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Message: Contacted IIROC - we will see what happens

I called IIROC (regulatory agency on trading here in Canada).

They asked me to detail what I thought the problems were in an e-mail.

I expect to be sending that e-mail this week sometime.

Anybody want to help me with the contents and wording of what we are seeing happening?

Here is my first stab at what I want to tell them:

On October 12th, 2011 (after trading hours), Premium Exploration issued a very positive news release.

On October 13th, the share price rose from 0.27 or so, where it had been trading to 0.30.

Over the next several trading days, it was observed that any (apparent) attempt of the share price to rise above 0.30 was met by (apparently) determined selling at the 0.30 level.

It was also observed that Cormark was a party that was heavily involved in the continual offering of shares of PEM at 0.30. It is unknown whether they were acting as an agent or as a principal in this offering of shares for sale.

There did not seem to be a profit motive (on the open market) for this "capping" as the share price had only dropped to a low of around 0.25 in the prior week and the volumes had been light. Nobody appeared to have a large stock of PEM shares purchased at a lower price to sell for profit.

It appeared (from various clues) that Cormark's potential interest in supressing the price might be related to their position as financial advisors to various mining firms and/or its position as a securities brokerage.

Speculation as to motive included the following two scenarios:

1. As financial advisor to other mining firms, it might have been participating in a scheme to supress the share price in order to make a potential buyout offer more lucrative to a potential buyer of the company.

2. As a potential purchaser/broker of a future potential secondary offering, it might be moving to make that a more lucrative opportunity by a combination of: a) keeping the share price depressed so that the secondary offering would be at more advantageous terms to the buyer of the secondary offereing, and/or b) by keeping the price below the 0.35 level, discouraging the exercise of a large number of warrants, and therefore depriving PEM of a potential source of revenues, and thereby influencing them towards obtaining additional funding through a secondary offering rather than through the exercise of previously issued warrants.

It is unknown if these speculations, even if accurate, indicate an unlawful pattern of trading, but I request the IIROC to investigate and determine if this is an allowed set of activities or an unlawful activity. I understand that because of privacy issues no feedback can be given regarding the investigation unless some disciplinary action is taken, at which point the ruling is posted to the website.

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