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From October 2017 until October 2018, the AWC Letter proceeds, Mr. Page distributed internet marketing resources that contained materially inaccurate information “to in excess of two dozen prospective traders.” Additionally, he allegedly “exchanged email messages with various potential traders in which he affirmed the accuracy with the Learn Fund’s efficiency effects as established forth within the Feeder Fund’s promoting materials.” FINRA states that investors while in the Feeder Fund designed “7 different investments… totaling around $1.

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