Business ProfileforMidam Ventures LLC

Gov. Action
As of September 30, 2021:

The Securities and Exchange Commission ("Commission") deems it appropriate that cease-
and-desist proceedings are instituted pursuant to Section 8A of the Securities Act
of 1933 ("Securities Act") and Section 21C of the Securities Exchange Act of 1934 ("Exchange
Act") against Adam Heimann ("Heimann"), Michael Perinotti ("Perinotti"), MIDAM Ventures
LLC ("MIDAM"), and EGM Firm Inc. ("EGM") (collectively, "Respondents").

Respondents have submitted Offers of Settlement (the "Offers") which the Commission has determined to accept. Solely for the purpose of these proceedings and any other proceedings brought by or on behalf of the
Commission, or to which the Commission is a party, and without admitting or denying the findings
herein, except as to the Commission's jurisdiction over them and the subject matter of these
proceedings, which are admitted, and except as provided herein in Section V, Respondents consent
to the entry of this Order Instituting Cease-and-Desist Proceedings Pursuant to Section 8A of the
Securities Act of 1933 and Section 21C of the Securities Exchange Act of 1934, Making Findings,
and Imposing Remedial Sanctions and a Cease-and-Desist Order ("Order"), as set forth below:

These proceedings arise out of Respondents' misconduct during their promotional
campaigns for ten microcap companies from July 2015 to August 2018 (the "Relevant Period").
During the Relevant Period, Respondents concealed they were buying and selling the shares of the
issuers that were the subjects of the promotional campaigns in the public market, through accounts
they secretly controlled, to create actual or apparent active trading volume with the expectation that
the increased volume would induce other investors to purchase or sell the securities, which would
thereby demonstrate Respondents' successful promotion efforts. Through their actions,
Respondents engaged in manipulative trading in violation of Exchange Act Section 9(a)(2). Also
during the Relevant Period, Heimann published certain online articles promoting six of these ten
stocks, and failed to accurately disclose that he was compensated to promote those stocks in
violation of Securities Act Section 17(b).

All Respondents have undertaken to refrain from trading in any account, or directing others to trade in any account, in the securities of any client or issuer that any Respondent is advertising, marketing, or otherwise promoting, or has been engaged to advertise, market, or otherwise promote.

Heimann has undertaken to refrain from preparing or disseminating any written communication advertising, marketing, or otherwise promoting any security without fully disclosing in the communication itself the source, amount, and duration of all consideration.

It is also ORDERED that: Heimann, Perinotti, EGM and MIDAM cease and desist from committing or causing any violations and any future violations of Section 9(a)(2) of the Exchange Act, and Respondent Heimann cease and desist from committing or causing any violations and any future violations of Section 17(b) of the Securities Act.

MIDAM shall pay a civil money penalty in the amount of $487,616 to the Securities and Exchange Commission.
EGM shall pay a civil money penalty in the amount of $487,616 to the Securities and Exchange Commission.
Perinotti shall pay a civil money penalty in the amount of $97,523 to the Securities and Exchange Commission.
Heimann shall pay a civil money penalty in the amount of $177,245 to the Securities and Exchange Commission.

LINK: https://www.sec.gov/litigation/admin/2021/33-10994.pdf?utm_medium=email&utm_source=govdelivery