▪ touted “the completion of the hologram prototype while omitting that it had been abandoned;”

▪ “a major investor’s personal and business relationship with Kavtaradze while using his endorsement and role as stockholder;

▪ Kavtaradze being “an experienced executive from a technology company;”

▪ Kavtaradze misappropriating some investor money for personal use,” including “meals, travel and application fees for MBA programs.”