Spot Runner's "Pump & Dump" Scheme

The March 2009 Admissions: The Company has raised $100 MM from investors, and has spent $80 MM without completing development of its principal product (an innovative media buying platform called Project Malibu). Spot Runner improperly sold $54 MM of common shares, when the Company was a start-up and in need of venture capital, with founders Nick Grouf and Waxman having received $30 MM in proceeds, and Battery and Index Ventures having received $24 MM.