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documents in order to lure the investors into believing that their subscription transactions had been executed and recorded when in fact Napasook did not use the money to subscribe for the fund units as
holding an aggregate of 10 percent of the total votes of the shareholders attending such meeting and having the right to vote for the offering at such offering price. In addition to seeking approval for the
attending the meeting or replying the letter hold at least 33% of the total investment units, and the number of unitholders must be at least 25 or half of the total number of unitholders. Previously, a
documents indicated that its total revenues relied on six major counterparties, accounting for 49 percent of total revenues from sales and services. It was found, however, that 30 percent of the applicant?s