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MONTH IN REVIEW & OUTLOOK June saw an extension of the sell-off that began in late April and ended the month sharply lower:

The index, which was just rebalanced as part of the regular quarterly process but has had 27 members since the end of March, saw 2 double-digit gainers and 9 double-digit percentage decliners during the month, including 5 that lost more than 33%. The index decreased 7.2% to 35.35 during June. The 420 Opportunity model portfolio decreased 8.6% in June and is up 31.7% YTD, dramatically outperforming the index, which is down 9.9% YTD. The DEA had been expected to rule on rescheduling this month, but it failed to do so. It did participate in a raid of Care By Design, a leading Northern California cannabis company that was temporarily shut down following false accusations filed by a former employee. KIND Financial announced a deal with Microsoft, which will provide cloud storage for its seed-to-sale software service. The SEC took action against perennial penny stock scammers Hemp, Inc. and its CEO, Bruce Perlowin, his brother and Barry Epling, alleging that they engaged in a fraudulent scheme to sell stock that should have been restricted. In a surprise move, Congress removed

a rider that would have helped protect doctors in the V.A. who counseled veterans about MMJ. California will vote on legalization in November as the ballot initiative was officially approved. A judge is forcing Illinois to add PTSD to its list of qualifying conditions. Ohio Governor Kasich signed into law the state's new MMJ program. In Vermont, Governor Shumlin signed legislation expanding the list of qualifying conditions to include chronic pain, glaucoma and hospice care. In Canada, life insurance companies are beginning to abandon the treatment of cannabis consumers as "smokers", a move that will dramatically lower their premium costs. Health Canada added a new LP, Canada's Island Garden, the third LP east of Ontario, and United Greeneries, which is part of MMJ Phytotech, a publicly-traded company in Australia. The legalization task force will be headed by Anne McLellan, who leads a group of 8 others charged with gathering information to be shared in a report due in November in advance of the introduction of legislation next year to legalize. Colombia awarded its first extracts license for research purposes. Longer-term fundamentals for the industry remain positive, as legal and medical cannabis continue to expand on a state-by-state basis and as the industry moves from the black-market. The early-in-the-year explosion in demand for the stocks in 2014 led to unsustainable valuations (and a lot more supply of stock, much of which was from companies that appear to lack substance). Investors are now focused on the few companies with more visible near-term revenue opportunities, especially in Canada. The big themes ahead are likely to be the potential for the DEA to reschedule cannabis and better clarity from the federal government for banks (both part of the proposed CARERS Act and other proposed legislation), resolution of the MMAR/MMPR lawsuit in Canada, the inclusion of

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extracts in Health Canada's MMPR program and its continued growth in patient enrollment, potential legalization in Canada, the introduction early next year in Germany of MMJ legislation as well as continued advances in South America, progress in 2015 with respect to MMJ expansion and 2016 ballot initiatives for legal cannabis (AZ, CA, MA, ME, MI, NV and possibly others) another MMJ vote in Florida, the Presidential election in 2016, rollouts in Oregon and Alaska, congressional handling of D.C.'s attempts to legalize, and implementations of several state MMJ programs, including Florida (CBD only), Hawaii, Illinois, Maryland, Minnesota, New York, Nevada, Massachusetts, Ohio, Pennsylvania and Texas, and the implementation of the new state program in California. The slide, which began in March of 2014, reversed out the entire gains from early 2014, with the market currently well below the summer 2013 lows despite the rally since mid-February. Most valuations remain high. Positively, we are seeing some new entrants into the publicly-traded sector of higher quality, and hopefully we see more in 2016. Already, traders are contemplating some attention on the sector later this year during the election season given the likely record number of legalization ballot initiatives. Please remember that it remains the case that most of the penny stocks will not succeed. I expect that there will be just a few winners among the 350+ companies that are currently on our Broad List.

June Index Rebalancing Each quarter, I rebalance the 420 Investor Marijuana Index, which is designed to reflect the universe of publicly-traded cannabis stocks. The index, which is equally weighted at the beginning of the quarter, includes all cannabis stocks that have average daily trading value in excess of $25K and a price of at least $0.0020. In the prior quarter, the threshold for the minimum daily average trading value was also $25K, though it was $15K for Q1. To be included in the index, the company must have a U.S. listing, though volume requirements incorporate Canadian volume as well. This quarter, the index will include 28 names, up from 27 in Q2 and representing about 8% of the entire universe of companies. The 420 Investor Focus List, which currently has 24 members, includes 9 names outside of this index, including several Canadian LPs that don't have U.S. listings and some companies that don't meet the daily trading value requirement or price minimum. 5 companies that were eliminated failed to meet the daily trading value minimum, mCig (MCIG), Minerco Resources (MINE), Pineapple Express (PNPL), Sipp Industries (SIPC) and Vape Holdings (VAPE). Two fell below the minimum price, including Directview Holdings (DIRV), which also fell below the daily trading value minimum, and Notis Global (NGBL). The eight additions included four names that had previously been part of the index, with Aero Grow International (AERO), American Cannabis Company (AMMJ), GrowBlox Sciences (GBLX) and Greenhouse Solutions (GRSU) returning. AMMJ and GBLX are on the Focus List. Aero Grow International (AERO) makes the Miracle-Gro AeroGarden line of indoor gardens for consumer markets and is controlled by Scotts

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Miracle Gro (SMH), which will likely exercise warrants it holds in the near future. American Cannabis Company (AMMJ) is a consultant that also markets several products to cultivators. Aphria (APHQF), one of the leading Canadian MMPR LPs, is on the list because it now has a real U.S. listing. The company operates a greenhouse in Ontario and is about to increase its footprint. GrowBlox Sciences (GBLX) has focused on its Nevada cultivation facility that will soon produce revenue. Greenhouse Solutions (GRSU) hasn't done much since its launch, but it has partnered with Koios on a hemp oil infused drink projected to launch later this year and is working to create probiotic infused phytocannabinoid oils. CannaSys (MJTK) has several ventures, including a loyalty reward card, a branding company, a lab information management system and several investments. The company has been in the middle of a massive toxic convertible note conversion process that has pumped up trading volume. Grow Condos (GRWC) operates in Oregon, selling or leasing grow space. 1PM Industries (OPMZ) is a California-based edibles company. The other 20 returning members of the index include the following tickers: ACBFF, BLOZF, CANN, CBDS, CBIS, CVSI, GRNH, GWPH, HEMP, IGC, MJNA, MSRT, OGRMF, PHOT, PMCB, RMHB, SPRWF, SRNA, TRTC and XXII. The current index includes four companies based in or operating in Canada. Only 11 of the 27 companies are trading with daily average trading value in excess of $100K (including in Canada), including ACBFF, APHQF, CANN, GRNH, GWPH, HEMP, MJNA, MSRT, OGRMF, TRTC and XXII.

Who Owns the Canadian LPs' Land?

One of the ways in which investors will likely differentiate LPs in the future is an issue that isn't being discussed much these days. While some own their land, others lease it, often from insiders.

While there is nothing inherently wrong with this arrangement, it can lead to conflicts of interest and incentives that might be contrary to the best interests of outside investors. In a worst-case scenario, leasehold improvements can be lost and a license can become a wasted asset, as they are tied to specific locations. More likely, it is possible that lease extensions can be problematic. With this in mind, here are the real estate ownership details for the leading publicly-traded LPs. Aphria has been leasing from insiders, with a total commitment through 12/31/18 to pay $659K. During the first three quarters of FY2016, the rent paid has been $135K. In April, the company announced the purchased of 36 acres including 9 acres of greenhouses for $6.5mm, which is split equally between cash and a mortgage (5 years, 6.75%). Aurora Cannabis owns its land, which has a mortgage of $1.65mm with a 12% interest rate. The company also pays $3K per month to rent two offices in Edmonton and Calgary to a company controlled by CEO Terry Booth and President Steve Dobler. Canopy Growth owns the Tweed Farms land and facility. As of 12/31/15, the company owed $1.648mm on a mortgage, which is at 5.3%. The land and facility for Bedrocan Cannabis (and an additional property) is owned by Director Murray Goldman (father-in-law of Marc Wayne, the former CEO and current CGC exec). The company paid $227K in rent for the quarter ending 12/31. The Smith Falls facility is owned by a third party in which CEO Bruce Linton (and former CEO Chuck Rifici as well) is an owner. The rent was $2.4mm in the year ending 03/31/16. Mettrum owns the land for its new Bowmanville facility. The company secured a $3.5mm credit facility with an interest rate of 4.8% that is backed by the company's property. It leases the Mettrum Originals facility from the Gregory Herriott, its

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founder (of Hempola, as it was known originally), who serves as President of the unit, paying $4150 per month. More importantly, it leases the Creemore facility from the Miller family. The lease expires in June, 2019 but has extension options and costs $2500 per month. The landlord for the smaller Bowmanville facility, which represents only 5% of production capacity, has the right to evict the company for any reason with six months' notice. Organigram owns its facility in New Brunswick. The company has pledged it against two Farm Credit Canada loans totaling $4mm, including a $2.5mm 5.45% loan and a $1.5mm 5.936% loan. Supreme Pharma owns its land, which came with the $4.5mm purchase in May 2014. The company has a $3.5mm mortgage that was recently extended to July 31, 2016 at a rate of just 3.5%. Management expects to refinance the loan before maturity.

Surna's Attractive Valuation Surna (SRNA) is one of the names I have favored in 420 Opportunity, as it appears to stand out relative to the cannabis stock universe on many fronts. The company has a growing business that addresses critical needs for the industry, and it has upgraded its management team as it has confronted a lot of start-up pains over the past year. The stock is up in the first half of the year, in contrast to the overall market, but the stock price over the past year has been relatively flat despite dynamic growth in sales and only a modest gain in the number of shares outstanding. Is it a bargain? Valuing Surna has its challenges. Not only is the exercise impacted by normal start-up company valuation issues, but the company has substantial debt due beginning later this year, as I will explain below. As the company is generating sales, we

have a metric that can serve as a starting point. The company provides quarterly updates and has generated choppy growth from quarter-to-quarter but has steadily increased its trailing one-year sales over the past five quarters, with the sales over the past year totaling almost $10mm:

Ten months ago, I wrote in the 420 Investor Newsletter (September Edition) that 2016 sales should exceed $10mm and might reach $15mm, which was based on the HVAC business and the added sales from its new reflectors. Despite a delay in the launch of the reflectors, these goals still remain in sight. I had suggested the possibility (not prediction) that if the company could generate sales at that level, it might produce net income of $1mm and that might justify a price of $0.20 per year. With three quarterly reports since I shared that framework, it's worth revisiting some of those assumptions. The first observation is that while the company has finally started to see some improvements in its cost structure, it still remains deep in the red based on net income. In Q1, the operating income was $365K, so, on the surface, the company appeared to be well on its way to achieving a net income of $1mm or more. Unfortunately, the net income was a loss of $1.11mm, as "interest expense", "amortization of

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debt discount on convertible promissory notes" and "loss on change in derivative liabilities" all hurt the bottom-line. Very encouragingly, though, the company generated positive cash from operations that exceeded the operating income. It's not clear how sustainable the operational improvements have been, but the company pointed to a litany of factors that helped it generate better gross margins (44%) and lower operating expenses (down 25% despite a tripling in sales). When the company reports its Q2 results, similar metrics, if achieved, will inspire a lot of confidence from investors and lenders, in my view. It's the latter that is most important, the lenders. As I have pointed out for some time, Surna's balance sheet remains weak, and the company will need to address this later this year. At the end of Q1, the company had current assets of $2.75mm but current liabilities of $6.18mm, meaning that unless the company is able to generate a lot of cash from operations it will need to refinance the short-term obligations, which are mainly cash obligations. The company has several convertible notes. The discussion of the balance sheet is very important in terms of discussing the valuation, as addressing the short-term funding challenge will in almost all likelihood result in a higher share-count. The company could sell equity to a third-party or negotiate with the debt-holders by issuing some amount of stock to get them to forgive or extend their debt. It's impossible to predict how many shares might be issued, but my concern is that it could lead to more shares outstanding than I had assumed previously, 200mm. The debt in issue is the Series 2 debt that was issued beginning in October 2014, part of an offering of units that included equity, the 10% convertible note and warrants. Buyers of the

units received stock at $0.20 but debt for the full value of the unit (plus the warrants). The notes were convertible at a much higher price ($0.60) and, thus, remain outstanding. The total carrying value is $1.694mm, but this excludes $834K in unamortized debt discount. Thus, SRNA will need to come up with $2.5mm roughly to pay of these notes later this year and into 2017. The company has some other smaller converts (Series 3, Series 4) that could also inflate the share-count a bit, but paying off the Series 2 could have a substantial impact on it. It's possible that the company could sell stock to a third party to repay the lenders, and it could also cut a deal with them. For instance, it could kick the can down the road by getting the lenders to agree to extend the maturity in exchange for free-trading stock or warrants. It could also replace the convertible notes with new convertible notes issued to other lenders. In any event, the company will likely need to raise a substantial amount of capital in order to completely address this issue. Assuming it is able to do a private placement of shares, the number of shares issued would depend upon the price of the private placement. Here are the number of shares that would be issued upon raising $3mm:

The company could end up raising more to further strengthen the balance sheet, but it's clear that a reasonable expectation would be too add 50mm, though it could be more or fewer. SRNA reported 145mm shares roughly as of May 12th, up from 122mm a year ago (19%). It also has about 6mm options at $0.00024 that should be included, so 151mm shares. It could be, then, that the 200mm

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shares I predicted could prove to be correct, though I would suspect it would be slightly higher. I believe that the valuation framework I provided last year, suggesting a possible price of $0.20, based on 40 PE, remains appropriate, even if the company has to issue 50mm shares. While the net income is off to a bad start in 2016, it's being depressed by non-cash items related to this outstanding debt. The sales are trending higher than I would have projected, and the share-count seems likely to be close to the 200mm that I expected. Operating income appears to be on track to exceed $2mm if the company can maintain its strong sales growth and continue to control costs. While there is a lot of uncertainty on that issue, I continue to believe that the stock has a very reasonable valuation. The price when I wrote about it ten months ago was $0.131, but today it is $0.094, a decline of 28.2%.

The overall cannabis sector as measured by the 420 Investor Cannabis Stock Index is down 26.5% from 48.10 ten months ago. Concern over the debt and perhaps a lack of appreciation for the operational improvements that are being masked by continued net income losses are also weighing on the stock, but through renegotiation with the lenders or an equity offering, it can be addressed.

To the extent the company can report strong numbers again for Q2 (in August), it should generate interest in either of these solutions. Assuming 200mm shares, and, thus, a market capitalization of $18.8mm, the current valuation seems very fair for a company that is growing sales rapidly and generating free cash flow. Of course, late in the month, the company announced the sudden departure of its CFO, adding yet another near-term headwind. With the sector likely to attract a lot of attention during the election season, SRNA appears to have significant upside.

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Cannabis Industry Calendar

07/19-21: Cannabis Quality Summit in Los Angeles, CA 07/20-21: Imperious Cannabis Business Expo in Seattle/Tacoma, WA 07/27-29: The Science of Industrial Hemp in Denver, CO 07/30: National Cannabis Summit in Hollywood, CA

OTC Disclosure , SEC and Canadian Reporting Deadlines* Fiscal Year ending in April: Annual report due on or before 07/29 Fiscal Year ending August, November or February: Quarterly report due on or before 07/15 Canadian (Venture) Fiscal Year ending in March: Annual due 07/31 Canadian (Venture) Fiscal Year ending in August, November or February: Quarterly due

08/02 *Note that many U.S. companies take advantage of automatic extensions

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SPOTLIGHT ON THE FOCUS LIST 420 Investor maintains a "Broad List" that includes over 350 companies that purport to be in the cannabis sector. At the same time, it monitors a narrower group of 24 companies, the "Focus List", which consists of what we consider the most important companies among the publicly-traded stocks, including the most actively traded as well as several that are under-the-radar but that appear worthy of consideration. We provide numerical ratings to VIP subscribers on three different measures for each member of the Focus List, including relative valuation, technicals and relative quality. PHOT was removed from the Focus List in June. Our relative quality rankings, which range from 1 (best) to 5 (worst) are a subjective assessment of each company relative to the entire Focus List and are based on management capability, corporate governance and transparency, execution and capital structure. The companies that we currently rank below average (4 or 5) include alphabetically by ticker Cannabis Sciences (CBIS), CV Sciences (CVSI), DigiPath (DIGP), GrowBlox (GBLX), Hemp, Inc. (HEMP), Indoor Harvest (INQD), Lexaria Bioscience (LXRP), Medical Marijuana, Inc. (MJNA), MassRoots (MSRT) and Vape Holdings (VAPE). Here were some of the key news items for Focus List companies in June:

American Cannabis Company (AMMJ) finalized its patent for The Satchel exit packaging. The company announced a financing with Tangiers that included a pending equity line as well as a bridge loan. The company added a new consulting client in Colorado

Aphria (APHQF) announced a small investment and that it will more than double its growing capacity with a $10mm expansion project. It also gained an OTC listing that will ultimately be OTCQB but is currently Pink Sheets

Aurora Cannabis (ACBFF) reported that it had generated more than $1mm cumulative sales through early June while surpassing 3500 registered patients. The company announced an LOI to acquire CanvasRx and its plans to conduct a $15mm brokered equity offering

Cannabis Science (CBIS) reported its Q1 late and showed minimal sales despite its new lines of business that have been announced

Canopy Growth (TWMJF) said that it will be uplisting to the TSX later this year. It also began shipping Bedrocan extracts. Sales accelerated in Q4 to over $5mm as the registered patient count soared to 16K as of late June. Bedrocan Brazil was launched as a partnership between the company, Bedrocan and Entourage Phytolab

CV Sciences (CVSI) unveiled its new pre-clinical biotech product, a chewing gum with nicotine and CBD

DigiPath (DIGP) Chairman Bianco replaced Todd Denkin as CEO. Denkin will continue to "earn" his $192K salary while now serving as President.

Growblox (GBLX) announced its exclusive rights to Kyle Kushman's cannabis brands, strains and genetics in Nevada. The company has a 10% stake in a dispensary that just opened.

GW Pharma (GWPH) rival Zogenix moved its Dravet Syndrome drug into Phase 3 trials. It received Orphan designation for its Epidiolex in a fourth area, Infantile Spasms. The Epidiolex Phase 3 trial results for LGS patients showed efficacy without any substantial safety issues.

Hemp, Inc. (HEMP) was hit with a civil lawsuit by the SEC alleging fraud

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Indoor Harvest (INQD) described a $25mm sales pipeline with $10mm in contracts. The company, which is considering splitting into two in order to separate the cannabis business from the vertical farming business, withdrew the S-1 that had gone effective to register the Kodiak shares. The company announced an LOI with an applicant in the Texas CBD program

Lexaria (LXRP) sold shares with warrants to an I.R. firm that will be paid with the bulk of that cash as well as options for services rendered

MassRoots (MSRT) named a new CTO and announced a new member to its Board of Advisors Mettrum (MQTRF) sales rose 35% from the prior quarter and its registered patient count rose to 12K

as of late June Nemus (NMUS) has agreed to license biosynthetic technology fro Teewinot Life Sciences to produce

cannabinoids. It reported positive data regarding its glaucoma drug in development OrganiGram (OGRMF) closed its $10mm equity raise and received its license to sell extracts Supreme Pharma (SPRWF) reported Q3 financial results and announced that it will be supplying

other LPs with clones Surna (SRNA) announced the sudden departure of its CFO Terra Tech (TRTC) announced a convertible note deal and released audited financials for Blum

Oakland, which is seeing growth subsequent to the close in its overall business and especially in IVXX extracts. It named Katie Burnett, LPGA Pro, as a spokesperson for Edible Garden. It also disclosed a distribution relationship with Callow Distribution in California. A Washington Post article revealed that the company has applied for cultivation, processing and dispensary licenses in Maryland.

Vape Holdings (VAPE) replaced its CEO with its COO

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FOCUS LIST - RETURNS FROM JUNE:

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420 Investor Canadian Cannabis Model Portfolio

I introduced a new model portfolio at the end of 2015 that includes the licensed producers in Canada.

The model portfolio selects from names in the index and can include a weighting of 0-200% of the company's representation in the index. The index includes companies that operate or are invested in facilities approved by Health Canada to sell medical cannabis. The index weights are based upon holding a license with additional credit (a double-weight) given for sales in the most recent quarter in excess of $1mm. The criteria are likely to change over time. The initial index included seven companies and gave extra credit to three. OrganiGram reported quarterly sales in excess of $1mm and is now double-weighted, while THC was added in March and SL in April following license approvals.

Here is the index weighting along with the model portfolio exposure from last month with the month's results:

The stocks bounced back after the profit-taking in May following the big April rally. The model outperformed the index by 7.7%, with the model rising 12.3% compared to the 4.6% gain in the index. YTD, the model has outperformed by 16.6%. Being underweight ACB, EMH, MJN, OGI and THC and overweight APH, CGC and especially MT helped in June, while being overweight SL hurt returns. The returns continued to vary greatly from LP to LP. YTD returns for the 4 names that are most heavily weighted in the index are +24% for APH, -7% for CGC, +10% for MT and +11% for OGI. ACB has declined 22%, while EMH and MJN are down 18% and 37% respectively. While they weren't included in the index at year-end, SL has declined 26%, and THC has increased 11%.

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This month, I made some adjustments, decreasing the relative weightings in APH by 7% and MT by 4% and increasing CGC by 4.6%, OGI by 2.1% and SL by 4.3% (posted at 3PM ET 06/30):

My rationale for the relative exposures:

Aurora Cannabis (ACB) has a market cap near $95mm and substantial debt. The fundamentals are improving, and the stock is getting more attractive

Aphria (APH) has a market cap of approximately $144mm and a balanced model that includes wholesale and is a low cost producer, with added capacity adding to growth potential. It has performed very well in the first half of 2016 and could pause.

Canopy Growth (CGC) is the clear leader but the $300mm market cap is now more line in line with its peers after underperformance. Strong assets and brands will continue to attract investors.

Emerald Health (EMH) has a market cap of just $9mm but needs to raise capital and establish its brand

PharmaCan Capital (MJN) has a market cap of $17mm but has recapitalized after a large equity deal and trades near asset value with no near-term liquidity issues

Mettrum (MT) has a market cap of $88mm after a recent capital raise and recently expanded capacity. Despite strong performance, it remains inexpensive to others adjusted for capacity

OrganiGram (OGI) has a market cap of $76mm, which seems a bit expensive. The company, despite its insistence otherwise, is not generating cash flow from operations

Supreme Pharma (SL), with a market cap of $52mm, is significantly leveraged to legalization and could emerge as one of the lowest-cost producers. Cheap to ACB with better balance sheet and better LT prospects. Stock should rally into sales license receipt in Q4.

THC Biomed (THC) has a market cap near $11mm and needs to raise capital

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ABOUT THE 420 INVESTOR – ALAN BROCHSTEIN, CFA:

I have spent decades inside the investment industry. Prior to earning my CFA charter in 1997, I worked in NYC for Kidder, Peabody, & Co. in bonds from 1986 to 1992. In 1992, I joined First Boston’s investment management subsidiary before becoming a portfolio manager with Criterion Investment Management in 1994 —co-managing $10 billion in fixed-income investments. In 2000, I made the move to stocks, joining a small firm in Houston as an analyst and portfolio manager. I remained at the firm, which grew to $550mm in assets under management, until 2006, when I left to form my own business, AB Analytical Services—working as a research consultant for several investment advisors.

In 2008, I began offering Invest By Model, a model portfolio service, to individual investors. I met Marketfy in 2013 and created The Analytical Trader, a service focused on providing swing-trading ideas. Both of these services delivered strong performance. I also became a leading contributor to Seeking Alpha. After seeing a strong need for more investor transparency among cannabis companies in early 2013, I launched 420 Investor— a service committed to providing real-time, objective information about the top cannabis companies in the market. 420 Investor has evolved into a collaborative due diligence platform, and I am proud to lead our efforts. I am also co-founder of New Cannabis Ventures, which provides curated content and other resources to help inform cannabis investors and entrepreneurs about the most exciting companies and the most influential investors in the rapidly changing cannabis industry. In the process of launching the 420 Investor, I became a much-needed ally to cannabis investors, being hailed as a leading authority in the industry as I developed a network of investors and industry professionals. In early 2014, I exited all of my other business in order to focus exclusively on the cannabis sector. I have supported marijuana legalization since 1980, when I became active in the Libertarian Party. I currently sponsor Americans for Safe Access, the Drug Policy Alliance, the Marijuana Policy Project , the National Cannabis Industry Association, NORML, Students for Sensible Drug Policy, and Women Grow. Follow Alan on Twitter: http://www.twitter.com/Invest420 Follow Alan on Facebook: http://www.facebook.com/420investor Join Alan's LinkedIn Group: Cannabis Investors & Entrepreneurs The 420 Investor Newsletter is available via annual subscription ($149/yr) and is included as part of the monthly ($42/mo) or the annual ($420/yr) 420 Investor VIP subscription.