Wayne M. Carlin (WC-2114)
Regional Director
Northeast Regional Office
SECURITIES AND EXCHANGE COMMISSION
233 Broadway
New York, New York 10279
(646) 428-1500
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
SECURITIES AND EXCHANGE COMMISSION
:
Plaintiff, :
:
v. : 02 Civ. ______ ( )
:
INTRACOM CORPORATION, HYPERBARIC :
SYSTEMS, INC., SURGICA CORPORATION, COMPLAINT
:
ALFRED BRAUNBERGER, HARRY MASUDA, :
LOUIS MATSON, LARRY BRYANT, COMCO, INC. :
AND PAUL MAROTTA, :
Defendants.
Plaintiff Securities and Exchange Commission ("Commission"), for its Complaint against
Defendants Intracom Corporation ("Intracom"), Hyperbaric Systems, Inc. ("Hyperbaric"),
Surgica Corporation ("Surgica"), Alfred Braunberger ("Braunberger"), Harry Masuda
("Masuda"), Louis Matson ("Matson"), Larry Bryant ("Bryant"), Comco, Inc. ("Comco"),
and Paul Marotta ("Marotta"), alleges as follows:
SUMMARY
1. This action involves fraudulent schemes to offer and sell securities in Intracom,
Hyperbaric and Surgica, companies that develop technology for medicine, including
medical devices and software for health care professionals. In offerings coordinated
through defendant Bryant, an unregistered securities broker, the defendants raised over
$13 million in aggregate from approximately 670 investors between 1997 and 2000.
These offerings were fraudulent because the defendants used an excessive portion of the
offering proceeds to pay commissions to Bryant and telemarketers for soliciting
investors. Not only did the defendants fail to disclose these excessive commissions to
SNIPPETS:
SECURITIES AND EXCHANGE COMMISSION
UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK
LOUIS MATSON, LARRY BRYANT, COMCO, INC.:
This action involves fraudulent schemes to offer and sell securities in Intracom, Hyperbaric
In offerings coordinated through defendant Bryant, an unregistered securities broker, the
These offerings were fraudulent because the defendants used an excessive portion of the
These offering materials stated that the issuers would use approximately 12% of the offering
In fact, however, each of the three issuers had agreed to pay Bryant a commission of 25%,
Defendants Intracom, Braunberger, Hyperbaric, Masuda, Surgica, Matson, Bryant and Comco, have
Defendant Bryant has engaged in, and unless enjoined, will continue to engage directly or
Defendant Marotta knowingly aided and abetted Bryant, Comco, Intracom, Hyperbaric, Surgica,
Hyperbaric is a California corporation that was incorporated in February 1998 and maintains
The offering memoranda distributed to investors in connection with Intracom's second and
The agreements to pay Bryant 25% commissions rendered materially false Intracom's
The misrepresentations set forth in paragraphs 21 to 25 above were and are material.
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