In the deal that Dato' Goh bagged from the Muar carpenters in late March 2004 that consisted the placement of 5,000,000 shares in stage one at a discounted price to him, Tan Bee Eng, the executive director of Lii Hen and Tok Soon Hing were the initial sellers whom the Dato' had acted as their remisier in SJ Securities Sdn. Bhd. There were another group of sellers in the Muar Branch of Avenue Securities Sdn. Bhd. who were believed to be the relatives or nominees of the Muar carpenters, especially those of Chua Lee Seng's. Together, these parties sold a combined 2,961,000 shares initially.

We were told that Tok Soon Hing is the relative of Tok Heng Leong, another executive director of Lii Hen. We were also reliably informed that the discounted price given to Dato' Goh on the first 5 million Lii Hen shares is RM 1.10 a share. That mean a 10 sen discount to the closing price of RM 1.20 of Lii Hen on March 31, 2004.

Since we do not have the identity of those selling from Avenue Securities Sdn. Bhd and for the fact that Tok Soon Hing is not a member of the board of Lii Hen, it is only fair for now that we exclude them from their relationship to the Unusual Market Action ("UMA") announcement to Bursa Malaysia on August 10, 2004. That mean the focus will be on Tan Bee Eng for now. Henceforth the reason he is named one of the two suspects in Dato Goh's police report.

Tan Bee Eng had disclosed to Bursa Malaysia on June 15, 2004 that he sold a total of 508,500 Lii Hen shares on June 10, 2004 at the price of RM 1.813 per share. As can be seen from the payment voucher of SJ Securities Sdn. Bhd. (pic), the net sale proceed due to him was RM 918,643.37. This amount was deposited into his AmBank Berhad account No. : 018-201-100645-1 on June 14, 2004.

According to the police report of Dato' Goh on April 5, 2013 which we now have a copy (pic), he alleged that this was a false trading price by Tan Bee Eng on June 9, 2004. The actual price of the trade was supposedly to be RM 1.10 a share and not RM 1.813 a share, which was the discounted price agreed and given to him by both Tan Bee Eng and Chua Lee Seng in late March 2004.

To prove his point, he said that the net sale proceed on 508,500 Lii Hen shares at the price of RM 1.10 per share would have been RM 557,271.95. Dato' Goh further produced an evidence that Tan Bee Eng paid to him on June 14, 2004 the differential sum of RM 361,371.42 into a Malayan Banking Berhad account of his which served to confirm that the actual selling price by Tan Bee Eng was indeed RM 1.10 a share and not RM 1.813 a share as have been disclosed to Bursa Malaysia by Tan Bee Eng dishonestly.

Dato' Goh said he was instructed by Tan Bee Eng as his remisier to contract these 508,500 Lii Hen at the price of RM 1.813 a share instead of their agreed price of RM 1.10 a share. By contracting at a higher price, Tan Bee Eng had caused to be created a false and misleading appearance to the market that although he as a substantial shareholder was selling at a high price of RM 1.813 a share, the market is still unfazed by that price and demanded for more Lii Hen shares.

Further, Tan Bee Eng knew fully well that as a director and a substantial shareholder of Lii Hen, he is required to disclose his disposal through Form 29B and the market will be notified eventually through Bursa Malaysia that there exist strong interests on Lii Hen shares even at RM 1.813 a share. If it is not a false trading or a false trading price, there appeared to have no other reasonable explanation for Tan Bee Eng to have contracted the sale at RM 1.813 a share as the cost of commission will be higher than at RM 1.10 a share.

Tan Bee Eng's motive in disclosing a false trading or a false trading price went far beyond this snideness. He did not benefit monetarily from contracting at a higher price as after the deduction of RM 361,371.42 paid to Dato' Goh from the RM 918,643.37 he received from SJ Securities Sdn. Bhd., he ended up with RM 557,271.95 which is exactly his net proceed for his discounted price of RM 1.10 agreed and given to Dato' Goh in late March 2004. He had set his sight further afield because he is aware that without a higher market price for Lii Hen, Dato' Goh will not be able to secure a buyer for his Assets Muar Sdn. Bhd.'s stake of 32% interest in Lii Hen. What is then this 508,500 shares  compared to the 19,200,000 shares he is going to unload soon? That said, he knew it was in his best interest to see a higher market price for Lii Hen. Anyway, the Muar carpenters have given their words to the Dato' on day one that they will coordinate with the deal by disseminating stock positive informations. That Bursa Malaysia announcement by Tan Bee Eng is one, obviously.

The Muar carpenters have sold a combined 2,961,000 Lii Hen shares through SJ Securities and Avenue Securities between April 16 and June 9, 2004 under the same modus operandi. This would mean that all those who sold had committed the same false trading felony.

The Securities Commission ("SC") had charged Dato' Goh under Section 84(1) of The Securities Industry Act 1983 for creating a misleading appearance of active trading of Lii Hen shares by being concerned in the sale and purchase of Lii Hen shares that did not involved any change of beneficial ownership. One of the stock accounts being alleged by the SC in the sale and purchase of Lii Hen shares is the owner of the Maybank account that Tan Bee Eng had deposited the differential sum of RM 361,371.42 to on June 14, 2004. By virtue of the foregoing, Tan Bee Eng is now caught red-handed under the same Section 84(1) in the sale and purchase of Lii Hen shares that did not involved any change of beneficial ownership because part of his sale proceed of RM 361,371.42 was used to purchase his Lii Hen shares through Dato' Goh. That mean Tan Bee Eng had used the said Dato' Goh's account to buy his own shares with the sale proceed from his sale of the 508,500 Lii Hen shares, resulting in no change of beneficial ownership.

Together with his false trading price which caused a misleading appearance of active trading of Lii Hen shares, Tan Bee Eng should have been charged under the same Act together with Dato' Goh and Siow Chung Peng by now. The legal chain of criminal liabilities would also shackles all those who sold the Lii Hen shares from Avenue Securities under the same modus operandi.

But hang on. Isn't the Securities Industry Act 1983 under the purview and supervision of the SC? Why isn't then Dato' Goh lodge his complaint with the SC instead of walking to the Police? As the man who is central in the debacle of Lii Hen in 2004, we are certain he has the pandora's box in hand and he will not hesitate to unleash it now that he had gone on the offensive.

Please visit the new Lii Hen Shareholder Activists website at www.liihen.com

September 13, 2013