IIS Security And Programming CountermeasuresJason Coombs
This document provides an introduction to a book about securing Microsoft Internet Information Services (IIS). It discusses how IIS works, common security threats to web applications, and an overview of topics that will be covered in the book such as hardening the IIS platform, securing applications, and protecting against network vulnerabilities. The goal of the book is to teach professionals how to build secure solutions using IIS without providing instructions for exploits.
Homeland Forensics, Inc. Rule 506(c) JOBS Act public offering general solicit...Jason Coombs
A general solicitation advertisement for the JOBS Act Rule 506(c) public offering for Homeland Forensics, Inc. published in compliance with Regulation D.
JOBS Act Rulemaking Comments on SEC File Number S7-06-13 Dated June 17, 2014Jason Coombs
This letter summarizes concerns about protecting confidential investor information when verifying accredited investor status under Regulation D, Rule 506(c) offerings. It argues that requiring issuers or third parties to retain copies of sensitive personal data will result in that data being stolen, and suggests instead raising the threshold for accredited investor status as long as no copies of personal information are retained. The letter also supports enacting rules that preempt state securities regulators and establish an integrated regulatory framework for JOBS Act exemptions.
JOBS Act Rulemaking Comments on SEC File Number S7-06-13 Dated June 25, 2014Jason Coombs
The letter supports revising the definition of an "Accredited" investor under SEC rules to raise financial or other thresholds. It argues that any changes must be clearly explained by the SEC chair and justified in the final rules. While initially opposed to the concept of Accredited investors, the letter writer now believes the definition makes sense under JOBS Act rules to encourage experienced investors to invest alongside less experienced ones in crowdfunding, helping crowdfunding become a viable market. The letter urges the SEC to clearly articulate the reasoning behind its actions.
Public Startup Company "Re-Repo" Startup Capital Formation ModelJason Coombs
Reverse Repurchase Agreements might become the standard of practice in startup capital formation and startup tax accounting. This concept properly balances the competing interests of all stakeholders, including tax authorities, to solve a core problem with startup finance. Without Reverse Repurchase Agreements between startups and seed capital investors cash payments to investors are usually mistakenly accounted for as taxable dividends long before the investor has realized any actual return on investment. With Re-Repos, startups will be able to make cash distributions to early investors and account properly for this return OF capital until such payments become a return ON capital.
Expert witness CV / resume for Jason Coombs in fields of forensic engineering and expert witness services such as: derivatives trading algorithms, software, cloud computing, virtualization, information security and forensics, Internet architecture and services, software development and software analysis, electronic commerce, payments, trademarks, copyright infringement, cybercrime investigation, cybersecurity, criminal defense, patent litigation, vulnerability research, and network intrusion countermeasures.
IIS Security And Programming CountermeasuresJason Coombs
This document provides an introduction to a book about securing Microsoft Internet Information Services (IIS). It discusses how IIS works, common security threats to web applications, and an overview of topics that will be covered in the book such as hardening the IIS platform, securing applications, and protecting against network vulnerabilities. The goal of the book is to teach professionals how to build secure solutions using IIS without providing instructions for exploits.
Homeland Forensics, Inc. Rule 506(c) JOBS Act public offering general solicit...Jason Coombs
A general solicitation advertisement for the JOBS Act Rule 506(c) public offering for Homeland Forensics, Inc. published in compliance with Regulation D.
JOBS Act Rulemaking Comments on SEC File Number S7-06-13 Dated June 17, 2014Jason Coombs
This letter summarizes concerns about protecting confidential investor information when verifying accredited investor status under Regulation D, Rule 506(c) offerings. It argues that requiring issuers or third parties to retain copies of sensitive personal data will result in that data being stolen, and suggests instead raising the threshold for accredited investor status as long as no copies of personal information are retained. The letter also supports enacting rules that preempt state securities regulators and establish an integrated regulatory framework for JOBS Act exemptions.
JOBS Act Rulemaking Comments on SEC File Number S7-06-13 Dated June 25, 2014Jason Coombs
The letter supports revising the definition of an "Accredited" investor under SEC rules to raise financial or other thresholds. It argues that any changes must be clearly explained by the SEC chair and justified in the final rules. While initially opposed to the concept of Accredited investors, the letter writer now believes the definition makes sense under JOBS Act rules to encourage experienced investors to invest alongside less experienced ones in crowdfunding, helping crowdfunding become a viable market. The letter urges the SEC to clearly articulate the reasoning behind its actions.
Public Startup Company "Re-Repo" Startup Capital Formation ModelJason Coombs
Reverse Repurchase Agreements might become the standard of practice in startup capital formation and startup tax accounting. This concept properly balances the competing interests of all stakeholders, including tax authorities, to solve a core problem with startup finance. Without Reverse Repurchase Agreements between startups and seed capital investors cash payments to investors are usually mistakenly accounted for as taxable dividends long before the investor has realized any actual return on investment. With Re-Repos, startups will be able to make cash distributions to early investors and account properly for this return OF capital until such payments become a return ON capital.
Expert witness CV / resume for Jason Coombs in fields of forensic engineering and expert witness services such as: derivatives trading algorithms, software, cloud computing, virtualization, information security and forensics, Internet architecture and services, software development and software analysis, electronic commerce, payments, trademarks, copyright infringement, cybercrime investigation, cybersecurity, criminal defense, patent litigation, vulnerability research, and network intrusion countermeasures.
Comments on SEC File Number 4-692 (Accredited Investor) and S7-06-13 (Regulat...Jason Coombs
My comment letter submitted to the Securities and Exchange Commission in response to the SEC report on the review of the "Accredited Investor" definition required by the Dodd-Frank Act and pending revisions to Regulation D.
JOBS Act Rulemaking Comments on SEC File Number S7-06-13 Dated June 11, 2014Jason Coombs
This document is a letter from the CEO of Public Startup Company, Inc. addressed to the Chair and Secretary of the Securities and Exchange Commission regarding recent JOBS Act legislation and proposed changes to regulations around accredited investors and funding startups. The CEO criticizes so-called "Angel" investors for ignoring securities regulations and urges them to educate themselves on Titles III and IV of the JOBS Act regarding new funding portal opportunities and Regulation A+ to qualify securities offerings. The CEO argues the SEC should have broad authority to regulate startup investing and determine who can qualify as investors.
JOBS Act Rulemaking Comments on SEC File Number S7-06-13 Dated July 24, 2014Jason Coombs
This letter supports raising the thresholds for accredited investors and requiring more disclosure from startup companies seeking investment. It argues that few accredited investors actually invest in startups without proven revenue, so basic disclosures about the business, founders, and vision should be required for all investors. Requiring revenue-generating startups to disclose financial information like bank statements is reasonable. Opponents of changing the accredited investor rules are not considering how online funding could positively change startup investing through JOBS Act-compliant solicitations like on Kickstarter. The SEC should ignore critics unwilling to accept change.
JOBS Act Rulemaking Comments on SEC File Number S7-06-13 Dated July 10, 2014Jason Coombs
The letter argues that the current accredited investor definition and angel investing model in the US is broken because it only allows a small fraction of accredited investors to participate. The writer believes the JOBS Act provides an opportunity to replace this broken model with public startup companies that can raise capital through crowdfunding and light-touch regulation, enabling more widespread participation. The letter urges the SEC to finalize JOBS Act rules in a way that preempts state securities laws and establishes a streamlined process for startups to list on OTC markets.
JOBS Act Rulemaking Comments on SEC File Number S7-06-13 Dated July 4, 2014Jason Coombs
The letter summarizes various historical injustices and delays in establishing rights and freedoms in the United States. It argues that the SEC's failure to enact rules for Titles III and IV of the JOBS Act in a timely manner is absurd and deprives people of their basic economic rights. The letter calls on the SEC to stop creating absurdity and finish enacting the JOBS Act rules as mandated by Congress to restore economic freedoms for all.
JOBS Act Rulemaking Comments on SEC File Number S7-06-13 CorrectionJason Coombs
This letter summarizes the writer's support for recent SEC rule changes allowing general solicitations when raising capital under Rule 506(c). The writer acknowledges others' concerns that the new rules could increase fraud risk for non-accredited investors. However, the writer believes civil/criminal fraud laws and regulators will still protect investors. The writer hopes the new rules level the playing field for capital raising and allow more startups the opportunity to get funded, especially those launched by people with strong ethics who follow regulations.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated March 30, 2014Jason Coombs
This letter addresses proposed SEC rule revisions implementing Titles II, III, and IV of the JOBS Act. It argues that the SEC should not restrict the definition of "crowdfunding" or prevent the use of crowdfunding terminology for public offerings under Titles II and IV. The letter asserts issuers have a right to communicate freely with the public about crowdfunding efforts involving public offers of unregistered securities. It asks the SEC to clarify in final rules that using crowdfunding language does not require conducting offerings through registered funding portals.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated March 26, 2014Jason Coombs
This letter from the CEO of Public Startup Company responds to a comment letter from William F. Galvin, Secretary of the Commonwealth of Massachusetts, regarding proposed rules for Regulation A under Title IV of the JOBS Act. The CEO argues that the JOBS Act and existing law give the SEC authority to preempt state regulation of certain securities offerings. While acknowledging Galvin's concerns, the CEO asserts the proposed rules are consistent with congressional intent and that alternative approaches could address Galvin's objections without compromising preemption. The CEO urges all parties to remain calm and focus on protecting investors' rights.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated March 26, 2014...Jason Coombs
This letter addresses proposed rules for Regulation A+ under the JOBS Act. It urges the SEC to adopt the proposed rules with some minor modifications: 1) Add a Tier 2 between proposed Tiers 1 and 2, with lesser financial statement and capital raising requirements than Tier 2. 2) Require different levels of auditing for each tier, including "self-auditing" for Tier 1. 3) Provide preemption from state registration for national issuers in all tiers, but allow states to regulate local issuers in Tier 1. It also requests clarification on the use of brokers and investor qualification requirements.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated March 25, 2014Jason Coombs
This letter addresses proposed SEC rules implementing provisions of the JOBS Act regarding Regulation A and the shareholder caps under Section 12(g). The letter argues that the SEC needs to clarify that Section 12(g)’s shareholder caps do not apply to companies with less than $10 million in assets. The letter also argues the SEC should not require audited financial statements prior to a company’s first public sale under Regulation A, but only after the first year of operations as a publicly funded startup.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated March 24, 2014Jason Coombs
This document is a letter from the Co-Founder and CEO of Public Startup Company, Inc. commenting on proposed rules by the SEC to revise Regulation A. The letter calls for a full law enforcement investigation of the SEC for failing to enact JOBS Act rules by congressional deadlines. However, it praises two recent positive developments: the appointment of Mary Jo White as SEC Chair, and proposed rules to revise Regulation A that simplify capital raising for small issuers. The letter provides suggestions to improve the proposed Regulation A rules, including allowing preemption of state securities laws for Tier 1 offerings and ensuring Regulation A compliance satisfies certain broker-dealer rules.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated March 24, 2014...Jason Coombs
This letter requests that the SEC revise Rule 144 regarding former shell companies as part of finalizing rules for Title IV of the JOBS Act. Specifically, it asks the SEC to issue guidance clarifying that Rule 144 prohibitions on former shell companies only apply to those previously registered under the Exchange Act. It argues that companies selling unregistered securities under Regulation A, or that were previously registered but voluntarily de-registered, should have clear eligibility to use Rule 144 without re-registering. This would eliminate an unintended "scarlet letter" effect of the current rules that unfairly restricts resale of securities from these former shell companies.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated June 6, 2014Jason Coombs
The document is a letter from the co-founder and CEO of Public Startup Company addressing the SEC regarding regulations under Title IV of the JOBS Act. It argues that prohibiting unregistered securities offerings across state lines is unconstitutional and violates free speech and property rights. It urges the SEC to adopt a final rule for Regulation A+ that includes preemption of state securities review for offerings up to $500,000 to help startups raise capital within constitutional limits. It criticizes a letter from members of Congress opposing preemption and argues they have violated their oath of office.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated July 26, 2014Jason Coombs
The letter is from the co-founder and CEO of Public Startup Company to the SEC regarding Title IV of the JOBS Act and Regulation A+. It argues that Title IV must preempt state securities regulation to allow direct investment between individuals and restore freedom of communication and equity investment relationships. It criticizes the SEC for failing to enact JOBS Act rules as mandated by Congress and for investigating the company when it tried to use Regulation D Rule 506(c). The letter urges the SEC to stop aiding banks and declare all people as equity-worthy to establish a viable market for Regulation A+ securities.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated August 13, 2014Jason Coombs
The document is a letter from the CEO of Public Startup Company to the SEC criticizing a group of 9 Senators who urged the SEC to withdraw its proposed preemption of state securities regulation for Regulation A+ offerings under Title IV of the JOBS Act. The CEO argues the Senators failed to provide reasonable justification and made factually incorrect claims. The CEO asserts full federal preemption is necessary for the SEC to properly implement Title IV and that states would still be able to prosecute fraud even without prohibitions on unregistered securities. The CEO believes the Senators are harming small businesses and job creation with their opposition to preemption.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated April 2, 2014Jason Coombs
This letter from the CEO of Public Startup Company addresses the constitutionality of JOBS Act revisions to securities regulation in light of the recent Supreme Court decision in McCutcheon v. FEC. The CEO argues that while reasonable limits on individual investments in a single crowdfunding campaign may be valid, aggregate limits on total investments in securities offered via crowdfunding would not be constitutionally valid based on the McCutcheon decision. The CEO provides an analogy comparing political contributions to campaign financing and startup investments to crowdfunding campaigns.
JOBS Act Rulemaking Comments on SEC File Number S7-09-13 Dated July 16, 2014Jason Coombs
The document is a letter from the co-founder and CEO of Public Startup Company to the SEC regarding rules for crowdfunding transactions under Section 4(a)(6) of the Securities Act of 1933 and Title II and III of the JOBS Act. The letter provides feedback on SEC proposed rules, highlights issues with general solicitation under Rule 506(c), and encourages the SEC to provide more guidance to allow companies like Twitter to safely permit securities advertising. It also suggests the SEC require public profiles for issuers in an offender registry to improve transparency.
JOBS Act Rulemaking Comments on SEC File Number S7-09-13 Dated February 22, 2014Jason Coombs
This document is a letter from the co-founder and CEO of Public Startup Company addressing challenges with the SEC's proposed rules for crowdfunding under Regulation Crowdfunding. The letter argues that the rules do not provide enough clarity or legal protection for media companies to publish advertisements for securities offerings under the JOBS Act. It urges the SEC to establish a clear safe harbor allowing general solicitation and advertising of unregistered offerings as long as they cite and comply with the JOBS Act. It contends this is necessary to achieve the goals of the JOBS Act in promoting capital formation and reducing barriers to raising money. Screenshots are included showing social media platforms like Twitter currently prohibit securities advertising, and the letter says the SEC rules
JOBS Act Rulemaking Comments on SEC File Number S7-09-13 Dated February 11, 2014Jason Coombs
This letter comments on proposed SEC rules for crowdfunding under Title III of the JOBS Act. It argues that the SEC rules insert more SEC control over capital raising rather than eliminating SEC involvement as mandated by Congress. The letter calls for eliminating the SEC and replacing it with state-level securities regulation to reduce costs and comply with the intent of the JOBS Act to give issuers more freedom to raise capital. It asserts the SEC rules threaten economic freedom and could result in civil conflict if reasonable crowdfunding rules are not implemented.
JOBS Act Rulemaking Comments on SEC File Number S7-09-13 Dated February 3, 2014Jason Coombs
This letter from the CEO of Public Startup Company summarizes previous correspondence between the CEO and the SEC regarding proposed rules for crowdfunding under the JOBS Act. The CEO argues that the SEC's proposed rules do not properly eliminate fear of government reprisal for unregistered securities offerings and instead seem designed to protect the SEC and guarantee work for former SEC attorneys. The CEO believes the SEC should be abolished if it does not stop interfering with capital formation and people's freedoms as mandated by Congress in the JOBS Act.
Comments on SEC File Number 4-692 (Accredited Investor) and S7-06-13 (Regulat...Jason Coombs
My comment letter submitted to the Securities and Exchange Commission in response to the SEC report on the review of the "Accredited Investor" definition required by the Dodd-Frank Act and pending revisions to Regulation D.
JOBS Act Rulemaking Comments on SEC File Number S7-06-13 Dated June 11, 2014Jason Coombs
This document is a letter from the CEO of Public Startup Company, Inc. addressed to the Chair and Secretary of the Securities and Exchange Commission regarding recent JOBS Act legislation and proposed changes to regulations around accredited investors and funding startups. The CEO criticizes so-called "Angel" investors for ignoring securities regulations and urges them to educate themselves on Titles III and IV of the JOBS Act regarding new funding portal opportunities and Regulation A+ to qualify securities offerings. The CEO argues the SEC should have broad authority to regulate startup investing and determine who can qualify as investors.
JOBS Act Rulemaking Comments on SEC File Number S7-06-13 Dated July 24, 2014Jason Coombs
This letter supports raising the thresholds for accredited investors and requiring more disclosure from startup companies seeking investment. It argues that few accredited investors actually invest in startups without proven revenue, so basic disclosures about the business, founders, and vision should be required for all investors. Requiring revenue-generating startups to disclose financial information like bank statements is reasonable. Opponents of changing the accredited investor rules are not considering how online funding could positively change startup investing through JOBS Act-compliant solicitations like on Kickstarter. The SEC should ignore critics unwilling to accept change.
JOBS Act Rulemaking Comments on SEC File Number S7-06-13 Dated July 10, 2014Jason Coombs
The letter argues that the current accredited investor definition and angel investing model in the US is broken because it only allows a small fraction of accredited investors to participate. The writer believes the JOBS Act provides an opportunity to replace this broken model with public startup companies that can raise capital through crowdfunding and light-touch regulation, enabling more widespread participation. The letter urges the SEC to finalize JOBS Act rules in a way that preempts state securities laws and establishes a streamlined process for startups to list on OTC markets.
JOBS Act Rulemaking Comments on SEC File Number S7-06-13 Dated July 4, 2014Jason Coombs
The letter summarizes various historical injustices and delays in establishing rights and freedoms in the United States. It argues that the SEC's failure to enact rules for Titles III and IV of the JOBS Act in a timely manner is absurd and deprives people of their basic economic rights. The letter calls on the SEC to stop creating absurdity and finish enacting the JOBS Act rules as mandated by Congress to restore economic freedoms for all.
JOBS Act Rulemaking Comments on SEC File Number S7-06-13 CorrectionJason Coombs
This letter summarizes the writer's support for recent SEC rule changes allowing general solicitations when raising capital under Rule 506(c). The writer acknowledges others' concerns that the new rules could increase fraud risk for non-accredited investors. However, the writer believes civil/criminal fraud laws and regulators will still protect investors. The writer hopes the new rules level the playing field for capital raising and allow more startups the opportunity to get funded, especially those launched by people with strong ethics who follow regulations.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated March 30, 2014Jason Coombs
This letter addresses proposed SEC rule revisions implementing Titles II, III, and IV of the JOBS Act. It argues that the SEC should not restrict the definition of "crowdfunding" or prevent the use of crowdfunding terminology for public offerings under Titles II and IV. The letter asserts issuers have a right to communicate freely with the public about crowdfunding efforts involving public offers of unregistered securities. It asks the SEC to clarify in final rules that using crowdfunding language does not require conducting offerings through registered funding portals.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated March 26, 2014Jason Coombs
This letter from the CEO of Public Startup Company responds to a comment letter from William F. Galvin, Secretary of the Commonwealth of Massachusetts, regarding proposed rules for Regulation A under Title IV of the JOBS Act. The CEO argues that the JOBS Act and existing law give the SEC authority to preempt state regulation of certain securities offerings. While acknowledging Galvin's concerns, the CEO asserts the proposed rules are consistent with congressional intent and that alternative approaches could address Galvin's objections without compromising preemption. The CEO urges all parties to remain calm and focus on protecting investors' rights.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated March 26, 2014...Jason Coombs
This letter addresses proposed rules for Regulation A+ under the JOBS Act. It urges the SEC to adopt the proposed rules with some minor modifications: 1) Add a Tier 2 between proposed Tiers 1 and 2, with lesser financial statement and capital raising requirements than Tier 2. 2) Require different levels of auditing for each tier, including "self-auditing" for Tier 1. 3) Provide preemption from state registration for national issuers in all tiers, but allow states to regulate local issuers in Tier 1. It also requests clarification on the use of brokers and investor qualification requirements.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated March 25, 2014Jason Coombs
This letter addresses proposed SEC rules implementing provisions of the JOBS Act regarding Regulation A and the shareholder caps under Section 12(g). The letter argues that the SEC needs to clarify that Section 12(g)’s shareholder caps do not apply to companies with less than $10 million in assets. The letter also argues the SEC should not require audited financial statements prior to a company’s first public sale under Regulation A, but only after the first year of operations as a publicly funded startup.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated March 24, 2014Jason Coombs
This document is a letter from the Co-Founder and CEO of Public Startup Company, Inc. commenting on proposed rules by the SEC to revise Regulation A. The letter calls for a full law enforcement investigation of the SEC for failing to enact JOBS Act rules by congressional deadlines. However, it praises two recent positive developments: the appointment of Mary Jo White as SEC Chair, and proposed rules to revise Regulation A that simplify capital raising for small issuers. The letter provides suggestions to improve the proposed Regulation A rules, including allowing preemption of state securities laws for Tier 1 offerings and ensuring Regulation A compliance satisfies certain broker-dealer rules.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated March 24, 2014...Jason Coombs
This letter requests that the SEC revise Rule 144 regarding former shell companies as part of finalizing rules for Title IV of the JOBS Act. Specifically, it asks the SEC to issue guidance clarifying that Rule 144 prohibitions on former shell companies only apply to those previously registered under the Exchange Act. It argues that companies selling unregistered securities under Regulation A, or that were previously registered but voluntarily de-registered, should have clear eligibility to use Rule 144 without re-registering. This would eliminate an unintended "scarlet letter" effect of the current rules that unfairly restricts resale of securities from these former shell companies.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated June 6, 2014Jason Coombs
The document is a letter from the co-founder and CEO of Public Startup Company addressing the SEC regarding regulations under Title IV of the JOBS Act. It argues that prohibiting unregistered securities offerings across state lines is unconstitutional and violates free speech and property rights. It urges the SEC to adopt a final rule for Regulation A+ that includes preemption of state securities review for offerings up to $500,000 to help startups raise capital within constitutional limits. It criticizes a letter from members of Congress opposing preemption and argues they have violated their oath of office.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated July 26, 2014Jason Coombs
The letter is from the co-founder and CEO of Public Startup Company to the SEC regarding Title IV of the JOBS Act and Regulation A+. It argues that Title IV must preempt state securities regulation to allow direct investment between individuals and restore freedom of communication and equity investment relationships. It criticizes the SEC for failing to enact JOBS Act rules as mandated by Congress and for investigating the company when it tried to use Regulation D Rule 506(c). The letter urges the SEC to stop aiding banks and declare all people as equity-worthy to establish a viable market for Regulation A+ securities.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated August 13, 2014Jason Coombs
The document is a letter from the CEO of Public Startup Company to the SEC criticizing a group of 9 Senators who urged the SEC to withdraw its proposed preemption of state securities regulation for Regulation A+ offerings under Title IV of the JOBS Act. The CEO argues the Senators failed to provide reasonable justification and made factually incorrect claims. The CEO asserts full federal preemption is necessary for the SEC to properly implement Title IV and that states would still be able to prosecute fraud even without prohibitions on unregistered securities. The CEO believes the Senators are harming small businesses and job creation with their opposition to preemption.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated April 2, 2014Jason Coombs
This letter from the CEO of Public Startup Company addresses the constitutionality of JOBS Act revisions to securities regulation in light of the recent Supreme Court decision in McCutcheon v. FEC. The CEO argues that while reasonable limits on individual investments in a single crowdfunding campaign may be valid, aggregate limits on total investments in securities offered via crowdfunding would not be constitutionally valid based on the McCutcheon decision. The CEO provides an analogy comparing political contributions to campaign financing and startup investments to crowdfunding campaigns.
JOBS Act Rulemaking Comments on SEC File Number S7-09-13 Dated July 16, 2014Jason Coombs
The document is a letter from the co-founder and CEO of Public Startup Company to the SEC regarding rules for crowdfunding transactions under Section 4(a)(6) of the Securities Act of 1933 and Title II and III of the JOBS Act. The letter provides feedback on SEC proposed rules, highlights issues with general solicitation under Rule 506(c), and encourages the SEC to provide more guidance to allow companies like Twitter to safely permit securities advertising. It also suggests the SEC require public profiles for issuers in an offender registry to improve transparency.
JOBS Act Rulemaking Comments on SEC File Number S7-09-13 Dated February 22, 2014Jason Coombs
This document is a letter from the co-founder and CEO of Public Startup Company addressing challenges with the SEC's proposed rules for crowdfunding under Regulation Crowdfunding. The letter argues that the rules do not provide enough clarity or legal protection for media companies to publish advertisements for securities offerings under the JOBS Act. It urges the SEC to establish a clear safe harbor allowing general solicitation and advertising of unregistered offerings as long as they cite and comply with the JOBS Act. It contends this is necessary to achieve the goals of the JOBS Act in promoting capital formation and reducing barriers to raising money. Screenshots are included showing social media platforms like Twitter currently prohibit securities advertising, and the letter says the SEC rules
JOBS Act Rulemaking Comments on SEC File Number S7-09-13 Dated February 11, 2014Jason Coombs
This letter comments on proposed SEC rules for crowdfunding under Title III of the JOBS Act. It argues that the SEC rules insert more SEC control over capital raising rather than eliminating SEC involvement as mandated by Congress. The letter calls for eliminating the SEC and replacing it with state-level securities regulation to reduce costs and comply with the intent of the JOBS Act to give issuers more freedom to raise capital. It asserts the SEC rules threaten economic freedom and could result in civil conflict if reasonable crowdfunding rules are not implemented.
JOBS Act Rulemaking Comments on SEC File Number S7-09-13 Dated February 3, 2014Jason Coombs
This letter from the CEO of Public Startup Company summarizes previous correspondence between the CEO and the SEC regarding proposed rules for crowdfunding under the JOBS Act. The CEO argues that the SEC's proposed rules do not properly eliminate fear of government reprisal for unregistered securities offerings and instead seem designed to protect the SEC and guarantee work for former SEC attorneys. The CEO believes the SEC should be abolished if it does not stop interfering with capital formation and people's freedoms as mandated by Congress in the JOBS Act.
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