UNITED STATES SECURITIES AND EXCHANGE COMMISSION

SEC NEWS DIGEST, ISSUE NO. 99-5, DATED JANUARY 8, 1999, ENFORCEMENT PROCEEDINGS DISCLOSES; "SEC CHARGES STOCK PROMOTERS WITH FRAUDULENT SCHEME." THE COMMISSION ANNOUNCED THAT IT FILED SUIT IN THE UNITED STATES DISTRICT COURT ON JANUARY 7, 1999 FOR THE DISTRICT OF COLUMBIA AGAINST A FORMER LEAD ANALYST AND ASSISTANT DIRECTOR OF RESEARCH FOR A SPRINGFIELD, ILLINOIS BASED STOCK PROMOTER. THE COMPLAINT ALLEGES THAT BETWEEN 1993 AND 1997, IN EXCHANGE FOR CASH AND SECURITIES IN EXCESS OF $700,000, THE DEFENDANT FRAUDULENTLY PROMOTED MICROCAP COMPANIES BY DECEIVING INVESTORS INTO BELIEVING THAT HIS WAS AN INDEPENDENT SECURITIES RESEARCH FIRM THAT PROVIDED OBJECTIVE INVESTMENT ADVICE ABOUT "UNDISCOVERED" COMPANIES WHEN, IN FACT, IT WAS A PAID PROMOTIONAL FIRM THAT UNCRITICALLY PUBLISHED GLOWINGLY OPTIMISTIC RECOMMENDATIONS OF THE SECURITIES OF ITS CLIENTS.THE COMPLAINT ALLEGES THAT THE DEFENDANT FAILED TO DISCLOSE ADEQUATELY THAT HE HAD RECEIVED COMPENSATION PAID FROM ISSUER-CLIENTS OR THE FACT THAT HE WAS SELLING THE SECURITIES HE WAS RECOMMENDING TO THE INVESTING PUBLIC. THE COMPLAINT ALLEGES THE DEFENDANT VIOLATED SECTION 17(A) AND (B) THE SECURITIES ACT OF 1933 AND SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934.

Judgment Rendered

Monetary/Fine

$10,000.00

Disgorgement/Restitution

SEC LITIGATION RELEASE 17953, JANUARY 29, 2003; JUDGE SCOTT ENTERED AN ORDER OF FINAL JUDGMENT AGAINST GEBBEN, FOLLOWING A REMEDY HEARING. THE COURT ORDERED GEBBEN TO DISGORGE $10,208.50 IN ILL-GOTTEN GAINS, PREJUDGMENT INTEREST TOTALING $7,128.93, AND PAY A CIVIL PENALTY OF $10,000.

FOR ACTIONS OCCURRING DURING THE COURSE OF HIS EMPLOYMENT WITH STRATEGIC ADVISORY, GEBBEN WAS CHARGED BY THE S.E.C. CLAIMING VIOLATION OF CERTAIN RULES. IN JANUARY, 2002, THE US DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS FOUND THAT PHILLIP B. GEBBEN IN VIOLATION OF SECTION 10(B) OF THE SECURITIES AND EXCHANGE ACT OF 1934 AND RULE 10(B)5 THERE UNDER BY KNOWINGLY OR RECKLESSLY MAKING FALSE AND MISLEADING STATEMENTS IN FIVE WEB SITE POSTINGS MADE IN 1996. MR. GEBBEN WAS ALSO FOUND TO HAVE VIOLATED SECTION 17(B) OF THE SECURITIES ACT OF 1973 IN CONNECTION WITH THE DISTRIBUTION OF HIS EMPLOYER?S PROMOTIONAL MATERIALS DURING HIS EMPLOYMENT WITH AN INVESTOR'S RELATIONS FIRM BETWEEN DECEMBER 1994 - NOVEMBER 1996.