Subject: Comments on Distribution Plan of 3-20537 GTV/Saraca
From: Z N/A
Affiliation:

Feb. 12, 2022



Proceeding File No. 3-20537 
In the Matter of
GTV Media Group, Inc., Saraca Media Group, Inc. 
 
Dear SEC officers, 
 
As a harmed investor of GTV/Saraca, I am extremely grateful for your hard work in getting refunds to the Eligible Claimants as soon as possible. Thank you very much for considering my suggestions below. 
 
Some Eligible Claimants have made contributions during the SEC’s investigation phrase on this matter directly and indirectly (see below for details), some Eligible Claimants require much less administrative work than others (i.e., refund to their original U.S. bank accounts), Eligible Claimants with larger Recognized Losses will be impacted more by refund percentage and they have been suffering greater deal of financial losses and emotional distress. Considering the tremendous amount of additional validation work/costs required and risks involved in Third-Party Filers and foreigners, and to be fair to those previously mentioned Eligible Claimants, please refund Third-Party Filers and foreign Eligible Claimants ONLY during the second tranche. This approach provides more time for the refund companies to conduct thorough investigations and avoid potential irreversible international fraud through Third-Party Filers.
 
For the Initial Tranche, I strongly suggest SEC to please prioritize the Eligible Claimants who meet most or all below credentials, and please refund them at least 90% to 100% of their Recognized Losses during the Initial Tranche:
 
1.     Eligible Claimants who are U.S. Citizens: because this investigation cost a huge amount of U.S. government’s resources and U.S. tax payers’ tax contributions. (Indirect contribution) 
2.     Eligible Claimants who have been working directly with SEC investigators to provide helpful evidence and support on this matter, proof by SEC officers involved in the investigations of this matter is required. (Direct contribution) 
3.     Eligible Claimants who requested their refund to be returned to their original U.S. bank account without Third-Party Filer involvement, because this requires minimum verification work, cost and is least risky. 
4.     Eligible Claimants who invested large amounts of money, i.e., $450, 000 or more because the financial loss caused due to refund percentage adjustment is much greater. In Addition, they have been suffering greater financial losses and emotional distress. 
5.     Eligible Claimants who experienced extreme hardships, e.g., older people’s retirement savings. The measurements must be tangible and easy to verify, such as account holders’ names on their refund bank account. 


Regarding timing, I strongly suggest please consider 30 days instead of 45 and speed up the refund timing especially for the First Tranche. 
 
Highest Regards,