UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934
Release No. 49974 / July 7, 2004

Admin. Proc. File No. 3-11507

I.

In connection with previously instituted public administrative proceedings pursuant to Section 15(b) of the Securities Exchange Act of 1934 ("Exchange Act"), Respondent Alex Solon ("Solon" or "Respondent") has submitted an Offer of Settlement ("Offer") which the Commission has determined to accept. Solely for the purpose of these proceedings, and any other proceedings brought by or on behalf of the Commission or in which the Commission is a party, and without admitting or denying the findings herein, except as to the Commission's jurisdiction over him and the subject matter of these proceedings, and the findings contained in Section II.C. and II.E., below, which are admitted, Solon consents to the entry of this Order Making Findings and Imposing Remedial Sanctions Against Alex Solon ("Order"), as set forth below.

II.

On the basis of this Order and the Respondent's Offer, the Commission finds that:

A. At all relevant times, International Investment Group, Ltd. ("IIGR") was a Delaware corporation whose principal offices were in New York, New York. The common stock of IIGR was publicly traded on the over-the-counter market.

B. For part of the relevant time period, Solon was a registered representative of Capital Growth Management, Inc., formerly known as Investech Capital Corporation.

C. On June 26, 2003, Solon was permanently enjoined by the United States District Court for the Southern District of New York in SEC v. Ruge, et al., 97 Civ. 9306 (S.D.N.Y.) (DAB), from violating Section 17(a) of the Securities Act of 1933 ("Securities Act"), and Section 10(b) of the Exchange Act and Rule 10b-5 thereunder.

D. The Commission's amended complaint in the above-referenced action alleged, among other things, that:

1. From June 1995 through February 1996, Solon and the other defendants engaged in a fraudulent scheme to manipulate the public trading market for securities issued by IIGR through the payment of undisclosed bribes to various registered representatives and other individuals who sold IIGR stock to retail investors. The Chairman of IIGR provided blocks of IIGR shares to the promoters of this scheme at a substantial discount from the prevailing market price so that the promoters could sell those shares to Solon and other brokers who received bribes for retail activity. Solon and the other defendants realized approximately $500,000 in illegal profits from the fraudulent scheme.

2. Solon violated Section 17(a) of the Securities Act and Section 10(b) of the Exchange Act and Rule 10b-5 thereunder, in connection with the offer and sale of IIGR securities.

E. On March 26, 1999, Solon pleaded guilty to one count of conspiracy to commit securities fraud, wire fraud and commercial bribery in violation of 18 U.S.C. § 371. United States v. Mark Zaborsky, et al., 98 Cr. 1037 (Alex Solon) (S.D.N.Y.) (LAK).

F. The indictment underlying Solon's guilty plea alleged, among other things, that at various times between February 1995 and February 1997, Solon caused his customers to purchase IIGR stock for the purpose of artificially inflating the stock price in exchange for bribes that he did not disclose to his customers.

G. On the basis of his guilty plea, Solon was sentenced to one year and one day of imprisonment followed by three years supervised release. As part of his criminal sentence, Solon was ordered to pay $15,000 in restitution to investors.

III.

In view of the foregoing, the Commission deems it appropriate and in the public interest to impose the sanctions agreed to in Respondent Solon's Offer.

Accordingly, it is hereby ORDERED:

A. Pursuant to Section 15(b)(6) of the Exchange Act, that Respondent Solon be, and hereby is, barred from association with any broker or dealer.

Any reapplication for association by Respondent Solon will be subject to the applicable laws and regulations governing the reentry process, and reentry may be conditioned upon a number of factors, including, but not limited to, the satisfaction of any or all of the following:

(a) any disgorgement ordered against the Respondent, whether or not the Commission has fully or partially waived payment of such disgorgement; (b) any arbitration award related to the conduct that served as the basis for the Commission order; (c) any self-regulatory organization arbitration award to a customer, whether or not related to the conduct that served as the basis for the Commission order; and (d) any restitution order by a self-regulatory organization, whether or not related to the conduct that served as the basis for the Commission order.

For the Commission, by its Secretary, pursuant to delegated authority.

http://www.sec.gov/litigation/admin/34-49974.htm