Charles
Jordan Simons and Kenin Spivak had a consulting agreement with Traffic Monsoon to help get PayPal to release the funds due to a sudden PayPal limitation. They lined Traffic Monsoon up with a former US Attorney named Dennis Burke (also previous years of experience in the Dept of Justice), who reviewed the business model of Traffic Monsoon, and the terms of service of PayPal. Not only did Dennis Burke find nothing wrong with the Traffic Monsoon business model, but he also found that Traffic Monsoon did not break a single term of service within the PayPal user agreement. When I flew out to California to meet with Kenin Spivak and Jordan Simons, I sat down in Kenin's home where I asked the direct question: Is Traffic Monsoon a ponzi, or doing anything wrong? Kenin went on to explain how it definitely was not a ponzi, and described purchases that give benefits to the customer such as airline tickets providing miles to the buyer. He recognized the revenue sharing position was simply a tracking mechanism and not a "share" in the company. When a customer who buys this service surfs ads and by surfing ads qualifies, they are rewarded for surfing. In all honest truth, Traffic Monsoon has never positioned its services as investments. There has never been any promise of returns. There is a cap placed on surf rewards, but no guarantee what they might be (if anything at all). After getting PayPal to release the funds, their next objective was to build up the business. They wanted to know various company statistics to discover areas of success and areas within the business which would need improvement to make the business better. Among the group is a former SEC attorney named Ed Swanson who reviewed the business model and said it wasn't a ponzi, but said (and did not specify) that some word choices could be improved in the explanation on the website to completely remove it from an area of misunderstanding. The same business model existed with AdHitProfits which was reviewed by the State of Utah Securities Division. They closed their file because a security was not involved. If AdHitProfits and TrafficMonsoon both have NOT been offering any investment on the website, any of my content, or at anytime verbally positioned anything offered on either of these websites as investments.. and all these professionals have reviewed the business model and through definition established there was no investment or security being offered... then why is the SEC labeling customers as "investors" ? Especially when the website expressly advises potential customers there is no refunds, and no promise of any returns? People who buy service on Traffic Monsoon are customers. Plain and simple. Not investors. In seeking attorneys for Traffic Monsoon through this civil case filed by the SEC, professionals such as Loren Washburn among others also listened to the business model explanation, and concluded that their opinion also is that there is no investment being offered, and it's not a security.
Jordan Simons and Kenin Spivak had a consulting agreement with Traffic Monsoon to help get PayPal to release the funds due to a sudden PayPal limitation. They lined Traffic Monsoon up with a former US Attorney named Dennis Burke (also previous years of experience in the Dept of Justice), who reviewed the business model of Traffic Monsoon, and the terms of service of PayPal. Not only did Dennis Burke find nothing wrong with the Traffic Monsoon business model, but he also found that Traffic Monsoon did not break a single term of service within the PayPal user agreement. When I flew out to California to meet with Kenin Spivak and Jordan Simons, I sat down in Kenin's home where I asked the direct question: Is Traffic Monsoon a ponzi, or doing anything wrong? Kenin went on to explain how it definitely was not a ponzi, and described purchases that give benefits to the customer such as airline tickets providing miles to the buyer. He recognized the revenue sharing position was simply a tracking mechanism and not a "share" in the company. When a customer who buys this service surfs ads and by surfing ads qualifies, they are rewarded for surfing. In all honest truth, Traffic Monsoon has never positioned its services as investments. There has never been any promise of returns. There is a cap placed on surf rewards, but no guarantee what they might be (if anything at all). After getting PayPal to release the funds, their next objective was to build up the business. They wanted to know various company statistics to discover areas of success and areas within the business which would need improvement to make the business better. Among the group is a former SEC attorney named Ed Swanson who reviewed the business model and said it wasn't a ponzi, but said (and did not specify) that some word choices could be improved in the explanation on the website to completely remove it from an area of misunderstanding. The same business model existed with AdHitProfits which was reviewed by the State of Utah Securities Division. They closed their file because a security was not involved. If AdHitProfits and TrafficMonsoon both have NOT been offering any investment on the website, any of my content, or at anytime verbally positioned anything offered on either of these websites as investments.. and all these professionals have reviewed the business model and through definition established there was no investment or security being offered... then why is the SEC labeling customers as "investors" ? Especially when the website expressly advises potential customers there is no refunds, and no promise of any returns? People who buy service on Traffic Monsoon are customers. Plain and simple. Not investors. In seeking attorneys for Traffic Monsoon through this civil case filed by the SEC, professionals such as Loren Washburn among others also listened to the business model explanation, and concluded that their opinion also is that there is no investment being offered, and it's not a security.