;EA"). His duty was to oversee and ensure that EA’s offering for sale of securities complied with the law. However, Mr. Amorn failed to issue instructions or perform the necessary duties required

preparing, approving, and supervising advertisements. In this respect, Merkle published advertisements without providing a channel for investors to study Merkle’s historical performance. Furthermore, Merkle

and processes for preparing, approving, and supervising advertisements. In this respect, Merkle published advertisements without providing a channel for investors to study Merkle’s historical