of shares, then use newsletter websites, chat rooms, stock message boards, fake press releases, or e-mail blasts to drive up interest in the stock. Very often, the perpetrator will claim to have "inside" information about impending news to persuade the unwitting investor to quickly buy the shares. When buying pressure pushes the share price up, the rise in price entices more people to believe the hype and to buy shares as well. Eventually the manipulators doing the "pumping" end up "dumping," when they sell their holdings. The expanding use of the Internet and personal communication devices has made penny stock scams easier to perpetrate. Since the Securities & Exchange Commission allowed for the use of social media outlets like Twitter to disclose public information in lieu of press services, many fraudsters have set up accounts to take advantage of this higher level of traffic on social media, giving investors another thing to consider when searching for viable sources of information. Notable cases The Mafia had infiltrated Wall Street by the 1970s. In the 1980s Lorenzo Formato conducted penny-stock manipulations. Formato testified in Congressional hearings that during the years he promoted and sold penny stocks, he was involved in organized crime, and testified to rampant penny stock manipulation by organized crime. The Congressional hearings led to passage of the Penny Stock Reform Act of 1990. By 1989, American investors were being cheated out of at least $2 billion a year by schemes involving penny stocks. Mob activity on Wall Street reportedly increased in the 1990s. On February 10, 1997, The New York Times reported that "Mafia crime families are switching increasingly to white collar crimes" with a focus on "small Wall Street brokerage houses." In May 1997, an FBI sting operation led to charges against Louis Malpeso Jr., a reported Colombo crime family associate, for conspiring to commit securities fraud with stock broker Joseph DiBella and Robert Cattogio to inflate the price of a penny stock, First Colonial Ventures. All three defendants pled guilty. Another example of an activity that skirts the borderline between legitimate promotion and hype is the case of LEXG. Lithium Exploration Group's market capitalization soared to over $350 million after an extensive direct mail campaign. The promotion drew upon the legitimate growth in production and use of lithium, while touting Lithium Exploration Group's position within that sector. According to the company's December 31, 2010, form 10-Q (filed