Wayne M. Carlin (WC-2114)
Regional Director
Northeast Regional Office
SECURITIES AND EXCHANGE COMMISSION
233 Broadway
New York, New York 10048
(646) 428-1500
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
SECURITIES AND EXCHANGE COMMISSION,
Plaintiff, :
:
v. : 2002 Civ. ____ ( )
:
AMERICA IN LINE CORPORATION, AMERICA : COMPLAINT
IN LINE OF MOUNT SINAI CORP., and :
PETER RICCARDO, :
Defendants.
Plaintiff Securities and Exchange Commission ("Commission"), for its Complaint against
Defendants America In Line Corporation ("America In Line"), America In Line of Mount
Sinai Corp. ("Mount Sinai") and Peter Riccardo ("Riccardo"), alleges as follows.
PRELIMINARY STATEMENT
1. This action involves a scheme through which the Defendants raised at least $650,000
from approximately 52 investors by offering and selling stock in America In Line and its
subsidiary, Mount Sinai. Between approximately March 1996 and May 2000, Riccardo,
America In Line and Mount Sinai fraudulently offered and sold shares of America In
Line and Mount Sinai stock in at least five unregistered offerings to investors throughout
the United States. America In Line and its subsidiary Mount Sinai conducted purported
private placements of over two million shares of common and preferred stock in the
companies at prices ranging from $1 to $2.50 per share. The offerings were fraudulent
because an excessive portion of the offering proceeds - some 29% - went to telemarketers
as sales commissions for soliciting investors.
2. America In Line, Mount Sinai, and Riccardo deceived investors about the anticipated
use of the offering proceeds. America In Line and Mount Sinai, directed by Riccardo,
SNIPPETS:
SECURITIES AND EXCHANGE COMMISSION
New York, New York 10048
AMERICA IN LINE CORPORATION, AMERICA: COMPLAINT
Plaintiff Securities and Exchange Commission, for its Complaint against Defendants America In
This action involves a scheme through which the Defendants raised at least $650,000 from
Between approximately March 1996 and May 2000, Riccardo, America In Line and Mount Sinai
The offerings were fraudulent because an excessive portion of the offering proceeds - some
These agreements rendered false and misleading the representations made to investors in the
The first two offering memoranda said nothing about the use of offering proceeds to pay sales
Defendants America In Line, Mount Sinai, and Riccardo have engaged, and unless permanently
Unless they are permanently enjoined, America In Line, Mount Sinai, and Riccardo will
The Commission brings this action under Section 20 of the Securities Act, 15 U.S.C. § 77t,
ities registered pursuant to Section 12 of the Exchange Act, 15 U.S.C. § 78l, or that is required
Neither of the two offering memoranda disclosed, however, that Riccardo and Mount Sinai had
The omissions and misrepresentations set forth in paragraphs 14 to 17 above were and are
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