As evidenced by ample testimony on these topics, the government had prior knowledge of “gifted” packages and commissions used to purchase products via gift certificates and internal transfers. These commissions were “filtered” out of 101i’s gain-loss representations and inflated the loss representations by at least 28 million dollars.

In addition, the government had substantial evidence before the trial confirming “gifting,” gift certificate purchases, and internal transfers. The significance of this is that they were aware they filtered out 28 million dollars in commissions from 101i and failed to account for $600,000 in refunds, $800,000 in waived auto-ships, and millions in “gifted positions.” The government deliberately misrepresented i2G losses by 28 million to 32 million dollars through four key witnesses and 12 distributor witnesses. They knowingly procured false statements from 16 witnesses and failed to correct the false statements.

Please refer to the attached summary chart 234, where the government recognizes $1.2 million in “gifted” emperor packages held by Jason Syn, as indicated in the summary chart used at trial. However, Syn’s gifted positions were inaccurately presented as gross losses in 101i. Millions of dollars in gifted positions, similar to Syn’s, were misrepresented as false losses, which led to inflated I2G loss representations by millions of dollars.

Jason Syn’s payment records reveal a significant use of “gift certificates” for product purchases and internal transfers, totaling $3 million in commissions. In a post-trial affidavit, Syn stated that he received over $2 million from I2G. The payment details indicate that the government was aware of substantial payments that were not documented in document 101i. In fact, Syn is recorded as a net loser in Exhibit 101i.

Syn received a probation plea deal after admitting to receiving over two million dollars for I2G and acknowledging that he took large sums of money from his team members. However, his admission about his team’s use of cash payments outside the system underscores the government’s understanding of the significant unreliability of the 101i Gains/Losses, which were falsely used to convict the defendants based on grossly inflated loss representations.