11. Ace Payday holds it self down as being a start-up, Southern Florida business within the company of supplying customers with "retail wage advance" and "check cashing" services. Purportedly to improve capital to invest in these operations, since at the very least August 2001 through March 2002, Ace Payday, Ace Management, Ace Management Inc., and Bianco happen providing and offering unregistered units of Ace Payday by way of a purported personal placement. Through the offering, defendants have now been trying to sell 100 devices of Ace Payday at a purchase cost of $10,000 per product to improve a complete of $1 million. The defendants have actually solicited investors through the ISOs, who will be telemarketers that cold-call unsophisticated investors and are maybe perhaps not registered as broker-dealers aided by the Commission. Through the providing, defendants have actually raised at the very least $800,000 from at the least 30 investors.