[(i)] Claimant's information was significant as it allowed Commission staff to uncover hidden conduct occurring, in part, overseas; (ii) Claimant provided a substantial amount of ongoing assistance and cooperation by meeting with staff numerous times and providing relevant documents and critical investigative leads that advanced the investigation and saved the Commission a significant amount of time and resources; (iii) Claimant's information helped the Commission further significant law enforcement interests by enabling the Commission to bring an action addressing a particular form of misconduct [Redacted]; and (iv) Claimant repeatedly and strenuously raised Claimant's concerns internally. In determining the appropriate award percentage, we also considered whether Claimant unreasonably delayed in reporting the information to the Commission. We are mindful of the importance of whistleblowers reporting their information to the Commission promptly, and will continue to make appropriate reductions to award percentages in cases where we find, under all of the facts and circumstances, that the whistleblower unreasonably delayed in doing so. However, we determined that no reduction for unreasonable reporting delay was warranted under the specific facts and circumstances of this case due to the strength of the positive factors and the fact that Claimant repeatedly and tenaciously objected to and escalated Claimant's concerns about misconduct within Claimant's organization. 

[S]tarting in at least 2016 and proceeding through 2018, Friedland and his companies fraudulently solicited customers and prospective customers to purchase a digital asset known as Compcoin. The defendants falsely promised, among other things, that Compcoin would allow customers to gain access to Fintech's proprietary forex trading algorithm known as ART, and falsely advertised that ART would deliver high rates of return. 

According to the complaint, in marketing Compcoin, the defendants also falsely represented, among other things, the use and function of Compcoin and that ART "was ready for release on the open market." In fact, as alleged in the complaint, the defendants knew that no customer could lawfully utilize ART until Fintech obtained approval from the National Futures Association (NFA), which never occurred. Thus, according to the complaint, the purchasers of Compcoin never gained access to ART as promised, and were left with a valueless asset. 

Wooldridge is claiming that investors in Texas Shallow projects will "set [themselves] up for retirement," according to the order.

Wooldridge is touting his decades of experience in the oil and gas business and relationships with oil giants like Schlumberger Ltd. and Halliburton Co. But he is omitting a pending lawsuit by an investor and Orders against Texas Shallow entered by the Texas Railroad Commission. Neither Wooldridge nor Texas Shallow are registered to deal in securities in Texas.

In 2019, a company sued Wooldridge to recover the $20,500 it paid to Texas Shallow to buy a 16% working interest in a well field project in Young County. The suit is pending in the 90th District Court of Young County.

The Railroad Commission in 2018 entered a consolidated Order against Wooldridge's company that require him to pay penalties totaling $50,000. Wooldridge has not resolved the debt, according to the emergency order.

Besides not disclosing the lawsuit and Railroad Commission sanction, Wooldridge, according to the order, is committing fraud by not disclosing risks of investing in oil and gas wells. Chief among them: changes in the price of oil or declines in demand can affect the profitability of investments in oil and gas wells.

Wooldridge is publicly soliciting investments in oil and gas wells on www.texasshallow.com and through two worldwide platforms, LinkedIn and Dealstream.

Dealstream is an online marketplace with more than 500,000 members in 100 countries. The platform facilitates the purchase and sale of businesses, real estate, oil and gas assets, and private investments.

Wooldridge is representing that he has expertise in the exploration of leases in northern Young County and the Gun Sight Oil Sands Formation, which runs through Young County. Texas Shallow and Wooldridge are promoting "silent investment programs" in the Gun Sight formation.

Texas Shallow and Wooldridge, however, aren't disclosing any geological or geophysical information that can be used to independently evaluate oil wells in Young County and the Gun Sight Oil Sands Formation.

Texas Shallow and Wooldridge have been promoting their unregistered investments in Texas wells over the course of sharp decline in oil prices over the past year. The price of West Texas Intermediate crude hit $21 per barrel on April 1, a decline of 65% in the past 12 months. 

In the Gun Sight formation, Texas Shallow is offering a 1% working interest in wells for $1,000. Wooldridge is telling investors the wells have the potential to produce up to seven barrels of oil a day, according to the order, but production could rise to 55 to 110 barrels a day.

Wooldridge and Texas Shallow are also promoting investments in other Young County exploration projects.

In DealStream advertisements in March and April, Wooldridge solicited investors to fund new oil wells, one injection well and one water supply well for $17,500 per well. According to the order, Wooldridge is telling investors the project has potential to produce 25 to 60 barrels per day to start and production could rise as high as 125 to 300 barrels of oil a day. . . .