Fact Pattern $21-1$

Drilling Tools, Inc., wants to make an initial public offering of securi$-$ties. Drilling Tools believes that it qualifies for an exemption under Regulation A from the full registration requirement of the federal Securities Act of $1933.$

$$

Refer to Fact Pattern $21-1.$ Drilling Tools decides to sell its new securities via the Internet. This offering

$$will avoid the payment of commissions to brokers or underwriters.

$$is an investment scam.

$$is a Ponzi scheme.

$$constitutes insider trading.