2003 Opinions

12/29/2003

The staff of the Colorado Division of Securities has taken a “No-Action” position with regard to the offer and sale of general obligation bonds by Starboard Media Foundation, Inc which requested a discretionary exemption from securities registration under Rule 51-3.14.

OPINION REQUEST AND ANSWER

7/1/2003

 The staff of the Colorado Division of Securities issued an opinion that they could not confirm an exemption for the online auction and transactions related thereto as proposed by EnergyNet and issued the opinion that the described properties and related interests to be auctioned according to the official opinion request appeared to fall within the statutory definition of a “security” under the Act.

OPINION REQUEST AND ANSWER

6/24/2003

 The staff for the Colorado Division of Securities has taken a “No-Action” position with regard to a proposed distribution of all the outstanding shares of common stock for Mindspeed by Conexant Systems, Inc and whether such distribution would be subject to an exemption.

OPINION REQUEST AND ANSWER

6/23/2003

 The staff for the Colorado Division of Securities has taken a “No-Action” position with regard to the Individual Deductible Service Plan offered by IDA Management Services, Inc.

OPINION REQUEST AND ANSWER

5/2/2003

 The staff for the Colorado Division of Securities has taken a “No-Action” position with regard to whether “Tuition Certificates,” issued by Tuition Plan Consortium, LLC, would constitute an offer and sale of “securities,” as the term is defined under the Colorado Securities Act.

OPINION REQUEST AND ANSWER

4/8/2003 

 The staff for the Colorado Division of Securities has taken a “No-Action” position with regard to whether a proposed distribution of all the outstanding shares of common stock for Hudson Highland Group, Inc. by TMP Worldwide Search, Inc. was subject to an exemption from the broker-dealer and sales representative licensing provisions of the Colorado Securities Act.

OPINION REQUEST AND ANSWER

1/31/2003 

 The staff for the Colorado Division of Securities has taken a “No-Action” position with regard to whether a proposed Facilities Construction and Service Agreement are subject to the registration provisions of the Colorado Municipal Bond Supervision Act.

OPINION REQUEST AND ANSWER

1/23/2003 

The staff for the Colorado Division of Securities has confirmed an exemption under §11-51-307(1)(g), C.R.S., and Rule 51-3.15 relative to the offer and sale of Church Development Fund, Inc. unsecured debt instruments and has taken a “No-Action” position with regard to violations of the broker-dealer and sales representative licensing provisions of the Act. 

OPINION REQUEST AND ANSWER