manipulated the Issuers’ stock price so he could sell at inflated prices. Beck failed to disclose that he was simultaneously selling or intended to sell the very stock he recommended that others purchase. Beck’s deceitful pattern persisted over the eight Issuers’ stocks, over a period of years, garnering him over $900,000 in illicit profits in his account and that of his nominee. 137. By engaging in the conduct described above, Defendant Beck, acting with scienter, directly or indirectly, in connection with the purchase or sale of a security, 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 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 other persons. 138. By engaging in the conduct described above, Defendant Beck violated, and unless restrained and enjoined will continue to violate, Section 10(b) of the Exchange Act, 15 U.S.C. § 78j(b), and Rules 10b-5(a), 10b-5(b), and 10b-5(c) thereunder, 17 C.F.R. §§ 240.10b-5(a), 240.10b-5(b) & 240.10b-5(c). SECOND CLAIM FOR RELIEF Fraud in the Offer or Sale of Securities Violations of Section 17(a) of the Securities Act (against Defendant Beck) 139. The SEC realleges and incorporates by reference paragraphs 1 through 134 above. 140. Defendant Beck Defendant Beck intentionally, recklessly, and/or negligently engaged in a scheme to scalp the Issuers’ stock. Through his promotional Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 22 of 25 Page ID #:22 23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 campaign, consisting of his tweeted stock alerts, emails to his TeamBillionaire group, and message board posts he procured in others’ names, Beck manipulated the Issuers’ stock price so he could sell at inflated prices. Beck failed to disclose that he was simultaneously selling or intended to sell the very stock he recommended that others purchase. Beck’s deceitful pattern persisted over the eight Issuers’ stocks, over a period of years. By means of his materially false and misleading statements, Beck obtained over $900,000 in illicit profits in his account and that of his nominee. 141. By engaging in the conduct described above, Defendant Beck has, directly or indirectly, in the offer or sale of securities, and by the use of means or instruments of transportation or communication in interstate commerce or by use of the mails directly or indirectly: (a) employed devices, schemes, or artifices to defraud; (b) obtained money or property by means of untrue statements of a material fact or by omitting to state a material fact necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading; and (c) engaged in transactions, practices, or courses of business which operated or would operate as a fraud or deceit upon the purchaser. 142. Defendant Beck, with scienter, employed devices, schemes and artifices to defraud; with scienter or negligence, obtained money or property by means of untrue statements of a material fact or by omitting to state a material fact necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading; and, with scienter or negligence, engaged in transactions, practices, or courses of business which operated or would operate as a fraud or deceit upon the purchaser. 143. By engaging in the conduct described above, Defendant Beck has violated, and unless restrained and enjoined will continue to violate, Sections 17(a)(1), 17(a)(2), and 17(a)(3) of the Securities Act, 15 U.S.C. §§ 77q(a)(1), 77q(a)(2), & 77q(a)(3). Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 23 of 25 Page ID #:23 24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PRAYER FOR RELIEF WHEREFORE, the SEC respectfully requests that the Court: I. Issue findings of fact and conclusions of law that Defendant committed the alleged violations. II. Issue judgment, in a form consistent with Rule 65(d) of the Federal Rules of Civil Procedure, permanently enjoining Defendant Beck and his officers, agents, servants, employees and attorneys, and those persons in active concert or participation with him, who receive actual notice of the judgment by personal service or otherwise, and each of them, from violating 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] and Securities Act Section 17(a) [15 U.S.C. §77q(a)]. III. Order Defendant Beck and Relief Defendant Robinson to disgorge all funds received from their illegal conduct, together with prejudgment interest thereon, pursuant to Securities Exchange Act of 1934, Sections 21(d)(5) and 21(d)(7) [15 U.S.C. §§ 78u(d)(5) and 78u(d)(7)]. IV. Order Defendant Beck to pay civil penalties under Section 21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)] and Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)]. V. Enter an order against Defendant Beck, pursuant to Section 20(g) of the Securities Act, 15 U.S.C. § 77t(g), prohibiting him from participating in an offering of penny stock. VI. Retain jurisdiction of this action in accordance with the principles of equity and Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 24 of 25 Page ID #:24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 the Federal Rules of Civil Procedure in order to implement and carry out the terms of all orders and decrees that may be entered, or to entertain any suitable application or motion for additional relief within the jurisdiction of this Court. VII. Grant such other and further relief as this Court may determine to be just and necessary. Dated: February 7, 2022 /s/Amy Jane Longo Amy Jane Longo Roberto Tercero Attorneys for Plaintiff Securities and Exchange Commission Case 2:22-cv-00812 Document 1 Filed 02/07/22 Page 25 of 25 Page ID #:25