UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

ADMINISTRATIVE PROCEEDING 

File No. 3-18171

In the Matter of

Jeremy A. Licht d/b/a 

JL Capital Management,

Respondent.

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PROPOSED PLAN OF DISTRIBUTION

I. Overview 

1. Purpose. The Division of Enforcement (“Division”) submits this proposed plan 

of distribution (the “Plan”) pursuant to Rule 1101 of the Commission’s Rules on Fair Fund and 

Disgorgement Plans (“Commission’s Rules”), 17 C.F.R. § 201.1101. As described more 

specifically below, the Plan provides for the distribution of the disgorgement, prejudgment 

interest, and civil money penalty paid Jeremy A. Licht, d/b/a JL Capital Management (“Licht” or 

“Respondent”) in the above-captioned administrative proceedings.

2. Structure of Plan. The structure of this Plan is based on the non-transparent 

nature of the “cherry-picking” violation and the need to conduct a cost-effective in-house 

distribution given the small size of the fund. The Plan does not provide for a claims process or 

dispute resolution process because: (a) the “cherry-picking” scheme is by its nature a nontransparent fraud; (b) investors are not aware of the harm suffered nor do they have access to the 

trading data from the cherry-picking scheme; (c) investors do not have the information, some of 

which is nonpublic, to calculate the harm caused by the cherry-picking scheme; and (d) investors 

will only be aware of their harm/losses when they receive a distribution check based upon the 

harm calculations performed by the Commission staff as part of their investigation.

3. Background. On September 12, 2017, the Commission issued an Order

Instituting Administrative and Cease-and-Desist Proceedings Pursuant to Section 21C of the 

Securities Exchange Act of 1934, Sections 203(f) and 203(k) of the of the Investment Advisers 

Act of 1940, and Section 9(b) of the Investment Company Act of 1940, Making Findings, and 

Imposing Remedial Sanctions and a Cease-and-Desist Order (the “Order”)1against Licht, a

former California registered investment adviser.

 

1

Exchange Act Rel. No. 81584 (Sept. 12, 2017).
2

In the Order, the Commission found that, from at least January 2011 to November 2015, 

Licht engaged in a fraudulent trade allocation scheme, or “cherry-picking” that harmed his 

advisory clients. Licht allocated a disproportionate number of favorable trades (i.e., trades that 

had a positive first-day return) to his own account and allocated a disproportionate number of 

unfavorable trades (i.e., trades that had a negative first-day return) to his clients’ accounts over 

which he had discretionary authority. He generally traded the same securities for his clients’ 

accounts and his personal accounts. Licht used two broker dealers as custodians for all accounts 

under his management at different times during the relevant period. From January 2011 to 

September 2012, Broker 1 was custodian for the accounts under Licht’s management. Broker 1 

terminated the relationship with Licht in August 2012 (effective October 2012) because they 

suspected that Licht was improperly allocating trades on their trading platform. Licht then 

moved his business to Broker 2’s platform, where he continued the “cherry picking” scheme 

until Broker terminated its relationship with Licht in March 2016. 

Licht executed this scheme by trading in an omnibus account and delaying allocation of 

those trades to a specific account until he had an opportunity to observe the security’s intraday 

performance. In many cases, when the price of a stock rose on the purchase date, Licht sold the 

security the same day, locking in a day-trading profit that he allocated to himself. By contrast, 

Licht disproportionately allocated purchases that were not profitable on the purchase date to 

clients. Licht often waited several hours and/or until after the close of the trading day to allocate 

trades from his omnibus account. Licht’s cherry-picking financially benefited him and 

disadvantaged his clients.

The Commission ordered Licht to pay disgorgement of $88,504.00, prejudgment interest 

of $8,714.34 and a civil penalty of $181,071.00. In the Order, the Commission also created a 

fair fund, pursuant to Section 308(a) of the Sarbanes-Oxley Act of 2002, so the penalty paid, 

along with the disgorgement and prejudgment interest, can be distributed to harmed investors

(the “Fair Fund”). 

Licht paid the full total of $278,289.34, pursuant to the Order. The Fair Fund is currently 

deposited in an interest-bearing account at the United States Department of the Treasury’s 

Bureau of Fiscal Service (“BFS”). All BFS fees and expenses will be paid by the Fair Fund. 

Other than potential interest income from the BFS investment, the Commission does not 

anticipate that the Fair Fund will receive any additional funds. If any additional funds are 

received, those funds will be sent to the U.S. Treasury and not be distributed. 

This Plan provides for the distribution of the Fair Fund, less the Reserve, defined in 

paragraph 7 below (“Net Fair Fund”), to those Eligible Investors, as defined in paragraph 12

below. The Fund Administrator has determined that the total amount (including interest) that 

will be distributed to Eligible Investors who suffered harm will be $101,791.46.

4. Jurisdiction and Control. The assets of the Fair Fund are subject to the 

continuing jurisdiction and control of the Commission. The Plan is subject to approval by the 

Commission, and the Commission retains jurisdiction over its implementation. 

II. Administration of the Plan
3

5. Fund Administrator. Noel Gittens is proposed to be the fund administrator for the 

Fair Fund (“Fund Administrator”). As a Commission employee, the Fund Administrator shall 

receive no compensation for his services in administering the Fair Fund, other than his regular 

salary as a Commission employee. In accordance with Rule 1105(c) of the Commission’s 

Rules,2no bond is required since the Fund Administrator is a Commission employee. 

The Fund Administrator will, among other things: oversee the administration of the Fair 

Fund; obtain contact and mailing information for the Eligible Investors; distribute money from 

the assets of the Fair Fund to Eligible Investors in accordance with the Plan; resolve payment

issues, prepare a final accounting; and provide the Tax Administrator with funds to pay tax 

liabilities and tax compliance fees and costs. The Fund Administrator will engage a third party 

to perform some of the administrative tasks associated with implementing the Plan (the “ThirdParty”). The Fund Administrator may be removed at any time by order of the Commission or 

hearing officer. 

6. Tax Administrator. Pursuant to the Omnibus Order Directing the Appointment of 

Tax Administrator in Administrative Proceedings that Establish Distribution Funds beginning 

June 30, 2017 through the 2018 calendar year,3the Commission appointed Miller Kaplan Arase 

LLP as the tax administrator (the “Tax Administrator”) for the Fair Fund.4Further, the Fund 

Administrator will cooperate with the Tax Administrator for purposes of timely and accurately 

fulfilling the information reporting and withholding obligations of the Fair Fund in compliance 

with IRS regulations, including but not limited to the Foreign Account Tax Compliance Act 

(“FATCA”). The Tax Administrator shall prepare a description of the tax information reporting 

and other related tax matters, which shall be provided to the Fund Administrator for 

dissemination to Eligible Investors before or contemporaneously with their distribution 

payments. The Tax Administrator shall be compensated for all reasonable costs and expenses 

from the Fair Fund according to the terms of Tax Administrator’s Revised 2017-2018 Letter 

Agreement with the Commission, and tax obligations will be paid out of the Fair Fund.

7. Reserve. A reserve is established for (a) future taxes and the fees and expenses of 

the Tax Administrator in the amount of $14,000.00, and (b) administrative expenses of the 

Third-Party engaged to assist the Fund Administrator in implementing the Plan in the amount of 

$5,144.00 (the “Reserve”). The Reserve will be $19,144.00. After the distribution is completed, 

any remaining amounts in the Reserve will become part of the Residual described in paragraph 

20 below.

8. Qualified Settlement Fund. The Fair Fund constitutes a Qualified Settlement 

Fund under Section 468B(g) of the Internal Revenue Code, 26 U.S.C. § 468B(g), and related 

regulations, 26 C.F.R. §§ 1.468B-1 through 1.468B-5. 

III. Plan Procedures 

 

2

17 C.F.R. § 201.1105(c).

3 Exchange Act Rel. No. 81057 (June 30, 2017).

4 Exchange Act Rel. No. 83068 (Apr. 19, 2018).
4

9. No Claims and Dispute Resolution Process. Based on information obtained by 

the Commission staff during its investigation and the review and analysis of applicable records, 

the Commission staff reasonably concluded that it had all records necessary to identify investors 

and calculate harm, but such records were not available to investors. As a result, the Fair Fund is 

not being distributed according to a claims-made process, so procedures for making, approving 

and disputing claims are not applicable.

10. Specification of Potentially Eligible Investors. The Fair Fund shall be distributed

to the harmed investors identified by Commission staff during its investigation of the underlying 

securities violations. An investor is deemed harmed only if that investor was determined, 

pursuant to the methodology described in paragraph 11, to have an account that sustained a loss 

from January 1, 2012 to March 31, 2016 (the “Investment Period”) due to the “cherry-picking”

scheme, detailed in the Order. Based on its investigation, Commission staff identified ninety 

three (93) investor accounts that were potentially harmed (“Potentially Eligible Investors”).

11. Methodology Used to Determine Distribution Amounts. The Fund Administrator

shall determine the amount to be distributed to each Potentially Eligible Investor by calculating 

the loss for each Potentially Eligible Investor account as the difference between the First-day 

Profit that the customer account actually earned over the Investment Period and the estimated 

non-scheme First-day Profit that the customer account would have earned without the 

preferential trade allocation scheme. First-day Profit on a security purchase is calculated as the 

number of shares purchased for the account multiplied by either (a) the sale price per share less 

the purchase price per share if the security was sold on the same day as the purchase, or (b) the 

closing price on the day the shares were purchased less the purchase price per share if the 

security was not sold on the same day. The total First-day Profit for an account is the sum of 

First-day Profits across all purchases in the account during the Investment Period. Distributable 

amounts shall be determined, in the following manner:

a. Calculation of the first-day return weighted by purchase amount for all trading 

during the period January 2012 to September 2012 (“Trading Period 1”) for all 

customer accounts (favored and non-favored accounts) without the preferential 

trade allocation scheme, which is equal to -1.396% (“the non-scheme first-day 

return”) for Trading Period 1;

b. Calculation of the first-day return weighted by purchase amount for all trading 

during the period October 2012 to March 2016 (“Trading Period 2”) for all 

customer accounts (favored and non-favored accounts) without the preferential 

trade allocation scheme, which is equal to -0.215% (“the non-scheme first-day 

return”) for Trading Period 2;

c. Calculate the non-scheme First-day Profit that each customer account would have 

earned without preferential trade allocations as the dollar value of purchases in the 

customer account over the Investment Period times the non-scheme first-day 

returns of -1.396% and -0.215%, respectively for Trading Periods 1 and 2;
5

d. Calculate the estimated loss or gain for each customer account, during Trading 

Periods 1 and 2, attributable to the preferential trade allocation scheme as the 

difference between the calculated non-scheme first-day loss or gain for the 

account and the total First-Day Profit for each customer account (“Net Harm”);

e. Each account will be paid reasonable interest on its Net Harm, calculated using 

the short-term Applicable Federal Rate compounded quarterly from the midpoint 

of the trading period in which the harm occurred through August 31, 2019. 

f. The Distribution Payment for each account will be the Net Harm plus the 

reasonable interest amount.

g. Accounts with a Net Harm of less than $10.00 are excluded from the distribution.

Excluding all customer accounts with gains attributable to the preferential trade 

allocation scheme or which had a Net Harm less than $10.00, the Net Harm applicable to 

customer accounts that were defrauded because of the preferential trade allocation scheme is 

$34,089 for accounts during Trading Period 1 and $61,547 during Trading Period 2. The total 

Net Harm plus interest for all customer accounts (during Trading Periods 1 and 2) is 

$101,791.46. 

The Net Fair Fund available for distribution is greater than the total Net Harm suffered by 

all Eligible Investors. Accordingly, each Eligible Investor will receive a distribution amount 

from the Net Fair Fund equal to the full amount of loss sustained plus interest (the “Distribution 

Payment”). The Distribution Payment amounts are set forth in Exhibit A.

In the view of the Commission staff and the Fund Administrator, this methodology 

constitutes a fair and reasonable allocation of the Fair Fund to compensate an investor’s harm. It 

is anticipated that there will be one distribution, which will take place as described herein.

12. De Minimis Amount. Potentially Eligible Investors with a Net Harm totaling less 

than $10.00 (“De Minimis Amount”) will not be eligible for a Distribution Payment. The Fair 

Fund shall be distributed to the Potentially Eligible Investors whose Net Harm exceed the De 

Minimis Amount (“Eligible Investors”). After applying the De Minimis Amount, there are 

eighty-seven (87) Eligible Investors who will receive a distribution payment. 

13. Procedures for Locating and Notifying Certain Eligible Investors. From 

information obtained by the Commission staff based on the review and analysis of applicable 

records from its investigation, the Fund Administrator has identified the Eligible Investors as 

defined in paragraph 12 above. The Fund Administrator will coordinate with the Tax 

Administrator to obtain information that is needed to accomplish the distribution in accordance 

with applicable tax requirements relating to the Fair Fund. To the extent possible, within sixty 

(60) days of the publication of the Plan for notice and comment, requests will be sent to certain 

Eligible Investors whose tax information is uncertain, to supply IRS Forms W-8 or W-9 tax 

information, and such other information needed to ensure an efficient and accurate delivery of 
6

the full Distribution Payment (the “Request”). The Eligible Investor shall respond within thirty 

(30) days in order to receive a Distribution Payment.

14. Undeliverable Mail. If a Request and/or Distribution Payment is/are returned as 

undeliverable, best practicable efforts will be made to ascertain an Eligible Investor’s correct 

address. If another address is obtained, the Request and/or Distribution Payment will be resent

to the Eligible Investor’s new address. Despite best practicable efforts, if an Eligible Investor’s

correct address is not obtained, the Fund Administrator may remove such Eligible Investor from 

the distribution. 

15. Distribution Timing. The Fund Administrator will use his best efforts to start the 

distribution within ninety (90) days of the Commission’s approval of the Plan.

16. Distribution Payments. The Fund Administrator will make arrangement for and 

oversee the transfer of funds to the Third-Party who is responsible for depositing the funds in an 

account at a commercial bank not unacceptable to the Fund Administrator in order to issue 

Distribution Payment checks. All Distribution Payment checks presented for payment or 

electronic transfer will be subject to “positive pay” controls before being honored by the bank, 

and all such checks issued shall bear a stale date of ninety (90) days. Accordingly, checks that 

are not negotiated within this ninety (90) day period shall be voided and the issuing financial 

institution shall be instructed to stop payment on those checks. An investor’s claim to payment 

is extinguished as of the stale date and the funds will remain in the Fair Fund. A check reissue 

request should be made within ninety (90) days from the original check issuance date as 

instructed in the mailing with the check. 

All Distribution Payments shall be preceded or accompanied by a communication that 

includes, as appropriate: (a) a statement characterizing the distribution; (b) a statement that the 

tax treatment of the distribution is the responsibility of each recipient and that the recipient 

should consult his or her tax advisor for advice regarding the tax treatment of the distribution; (c) 

a statement that checks will be void after ninety (90) days; and (d) the name of a person or entity 

to contact, if the Eligible Investor has any questions regarding the distribution. Any such 

communication shall be submitted to the Commission staff and the Tax Administrator for review 

and approval. The Fair Fund Distribution Payments, on their face, or the accompanying mailing 

shall clearly indicate that the money is being distributed from a Fair Fund established by the 

Commission to compensate investors for harm as a result of the Respondent’s conduct described 

in the Order.

17. Disbursement of the Fair Fund. Pursuant to Rule 1101(b)(6) of the 

Commission’s Rules, 17 C.F.R. § 201.1101(b)(6), the Fund Administrator will obtain an order 

from the Commission to disburse the Fair Fund. Pursuant to the order, the Commission’s Office 

of Financial Management (“OFM”) will transfer funds to the Third-Party for issuance of 

Distribution Payment checks.

18. Amendments and Procedural Deadline Extensions. The Fund Administrator will 

take reasonable and appropriate steps to distribute the Net Fair Fund according to the Plan. If 

there are any changes to the Plan that are determined to be material, Commission approval is 
7

required prior to implementation by amending the Plan. Immaterial changes may be made by the 

Fund Administrator. For good cause shown, the Fund Administrator, in consultation with the 

Commission staff, may extend any of the procedural dates set forth in the Plan. 

19. Procedures for Investor Inquiries. Eligible Investor inquiries will be limited to

questions regarding the calculations of disbursement amounts. The Fund Administrator will 

investigate and respond to any inquiry within thirty (30) days of receipt of the inquiry. The Fund 

Administrator’s resolution will be conclusive and final. 

20. Disposition of Undistributed Funds. A residual account within the Fair Fund will 

be established for any amounts remaining after the disbursement to Eligible Investors from the 

Fair Fund. The residual account may include funds from the unused Reserve, distribution checks 

that have not been cashed, checks that were not delivered or returned to the Fund Administrator, 

and Fair Fund tax refunds for overpayment or for waiver of IRS penalties. All funds remaining 

in the residual account will be transferred to the U.S. Treasury after the final accounting is 

approved by the Commission. 

21. Accountings. When all funds have been disbursed, except for the residual 

described in paragraph 20 above, the Fund Administrator will submit a final accounting pursuant 

to Rule 1105(f) of the Commission’s Rules, 17 C.F.R. § 201.1105(f), for the approval of the 

Commission prior to termination of the Fair Fund and discharge of the Fund Administrator. 

Since the funds are being held in a Commission designated account at the U.S. Treasury and the 

proposed Fund Administrator is a Commission employee, no interim accountings will be made. 

22. Termination of the Fair Fund. Following the completion of the distribution from 

the Net Fair Fund to Eligible Investors, the Fund Administrator will make arrangement for the 

final payment of taxes, Tax Administrator fees and expenses, and other administration expenses 

and will submit a final accounting to the Commission. The Fair Fund will be eligible for 

termination after all of the following have occurred: (a) a final accounting, appearing on the 

standard accounting form utilized by the Commission staff, has been submitted by the Fund 

Administrator, and has been approved by the Commission; and (b) all taxes, fees and expenses

have been paid. Upon Commission approval of the final accounting, Commission staff will seek 

an order from the Commission to: (a) transfer the remaining residual amount, and any amounts 

returned to the Fair Fund in the future, to the U.S. Treasury; (b) terminate the Fair Fund; and (c) 

discharge the Fund Administrator. 

IV. Notice of Proposed Plan and Opportunity for Comment

23. Notice for Comment. The Notice of Proposed Plan of Distribution (the “Notice”) 

will be published on the Commission’s website at http://www.sec.gov/litigation/fairfundlist.htm. 

Any person wishing to comment on the Plan must do so in writing by submitting their comments 

to the Commission within thirty (30) days from the date of the Notice: (a) to the Office of the 

Secretary, United States Securities and Exchange Commission, 100 F Street, NE, Washington, 

DC 20549-1090; (b) by using the Commission’s Internet comment form 

(www.sec.gov/litigation/admin.shtml); or (c) by sending an e-mail to rule-comments@sec.gov. 

Comments submitted by email or via the Commission’s website should include “Administrative 
8

Proceeding File Number 3-18171” in the subject line. Comments received will be publicly 

available. Persons should only submit comments that they wish to make publicly available.
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EXHIBIT A

DISTRIBUTION CHART

Eligible Investor Trading 

Period Net Harm Reasonable Interest

Distribution 

Amount

Eligible Investor # 1 1 $14,151.39 $940.08 $15,091.47 

Eligible Investor # 2 1 $6,915.81 $459.42 $7,375.23 

Eligible Investor # 3 1 $6,604.66 $438.75 $7,043.41 

Eligible Investor # 4 1 $6,150.88 $408.60 $6,559.48 

Eligible Investor # 5 1 $4,586.02 $304.65 $4,890.67 

Eligible Investor # 6 1 $3,775.27 $250.79 $4,026.06 

Eligible Investor # 7 1 $3,054.05 $202.88 $3,256.93 

Eligible Investor # 8 1 $2,772.46 $184.17 $2,956.63 

Eligible Investor # 9 1 $2,205.99 $146.54 $2,352.53 

Eligible Investor # 10 1 $1,799.88 $119.57 $1,919.45 

Eligible Investor # 11 1 $1,760.83 $116.97 $1,877.80 

Eligible Investor # 12 1 $1,033.33 $68.64 $1,101.97 

Eligible Investor # 13 1 $735.06 $48.83 $783.89 

Eligible Investor # 14 1 $539.55 $35.84 $575.39 

Eligible Investor # 15 1 $498.22 $33.10 $531.32 

Eligible Investor # 16 1 $475.26 $31.57 $506.83 

Eligible Investor # 17 1 $388.35 $25.80 $414.15 

Eligible Investor # 18 1 $381.52 $25.34 $406.86 

Eligible Investor # 19 1 $268.65 $17.85 $286.50 

Eligible Investor # 20 1 $244.48 $16.24 $260.72 

Eligible Investor # 21 1 $227.68 $15.12 $242.80 

Eligible Investor # 22 1 $197.46 $13.12 $210.58 

Eligible Investor # 23 1 $172.03 $11.43 $183.46 

Eligible Investor # 24 1 $134.66 $8.95 $143.61 

Eligible Investor # 25 1 $129.02 $8.57 $137.59 

Eligible Investor # 26 1 $126.99 $8.44 $135.43 

Eligible Investor # 27 1 $125.55 $8.34 $133.89 

Eligible Investor # 28 1 $119.25 $7.92 $127.17 

Eligible Investor # 29 1 $117.01 $7.77 $124.78 

Eligible Investor # 30 1 $116.43 $7.73 $124.16 

Eligible Investor # 31 1 $113.78 $7.56 $121.34 

Eligible Investor # 32 1 $103.55 $6.88 $110.43 
10

Eligible Investor Trading 

Period Net Harm Reasonable Interest

Distribution 

Amount

Eligible Investor # 33 1 $98.33 $6.53 $104.86 

Eligible Investor # 34 1 $92.99 $6.18 $99.17 

Eligible Investor # 35 1 $88.92 $5.91 $94.83 

Eligible Investor # 36 1 $86.31 $5.73 $92.04 

Eligible Investor # 37 1 $84.37 $5.60 $89.97 

Eligible Investor # 38 1 $75.48 $5.01 $80.49 

Eligible Investor # 39 1 $73.17 $4.86 $78.03 

Eligible Investor # 40 1 $71.43 $4.75 $76.18 

Eligible Investor # 41 1 $66.85 $4.44 $71.29 

Eligible Investor # 42 1 $61.76 $4.10 $65.86 

Eligible Investor # 43 1 $51.13 $3.40 $54.53 

Eligible Investor # 44 1 $47.86 $3.18 $51.04 

Eligible Investor # 45 1 $45.02 $2.99 $48.01 

Eligible Investor # 46 1 $43.73 $2.91 $46.64 

Eligible Investor # 47 1 $40.11 $2.66 $42.77 

Eligible Investor # 48 1 $37.75 $2.51 $40.26 

Eligible Investor # 49 1 $35.91 $2.39 $38.30 

Eligible Investor # 50 1 $33.56 $2.23 $35.79 

Eligible Investor # 51 1 $32.49 $2.16 $34.65 

Eligible Investor # 52 1 $30.77 $2.04 $32.81 

Eligible Investor # 53 1 $27.63 $1.84 $29.47 

Eligible Investor # 54 1 $27.29 $1.81 $29.10 

Eligible Investor # 55 1 $26.60 $1.77 $28.37 

Eligible Investor # 56 1 $24.98 $1.66 $26.64 

Eligible Investor # 57 1 $24.97 $1.66 $26.63 

Eligible Investor # 58 1 $21.99 $1.46 $23.45 

Eligible Investor # 59 1 $21.16 $1.41 $22.57 

Eligible Investor # 60 1 $20.97 $1.39 $22.36 

Eligible Investor # 61 1 $19.73 $1.31 $21.04 

Eligible Investor # 62 1 $18.67 $1.24 $19.91 

Eligible Investor # 63 1 $17.14 $1.14 $18.28 

Eligible Investor # 64 1 $15.42 $1.02 $16.44 

Eligible Investor # 65 1 $12.58 $0.84 $13.42 

Eligible Investor # 66 1 $12.11 $0.80 $12.91 

Eligible Investor # 67 1 $11.69 $0.78 $12.47 
11

Eligible Investor Trading 

Period Net Harm Reasonable Interest

Distribution 

Amount

Eligible Investor # 68 1 $10.52 $0.70 $11.22 

Eligible Investor # 69 1 $10.40 $0.69 $11.09 

Eligible Investor # 70 2 $6,437.13 $390.28 $6,827.41 

Eligible Investor # 71 2 $5,946.69 $360.55 $6,307.24 

Eligible Investor # 72 2 $3,842.06 $232.94 $4,075.00 

Eligible Investor # 73 2 $2,555.20 $154.92 $2,710.12 

Eligible Investor # 74 2 $2,428.91 $147.26 $2,576.17 

Eligible Investor # 75 2 $2,392.44 $145.05 $2,537.49 

Eligible Investor # 76 2 $2,286.32 $138.62 $2,424.94 

Eligible Investor # 77 2 $1,823.70 $110.57 $1,934.27 

Eligible Investor # 78 2 $1,619.43 $98.19 $1,717.62 

Eligible Investor # 79 2 $1,420.43 $86.12 $1,506.55 

Eligible Investor # 80 2 $1,192.56 $72.30 $1,264.86 

Eligible Investor # 81 2 $1,022.70 $62.01 $1,084.71 

Eligible Investor # 82 2 $465.25 $28.21 $493.46 

Eligible Investor # 83 2 $191.86 $11.63 $203.49 

Eligible Investor # 84 2 $191.86 $11.63 $203.49 

Eligible Investor # 85 2 $168.72 $10.23 $178.95 

Eligible Investor # 86 2 $66.18 $4.01 $70.19 

Eligible Investor # 87 2 $37.76 $2.29 $40.05 

Totals $95,636.09 $6,155.37 $101,791.46