cudeco(cdu) trading - representations, page-53

Hi CDU'ers


Sent:6th October, 2012.
Subject: CuDeco(CDU) Trading - Representations

The following is the text of a letter that I have sent to Mr.Peter Cotter, APM, Detective Chief Superintendent,
Director, Serious Crime Directorate,State Crime Command, Parramatta NSW:- "Your ref. D/2012/28970, SCC 012-0177 CuDeco(CDU) Limited - Trading.

Dear Mr.Cotter,

Further to your letter of the 1st May, 2012, in response to my request for an investigation into the trading of CuDeco(CDU) Limited Securities, further research on the
“CuDeco Shareholder Research” Document has been undertaken.

Therefore, to give you an overview of the situation I have made a précis as to how I see the situation with CuDeco(CDU) Trading on the Australian Securities Exchange(ASX):-

CuDeco(CDU) Limited is a Junior Mining Company located in Cloncurry, Queensland.

The mining tenement is called Rocklands and to date has over 1 million tonnes of mineralisation, such as copper, gold and cobalt ready to be mined when all structures are completed. Mining is expected to start late 2013.

Since CuDeco(CDU) Limited started drilling at Rocklands in 2006, on most occasions when a good drilling announcement has been made by the Australian Securities Exchange(ASX), the CDU share price has been capped as a result of share churning by an unknown Group.

As a result,a “CuDeco Shareholder Research” Document has been developed by a CDU shareholder.

This Document can be downloaded on:-

http://www.s......com/cudeco_research/collections

Reports completed up to the present time reveal the need for a forensic examination of CDU Securities traded on the ASX. The Australian Securities and Investments Commission(ASIC), have indicated that they do not have unlimited resources, and have not acted. It would appear surveillance techniques used are not able to detect some forms of manipulation evident in trading as revealed by the research in the “CuDeco Shareholder Research” Document.

In Chapter 5.4 of the “CuDeco Shareholder Research” Document, the research has indicated that there is a need for a number of Audits into the following Issues of trading in CuDeco(CDU) Securities:-

Issue 1 The Dominance Over Trading by Institutions.

Issue 2 Transactions that bypass Normal Trading (i.e. Off Market).

Issue 3 Dominance Over Auction Pricing.

Issue 4 Dominance Over Price Movements (Up Ticks and Down Ticks).

Issue 5 Repetitive Selling into Significant Announcements.

Issue 6 Algorithmic Trading.

Issue 7 Confusion over the use of Broker Settlement Accounts.

Issue 8 Possible Loss Making Trading – Genuineness of Trading.

Issue 9 Short Selling.

Issue 10 Misinformation Related to ASX JORC Compliance.

Issue 11 18th August, 2110, Trading of CDU Securities on the ASX.

Issue 12 Regulatory Issues.


Chapter 5.4 - pages 3-13, give an excellent summary of the above 12 Issues.They make very compelling reading. Other areas of the Australian Securities Exchange may also be affected.

In addition, Chapter 6, Section 4 – pages 34-38, give an overview of Share Market Trends, Trading Behaviours and Market Trends over 2.5 years of CDU trading from January, 2010, through to June, 2012.


Some questions needing investigation are:-

1. How can such levels of Wash Trades evident in the trading of CDU not be viewed upon with suspicion?


2. What steps have been taken by the Australian Securities and Investments Commission(ASIC), to ensure that these Wash Trades are above board?

3. How can persistent data anomalies associated with shorting CDU, wher reported data doesn’t match daily trading or the register, be sanctioned by Authorities, when it clearly doesn’t add up and looks to short circuit price discovery by allowing covering off-market?

4. How can high volumes of Dark Trades be judged as not presenting market issues when clearly nothing is known about such activity?

5. Why has there not been an investigation by ASIC into an unsigned document “F..... S...........” circulated to subscribers about CDU around the 18th August, 2010?

6. Why the misinformation related to the ASX JORC Compliance?

7. Why no Forensic Audit of the trading of CDU Securities on the 18th August, 2010?


Thousands of people associated in some way with CuDeco(CDU) share trading have suffered as a result of financial losses and/or severe stress. It is incumbent that malpractice in the share market be eliminated by the Authorities responsible for the oversight of the ASX and the conduct of private businesses. So far there has not been any positive action by the Regulator(ASIC) into CDU trading.

Indeed, I do realize that all but one of the above questions are the responsibility of the Regulator the Australian Securities and Investments Commission(ASIC).

However, item 5 above, relating to an unsigned document “F..... S...........” circulated to subscribers about CDU around the 18th August, 2010, in my view indicates an intent to defraud CDU shareholders. A copy of the document and other relative comments as a result of the research undertaken is attached.

Shareholders like myself are especially vulnerable. We are entirely dependent and must therefore rely on the responsible Authority to ensure that justice is carried out,where any wrong has occurred with intent to defraud. As F..... S........... is a Company with Headquarters in Sydney, I request that you investigate this matter for me.

Yours sincerely,

Maxw.........."



Referred for the information of CDU shareholders concerned.

cheers,

Max