[GRADE A2 -- EFTA00756280, EFTA01156109 (seized emails)]
[GRADE B -- AMF Cease Trade Order (public records)]
The key email EFTA00756280 articulates the strategy with exceptional clarity: use Innovium Media Properties Corp, a company listed on the TSX Venture Exchange in Toronto, as a vehicle to "take seed public on TSX."
Innovium Media Properties Corp (CVE: IN) appears in TSX Venture Exchange data as a small-cap company -- a "penny stock" per exchange records. The TSX Venture Exchange is specifically designed for early-stage and small-cap companies, offering an entry path to Canadian public markets with lighter regulatory requirements than the main TSX.
Jamie Macintosh, President and COO of Innovium, is recorded in EFTA01156109 as describing the company as a "vehicle to go public." The same email contains a candid assessment of Adam Bly: "Adam brilliant but should not be running anything."
On May 5, 2011, the Autorite des marches financiers (AMF) of Quebec issues a cease trade order against Innovium for failure to file its audited 2010 financial statements. The TSX Venture Exchange suspends trading. The board approves the audit on July 12, 2011, but no public evidence indicates that trading ever resumed. The company remains federally "active" but operationally defunct -- a zombie shell.
WHAT THIS SHOWS AND DOES NOT SHOW: The documents indicate that the strategic plan was to use a Canadian publicly listed shell company as a conduit to public markets. The AMF subsequently issued a cease trade order, which is a matter of public record. This does not in itself prove securities fraud -- failure to file financial statements can result from ordinary operational difficulties. No formal charges of securities fraud, insider trading, or market manipulation have been identified in public records.