21.   He has also reportedly been questioned by the Securities and Exchange Commission, though an SEC spokesman said he could not comment.

22.   John Heine, an SEC spokesman, declined to comment, citing a commission policy against discussing matters not in the public record.

23.   No formal action was taken in the case, according to an SEC spokesman.

24.   None of the three former executives returned calls seeking comment, and an SEC spokesman declined to discuss the matter.

25.   SEC spokesman John Heine and SEC enforcement director William McLucas declined comment today, as did NASD spokesman Marc Beauchamp.

26.   SEC spokesman Duncan C. H. King declined comment.

27.   SEC spokesman John Heine declined comment and would not say whether this type of action would warrant agency attention.

28.   SEC spokesman John Heine declined to comment on the matter.

29.   SEC spokesman John Heine told The Chronicle that the agency had thought very carefully about the step it took.

30.   SEC spokesman John Heine, citing agency policy, declined to comment on whether the company is under investigation.