STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION CASE NO. SECURITIES AND EXCHANGE COMMISSION, Plaintiff, v. ERICK LASZLO MATHE and ASHIF JIWA, Defendants, and BLUEMARK ASSET MANAGEMENT, LLC, Relief Defendant COMPLAINT Plaintiff Securities and Exchange Commission alleges as follows: I. INTRODUCTION 1. The Commission brings this action to enjoin Defendants Erick Laszlo Mathe and Ashif Jiwa from violating the antifraud and registration provisions of the federal securities laws in connection with their unregistered sale of securities of Vision Broadcast Network, Inc., a purported early-stage, operational start-up television network and production company. From no later than August 2007 through February 2010, Defendants raised approximately $5.7 million from at least 100 investors nationwide through the sale of common stock and convertible debentures of Vision Broadcast. 2. In connection with the offer, purchase and sale of these securities, Defendants misrepresented nearly all aspects of Vision Broadcast's purported assets and operations. Case 1:14-cv-23573-XXXX Document 1 Entered on FLSD Docket 09/26/2014 Page 1 of 27
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STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
CASE NO.
SECURITIES AND EXCHANGE COMMISSION,
Plaintiff,
v.
ERICK LASZLO MATHE and ASHIF JIWA,
Defendants,and
BLUEMARK ASSET MANAGEMENT, LLC,
Relief Defendant
COMPLAINT
PlaintiffSecurities and Exchange Commission alleges as follows:
I. INTRODUCTION
1. The Commission brings this action to enjoin Defendants Erick Laszlo Mathe and
Ashif Jiwa from violating the antifraud and registration provisions of the federal securities laws
in connection with their unregistered sale of securities of Vision Broadcast Network, Inc., a
purported early-stage, operational start-up television network and production company. From no
later than August 2007 through February 2010, Defendants raised approximately $5.7 million
from at least 100 investors nationwide through the sale of common stock and convertible
debentures ofVision Broadcast.
2. In connection with the offer, purchase and sale of these securities, Defendants
misrepresented nearly all aspects of Vision Broadcast's purported assets and operations.
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