SEC v. Akshay Kamboj; and Dev Kamboj, No. 1:24-cv-07319, Southern District of New York (Sept. 27, 2024) — Complaint

ANTONIA M. APPS
REGIONAL DIRECTOR
Sheldon L. Pollock
Adam Grace
Travis Hill
Nicholas Flath
Rhonda L. Jung
Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
New York Regional Office
100 Pearl Street
Suite 20-100
New York, NY 10004-2616
212-336-9135 (Hill)
[email protected]

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

SECURITIES AND EXCHANGE
COMMISSION,

                                             Plaintiff,

                        -against-

AKSHAY KAMBOJ and DEV KAMBOJ,

                                             Defendants.

COMPLAINT

24 Civ. 7319

JURY TRIAL DEMANDED

Plaintiff Securities and Exchange Commission (“Commission”), for its Complaint against
Defendants Akshay Kamboj and Dev Kamboj (together, “Defendants”) alleges as follows:
SUMMARY
1. Beginning in April 2022, Defendants used fake trading data and forged audit
reports to convince dozens of investors to invest approximately $16 million in a currency trading
hedge fund (the “Fund”) managed by their firm, Crawford Ventures IM, LLC (the “Investment
Firm”).

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2. Defendants falsely represented to prospective investors in the Fund that they were
successful traders who had generated average annualized returns of nearly 70% on behalf of
investors in certain separately managed accounts,  using the same investment strategy as the
Fund’s.  But in fact, these returns were fabricated.
3. Based on these fabricated returns, Defendants touted in marketing materials for
investors that the Fund ranked as the “World’s #1 Performing Fund” out of thousands of hedge
funds.
4. Additionally, Defendants used forged audit reports—ostensibly issued by a global
accounting firm (the “Audit Firm”)—to verify their trading record, and even created an email
account with a domain name resembling that of the Audit Firm to perpetuate and conceal their
fraud.
5. By December 2023, in the face of substantial trading losses, the Investment Firm
announced plans to voluntarily liquidate the Fund.
6. As a result of Defendants’ fraud, investors suffered aggregate net losses of
approximately $4.1 million.
7. Meanwhile, Defendants personally profited through hundreds of thousands of
dollars in management and performance fees.
VIOLATIONS
8. By virtue of the foregoing conduct and as alleged further herein, Defendants
violated Section 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)],
Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. § 78j(b)] and
Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]  .

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9. Unless Defendants are restrained and enjoined, they will engage in the acts,
practices, transactions, and courses of business set forth in this Complaint or in acts, practices,
transactions, and courses of business of similar type and object.
NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT
10. The Commission brings this action pursuant to the authority conferred upon it by
Securities Act Sections 20(b) and 20(d) [15 U.S.C. §§ 77t(b) and 77t(d)] and Exchange Act
Section 21(d) [15 U.S.C. § 78u(d)].
11. The Commission seeks a final judgment: (a) permanently enjoining Defendants
from violating the federal securities laws and rules this Complaint alleges they have violated;
(b) ordering Defendants to disgorge all ill-gotten gains t hey received as a result of the violations
alleged here and to pay prejudgment interest thereon, pursuant to Exchange Act Sections
21(d)(3)  , 21(d)(5), and 21(d)(7) [15 U.S.C. §§ 78u(d)(3)  , 78u(d)(5), and 78u(d)(7)]; (c) ordering
Defendants to pay civil money penalties pursuant to Securities Act Section 20(d) [15 U.S.C.
§ 77t(d)] and Exchange Act Section 21(d)(3) [15 U.S.C. § 78u(d)(3)]; and (d) ordering any other
and further relief the Court may deem just and proper.
JURISDICTION AND VENUE
12. This Court has jurisdiction over this action pursuant to Securities Act Section
22(a) [15 U.S.C. § 77v(a)] and Exchange Act Section 27 [15 U.S.C. § 78aa].
13. Defendants, directly and indirectly, have made use of the means or
instrumentalities of interstate commerce or of the mails in connection with the transactions, acts,
practices, and courses of business alleged herein.
14. Venue lies in this District under Securities Act Section 22(a) [15 U.S.C. § 77v(a)]
and Exchange Act Section 27 [15 U.S.C. § 78aa].   C ertain of the acts, practices, transactions, and

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courses of business alleged in this Complaint occurred within this District.  For example, at all
relevant times, the Investment Firm was headquartered in Manhattan.  Additionally, Defendants
sent fabricated trading data and forged reports to Evan H. Katz (“Katz”), an Investment Firm
partner who worked out of Manhattan.  Defendants also caused the Investment Firm to send false
marketing materials to at least one prospective investor located in Manhattan.
DEFENDANTS
15. Akshay Kamboj, age 33, resides in Gurguram, India.  At all relevant times
following formation of the Fund, he was the Fund’s Co-  Chief Investment Officer (with his
brother Dev Kamboj) and Head of Strategy Development.  He also owns 25% of the Investment
Firm and the Fund’s general partner, Crawford Ventures GP (“General Partner”), and was a
manager of both entities.
16. Dev Kamboj, age 39, resides in Gurguram, India.  At all relevant times following
formation of the Fund, he was the Fund’s Co-Chief Investment Officer (with his brother Akshay
Kamboj) and Head of Research.  He also owns 25% of the Investment Firm and the General
Partner and was a manager of both entities.
OTHER RELEVANT INDIVIDUALS AND ENTITIES
17. Katz resides in Queens, New York.  He is the managing director of an alternative
asset investment firm that raises capital for hedge funds and private equity funds.  At all relevant
times following formation of the Fund, he was the Fund’s Chief Operating Officer and General
Counsel.  Katz also owns a 25% interest in the Investment Firm and the General Partner and was
a manager of both entities.
18. The Fund was a currency trading hedge fund formed as a Delaware limited
partnership in December 2021.  The Fund was co-founded and managed by Defendants and

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Katz.  It commenced trading activities in September 2022 and has been dormant since early
2024.  In May 2024, Katz commenced a proceeding in Delaware Chancery Court to dissolve the
General Partner and the Investment Firm and appoint a liquidating trustee for the Fund.  That
proceeding is pending as of the date of this Complaint.
19. The Investment Firm is a Delaware limited liability company formed in
December 2021.  The Investment Firm was the Fund’s investment manager and was entitled to
receive 2% of the Fund’s assets under management per year in management fees under the
Fund’s limited partnership agreement.  As of the date of this Complaint, the Investment Firm is
the subject of dissolution proceedings pending in Delaware Chancery Court.
20. General Partner is a Delaware limited liability company formed in December
2021 and the general partner of the Fund.  Pursuant to the Fund’s limited partnership agreement,
General Partner was entitled to receive 20% of the Fund’s net profits as performance fees.  As of
the date of this Complaint, the General Partner is the subject of dissolution proceedings pending
in Delaware Chancery Court.
FACTS
I. Background on Defendants’ Fabrication of Their Trading Performance
21. On or about May 11, 2021, prior to the formation of the Investment Firm or the
Fund, Akshay Kamboj sent an unsolicited email to Katz, a United States-based hedge fund
marketing consultant, to ask for assistance in “raising capital and connecting us to your well
established network.”
A. Defendants Fabricated Their Historical Trading Performance
22. The email attached a performance report claiming that, between 2018 and 2020,
Defendants had generated average annual returns on investment of 78.71% by trading currencies

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and that, as of 2021, Defendants had aggregate assets under management of more than $30
million (the “Historical Performance Report”).
23. The email also attached a  prospectus in which the Defendants asserted that they
used four different brokerage firms for “trade execution,” including a Swiss broker.
24. Separately, the email attached a  transactions sheet (“Historical Transactions
Sheet”) purporting to show a trade-by-trade record of net profits on trades since April 2018 in an
account for a Kamboj family fund that Defendants managed at the Swiss broker named in the
prospectus (the “Brokerage A ccount”).  These transactions appeared to represent a component of
the aggregate returns shown in the Historical Performance Report.
25. The purported net profits shown in the Historical Transactions Sheet ranged from
thousands to tens of thousands of dollars per individual trade, and from several hundred thousand
dollars to more than one million dollars per quarter, and over the entire reported period, totaled
more than $11.8 million.
26. As reflected by the actual trading records for the Brokerage Account, the
Historical Transactions Sheet sent to Katz included fake trades and altered trade data, falsely
inflating Defendants’ returns.
27. Specifically, 695 of the 793 total trades shown on the Historical Transactions
Sheet, purportedly placed between April 2018 and November 18, 2019, were fake, because the
Brokerage Account in which these trades supposedly had been placed was not opened until
November 19, 2019.  These fake trades accounted for more than $6.9 million of supposed trading
profits.
28. Further, 81 of the remaining 98 trades reported on the Historical Transactions
Sheet, supposedly placed on or after November 19, 2019, do not have ticket numbers that match

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real trades placed in the Brokerage Account.  These 81 additional fake trades account for $3.8
million of supposed trading profits.
29. For the remaining 17 trades on the Historical Transactions Sheet whose ticket
numbers match ticket numbers of real trades, the Historical Transactions Sheet falsely altered
information about the trades in a way that overstated the supposed profits.  These 17 trades, in
reality, resulted in aggregate net profits of only $86.73.  The Historical Transactions Sheet, by
contrast, reported net profits of almost $1 million from these trades.
30. Finally, the Historical Transactions Sheet omitted at least 20 real trades which had
occurred in the Brokerage Account between November 19, 2019 and March 31, 2021, and
resulted in aggregate net losses of more than $19,000.
31. In total, the actual trading record of the Brokerage Account during the period
November 19, 2019 to March 31, 2021 reflected net aggregate losses of almost $20,000–not the
net profits of $11.8 million reported on the Historical Transaction Sheets.
32. Accordingly, the millions of dollars of trading profits reported in the Historical
Transactions Sheet were fictitious.  And because the Historical Performance Report relied on the
accuracy of the Historical Transaction Sheets, the Historical Performance Report was fictitious
as well.
B. Defendants Fabricated Two Audit Reports
33. To add legitimacy to Defendants’ fake trading history, on or about May 25, 2021,
Akshay Kamboj sent Katz a purported independent audit report of the Kamboj family fund’s
2020 financial statements issued by the Audit Firm (the “Financial Statements Audit Report”).

 8
34. But the Financial Statements Audit Report was forged.  As Defendants knew by
virtue of their roles managing the Kamboj family fund, the Audit Firm did not perform any work
for Defendants or their family fund.
35. In or around June 2021, Katz agreed to co-found the Fund with Defendants, and it
was formally established in December 2021.
36. In or around March 2022, in preparation for soliciting investors in the Fund, Katz
asked Defendants to have the Audit Firm prepare a report verifying the historical investment
returns that Defendants had previously presented to Katz in the Historical Performance Report
and Historical Transaction Sheet.
37. In or around April 2022, Defendants provided Katz what purported to be a
performance audit report for the Kamboj family fund issued by the Audit Firm (the
“Performance Audit Report”).
38. The Performance Audit Report, like the Financial Statements Audit Report, was a
forgery, which purported to verify the historical investment returns shown in the Historical
Performance Report and the Historical Transaction Sheet.
39. The Performance Audit Report also listed a fake email address (“Fake Email
Address”) for the Audit Firm partner who ostensibly signed both the Financial Statement Audit
Report and Performance Audit Report (the “Audit Firm Partner”).
40. The Fake Email Address contained a domain name similar to the real Audit
Firm’s actual domain, but which was purchased in June 2021 by an individual providing a phone
number used by Defendants.
41. As Defendants knew or recklessly disregarded, the Audit Firm never issued an
audit report of any kind for Defendants or the Kamboj family fund the Defendants managed, and

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the investment returns reflected in the Performance Audit Report did not accurately reflect
Defendants’ trading history.
42. Defendants did not tell Katz that their trading record was fake, nor did they tell
him that they had forged the Financial Statements Audit Report or the Performance Audit.
II. Defendants Prepared False and Misleading Marketing Materials for the Fund Based on
Their Fictitious Returns.
43. In late 2021 and early 2022, Defendants, together with Katz, developed a
marketing strategy for investor outreach and authored marketing materials for the Fund.  These
marketing materials included a PowerPoint presentation (the “PowerPoint”) and a one-page
promotional document (the “One Pager”).
44. Defendants approved the content of the PowerPoint and One Pager.
45. The PowerPoint and the One Pager highlighted Defendants’ fictitious trading
returns as reflected in the Historical Performance Report and ostensibly verified by the
Performance Audit Report and the Historical Transaction Sheets, characterizing them as “the
actual performance metrics that have been managed” by Defendants in separately managed
accounts, using the fund’s strategy since February 2016.”
46. For example, the PowerPoint falsely asserted that “our fund’s strategy has
produced, since its inception in February 2016, exceptionally favorable investment performance
metrics,” and that “six years of proven track record and a repeatable process that has provided
high-return high-consistency returns of almost +70% per year (CAGR)
1
 with minimal
drawdowns.”

1
 “CAGR” means Compound Annual Growth Rate.  CAGR is the mean   annual growth rate of an investment over a
period longer than one year, with the effect of compounding taken into effect.  See Investopedia, Compound Annual
Growth Rate (CAGR): What You Should Know, May 15, 2024, available at
https://www.investopedia.com/investing/compound-annual-growth-rate-what-you-should-know/
.

 10
47. Both the PowerPoint and the One Pager also included a month-by-month chart of
supposed trading returns dating back to April 2016, as well as a summary chart showing the
Defendants’ strategy’s “cumulative return” and “annualized return,” among other metrics.
These supposed trading returns were the same trading returns supposedly verified by the
Performance Audit Report and the Historical Transaction Sheets.
48. As Defendants knew, these trading returns and metrics were fictitious.  As
discussed above, Defendants altered and inflated their actual trading record to radically overstate
the success of their trading strategy.
49. The PowerPoint also falsely claimed that the Fund ranked as “the World’s #1
Performing Fund for Best 3 and 5 Year Returns of any Equity Hedge Fund, CTA, or Currency
Fund.”
50. The ranking was based on information provided by a hedge fund analytics service
(“Service 1”) during a December 2021 videoconference in which Service 1 was promoting its
analytics product to the Investment Firm.
51. As Defendants knew or recklessly disregarded, Service 1’s comparison of the
Fund’s performance to other funds in Service 1’s database was based on Defendants’ fabricated
trading data that Katz sent to Service 1 in a November 2021 email, with Defendants’ consent.
52. During the December 2021 videoconference, Service 1 displayed charts showing
how Defendants’ (fabricated) trading record would rank in Service 1’s database of fund
performance.
53. Dev Kamboj then inserted screenshots of those charts—which he knew did not
accurately reflect Defendants’ actual trading performance—into the PowerPoint to demonstrate
the Fund’s purported “#1” ranking.

 11
54. The Fund’s July 2022 private placement memorandum (“PPM”) also cited
Service 1’s purported “rank[ing] of [Defendants’] investment strategy  . . . as the world’s #1
performing strategy for best three- and five-year returns” as a fact that “limited” the risk relating
to the Fund’s lack of operating performance history.
55. This statement in the PPM was false and misleading because, as Defendants knew
or recklessly disregarded, Service 1’s analysis was based on fabricated trading data.
56. Defendants had primary drafting responsibility for the PPM and approved its
contents.  Additionally, Akshay Kamboj sent the PPM to third parties, including the Fund’s
broker.
57. In addition to the falsely procured analysis by Service 1, the PowerPoint for the
Fund touted eight awards that the Fund obtained from a second hedge fund analytics service
(“Service 2”) between February and August 2022, based on the purported (but fictious) returns
employed by the Fund’s strategy.
58. Service 2 issued the awards based on the fake monthly returns reflected in the
Fund’s One Pager and PowerPoint, which the Investment Firm sent to Service 2.
59. As Defendants knew or recklessly disregarded, touting the awards from Service 2
was misleading because the awards did not reflect, and were not based upon, Defendants’ actual
trading performance.
III. Defendants Used the False PowerPoint, One Pager, PPM, and Performance Audit
Report to Solicit Investors.
60. In or around April 2022, the Investment Firm began communicating with
prospective investors about the opportunity to invest in the Fund.

 12
61. From in or around April 2022 to in or around August 2023, with Defendants’
approval, the Investment Firm sent the PowerPoint, One Pager, and PPM to prospective
investors, including at least one prospective investor located in New York, New York.
62. As discussed above, the PowerPoint and the One Pager featured Defendants’ fake
trading records, as well as accolades attributed to Service 1 and Serve 2, which were based on
the fake data.
63. With Defendants’ knowledge and approval, the Investment Firm sent certain
prospective investors the forged Performance Audit Report, and encouraged them to contact the
Audit Firm Partner who appeared to sign the report at the Fake Email Address associated with
Defendants.
A. Solicitation of Adviser-1’s Clients
64. In or around May 2022, Katz emailed the One Pager, the PowerPoint, and the
Performance Audit Report to an investment adviser (“Adviser 1”) in connection with the
Investment Firm’s efforts to solicit the investment adviser’s clients to invest in the Fund.
65. A few days later, Katz, copying Defendants, sought to introduce Adviser 1 via
email to the Audit Firm Partner to facilitate Adviser 1’s due diligence on behalf of clients
interested in investing in the Fund.  Unbeknownst to Katz or Adviser 1, the email address
identified for the Audit Firm Partner was actually the Fake Email Address associated with
Defendants.
66. Thereafter, Adviser 1 communicated about the Performance Audit Report with
the Fake Email Address associated with Defendants.  For example, on May 24, 2022, a
representative of Adviser 1 asked for confirmation that Audit Firm had generated the
Performance Audit.  Later that day, a message sent from the Fake Email Address stated in reply,
“Yes, we are the official auditing firm for [the Kamboj family f und] from FY 2016-2020.”

 13
67. Dev Kamboj himself also personally communicated by phone and email with a
representative of Adviser 1.  In these communications, he referred Adviser 1 to the (forged)
Performance Audit Report.
68. Following Adviser 1’s receipt of the false One Pager and PowerPoint and forged
Performance Audit Report, and after Adviser 1’s communications with the Fake Email Address
that Adviser 1 believed belonged to the actual Audit Firm Partner, Adviser 1 recommended that
its advisory clients invest in the Fund.
69. Ultimately, clients referred by Adviser 1 and its affiliates invested more than $9
million in the Fund, accounting for more than half of the Fund’s total assets under management.
70. Adviser 1 would not have recommended the Fund to its clients had Adviser 1
known that the One Pager, the PowerPoint, and the Performance Audit Report reflected
fabricated investment returns and that the Performance Audit Report was forged.
B. Solicitation of Investor 1
71. In or around June 2022, Defendants and Katz participated in a videoconference
with representatives of another prospective investor (“Investor 1”).
72. In or around August 2022, Katz sent the One Pager, PowerPoint, and Performance
Audit Report to representatives of Investor 1.  Katz wrote that “Akshay and Dev’s globally #1
ranked track record is, of course, audited by a large and highly competent accounting and audit
firm (e.g., several hundred employees, about 20 offices, some 10,000 clients, etc.).  Attached is a
copy of their audit and performance confirmation.”
73. After receiving the fake trading returns featured in the One Pager, the PowerPoint,
and the Performance Audit Report, in or around August 2022, Investor 1 invested $3 million in
the Fund, becoming the largest single investor.

 14
74. The Performance Audit Report, which was in fact forged, gave Investor 1 comfort
before Investor 1 invested in the Fund.
75. Defendants Used the False PowerPoint, One Pager, and Performance Audit
Report to Solicit Investors.
IV. Defendants Tried to Evade Detection of Their Fraudulent Conduct.
76. In or around June 2022, Akshay Kamboj instructed Katz to abandon efforts to
solicit an investment from a prospective investor (“Investor 2”) after representatives of Investor
2 asked for the Audit Firm Partner to participate in a due diligence call with an attorney.
77. Investor 2 chose not to invest in the Fund.
78. Later, in or around March 2023, as part of its due diligence, another prospective
investor (“Investor 3”), emailed the Audit Firm Partner both at the Fake Email Address
associated with Defendants and at Audit Firm Partner’s actual email account, which was publicly
listed on the Audit Firm website.
79. A reply message to Investor 3 sent from the Fake Email Address associated with
Defendants removed the Audit Firm Partner’s actual email address, falsely explaining to Investor
3 that the “other” address was “monitored by our internal/domestic compliance team for general
accounting and tax operations within Australia.”
80. Akshay Kamboj separately forwarded Investor 3’s email to the real Audit Firm
Partner, writing:
Hi [Audit Firm Partner], This is the below email that I have received on my
work accounts and saw you are also cc’d in the same email chain. Kindly do
not reply back to this email or open it as this is a malware domain, I happen to
have replied back to such an email a few days ago and realized all of my work
data and banking information was stolen.  I also tried to call you and warn you
but no reply. (Got your phone number from Zoominfo.)
I hope you do not fall for this as well. Please call me or text me if you need
more info on this.

 15
81. Akshay Kamboj did not include Katz or Investor 3 on his email to the real Audit
Firm Partner.
82. In response to a request from Investor 3 to meet the Audit Firm Partner, Akshay
Kamboj asked Investor 3 to “please confirm your availability and contact number,” but Investor
3 insisted on doing a “Teams or Zoom.”
83. A videoconference using Teams or Zoom would have enabled Investor 3 to see
that the purported Audit Firm Partner did not match his photograph on the Audit Firm’s website,
thereby revealing Defendants’ fraudulent conduct.
84. Although Katz had circulated an invite for a videoconference with Investor 3,
Defendants cancelled the meeting.
85. Investor 3 chose not to invest in the Fund.
V. Collapse of the Fund
86. After commencing trading in September 2022, the Fund’s returns never matched
the fictitious historical track record of the Fund strategy provided to prospective investors in the
One Pager and the PowerPoint.
87. In or around late 2023, Defendants executed a series of trades that caused the
Fund to suffer significant trading losses.
88. Those losses caused a roughly 40% decline in the Fund’s value over a four-month
period.
89. As a result of the Fund’s poor performance, the Fund experienced significant
redemption requests from investors.
90. In or around December 2023, the Investment Firm informed investors that the
Fund would be liquidating, and that the Investment Firm would cease taking any further
management fees.

 16
91. In or around early 2024, following revelations of potential fraudulent conduct
relating to the Fund and before the planned liquidation took place, the Fund’s prime broker froze
access to its brokerage account.
92. At the time, the Fund had approximately $7.9 million in assets and $12 million in
unredeemed investor capital contributions, meaning that investors had lost approximately $4.1
million.
93. Pursuant to the Fund’s limited partnership agreement, the Fund paid a total of
$80,308.01 in performance fees to the General Partner from inception through the end of 2023.
94. The Fund also paid management fees to the Investment Firm totaling $381,269.95
from inception through the end of 2023.
95. Akshay Kamboj’s share of the management and performance fees totaled
approximately $115,394.48 on account of his 25% share of the General Partner and the
Investment Firm.
96. Dev Kamboj’s share of the management and performance fees also totaled
approximately $115,394.48 on account of his 25% share of the General Partner and the
Investment Firm.
97. The Investment Firm and the General Partner transferred Akshay Kamboj’s and
Dev Kamboj’s respective shares of the management and performance fees to a Kamboj family
fund, which Akshay Kamboj controlled and of which he was the sole shareholder.
FIRST CLAIM FOR RELIEF
Violations of Securities Act Section 17(a)
(Against Both Defendants)

98. The Commission re-alleges and incorporates by reference here the allegations in
paragraphs 1 through 97.

 17
99. Defendants, directly or indirectly, singly or in concert, in the offer or sale of
securities and by the use of the means or instruments of transportation or communication in
interstate commerce or the mails, (1) knowingly or recklessly have employed one or more
devices, schemes or artifices to defraud, (2) knowingly, recklessly, or negligently have obtained
money or property by means of one or more untrue statements of a material fact or omissions of
a material fact necessary in order to make the statements made, in light of the circumstances
under which they were made, not misleading, and/or (3) knowingly, recklessly, or negligently
have engaged in one or more transactions, practices, or courses of business which operated or
would operate as a fraud or deceit upon the purchaser.
100. By reason of the foregoing, Defendants, directly or indirectly, singly or in concert,
have violated and, unless enjoined, will again violate Securities Act Section 17(a) [15 U.S.C.
§ 77q(a)].
SECOND CLAIM FOR RELIEF
Violations of Exchange Act Section 10(b) and Rule 10b-5 Thereunder
(Against Both Defendants)

101. The Commission re-alleges and incorporates by reference here the allegations in
paragraphs 1 through 97.
102. Defendants, directly or indirectly, singly or in concert, in connection with the
purchase or sale of securities and by the use of means or instrumentalities of interstate
commerce, or the mails, or the facilities of a national securities exchange, knowingly or
recklessly have (i) employed one or more devices, schemes, or artifices to defraud, (ii) made one
or more untrue statements of a material fact or omitted to state one or more material facts
necessary in order to make the statements made, in light of the circumstances under which they

 18
were made, not misleading, and/or (iii) engaged in one or more acts, practices, or courses of
business which operated or would operate as a fraud or deceit upon other persons.
103. By reason of the foregoing, Defendants, directly or indirectly, singly or in concert,
have violated and, unless enjoined, will again violate Exchange Act Section 10(b) [15 U.S.C.
§ 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].
PRAYER FOR RELIEF
 WHEREFORE, the Commission respectfully requests that the Court enter a Final
Judgment:
I.
Permanently enjoining Defendants and their agents, servants, employees and attorneys
and all persons in active concert or participation with any of them from violating, directly or
indirectly, Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)], Section 10(b) of the
Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5];
II.
Ordering Defendants to disgorge all ill-gotten gains they received directly or indirectly,
with pre-judgment interest thereon, as a result of the alleged violations, pursuant to Exchange
Act Sections 21(d)(3), 21(d)(5), and 21(d)(7) [15 U.S.C. §§ 78u(d)(3)  , 78u(d)(5), and 78u(d)(7)];
III.
Ordering Defendants to pay civil monetary penalties under Securities Act Section 20(d)
[15 U.S.C. § 77t(d)] and Exchange Act Section 21(d)(3) [15 U.S.C. § 78u(d)(3)]; and

 19
IV.
Granting any other and further relief this Court may deem just and proper.
JURY DEMAND
 The Commission demands a trial by jury.

Dated:  New York, New York
September 27, 2024
/s/  Antonia M. Apps
ANTONIA M. APPS
REGIONAL DIRECTOR
Sheldon L. Pollock
Adam Grace
Travis Hill
Nicholas Flath
Rhonda L. Jung
Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
New York Regional Office
100 Pearl Street
Suite 20-100
New York, NY 10004-2616
212-336-9135 (Hill)
[email protected]

ANTONIA M. APPS 
REGIONAL DIRECTOR 
Sheldon L. Pollock 
Adam Grace 
Travis Hill 
Nicholas Flath 
Rhonda L. Jung 
Attorneys for Plaintiff 
SECURITIES AND EXCHANGE COMMISSION 
New York Regional Office 
100 Pearl Street  
Suite 20-100 
New York, NY 10004-2616 
212-336-9135 (Hill) 
[email protected] 
 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
 
SECURITIES AND EXCHANGE 
COMMISSION, 
 
                                             Plaintiff, 
 
                        -against- 
 
AKSHAY KAMBOJ and DEV KAMBOJ, 
 
                                             Defendants.  
 

 
 
COMPLAINT 

   
24 Civ. 7319 

 
   

JURY TRIAL DEMANDED 
  

           
          

 
Plaintiff Securities and Exchange Commission (“Commission”), for its Complaint against 

Defendants Akshay Kamboj and Dev Kamboj (together, “Defendants”) alleges as follows: 

SUMMARY 

1. Beginning in April 2022, Defendants used fake trading data and forged audit 

reports to convince dozens of investors to invest approximately $16 million in a currency trading 

hedge fund (the “Fund”) managed by their firm, Crawford Ventures IM, LLC (the “Investment 

Firm”). 

Case 1:24-cv-07319     Document 1     Filed 09/27/24     Page 1 of 19



   
  

 2 

2. Defendants falsely represented to prospective investors in the Fund that they were 

successful traders who had generated average annualized returns of nearly 70% on behalf of 

investors in certain separately managed accounts, using the same investment strategy as the 

Fund’s.  But in fact, these returns were fabricated.   

3. Based on these fabricated returns, Defendants touted in marketing materials for 

investors that the Fund ranked as the “World’s #1 Performing Fund” out of thousands of hedge 

funds. 

4. Additionally, Defendants used forged audit reports—ostensibly issued by a global 

accounting firm (the “Audit Firm”)—to verify their trading record, and even created an email 

account with a domain name resembling that of the Audit Firm to perpetuate and conceal their 

fraud. 

5. By December 2023, in the face of substantial trading losses, the Investment Firm 

announced plans to voluntarily liquidate the Fund. 

6. As a result of Defendants’ fraud, investors suffered aggregate net losses of 

approximately $4.1 million. 

7. Meanwhile, Defendants personally profited through hundreds of thousands of 

dollars in management and performance fees. 

VIOLATIONS 

8. By virtue of the foregoing conduct and as alleged further herein, Defendants 

violated Section 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)], 

Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. § 78j(b)] and 

Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].   

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9. Unless Defendants are restrained and enjoined, they will engage in the acts, 

practices, transactions, and courses of business set forth in this Complaint or in acts, practices, 

transactions, and courses of business of similar type and object.   

NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT 

10. The Commission brings this action pursuant to the authority conferred upon it by 

Securities Act Sections 20(b) and 20(d) [15 U.S.C. §§ 77t(b) and 77t(d)] and Exchange Act 

Section 21(d) [15 U.S.C. § 78u(d)].  

11. The Commission seeks a final judgment: (a) permanently enjoining Defendants 

from violating the federal securities laws and rules this Complaint alleges they have violated; 

(b) ordering Defendants to disgorge all ill-gotten gains they received as a result of the violations 

alleged here and to pay prejudgment interest thereon, pursuant to Exchange Act Sections 

21(d)(3), 21(d)(5), and 21(d)(7) [15 U.S.C. §§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)]; (c) ordering 

Defendants to pay civil money penalties pursuant to Securities Act Section 20(d) [15 U.S.C. 

§ 77t(d)] and Exchange Act Section 21(d)(3) [15 U.S.C. § 78u(d)(3)]; and (d) ordering any other 

and further relief the Court may deem just and proper.  

JURISDICTION AND VENUE 

12. This Court has jurisdiction over this action pursuant to Securities Act Section 

22(a) [15 U.S.C. § 77v(a)] and Exchange Act Section 27 [15 U.S.C. § 78aa].  

13. Defendants, directly and indirectly, have made use of the means or 

instrumentalities of interstate commerce or of the mails in connection with the transactions, acts, 

practices, and courses of business alleged herein. 

14. Venue lies in this District under Securities Act Section 22(a) [15 U.S.C. § 77v(a)] 

and Exchange Act Section 27 [15 U.S.C. § 78aa].  Certain of the acts, practices, transactions, and 

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courses of business alleged in this Complaint occurred within this District.  For example, at all 

relevant times, the Investment Firm was headquartered in Manhattan.  Additionally, Defendants 

sent fabricated trading data and forged reports to Evan H. Katz (“Katz”), an Investment Firm 

partner who worked out of Manhattan.  Defendants also caused the Investment Firm to send false 

marketing materials to at least one prospective investor located in Manhattan. 

DEFENDANTS 

15. Akshay Kamboj, age 33, resides in Gurguram, India.  At all relevant times 

following formation of the Fund, he was the Fund’s Co-Chief Investment Officer (with his 

brother Dev Kamboj) and Head of Strategy Development.  He also owns 25% of the Investment 

Firm and the Fund’s general partner, Crawford Ventures GP (“General Partner”), and was a 

manager of both entities. 

16. Dev Kamboj, age 39, resides in Gurguram, India.  At all relevant times following 

formation of the Fund, he was the Fund’s Co-Chief Investment Officer (with his brother Akshay 

Kamboj) and Head of Research.  He also owns 25% of the Investment Firm and the General 

Partner and was a manager of both entities. 

OTHER RELEVANT INDIVIDUALS AND ENTITIES 

17. Katz resides in Queens, New York.  He is the managing director of an alternative 

asset investment firm that raises capital for hedge funds and private equity funds.  At all relevant 

times following formation of the Fund, he was the Fund’s Chief Operating Officer and General 

Counsel.  Katz also owns a 25% interest in the Investment Firm and the General Partner and was 

a manager of both entities. 

18. The Fund was a currency trading hedge fund formed as a Delaware limited 

partnership in December 2021.  The Fund was co-founded and managed by Defendants and 

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Katz.  It commenced trading activities in September 2022 and has been dormant since early 

2024.  In May 2024, Katz commenced a proceeding in Delaware Chancery Court to dissolve the 

General Partner and the Investment Firm and appoint a liquidating trustee for the Fund.  That 

proceeding is pending as of the date of this Complaint. 

19. The Investment Firm is a Delaware limited liability company formed in 

December 2021.  The Investment Firm was the Fund’s investment manager and was entitled to 

receive 2% of the Fund’s assets under management per year in management fees under the 

Fund’s limited partnership agreement.  As of the date of this Complaint, the Investment Firm is 

the subject of dissolution proceedings pending in Delaware Chancery Court. 

20. General Partner is a Delaware limited liability company formed in December 

2021 and the general partner of the Fund.  Pursuant to the Fund’s limited partnership agreement, 

General Partner was entitled to receive 20% of the Fund’s net profits as performance fees.  As of 

the date of this Complaint, the General Partner is the subject of dissolution proceedings pending 

in Delaware Chancery Court. 

FACTS 

I. Background on Defendants’ Fabrication of Their Trading Performance 

21. On or about May 11, 2021, prior to the formation of the Investment Firm or the 

Fund, Akshay Kamboj sent an unsolicited email to Katz, a United States-based hedge fund 

marketing consultant, to ask for assistance in “raising capital and connecting us to your well 

established network.”   

A. Defendants Fabricated Their Historical Trading Performance 

22. The email attached a performance report claiming that, between 2018 and 2020, 

Defendants had generated average annual returns on investment of 78.71% by trading currencies 

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and that, as of 2021, Defendants had aggregate assets under management of more than $30 

million (the “Historical Performance Report”). 

23. The email also attached a prospectus in which the Defendants asserted that they 

used four different brokerage firms for “trade execution,” including a Swiss broker.   

24. Separately, the email attached a transactions sheet (“Historical Transactions 

Sheet”) purporting to show a trade-by-trade record of net profits on trades since April 2018 in an 

account for a Kamboj family fund that Defendants managed at the Swiss broker named in the 

prospectus (the “Brokerage Account”).  These transactions appeared to represent a component of 

the aggregate returns shown in the Historical Performance Report. 

25. The purported net profits shown in the Historical Transactions Sheet ranged from 

thousands to tens of thousands of dollars per individual trade, and from several hundred thousand 

dollars to more than one million dollars per quarter, and over the entire reported period, totaled 

more than $11.8 million.   

26. As reflected by the actual trading records for the Brokerage Account, the 

Historical Transactions Sheet sent to Katz included fake trades and altered trade data, falsely 

inflating Defendants’ returns. 

27. Specifically, 695 of the 793 total trades shown on the Historical Transactions 

Sheet, purportedly placed between April 2018 and November 18, 2019, were fake, because the 

Brokerage Account in which these trades supposedly had been placed was not opened until 

November 19, 2019.  These fake trades accounted for more than $6.9 million of supposed trading 

profits.   

28. Further, 81 of the remaining 98 trades reported on the Historical Transactions 

Sheet, supposedly placed on or after November 19, 2019, do not have ticket numbers that match 

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real trades placed in the Brokerage Account.  These 81 additional fake trades account for $3.8 

million of supposed trading profits. 

29. For the remaining 17 trades on the Historical Transactions Sheet whose ticket 

numbers match ticket numbers of real trades, the Historical Transactions Sheet falsely altered 

information about the trades in a way that overstated the supposed profits.  These 17 trades, in 

reality, resulted in aggregate net profits of only $86.73.  The Historical Transactions Sheet, by 

contrast, reported net profits of almost $1 million from these trades.   

30. Finally, the Historical Transactions Sheet omitted at least 20 real trades which had 

occurred in the Brokerage Account between November 19, 2019 and March 31, 2021, and 

resulted in aggregate net losses of more than $19,000.   

31. In total, the actual trading record of the Brokerage Account during the period 

November 19, 2019 to March 31, 2021 reflected net aggregate losses of almost $20,000–not the 

net profits of $11.8 million reported on the Historical Transaction Sheets. 

32. Accordingly, the millions of dollars of trading profits reported in the Historical 

Transactions Sheet were fictitious.  And because the Historical Performance Report relied on the 

accuracy of the Historical Transaction Sheets, the Historical Performance Report was fictitious 

as well. 

B. Defendants Fabricated Two Audit Reports 

33. To add legitimacy to Defendants’ fake trading history, on or about May 25, 2021, 

Akshay Kamboj sent Katz a purported independent audit report of the Kamboj family fund’s 

2020 financial statements issued by the Audit Firm (the “Financial Statements Audit Report”). 

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34. But the Financial Statements Audit Report was forged.  As Defendants knew by 

virtue of their roles managing the Kamboj family fund, the Audit Firm did not perform any work 

for Defendants or their family fund. 

35. In or around June 2021, Katz agreed to co-found the Fund with Defendants, and it 

was formally established in December 2021. 

36. In or around March 2022, in preparation for soliciting investors in the Fund, Katz 

asked Defendants to have the Audit Firm prepare a report verifying the historical investment 

returns that Defendants had previously presented to Katz in the Historical Performance Report 

and Historical Transaction Sheet. 

37. In or around April 2022, Defendants provided Katz what purported to be a 

performance audit report for the Kamboj family fund issued by the Audit Firm (the 

“Performance Audit Report”). 

38. The Performance Audit Report, like the Financial Statements Audit Report, was a 

forgery, which purported to verify the historical investment returns shown in the Historical 

Performance Report and the Historical Transaction Sheet. 

39. The Performance Audit Report also listed a fake email address (“Fake Email 

Address”) for the Audit Firm partner who ostensibly signed both the Financial Statement Audit 

Report and Performance Audit Report (the “Audit Firm Partner”). 

40. The Fake Email Address contained a domain name similar to the real Audit 

Firm’s actual domain, but which was purchased in June 2021 by an individual providing a phone 

number used by Defendants. 

41. As Defendants knew or recklessly disregarded, the Audit Firm never issued an 

audit report of any kind for Defendants or the Kamboj family fund the Defendants managed, and 

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the investment returns reflected in the Performance Audit Report did not accurately reflect 

Defendants’ trading history.  

42. Defendants did not tell Katz that their trading record was fake, nor did they tell 

him that they had forged the Financial Statements Audit Report or the Performance Audit.   

II. Defendants Prepared False and Misleading Marketing Materials for the Fund Based on 
Their Fictitious Returns. 

43. In late 2021 and early 2022, Defendants, together with Katz, developed a 

marketing strategy for investor outreach and authored marketing materials for the Fund.  These 

marketing materials included a PowerPoint presentation (the “PowerPoint”) and a one-page 

promotional document (the “One Pager”). 

44. Defendants approved the content of the PowerPoint and One Pager. 

45. The PowerPoint and the One Pager highlighted Defendants’ fictitious trading 

returns as reflected in the Historical Performance Report and ostensibly verified by the 

Performance Audit Report and the Historical Transaction Sheets, characterizing them as “the 

actual performance metrics that have been managed” by Defendants in separately managed 

accounts, using the fund’s strategy since February 2016.” 

46. For example, the PowerPoint falsely asserted that “our fund’s strategy has 

produced, since its inception in February 2016, exceptionally favorable investment performance 

metrics,” and that “six years of proven track record and a repeatable process that has provided 

high-return high-consistency returns of almost +70% per year (CAGR)1 with minimal 

drawdowns.” 

 
1 “CAGR” means Compound Annual Growth Rate.  CAGR is the mean annual growth rate of an investment over a 
period longer than one year, with the effect of compounding taken into effect.  See Investopedia, Compound Annual 
Growth Rate (CAGR): What You Should Know, May 15, 2024, available at 
https://www.investopedia.com/investing/compound-annual-growth-rate-what-you-should-know/.  
 

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47. Both the PowerPoint and the One Pager also included a month-by-month chart of 

supposed trading returns dating back to April 2016, as well as a summary chart showing the 

Defendants’ strategy’s “cumulative return” and “annualized return,” among other metrics.   

These supposed trading returns were the same trading returns supposedly verified by the 

Performance Audit Report and the Historical Transaction Sheets. 

48. As Defendants knew, these trading returns and metrics were fictitious.  As 

discussed above, Defendants altered and inflated their actual trading record to radically overstate 

the success of their trading strategy. 

49. The PowerPoint also falsely claimed that the Fund ranked as “the World’s #1 

Performing Fund for Best 3 and 5 Year Returns of any Equity Hedge Fund, CTA, or Currency 

Fund.”  

50. The ranking was based on information provided by a hedge fund analytics service 

(“Service 1”) during a December 2021 videoconference in which Service 1 was promoting its 

analytics product to the Investment Firm. 

51. As Defendants knew or recklessly disregarded, Service 1’s comparison of the 

Fund’s performance to other funds in Service 1’s database was based on Defendants’ fabricated 

trading data that Katz sent to Service 1 in a November 2021 email, with Defendants’ consent. 

52. During the December 2021 videoconference, Service 1 displayed charts showing 

how Defendants’ (fabricated) trading record would rank in Service 1’s database of fund 

performance. 

53. Dev Kamboj then inserted screenshots of those charts—which he knew did not 

accurately reflect Defendants’ actual trading performance—into the PowerPoint to demonstrate 

the Fund’s purported “#1” ranking. 

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54. The Fund’s July 2022 private placement memorandum (“PPM”) also cited 

Service 1’s purported “rank[ing] of [Defendants’] investment strategy  . . . as the world’s #1 

performing strategy for best three- and five-year returns” as a fact that “limited” the risk relating 

to the Fund’s lack of operating performance history. 

55. This statement in the PPM was false and misleading because, as Defendants knew 

or recklessly disregarded, Service 1’s analysis was based on fabricated trading data. 

56. Defendants had primary drafting responsibility for the PPM and approved its 

contents.  Additionally, Akshay Kamboj sent the PPM to third parties, including the Fund’s 

broker. 

57. In addition to the falsely procured analysis by Service 1, the PowerPoint for the 

Fund touted eight awards that the Fund obtained from a second hedge fund analytics service 

(“Service 2”) between February and August 2022, based on the purported (but fictious) returns 

employed by the Fund’s strategy. 

58. Service 2 issued the awards based on the fake monthly returns reflected in the 

Fund’s One Pager and PowerPoint, which the Investment Firm sent to Service 2.   

59. As Defendants knew or recklessly disregarded, touting the awards from Service 2 

was misleading because the awards did not reflect, and were not based upon, Defendants’ actual 

trading performance. 

III. Defendants Used the False PowerPoint, One Pager, PPM, and Performance Audit 
Report to Solicit Investors.  

60. In or around April 2022, the Investment Firm began communicating with 

prospective investors about the opportunity to invest in the Fund.   

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61. From in or around April 2022 to in or around August 2023, with Defendants’ 

approval, the Investment Firm sent the PowerPoint, One Pager, and PPM to prospective 

investors, including at least one prospective investor located in New York, New York. 

62. As discussed above, the PowerPoint and the One Pager featured Defendants’ fake 

trading records, as well as accolades attributed to Service 1 and Serve 2, which were based on 

the fake data. 

63. With Defendants’ knowledge and approval, the Investment Firm sent certain 

prospective investors the forged Performance Audit Report, and encouraged them to contact the 

Audit Firm Partner who appeared to sign the report at the Fake Email Address associated with 

Defendants.  

A. Solicitation of Adviser-1’s Clients  

64. In or around May 2022, Katz emailed the One Pager, the PowerPoint, and the 

Performance Audit Report to an investment adviser (“Adviser 1”) in connection with the 

Investment Firm’s efforts to solicit the investment adviser’s clients to invest in the Fund. 

65. A few days later, Katz, copying Defendants, sought to introduce Adviser 1 via 

email to the Audit Firm Partner to facilitate Adviser 1’s due diligence on behalf of clients 

interested in investing in the Fund.  Unbeknownst to Katz or Adviser 1, the email address 

identified for the Audit Firm Partner was actually the Fake Email Address associated with 

Defendants.  

66. Thereafter, Adviser 1 communicated about the Performance Audit Report with 

the Fake Email Address associated with Defendants.  For example, on May 24, 2022, a 

representative of Adviser 1 asked for confirmation that Audit Firm had generated the 

Performance Audit.  Later that day, a message sent from the Fake Email Address stated in reply, 

“Yes, we are the official auditing firm for [the Kamboj family fund] from FY 2016-2020.”   

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67. Dev Kamboj himself also personally communicated by phone and email with a 

representative of Adviser 1.  In these communications, he referred Adviser 1 to the (forged) 

Performance Audit Report. 

68. Following Adviser 1’s receipt of the false One Pager and PowerPoint and forged 

Performance Audit Report, and after Adviser 1’s communications with the Fake Email Address 

that Adviser 1 believed belonged to the actual Audit Firm Partner, Adviser 1 recommended that 

its advisory clients invest in the Fund.   

69. Ultimately, clients referred by Adviser 1 and its affiliates invested more than $9 

million in the Fund, accounting for more than half of the Fund’s total assets under management. 

70. Adviser 1 would not have recommended the Fund to its clients had Adviser 1 

known that the One Pager, the PowerPoint, and the Performance Audit Report reflected 

fabricated investment returns and that the Performance Audit Report was forged.  

B. Solicitation of Investor 1  

71. In or around June 2022, Defendants and Katz participated in a videoconference 

with representatives of another prospective investor (“Investor 1”).   

72. In or around August 2022, Katz sent the One Pager, PowerPoint, and Performance 

Audit Report to representatives of Investor 1.  Katz wrote that “Akshay and Dev’s globally #1 

ranked track record is, of course, audited by a large and highly competent accounting and audit 

firm (e.g., several hundred employees, about 20 offices, some 10,000 clients, etc.).  Attached is a 

copy of their audit and performance confirmation.”   

73. After receiving the fake trading returns featured in the One Pager, the PowerPoint, 

and the Performance Audit Report, in or around August 2022, Investor 1 invested $3 million in 

the Fund, becoming the largest single investor. 

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74. The Performance Audit Report, which was in fact forged, gave Investor 1 comfort 

before Investor 1 invested in the Fund.   

75. Defendants Used the False PowerPoint, One Pager, and Performance Audit 

Report to Solicit Investors.  

IV. Defendants Tried to Evade Detection of Their Fraudulent Conduct. 

76. In or around June 2022, Akshay Kamboj instructed Katz to abandon efforts to 

solicit an investment from a prospective investor (“Investor 2”) after representatives of Investor 

2 asked for the Audit Firm Partner to participate in a due diligence call with an attorney.   

77. Investor 2 chose not to invest in the Fund.   

78. Later, in or around March 2023, as part of its due diligence, another prospective 

investor (“Investor 3”), emailed the Audit Firm Partner both at the Fake Email Address 

associated with Defendants and at Audit Firm Partner’s actual email account, which was publicly 

listed on the Audit Firm website.   

79. A reply message to Investor 3 sent from the Fake Email Address associated with 

Defendants removed the Audit Firm Partner’s actual email address, falsely explaining to Investor 

3 that the “other” address was “monitored by our internal/domestic compliance team for general 

accounting and tax operations within Australia.” 

80. Akshay Kamboj separately forwarded Investor 3’s email to the real Audit Firm 

Partner, writing: 

Hi [Audit Firm Partner], This is the below email that I have received on my 
work accounts and saw you are also cc’d in the same email chain. Kindly do 
not reply back to this email or open it as this is a malware domain, I happen to 
have replied back to such an email a few days ago and realized all of my work 
data and banking information was stolen.  I also tried to call you and warn you 
but no reply. (Got your phone number from Zoominfo.) 

I hope you do not fall for this as well. Please call me or text me if you need 
more info on this. 

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81. Akshay Kamboj did not include Katz or Investor 3 on his email to the real Audit 

Firm Partner. 

82. In response to a request from Investor 3 to meet the Audit Firm Partner, Akshay 

Kamboj asked Investor 3 to “please confirm your availability and contact number,” but Investor 

3 insisted on doing a “Teams or Zoom.” 

83. A videoconference using Teams or Zoom would have enabled Investor 3 to see 

that the purported Audit Firm Partner did not match his photograph on the Audit Firm’s website, 

thereby revealing Defendants’ fraudulent conduct. 

84. Although Katz had circulated an invite for a videoconference with Investor 3, 

Defendants cancelled the meeting.     

85. Investor 3 chose not to invest in the Fund. 

V. Collapse of the Fund 

86. After commencing trading in September 2022, the Fund’s returns never matched 

the fictitious historical track record of the Fund strategy provided to prospective investors in the 

One Pager and the PowerPoint.   

87. In or around late 2023, Defendants executed a series of trades that caused the 

Fund to suffer significant trading losses.   

88. Those losses caused a roughly 40% decline in the Fund’s value over a four-month 

period. 

89. As a result of the Fund’s poor performance, the Fund experienced significant 

redemption requests from investors. 

90. In or around December 2023, the Investment Firm informed investors that the 

Fund would be liquidating, and that the Investment Firm would cease taking any further 

management fees.  

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91. In or around early 2024, following revelations of potential fraudulent conduct 

relating to the Fund and before the planned liquidation took place, the Fund’s prime broker froze 

access to its brokerage account.  

92. At the time, the Fund had approximately $7.9 million in assets and $12 million in 

unredeemed investor capital contributions, meaning that investors had lost approximately $4.1 

million. 

93. Pursuant to the Fund’s limited partnership agreement, the Fund paid a total of 

$80,308.01 in performance fees to the General Partner from inception through the end of 2023. 

94. The Fund also paid management fees to the Investment Firm totaling $381,269.95 

from inception through the end of 2023. 

95. Akshay Kamboj’s share of the management and performance fees totaled 

approximately $115,394.48 on account of his 25% share of the General Partner and the 

Investment Firm. 

96. Dev Kamboj’s share of the management and performance fees also totaled 

approximately $115,394.48 on account of his 25% share of the General Partner and the 

Investment Firm. 

97. The Investment Firm and the General Partner transferred Akshay Kamboj’s and 

Dev Kamboj’s respective shares of the management and performance fees to a Kamboj family 

fund, which Akshay Kamboj controlled and of which he was the sole shareholder. 

FIRST CLAIM FOR RELIEF 
Violations of Securities Act Section 17(a) 

(Against Both Defendants) 
 

98. The Commission re-alleges and incorporates by reference here the allegations in 

paragraphs 1 through 97. 

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99. Defendants, directly or indirectly, singly or in concert, in the offer or sale of 

securities and by the use of the means or instruments of transportation or communication in 

interstate commerce or the mails, (1) knowingly or recklessly have employed one or more 

devices, schemes or artifices to defraud, (2) knowingly, recklessly, or negligently have obtained 

money or property by means of one or more untrue statements of a material fact or omissions of 

a material fact necessary in order to make the statements made, in light of the circumstances 

under which they were made, not misleading, and/or (3) knowingly, recklessly, or negligently 

have engaged in one or more transactions, practices, or courses of business which operated or 

would operate as a fraud or deceit upon the purchaser. 

100. By reason of the foregoing, Defendants, directly or indirectly, singly or in concert, 

have violated and, unless enjoined, will again violate Securities Act Section 17(a) [15 U.S.C. 

§ 77q(a)]. 

SECOND CLAIM FOR RELIEF 
Violations of Exchange Act Section 10(b) and Rule 10b-5 Thereunder 

(Against Both Defendants) 
 

101. The Commission re-alleges and incorporates by reference here the allegations in 

paragraphs 1 through 97. 

102. Defendants, directly or indirectly, singly or in concert, in connection with the 

purchase or sale of securities and by the use of means or instrumentalities of interstate 

commerce, or the mails, or the facilities of a national securities exchange, knowingly or 

recklessly have (i) employed one or more devices, schemes, or artifices to defraud, (ii) made one 

or more untrue statements of a material fact or omitted to state one or more material facts 

necessary in order to make the statements made, in light of the circumstances under which they 

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were made, not misleading, and/or (iii) engaged in one or more acts, practices, or courses of 

business which operated or would operate as a fraud or deceit upon other persons. 

103. By reason of the foregoing, Defendants, directly or indirectly, singly or in concert, 

have violated and, unless enjoined, will again violate Exchange Act Section 10(b) [15 U.S.C. 

§ 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]. 

PRAYER FOR RELIEF 

 WHEREFORE, the Commission respectfully requests that the Court enter a Final 

Judgment: 

I. 

Permanently enjoining Defendants and their agents, servants, employees and attorneys 

and all persons in active concert or participation with any of them from violating, directly or 

indirectly, Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)], Section 10(b) of the 

Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5];  

II. 

Ordering Defendants to disgorge all ill-gotten gains they received directly or indirectly, 

with pre-judgment interest thereon, as a result of the alleged violations, pursuant to Exchange 

Act Sections 21(d)(3), 21(d)(5), and 21(d)(7) [15 U.S.C. §§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)]; 

III. 

Ordering Defendants to pay civil monetary penalties under Securities Act Section 20(d) 

[15 U.S.C. § 77t(d)] and Exchange Act Section 21(d)(3) [15 U.S.C. § 78u(d)(3)]; and  

 

 

 

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IV. 

Granting any other and further relief this Court may deem just and proper.  

JURY DEMAND 

 The Commission demands a trial by jury.  

 
 
 
Dated: New York, New York 

September 27, 2024 
/s/  Antonia M. Apps            
ANTONIA M. APPS  
REGIONAL DIRECTOR  
Sheldon L. Pollock 
Adam Grace 
Travis Hill 
Nicholas Flath 
Rhonda L. Jung 
Attorneys for Plaintiff 
SECURITIES AND EXCHANGE COMMISSION 
New York Regional Office 
100 Pearl Street  
Suite 20-100 
New York, NY 10004-2616 
212-336-9135 (Hill) 
[email protected] 
  

Case 1:24-cv-07319     Document 1     Filed 09/27/24     Page 19 of 19


	antonia M. apps
	Regional Director
	Sheldon L. Pollock
	Adam Grace
	Travis Hill
	Nicholas Flath
	Rhonda L. Jung
	Attorneys for Plaintiff
	SECURITIES AND EXCHANGE COMMISSION
	New York Regional Office
	100 Pearl Street
	Suite 20-100
	212-336-9135 (Hill)
	[email protected]
	Plaintiff Securities and Exchange Commission (“Commission”), for its Complaint against Defendants Akshay Kamboj and Dev Kamboj (together, “Defendants”) alleges as follows:
	SUMMARY
	1. Beginning in April 2022, Defendants used fake trading data and forged audit reports to convince dozens of investors to invest approximately $16 million in a currency trading hedge fund (the “Fund”) managed by their firm, Crawford Ventures IM, LLC (...
	2. Defendants falsely represented to prospective investors in the Fund that they were successful traders who had generated average annualized returns of nearly 70% on behalf of investors in certain separately managed accounts, using the same investmen...
	3. Based on these fabricated returns, Defendants touted in marketing materials for investors that the Fund ranked as the “World’s #1 Performing Fund” out of thousands of hedge funds.
	4. Additionally, Defendants used forged audit reports—ostensibly issued by a global accounting firm (the “Audit Firm”)—to verify their trading record, and even created an email account with a domain name resembling that of the Audit Firm to perpetuate...
	5. By December 2023, in the face of substantial trading losses, the Investment Firm announced plans to voluntarily liquidate the Fund.
	6. As a result of Defendants’ fraud, investors suffered aggregate net losses of approximately $4.1 million.
	7. Meanwhile, Defendants personally profited through hundreds of thousands of dollars in management and performance fees.
	VIOLATIONS
	8. By virtue of the foregoing conduct and as alleged further herein, Defendants violated Section 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)], Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S...
	9. Unless Defendants are restrained and enjoined, they will engage in the acts, practices, transactions, and courses of business set forth in this Complaint or in acts, practices, transactions, and courses of business of similar type and object.
	NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT
	10. The Commission brings this action pursuant to the authority conferred upon it by Securities Act Sections 20(b) and 20(d) [15 U.S.C. §§ 77t(b) and 77t(d)] and Exchange Act Section 21(d) [15 U.S.C. § 78u(d)].
	11. The Commission seeks a final judgment: (a) permanently enjoining Defendants from violating the federal securities laws and rules this Complaint alleges they have violated; (b) ordering Defendants to disgorge all ill-gotten gains they received as a...
	JURISDICTION AND VENUE
	12. This Court has jurisdiction over this action pursuant to Securities Act Section 22(a) [15 U.S.C. § 77v(a)] and Exchange Act Section 27 [15 U.S.C. § 78aa].
	13. Defendants, directly and indirectly, have made use of the means or instrumentalities of interstate commerce or of the mails in connection with the transactions, acts, practices, and courses of business alleged herein.
	14. Venue lies in this District under Securities Act Section 22(a) [15 U.S.C. § 77v(a)] and Exchange Act Section 27 [15 U.S.C. § 78aa].  Certain of the acts, practices, transactions, and courses of business alleged in this Complaint occurred within th...
	DEFENDANTS
	15. Akshay Kamboj, age 33, resides in Gurguram, India.  At all relevant times following formation of the Fund, he was the Fund’s Co-Chief Investment Officer (with his brother Dev Kamboj) and Head of Strategy Development.  He also owns 25% of the Inves...
	16. Dev Kamboj, age 39, resides in Gurguram, India.  At all relevant times following formation of the Fund, he was the Fund’s Co-Chief Investment Officer (with his brother Akshay Kamboj) and Head of Research.  He also owns 25% of the Investment Firm a...
	OTHER RELEVANT INDIVIDUALS AND ENTITIES
	17. Katz resides in Queens, New York.  He is the managing director of an alternative asset investment firm that raises capital for hedge funds and private equity funds.  At all relevant times following formation of the Fund, he was the Fund’s Chief Op...
	18. The Fund was a currency trading hedge fund formed as a Delaware limited partnership in December 2021.  The Fund was co-founded and managed by Defendants and Katz.  It commenced trading activities in September 2022 and has been dormant since early ...
	19. The Investment Firm is a Delaware limited liability company formed in December 2021.  The Investment Firm was the Fund’s investment manager and was entitled to receive 2% of the Fund’s assets under management per year in management fees under the ...
	20. General Partner is a Delaware limited liability company formed in December 2021 and the general partner of the Fund.  Pursuant to the Fund’s limited partnership agreement, General Partner was entitled to receive 20% of the Fund’s net profits as pe...
	FACTS
	21. On or about May 11, 2021, prior to the formation of the Investment Firm or the Fund, Akshay Kamboj sent an unsolicited email to Katz, a United States-based hedge fund marketing consultant, to ask for assistance in “raising capital and connecting u...
	A. Defendants Fabricated Their Historical Trading Performance
	22. The email attached a performance report claiming that, between 2018 and 2020, Defendants had generated average annual returns on investment of 78.71% by trading currencies and that, as of 2021, Defendants had aggregate assets under management of m...
	23. The email also attached a prospectus in which the Defendants asserted that they used four different brokerage firms for “trade execution,” including a Swiss broker.
	24. Separately, the email attached a transactions sheet (“Historical Transactions Sheet”) purporting to show a trade-by-trade record of net profits on trades since April 2018 in an account for a Kamboj family fund that Defendants managed at the Swiss ...
	25. The purported net profits shown in the Historical Transactions Sheet ranged from thousands to tens of thousands of dollars per individual trade, and from several hundred thousand dollars to more than one million dollars per quarter, and over the e...
	26. As reflected by the actual trading records for the Brokerage Account, the Historical Transactions Sheet sent to Katz included fake trades and altered trade data, falsely inflating Defendants’ returns.
	27. Specifically, 695 of the 793 total trades shown on the Historical Transactions Sheet, purportedly placed between April 2018 and November 18, 2019, were fake, because the Brokerage Account in which these trades supposedly had been placed was not op...
	28. Further, 81 of the remaining 98 trades reported on the Historical Transactions Sheet, supposedly placed on or after November 19, 2019, do not have ticket numbers that match real trades placed in the Brokerage Account.  These 81 additional fake tra...
	29. For the remaining 17 trades on the Historical Transactions Sheet whose ticket numbers match ticket numbers of real trades, the Historical Transactions Sheet falsely altered information about the trades in a way that overstated the supposed profits...
	30. Finally, the Historical Transactions Sheet omitted at least 20 real trades which had occurred in the Brokerage Account between November 19, 2019 and March 31, 2021, and resulted in aggregate net losses of more than $19,000.
	31. In total, the actual trading record of the Brokerage Account during the period November 19, 2019 to March 31, 2021 reflected net aggregate losses of almost $20,000–not the net profits of $11.8 million reported on the Historical Transaction Sheets.
	32. Accordingly, the millions of dollars of trading profits reported in the Historical Transactions Sheet were fictitious.  And because the Historical Performance Report relied on the accuracy of the Historical Transaction Sheets, the Historical Perfo...
	B. Defendants Fabricated Two Audit Reports
	33. To add legitimacy to Defendants’ fake trading history, on or about May 25, 2021, Akshay Kamboj sent Katz a purported independent audit report of the Kamboj family fund’s 2020 financial statements issued by the Audit Firm (the “Financial Statements...
	34. But the Financial Statements Audit Report was forged.  As Defendants knew by virtue of their roles managing the Kamboj family fund, the Audit Firm did not perform any work for Defendants or their family fund.
	35. In or around June 2021, Katz agreed to co-found the Fund with Defendants, and it was formally established in December 2021.
	36. In or around March 2022, in preparation for soliciting investors in the Fund, Katz asked Defendants to have the Audit Firm prepare a report verifying the historical investment returns that Defendants had previously presented to Katz in the Histori...
	37. In or around April 2022, Defendants provided Katz what purported to be a performance audit report for the Kamboj family fund issued by the Audit Firm (the “Performance Audit Report”).
	38. The Performance Audit Report, like the Financial Statements Audit Report, was a forgery, which purported to verify the historical investment returns shown in the Historical Performance Report and the Historical Transaction Sheet.
	39. The Performance Audit Report also listed a fake email address (“Fake Email Address”) for the Audit Firm partner who ostensibly signed both the Financial Statement Audit Report and Performance Audit Report (the “Audit Firm Partner”).
	40. The Fake Email Address contained a domain name similar to the real Audit Firm’s actual domain, but which was purchased in June 2021 by an individual providing a phone number used by Defendants.
	41. As Defendants knew or recklessly disregarded, the Audit Firm never issued an audit report of any kind for Defendants or the Kamboj family fund the Defendants managed, and the investment returns reflected in the Performance Audit Report did not acc...
	42. Defendants did not tell Katz that their trading record was fake, nor did they tell him that they had forged the Financial Statements Audit Report or the Performance Audit.
	43. In late 2021 and early 2022, Defendants, together with Katz, developed a marketing strategy for investor outreach and authored marketing materials for the Fund.  These marketing materials included a PowerPoint presentation (the “PowerPoint”) and a...
	44. Defendants approved the content of the PowerPoint and One Pager.
	45. The PowerPoint and the One Pager highlighted Defendants’ fictitious trading returns as reflected in the Historical Performance Report and ostensibly verified by the Performance Audit Report and the Historical Transaction Sheets, characterizing the...
	46. For example, the PowerPoint falsely asserted that “our fund’s strategy has produced, since its inception in February 2016, exceptionally favorable investment performance metrics,” and that “six years of proven track record and a repeatable process...
	47. Both the PowerPoint and the One Pager also included a month-by-month chart of supposed trading returns dating back to April 2016, as well as a summary chart showing the Defendants’ strategy’s “cumulative return” and “annualized return,” among othe...
	48. As Defendants knew, these trading returns and metrics were fictitious.  As discussed above, Defendants altered and inflated their actual trading record to radically overstate the success of their trading strategy.
	49. The PowerPoint also falsely claimed that the Fund ranked as “the World’s #1 Performing Fund for Best 3 and 5 Year Returns of any Equity Hedge Fund, CTA, or Currency Fund.”
	50. The ranking was based on information provided by a hedge fund analytics service (“Service 1”) during a December 2021 videoconference in which Service 1 was promoting its analytics product to the Investment Firm.
	51. As Defendants knew or recklessly disregarded, Service 1’s comparison of the Fund’s performance to other funds in Service 1’s database was based on Defendants’ fabricated trading data that Katz sent to Service 1 in a November 2021 email, with Defen...
	52. During the December 2021 videoconference, Service 1 displayed charts showing how Defendants’ (fabricated) trading record would rank in Service 1’s database of fund performance.
	53. Dev Kamboj then inserted screenshots of those charts—which he knew did not accurately reflect Defendants’ actual trading performance—into the PowerPoint to demonstrate the Fund’s purported “#1” ranking.
	54. The Fund’s July 2022 private placement memorandum (“PPM”) also cited Service 1’s purported “rank[ing] of [Defendants’] investment strategy  . . . as the world’s #1 performing strategy for best three- and five-year returns” as a fact that “limited”...
	55. This statement in the PPM was false and misleading because, as Defendants knew or recklessly disregarded, Service 1’s analysis was based on fabricated trading data.
	56. Defendants had primary drafting responsibility for the PPM and approved its contents.  Additionally, Akshay Kamboj sent the PPM to third parties, including the Fund’s broker.
	57. In addition to the falsely procured analysis by Service 1, the PowerPoint for the Fund touted eight awards that the Fund obtained from a second hedge fund analytics service (“Service 2”) between February and August 2022, based on the purported (bu...
	58. Service 2 issued the awards based on the fake monthly returns reflected in the Fund’s One Pager and PowerPoint, which the Investment Firm sent to Service 2.
	59. As Defendants knew or recklessly disregarded, touting the awards from Service 2 was misleading because the awards did not reflect, and were not based upon, Defendants’ actual trading performance.
	60. In or around April 2022, the Investment Firm began communicating with prospective investors about the opportunity to invest in the Fund.
	61. From in or around April 2022 to in or around August 2023, with Defendants’ approval, the Investment Firm sent the PowerPoint, One Pager, and PPM to prospective investors, including at least one prospective investor located in New York, New York.
	62. As discussed above, the PowerPoint and the One Pager featured Defendants’ fake trading records, as well as accolades attributed to Service 1 and Serve 2, which were based on the fake data.
	63. With Defendants’ knowledge and approval, the Investment Firm sent certain prospective investors the forged Performance Audit Report, and encouraged them to contact the Audit Firm Partner who appeared to sign the report at the Fake Email Address as...
	64. In or around May 2022, Katz emailed the One Pager, the PowerPoint, and the Performance Audit Report to an investment adviser (“Adviser 1”) in connection with the Investment Firm’s efforts to solicit the investment adviser’s clients to invest in th...
	65. A few days later, Katz, copying Defendants, sought to introduce Adviser 1 via email to the Audit Firm Partner to facilitate Adviser 1’s due diligence on behalf of clients interested in investing in the Fund.  Unbeknownst to Katz or Adviser 1, the ...
	66. Thereafter, Adviser 1 communicated about the Performance Audit Report with the Fake Email Address associated with Defendants.  For example, on May 24, 2022, a representative of Adviser 1 asked for confirmation that Audit Firm had generated the Per...
	67. Dev Kamboj himself also personally communicated by phone and email with a representative of Adviser 1.  In these communications, he referred Adviser 1 to the (forged) Performance Audit Report.
	68. Following Adviser 1’s receipt of the false One Pager and PowerPoint and forged Performance Audit Report, and after Adviser 1’s communications with the Fake Email Address that Adviser 1 believed belonged to the actual Audit Firm Partner, Adviser 1 ...
	69. Ultimately, clients referred by Adviser 1 and its affiliates invested more than $9 million in the Fund, accounting for more than half of the Fund’s total assets under management.
	70. Adviser 1 would not have recommended the Fund to its clients had Adviser 1 known that the One Pager, the PowerPoint, and the Performance Audit Report reflected fabricated investment returns and that the Performance Audit Report was forged.
	B. Solicitation of Investor 1
	71. In or around June 2022, Defendants and Katz participated in a videoconference with representatives of another prospective investor (“Investor 1”).
	72. In or around August 2022, Katz sent the One Pager, PowerPoint, and Performance Audit Report to representatives of Investor 1.  Katz wrote that “Akshay and Dev’s globally #1 ranked track record is, of course, audited by a large and highly competent...
	73. After receiving the fake trading returns featured in the One Pager, the PowerPoint, and the Performance Audit Report, in or around August 2022, Investor 1 invested $3 million in the Fund, becoming the largest single investor.
	74. The Performance Audit Report, which was in fact forged, gave Investor 1 comfort before Investor 1 invested in the Fund.
	75. Defendants Used the False PowerPoint, One Pager, and Performance Audit Report to Solicit Investors.
	76. In or around June 2022, Akshay Kamboj instructed Katz to abandon efforts to solicit an investment from a prospective investor (“Investor 2”) after representatives of Investor 2 asked for the Audit Firm Partner to participate in a due diligence cal...
	77. Investor 2 chose not to invest in the Fund.
	78. Later, in or around March 2023, as part of its due diligence, another prospective investor (“Investor 3”), emailed the Audit Firm Partner both at the Fake Email Address associated with Defendants and at Audit Firm Partner’s actual email account, w...
	79. A reply message to Investor 3 sent from the Fake Email Address associated with Defendants removed the Audit Firm Partner’s actual email address, falsely explaining to Investor 3 that the “other” address was “monitored by our internal/domestic comp...
	80. Akshay Kamboj separately forwarded Investor 3’s email to the real Audit Firm Partner, writing:
	81. Akshay Kamboj did not include Katz or Investor 3 on his email to the real Audit Firm Partner.
	82. In response to a request from Investor 3 to meet the Audit Firm Partner, Akshay Kamboj asked Investor 3 to “please confirm your availability and contact number,” but Investor 3 insisted on doing a “Teams or Zoom.”
	83. A videoconference using Teams or Zoom would have enabled Investor 3 to see that the purported Audit Firm Partner did not match his photograph on the Audit Firm’s website, thereby revealing Defendants’ fraudulent conduct.
	84. Although Katz had circulated an invite for a videoconference with Investor 3, Defendants cancelled the meeting.
	85. Investor 3 chose not to invest in the Fund.
	86. After commencing trading in September 2022, the Fund’s returns never matched the fictitious historical track record of the Fund strategy provided to prospective investors in the One Pager and the PowerPoint.
	87. In or around late 2023, Defendants executed a series of trades that caused the Fund to suffer significant trading losses.
	88. Those losses caused a roughly 40% decline in the Fund’s value over a four-month period.
	89. As a result of the Fund’s poor performance, the Fund experienced significant redemption requests from investors.
	90. In or around December 2023, the Investment Firm informed investors that the Fund would be liquidating, and that the Investment Firm would cease taking any further management fees.
	91. In or around early 2024, following revelations of potential fraudulent conduct relating to the Fund and before the planned liquidation took place, the Fund’s prime broker froze access to its brokerage account.
	92. At the time, the Fund had approximately $7.9 million in assets and $12 million in unredeemed investor capital contributions, meaning that investors had lost approximately $4.1 million.
	93. Pursuant to the Fund’s limited partnership agreement, the Fund paid a total of $80,308.01 in performance fees to the General Partner from inception through the end of 2023.
	94. The Fund also paid management fees to the Investment Firm totaling $381,269.95 from inception through the end of 2023.
	95. Akshay Kamboj’s share of the management and performance fees totaled approximately $115,394.48 on account of his 25% share of the General Partner and the Investment Firm.
	96. Dev Kamboj’s share of the management and performance fees also totaled approximately $115,394.48 on account of his 25% share of the General Partner and the Investment Firm.
	97. The Investment Firm and the General Partner transferred Akshay Kamboj’s and Dev Kamboj’s respective shares of the management and performance fees to a Kamboj family fund, which Akshay Kamboj controlled and of which he was the sole shareholder.
	Violations of Securities Act Section 17(a)
	(Against Both Defendants)
	98. The Commission re-alleges and incorporates by reference here the allegations in paragraphs 1 through 97.
	99. Defendants, directly or indirectly, singly or in concert, in the offer or sale of securities and by the use of the means or instruments of transportation or communication in interstate commerce or the mails, (1) knowingly or recklessly have employ...
	100. By reason of the foregoing, Defendants, directly or indirectly, singly or in concert, have violated and, unless enjoined, will again violate Securities Act Section 17(a) [15 U.S.C. § 77q(a)].
	Violations of Exchange Act Section 10(b) and Rule 10b-5 Thereunder
	(Against Both Defendants)
	101. The Commission re-alleges and incorporates by reference here the allegations in paragraphs 1 through 97.
	102. Defendants, directly or indirectly, singly or in concert, in connection with the purchase or sale of securities and by the use of means or instrumentalities of interstate commerce, or the mails, or the facilities of a national securities exchange...
	103. By reason of the foregoing, Defendants, directly or indirectly, singly or in concert, have violated and, unless enjoined, will again violate Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].
	PRAYER FOR RELIEF
	Dated: New York, New York
	Sheldon L. Pollock
	Adam Grace
	Travis Hill
	Nicholas Flath
	Rhonda L. Jung
	Attorneys for Plaintiff
	SECURITIES AND EXCHANGE COMMISSION
	New York Regional Office
	100 Pearl Street
	Suite 20-100
	212-336-9135 (Hill)
	[email protected]