Blackthorn Investment Group, Llc

Allegations: THE REGULATORY ACTION RELATED TO ALLEGED VIOLATIONS OF RULE 105 OF REGULATION M UNDER THE SECURITIES EXCHANGE ACT OF 1934. RULE 105 GENERALLY PROHIBITS BUYING AN EQUITY SECURITY IN A SECONDARY PUBLIC OFFERING IF THE BUYER SOLD SHORT THE SAME SECURITY DURING A RESTRICTED PERIOD (GENERALLY DEFINED AS FIVE BUSINESS DAYS BEFORE THE PRICING OF THE OFFERING), REGARDLESS OF WHETHER ANY INTENT TO VIOLATE THE RULE EXISTED. Status: Final Sanction Detail: THE CIVIL PENALTY OF $260,000, DISGORGEMENT OF $244,378.24 AND PREJUDGEMENT INTEREST OF $15,829.74 WAS PAID TO THE UNITED STATES TREASURY ON SEPTEMBER 20, 2013 Summary: ON OR ABOUT SEPTEMBER 16, 2013, BLACKTHORN AGREED, WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS, TO A SETTLEMENT WITH THE SEC RELATING TO RULE 105 OF REGULATION M UNDER THE SECURITIES EXCHANGE ACT OF 1934. RULE 105 GENERALLY PROHIBITS BUYING AN EQUITY SECURITY IN A SECONDARY PUBLIC OFFERING IF THE BUYER SOLD SHORT THE SAME SECURITY DURING A RESTRICTED PERIOD. THIS PROHIBITION CONTAINED IN RULE 105 OF REGULATION M APPLIES REGARDLESS OF WHETHER ANY INTENT TO VIOLATE THE RULE EXISTED. BLACKTHORN AGREED NOT TO VIOLATE RULE 105 IN THE FUTURE AND PAY DISGORGEMENT OF $244,378,24, PREJUDGMENT INTEREST OF $15,829.74, AND A CIVIL MONEY PENALTY IN THE AMOUNT OF $260,000.00 TO THE UNITED STATES TREASURY. BLACKTHORN MADE SUCH PAYMENTS ON SEPTEMBER 20, 2013, AND NO FUND OR OTHER CLIENT OF BLACKTHORN BORE ANY PORTION OF SUCH PAYMENTS OR ANY COSTS RESOLVING THE MATTER.