My point stands on it's own two feet. I never said Groupon was engaged in fraud. I was responding to the parent comment's proposition that criminal behavior is

My point stands on it's own two feet. I never said Groupon was engaged in fraud. I was responding to the parent comment's proposition that criminal behavior is irrelevant to pre-IPO activity. Fraud is a criminal offense, and fraud is defined as "an intentional deception made for personal gain". The point is: Fraud is always a course of action available to the SEC, FTC and AGs.