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

COMPANY LIMITED), instructed a group of former sales employees of GIFT to establish GLOOMMING GLOBAL COMPANY LIMITED (“GLOOMMING”) in order to operate a same business and in direct competition with