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

posts through his personal Facebook account that JKN was the first and sole owner of genuine hemp products and the company had a 24-hour time rental with a television station to conduct its business

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