April 14, 2010

The staff of the Securities and Exchange Commission (SEC) has received credible information suggesting that an individual named Eric Bartoli, who was previously sued by the SEC for securities fraud, may currently be located in Peru and engaged in securities solicitations of investors, using the alias Enrico Orlandini. The staff’s information indicates that Bartoli/Orlandini is operating through a company named DT Analysis a/k/a Dow Theory Analysis SAC. Investors who are solicited by these named persons or entities should take steps to satisfy themselves that the offer is legitimate and complies with the law. Investors are encouraged to review the SEC publication “Ask Questions” and other SEC publications located at http://www.sec.gov/investor.shtml before making any investment. Some questions investors may consider asking include:

• Is this investment product registered with the SEC and my state securities agency?
• Where can I get more information about this investment? Can I get the latest reports filed by the company with the SEC: a prospectus or offering circular, or the latest annual report and financial statements?
• Are you registered with our state securities regulator? Have you ever been disciplined by the SEC, a state regulator, or other organization (such as the Financial Industry Regulatory Authority (FINRA) or one of the stock exchanges)?

For more information about the SEC’s prior enforcement action against Bartoli, see Securities and Exchange Commission v. Latin American Services Co., Ltd., Cyprus Funds, Inc., Eric V. Bartoli, Douglas R. Shisler, James L. Binge And Peter J. Esposito, Case No. 99-2360-CIV-UNGARO-BENAGES (S.D. Fla.) Litigation Release No. 16768 / October 16, 2000, available at: http://www.sec.gov/litigation/litreleases/lr16768.htm, and Advisers Act Release No. 1995/November 7, 2001, available at: http://www.sec.gov/litigation/admin/ia-1995.htm. Bartoli was also the subject of a criminal action by the U.S. Department of Justice. See U.S. v. Bartoli, 5:03 CR 387, October 16, 2003 (N.D. Ohio).

LIMITATIONS OF THIS WARNING

The staff of the Division of Enforcement, Office of International Affairs, and Office of Investor Education and Advocacy are providing this Investor Warning as a service to investors. This Investor Warning should not be construed as indication that any determination has been made regarding whether the person or entities identified in this Investor Warning are engaged in wrongdoing or violation of law, or as indication of whether the SEC is investigating, or will investigate the persons or conduct identified in this Investor Warning. Additionally, investors should be aware that the names identified on this Investor Warning are not necessarily exhaustive.