Statement of Allegations: In The Matter of Gary A. Fitchett et al.

IN THE MATTER OF THE SECURITIES ACT
R.S.O. 1990, c. S.5, AS AMENDED

AND

IN THE MATTER OF
GARY A. FITCHETT, LLOYD E. DOVE, LEON H. GOUZOULES,
PAUL D. MACK AND EDWARD LAI

STATEMENT OF ALLEGATIONS OF STAFF
OF THE ONTARIO SECURITIES COMMISSION

Staff of the Ontario Securities Commission make the following allegations:

1. IBI Corporation ("IBI") is incorporated under the laws of Canada. IBI is a reportingissuer in Ontario.

2. Each of Gary A. Fitchett, Lloyd E. Dove, Leon H. Gouzoules, Paul D. Mack andEdward Lai (individually, a "Respondent" and collectively, the "Respondents") is,or was during the financial year of IBI ended December 31, 1999, a director, officer,significant shareholder (beneficial ownership of 10% or more of the voting rights ofIBI) or individual that has, or may have, access to material undisclosed information.

3. IBI failed to file annual financial statements for its financial year ended December31, 1999 on or before May 19, 2000, contrary to subsection 78(1) of the SecuritiesAct (Ontario).

4. By virtue of his/her/its relationship, each Respondent has, or may have, access toinformation regarding the affairs of IBI that has not been generally disclosed.

5. It would be prejudicial to the public interest to allow the Respondents to trade in thesecurities of IBI until such time as all disclosure required by Ontario securities lawhas been made by IBI.

6. It is therefore in the public interest for the Commission to order that all trading,whether direct or indirect, in the securities of IBI by the Respondents cease untilsuch time as IBI has made all filings it is required to make under Ontario securitieslaw.