FOIA Request: SEC Probe into Wrapped AMC (wAMC) and Market Manipulation

Dear Retail Investors,

We are writing to bring your attention to a critical issue regarding Wrapped AMC (wAMC) tokens and their potential impact on AMC Entertainment Holdings and its shareholders. A Freedom of Information Act (FOIA) request has been filed with the U.S. Securities and Exchange Commission (SEC) to investigate whether wAMC has contributed to market manipulation and potential violations of U.S. securities laws.

FOIA Request Submitted for Investigation

FOIA Request Details (Tracking #25-01481-FOIA):

On February 9, 2025, a FOIA request was submitted to the SEC and acknowledged on February 10, 2025. This request seeks:

- All SEC records, emails, memos, enforcement actions, or correspondence related to "Wrapped AMC (wAMC)" tokens or any blockchain-based AMC securities derivatives.

The SEC has invoked a 10-day extension to search geographically separated records, due to the potentially high volume of records and the need for consultation with multiple offices. This extension suggests that there may be a significant amount of data concerning wAMC and its potential regulatory issues.

1. Unregistered Securities Offering (Violation of Section 5 of the Securities Act of 1933)

Legal Reference: Securities Act of 1933, Section 5—prohibits the sale of unregistered securities unless an exemption applies.

Potential Violation:

- Wrapped AMC (wAMC) was issued as a tokenized derivative of AMC stock without SEC registration.

- The total supply of wAMC (8,008,595,000,000,000 tokens) vastly exceeds the actual outstanding shares of AMC (450 million shares).

- No SEC exemption filings (e.g., Reg A, Reg D, or Reg S) exist for wAMC.

- If wAMC was sold to U.S. investors without an exemption, it constitutes an unregistered securities offering.

Why This Matters:

This lack of registration means investors may have purchased a security without proper disclosures, exposing them to increased risk and potential fraud.

2. Market Manipulation & Fraud (Violations of Section 9(a)(2) and Rule 10b-5 of the Securities Exchange Act of 1934)

Legal Reference:

- Section 9(a)(2)—prohibits transactions that create a misleading appearance of trading activity.

- Rule 10b-5—prohibits fraud, misrepresentation, and deceptive practices in securities trading.

Potential Violation:

AMC Entertainment Holdings experienced a 3512.94% stock surge AMC went from $2.01 in January 2021 to $62.55 on June 2, 2021. This unprecedented increase was followed by a significant decline in stock price, coinciding with the introduction a activity of Wrapped AMC (AMC) tokens on the blockchain on June 5th 2021.

Evidence suggests that the creation and transfer of these tokens may have manipulated AMC's market performance.

- The massive oversupply of wAMC tokens may have artificially diluted AMC stock value.

- The smart contract allowed token transfers without Ethereum (ETH), raising concerns about wash trading or algorithmic manipulation.

- The creator of Wrapped AMC was funded through Tornado.Cash, a sanctioned crypto mixer used to obscure transaction origins.

Why This Matters:

If these actions artificially suppressed AMC’s stock price, retail investors could have been victims of illegal price manipulation, affecting their financial well-being.

3. Failure to Register as a Broker-Dealer (Violation of Section 15(a) of the Securities Exchange Act of 1934)

Legal Reference: Section 15(a)—requires anyone engaging in securities transactions to register as a broker-dealer.

Potential Violation:

- If Wrapped AMC was sold, traded, or used in decentralized finance (DeFi) lending, the creators may have engaged in securities transactions without proper licensing.

- No FINRA or SEC registration records exist for the issuers of Wrapped AMC, which would violate federal broker-dealer rules.

Why This Matters:

Investors unknowingly engaged with an unregistered financial entity, increasing their exposure to risk and potential legal issues.

4. Synthetic Shares & Potential Naked Short Selling (Regulation SHO Violations)

Legal Reference: Regulation SHO—designed to prevent abusive naked short selling and protect market integrity.

Potential Violation:

- If Wrapped AMC was used in swaps, lending, or derivatives, it could have artificially inflated AMC’s share supply—similar to naked short selling.

- Evidence suggests wAMC’s supply exceeded the actual AMC float, a known tactic used in synthetic shorting schemes.

- The SEC’s delay in responding to the FOIA request suggests they are reviewing a high volume of potentially relevant records.

Why This Matters:

This could indicate a coordinated effort to suppress AMC’s stock price through synthetic shares, a practice that undermines market integrity.

Volume Decline & Potential Coordinated Offloading

Evidence suggests that the creation and transfer of these tokens may have been used to manipulate AMC's market performance. For instance, the dramatic volume decline from June 5, 2021 (8,085,993,857,359,310 wAMC tokens) to January 5, 2023 (2,369,852,463,437,420 wAMC tokens) may indicate coordinated offloading, potentially suppressing AMC’s stock demand and contributing to its downward trajectory.

Urgent Call to Action for AMC Shareholders

Retail investors deserve transparency and accountability. The SEC must thoroughly investigate whether Wrapped AMC:

1. Was used to create synthetic shares, artificially diluting AMC’s stock value.

2. Served as a tool for illegal short-selling strategies.

3. Allowed Wall Street firms or hedge funds to manipulate AMC’s stock price.

4. Violated U.S. securities laws through unregistered sales and broker-dealer activity.

We call on regulators, legal experts, and whistleblowers to take immediate action to investigate these potentially unlawful practices and protect AMC investors. We urge the SEC to act decisively to restore fairness in the market.

Next Steps and Cooperation

We are currently awaiting a response from the SEC regarding the investigation into potential violations related to Wrapped AMC tokens. As we continue to monitor the situation, we remain committed to cooperating fully with any additional requests for information or evidence that could support the investigation.

Your voices, as retail investors, are crucial to ensuring accountability and transparency. We will continue to stand with you, providing updates as the situation unfolds and taking necessary steps to advocate for a fair and just market for all AMC shareholders.

Thank you for your attention to this important issue. Together, we can advocate for transparency and justice in our markets.

Sincerely,

MBT & D1ssoluti0ng0v