"On Monday, October 30, 2006, Mr. Brown and Mr. Dy

"On Monday, October 30, 2006, Mr. Brown and Mr. Dynkowski accepted an invitation from Jonathan Curshen, the owner of Red Sea Management, which in turn owns the firm Global Sentry Securities, to tour his headquarter office and see his operation in San Jose, Costa Rica. Red Sea Management and Global Sentry Securities of Costa Rica were customers of AIS Securities. These accounts were clients of Dan Landau and transferred in December, 2005 from Finance 500 when Mr. Landau joined AIS Securities as a registered representative. Matt Brown was provided office space at AIS Securities/Rubicon FinancialIncorporated in exchange for providing technology related services. In addition, Mr. Brown was building a new trading platform, through Mr. Brown's company Vertikal Technologies, Inc., for Rubicon Financial Incorporated.[11] Mr. Brown did not maintain his personal trading account at AIS Securities. "