Here's a brief summary of the chronology of events:

--- In January 2004, Ruder Finn announces that they are the Agency of Record for a biotech company, Efoora. The PR firm uses the release to puff both the firm and their new client. In it EVP Howard Solomon said, "Efoora is widely regarded as one of the top emerging biotech players in the Midwest, and we feel very good about the company's business prospects. Our communications efforts will play a very important role for Efoora in the next 12 months, which will without question be a milestone year for the company. Furthermore, this account is particularly strategic for our Chicago office as we look to capitalize on the Midwest's growing biotech market." (See release below.)

--- Ruder Finn then places a huge "puff piece" in Chicago Sun-Times. On February 5, 2004, the snookered Howard Wolinsky, Business Reporter for the Chicago Sun-Times wrote, "Medical diagnostics firm 'expecting a breakout year'. Quote: "Buffalo Grove-based Efoora Inc., a medical diagnostics company, is on the verge of hitting a trifecta ... and maybe more. This year, the start-up expects to have its first three tests for the U.S. market approved by federal agencies.

--- This brings on incessant heat from muckraker celebrity and Sun-Times competitor, Ron May. Ron in his publication by the same name, The May Report, subsequently dogged Efoora for the next year uncovering what seemed a constant flow of malfeasance.

--- On March 3, 05, The May Report broke the story about a Fed raid. QUOTE: "Federal agents, including the SEC, the FBI, and federal postal inspectors raided the offices of Efoora on Wednesday, March 2nd, in Buffalo Grove, and after fourteen hours leave with two mini vans' full of documents and boxes. Sources say that the case is already made, this was just icing on the cake." (NOTE: At this time, Efoora is still listed online on Ruder Finn's client list.)

--- And on May 18, 2006, a federal grand jury returned a 50-count indictment against the onetime executives of Efoora for allegedly swindling thousands of investors out of millions of dollars. (See release below.)

QUESTIONS

What did Solomon mean exactly when he said, "we look to capitalize on the Midwest's growing biotech market"?

What is Ruder Finn's culpability?

Did the firm know or should they have known?

When exactly did they resign the account and what took them so long?

Is PR a "manipulative and deceptive device" under the law? (See law below.)

How common is this practice in the PR Industry?

BEFORE

Ruder Finn Named Agency of Record for Midwestern Biotech Firm Efoora

CHICAGO, January 8, 2004 - Ruder Finn, a leading global communications, counseling and services agency, today announced that it has been named the agency of record for Efoora. The Buffalo Grove, IL-based, fast-growing developer of rapid, diagnostic products is best known for its strides in disease tests (including Mad Cow and Chronic Wasting rapid tests), rapid HIV testing, and its innovative, patent protected PRIMOS blood glucose monitoring platform.

The agency has been engaged to develop and implement a comprehensive communications program that will focus primarily on three significant products expected to receive approval from the United States Food and Drug Administration (FDA) and the United States Department of Agriculture (USDA) within the next six months.

"Ruder Finn has both an excellent reputation and a proven ability to generate impressive communications results," said David Grosky, chairman of the board of directors and chief executive officer of Efoora. "They offer a tremendous amount of experience and expertise in the biotech and healthcare arenas, and we expect them to play a significant role in helping us expand awareness of our products and technology platforms."

Ruder Finn's Chicago and Los Angeles offices will jointly service the account. Howard Solomon, executive vice president, U.S. regional operations for Ruder Finn in Chicago, and healthcare industry veteran Kathy Vincent, vice president, will co-head the team.

"Efoora is widely regarded as one of the top emerging biotech players in the Midwest, and we feel very good about the company's business prospects," said Solomon. "Our communications efforts will play a very important role for Efoora in the next 12 months, which will without question be a milestone year for the company. Furthermore, this account is particularly strategic for our Chicago office as we look to capitalize on the Midwest's growing biotech market."

About Efoora Efoora is a proprietary developer of rapid, diagnostic tests. Efoora's flagship test, the Efoora rapid HIV test is an immunochromatographic assay that detects the presence of circulating human antibodies to the HIV-1 and HIV-2 virus in whole blood, serum, and plasma. It provides the end user a method of screening a specimen for the presence of these antibodies as an indication of exposure to the virus in less than 30 minutes where other FDA-approved screening assays give results in 2-4 hours. In addition, Efoora develops and optimizes other rapid tests for several outside biodiagnostic companies. Efoora has a world class R&D scientific team made up of scientists from several major diagnostic companies. Efoora will continue to develop additional proprietary rapid tests on additional disease states as well as continue to build its third party development relationships.

About Ruder Finn Ruder Finn is a leading communications, counseling and services Agency with more than 55 years experience. The Ruder Finn Group maintains offices in New York, Boston, Chicago, Los Angeles, San Francisco, Washington, D.C. London, Paris, Jerusalem, Beijing, Guangzhou, Hong Kong, Shanghai, Singapore and Sydney. The Agency also works with affiliates in major markets throughout the U.S., Europe and Latin America. Ruder Finn recently ranked No. 1 in New York in revenues and staff size by O'Dwyer's Ranking for 2002, serves the global and local communications needs of more than 250 corporations and nonprofit organizations. Additional information about Ruder Finn can be found on the company's Web site (www.ruderfinn.com).

AFTER

Three Executives Indicted in Biotech Stock Fraud Scheme

CHICAGO, May 18, 2006 -- Two former executives and a current employee of a northwest suburban diagnostic testing company were indicted on federal fraud charges for allegedly swindling thousands of investors out of millions of dollars, law enforcement authorities said today. A federal grand jury returned a 50-count indictment late yesterday against the onetime executives of Buffalo Grove-based Efoora, Inc., which with two subsidiaries, purported to be in the business of designing, manufacturing and marketing rapid diagnostic tests for HIV, diabetes, mad cow disease and chronic wasting disease in mules, deer and elk. As part of the alleged fraud scheme, the defendants gave staged tours of Efoora's facilities to potential investors and customers that included stacking, labeling and arranging empty boxes for shipping, using temporary workers, operating machinery that was not ordinarily in use, and assembling and packaging fake test kits in an attempt to show that the company was more productive and successful than it actually was.

Efoora issued and sold more than 100 million shares of stock at prices ranging from 10 cents to $2.50 per share, raising more than $30 million from more than 3,000 investors, according to the indictment.

The defendants, David Grosky, Craig Rappin, and Melvin Dokich, were each charged with participating in a fraud scheme to deceive prospective and actual investors between the summer of 1999 and March of this year, announced Patrick J. Fitzgerald, United States Attorney for the Northern District of Illinois; Robert D. Grant, Special Agent-in-Charge of the Chicago Office of the Federal Bureau of investigation; and Kenneth T. Laag, Inspector-in-Charge of the U.S. Postal Inspection Service in Chicago. The U.S. Food and Drug Administration Office of Criminal Investigations and the Securities and Exchange Commission also assisted in the investigation.

Grosky, 44, of Highland Park, formerly chief executive officer and chairman of the board of directors of Efoora from 1998 through March 2005, was charged with three counts of mail fraud, six counts of wire fraud and eight counts of money laundering. Rappin, 45, of Long Grove, formerly Efoora's chief operating officer and a board member from 1998 through March 2004, was charged with one count of mail fraud. Through his attorney, Rappin authorized the government to disclose that he is cooperating with the government. Dokich, 58, of Forestview, an account executive responsible for selling Efoora stock and raising money through other investments since October 1999, was charged with three counts of mail fraud, six counts of wire fraud, eight counts of money laundering and 33 counts of illegally structuring cash withdrawals.

The indictment also seeks forfeiture of alleged proceeds of at least $1.5 million from all three defendants and their residences as substitute assets; it also seeks an additional $478,548 from Grosky and Dokich; and an additional $311,000 from Dokich alone.

According to the indictment, Efoora attempted to develop diagnostic tests for commercial distribution in the United States, including a rapid HIV test, a glucose test for diabetes, a test for mad cow disease, and a test for chronic wasting disease in mules, deer, and elk. The HIV and diabetes tests required approval from the U.S. Food and Drug Administration before they could be sold in the United States. Efoora was not able to obtain FDA approval to market the HIV test commercially and never submitted an application to the FDA for the glucose test. The mad cow disease and the chronic wasting disease tests required approval from the U.S. Department of Agriculture before they could be sold in the United States. Efoora never received USDA approval for the mad cow disease test, and although it did receive USDA approval for the wasting disease test in approximately March 2004, Efoora was not successful in marketing or selling that test.

The defendants allegedly schemed to fraudulently obtain money from prospective and actual investors by making false representations and promises. In connection with the scheme, the defendants each personally obtained financial benefits from Efoora, including receiving millions of shares of Efoora stock. Grosky received more than $1.5 million from the sale of Efoora shares; Grosky and Rappin each received a salary totaling approximately $1 million over the course of the scheme; and Dokich placed investor funds in a personal bank account from which he withdrew more than $500,000 in cash.

To convince individuals to invest in Efoora, the defendants made, and caused others to make, the following materially false representations: that Efoora was going to become a publicly traded company within a short period of time and the value of the stock would increase significantly -- in fact, Efoora could not go public because it had not taken, and Grosky did not intend to take, necessary actions, including obtaining audited financial statements, and refraining from the sale of any stock for six months; overstating Efoora's manufacturing capabilities, including that it could manufacture millions of tests a year with the equipment it had; that Efoora was producing millions of HIV tests and shipping them to other countries; that Efoora had obtained contracts with certain customers in countries around the world; overstating Efoora's revenues -- claiming that it had many millions of dollars of sales; that Efoora was going to receive FDA approval of its HIV test within a short period of time; Dokich falsely represented that Efoora's glucose test was ready to be commercially marketed; Grosky falsely represented that Efoora's mad cow disease test would be on the market in a short period of time; Grosky falsely represented that there was virtually no risk involved in investing in Efoora stock because the HIV test was going to receive FDA approval and Efoora was going to go public shortly; and Grosky and Dokich each falsely represented that he was selling stock on behalf of Efoora, in fact, they were selling that stock in whole or in part for their own benefit, with the proceeds being deposited into personal bank accounts that each controlled. In addition, the defendants allegedly provided written materials to certain investors and customers, including private placement memoranda, business plans, projected financials, newsletters, executive summaries, information on Efoora's website, and correspondence that they knew contained materially false information. These alleged false representations included that: Efoora would pay brokers 12 percent of the investment as commissions and fees, when, in fact, it paid commissions that were ordinarily 20 to 45 percent of the value of the investment, which drastically depleted the money Efoora needed to develop its products; Efoora's investors were all accredited investors, when, in fact, many were not; and a large accounting firm had provided a valuation of Efoora's technology, showing that it was worth hundreds of millions of dollars, when, in fact, the study was not completed and Efoora had agreed that the information would be used only internally and not publicly disseminated.

The fraud scheme and structuring counts against Dokich allege that in 2001 and 2002, he deposited investors' funds into his personal bank account and made a series of withdrawals -- totaling more than $500,000 -- in amounts less than $10,000 to evade bank currency transaction reporting requirements.

If convicted, the mail and wire fraud counts each carry a maximum penalty of 20 years in prison and a $250,000 fine; some of the money laundering counts carry a maximum penalty of 20 years in prison, while others carry a maximum of 10 years, and a $250,000 fine; and the structuring counts each carry a maximum of five years in prison and a $250,000 fine. As an alternative, the Court may impose a maximum fine equal to twice the loss to any victim or twice the gain to any defendant, whichever is greater. Restitution is mandatory and the Court would determine the appropriate sentence to be imposed.

All three defendants will be arraigned at a later date in U.S. District Court in Chicago.

THE LAW

Securities Act of 1933

Section 17 -- Fraudulent Interstate Transactions

1. It shall be unlawful for any person in the offer or sale of any securities by the use of any means or instruments of transportation or communication in interstate commerce or by the use of the mails, directly or indirectly --

a. to employ any device, scheme, or artifice to defraud, or

b. to obtain money or property by means of any untrue statement of a material fact or any omission to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading, or

c. to engage in any transaction, practice, or course of business which operates or would operate as a fraud or deceit upon the purchaser.

2. It shall be unlawful for any person, by the use of any means or instruments of transportation or communication in interstate commerce or by the use of the mails, to publish, give publicity to, or circulate any notice, circular, advertisement, newspaper, article, letter, investment service, or communication which, though not purporting to offer a security for sale, describes such security for a consideration received or to be received, directly or indirectly, from an issuer, underwriter, or dealer, without fully disclosing the receipt, whether past or prospective, of such consideration and the amount thereof.

Securities Exchange Act of 1934

Section 10

15 U.S.C. § 78j

Sec. 78j. Manipulative and deceptive devices

It shall be unlawful for any person, directly or indirectly, by the use of any means or instrumentality of interstate commerce or of the mails, or of any facility of any national securities exchange --

(b) To use or employ, in connection with the purchase or sale of any security registered on a national securities exchange or any security not so registered, any manipulative or deceptive device or contrivance in contravention of such rules and regulations as the Commission may prescribe as necessary or appropriate in the public interest or for the protection of investors.