18.  On August 12, 2016, Platinum published its Disclosure Statement dated August 4,  2016 to the Filings and Disclosure section of the OTCMarkets profile (the “August Disclosure  Statement”). The August Disclosure Statement was signed by Defendant Baioni on August 8,  2016.   19.  On August 13, 2016, Platinum published its consolidated financial statements for  the six months ended June 30, 2016 and December 31, 2015 which provided the Company’s  financial results and position for the first half of 2016.   21.  On September 12, 2016, the Company announced its acquisition of TBX Group,  stating that further details would be coming in the next few days.   24.  On November 14, 2016, Platinum published its quarterly financial report for the  period ending September 30, 2016 (the “3Q16 Quarterly Report”). The 3Q16 Quarterly Report  provided the Company’s financial results and position for the period ending September 30, 2016.  The 3Q16 Quarterly Report was signed by Defendants Baioni and Miller.   25.  The 3Q16 Quarterly Report discussed the Company’s controls and procedure,  stating in relevant part:  Item 3 - Controls and Procedures   Evaluation of Disclosure Controls and Procedures   Our management, with the participation of our chief executive officer and  chief financial officer, has evaluated the effectiveness of our disclosure controls  and procedures as of the end of this quarterly reporting period. Based on that  evaluation, our Chief Executive and Chief Financial officers have concluded  that as of such date, our disclosure controls and procedures were effective.   Changes in Internal Control   There were no changes in our internal control over financial reporting  identified in management’s evaluation during the period covered by this quarterly  reporting period, that materially affected, or are reasonably likely to materially  affect, our internal control over financing reporting.  (Emphasis added).   30.  On February 16, 2017, the SEC issued a release announcing the temporary  suspension of trading in the securities of Platinum, stating in pertinent part:  34.  Plaintiff brings this action as a class action pursuant to Federal Rule of Civil  Procedure 23(a) and (b)(3) on behalf of a class consisting of all those who purchased or  otherwise acquired Platinum securities publicly traded on the OTC Marketplaces during the  Class Period (the “Class”) and were damaged upon the revelation of the alleged corrective  disclosure. Excluded from the Class are Defendants herein, the officers and directors of the  Company, at all relevant times, members of their immediate families and their legal  representatives, heirs, successors or assigns and any entity in which Defendants have or had a  controlling interest.   36.  Plaintiff’s claims are typical of the claims of the members of the Class as all  members of the Class are similarly affected by Defendants’ wrongful conduct in violation of  federal law that is complained of herein.   37.  Plaintiff will fairly and adequately protect the interests of the members of the  Class and has retained counsel competent and experienced in class and securities litigation.  Plaintiff has no interests antagonistic to or in conflict with those of the Class.   39.  A class action is superior to all other available methods for the fair and efficient  adjudication of this controversy since joinder of all members is impracticable. Furthermore, as  the damages suffered by individual Class members may be relatively small, the expense and  burden of individual litigation make it impossible for members of the Class to individually  redress the wrongs done to them. There will be no difficulty in the management of this action as  a class action.   41.  Based upon the foregoing, Plaintiff and the members of the Class are entitled to a  presumption of reliance upon the integrity of the market.   42.  Alternatively, Plaintiff and the members of the Class are entitled to the  presumption of reliance established by the Supreme Court in Affiliated Ute Citizens of the State  of Utah v. United States, 406 U.S. 128, 92 S. Ct. 2430 (1972), as Defendants omitted material  information in their Class Period statements in violation of a duty to disclose such information,  as detailed above.  43.  Plaintiff repeats and realleges each and every allegation contained above as if  fully set forth herein.   45.   During the Class Period and/or the Private Placement, the Company and the  Individual Defendant, individually and in concert, directly or indirectly, disseminated or  approved the false statements specified above, which they knew or deliberately disregarded were  misleading in that they contained misrepresentations and failed to disclose material facts  necessary in order to make the statements made, in light of the circumstances under which they  were made, not misleading.   46.  The Company and the Individual Defendant violated §10(b) of the 1934 Act and  Rule 10b-5 in that they:  •  employed devices, schemes and artifices to defraud;  •  made untrue statements of material facts or omitted to state material facts  necessary in order to make the statements made, in light of the circumstances  under which they were made, not misleading; or  •  engaged in acts, practices and a course of business that operated as a fraud or  deceit upon plaintiff and others similarly situated in connection with their  purchases of Platinum securities during the Class Period and/or pursuant and/or  traceable to the Private Placement.   48.   Individual Defendant, who is the senior officer and/or director of the Company,  had actual knowledge of the material omissions and/or the falsity of the material statements set  forth above, and intended to deceive Plaintiff and the other members of the Class, or, in the  alternative, acted with reckless disregard for the truth when they failed to ascertain and disclose  the true facts in the statements made by them or other personnel of the Company to members of  the investing public, including Plaintiff and the Class.   49.  As a result of the foregoing, the market price of Platinum securities was  artificially inflated during the Class Period. In ignorance of the falsity of the Company’s and the  Individual Defendant’s statements, Plaintiff and the other members of the Class relied on the  statements described above and/or the integrity of the market price of Platinum securities during  the Class Period in purchasing Platinum securities at prices that were artificially inflated as a  result of the Company’s and the Individual Defendant’s false and misleading statements.   50.  Had Plaintiff and the other members of the Class been aware that the market price  of Platinum securities had been artificially and falsely inflated by the Company’s and the  Individual Defendant’s misleading statements and by the material adverse information which the  Company and the Individual Defendant did not disclose, they would not have purchased  Platinum securities at the artificially inflated prices that they did, or at all.   52.  By reason of the foregoing, the Company and the Individual Defendant have  violated Section 10(b) of the 1934 Act and Rule 10b-5 promulgated thereunder and are liable to  the Plaintiff and the other members of the Class for substantial damages which they suffered in  connection with their purchases of Platinum securities during the Class Period and/or pursuant  and/or traceable to the Private Placement.  53.  Plaintiff repeats and realleges each and every allegation contained in the  foregoing paragraphs as if fully set forth herein.   54.  During the Class Period, the Individual Defendant participated in the operation  and management of the Company, and conducted and participated, directly and indirectly, in the  conduct of the Company’s business affairs. Because of his senior positions, he knew the adverse  non-public information regarding the Company’s business practices.   55.  As officer and/or director of a publicly owned company, the Individual Defendant  had a duty to disseminate accurate and truthful information with respect to the Company’s  financial condition and results of operations, and to correct promptly any public statements  issued by the Company which had become materially false or misleading.   57.  The Individual Defendant, therefore, acted as a controlling person of the  Company. By reason of his senior management positions and/or being director of the Company,  the Individual Defendant had the power to direct the actions of, and exercised the same to cause,  the Company to engage in the unlawful acts and conduct complained of herein. The Individual  Defendant exercised control over the general operations of the Company and possessed the  power to control the specific activities which comprise the primary violations about which  Plaintiff and the other members of the Class complain.   58.  By reason of the above conduct, the Individual Defendant is liable pursuant to  Section 20(a) of the Exchange Act for the violations committed by the Company.  Materially False and Misleading Statements   Violation of Section 20(a) of The Exchange Act  Against The Individual Defendant    Violation of Section 10(b) of The Exchange Act and Rule 10b-5  Against All Defendants  