2016 revisited.
34. Alt also learned that PWCC solicited, assisted or facilitated bid
manipulation by others in connection with auctions on PWCC’s platform. In particular, PWCC
was aware of, and solicited bids from, a group of approximately six individuals (“Group 1”) who
fraudulently and collusively bid up items in PWCC auctions, including items that members of
Group 1 had put up for auction, notwithstanding PWCC’s representation that PWCC clients
could not bid, individually or collusively, on their own items.
35. In some instances, a member of Group 1 submitted the winning bid in a
PWCC auction, but did not consummate the transaction by paying the purchase price. PWCC’s
stated policy was that non-payment would result in a ban from participation in PWCC auctions.
PWCC, however, took no action and facilitated continued bid manipulation by members of
Group 1 by allowing such members to continue to participate in its auctions despite nonpayment.
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