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Defendant Park was a self-proclaimed Internet stock-picking guru, who operated an Internet web site through which investors paid monthly membership fees for stock recommendations and other investment advice. However, he allegedly defrauded members by failing to disclose that, in several instances, he had already purchased shares of the stock that he was recommending and planned to sell into the interest he generated. The Commission also charged that Park touted a company without disclosing that he had received shares of stock in exchange for his recommendation, and that the past performance results posted on the web site were materially false and misleading. This was a groundbreaking case, in applying the same duties and responsibilities to an internet business as applied to other investment advisers.