SEC v. Charles Baugh, No. 9:24-cv-80919, Southern District of Florida (July 30, 2024) — Complaint

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

__________________________________________
       :
SECURITIES AND EXCHANGE    :
COMMISSION,     :
       : CASE NO.:
  Plaintiff,    :
       :
 v.      :
       :
CHARLES BAUGH,    :
       :
  Defendant.    :
__________________________________________:

COMPLAINT

 Plaintiff Securities and Exchange Commission (“Commission”) alleges:
I. INTRODUCTION
1. This   case   involves   unlawful   insider   trading   by   Defendant   Charles   Baugh
(“Baugh”  or  “Defendant”)  in  the  securities  of  ADT,  Inc.  (“ADT”),  a  publicly  traded  company
that  provides  residential  and  small  business  electronic  security and  alarm  monitoring  services
throughout  the  United  States.  On  August  3,  2020,  ADT  announced  that  it  had  entered  into  a
long-term partnership with Google LLC (“Google”) to create the next generation of smart home
security  services  (the  “Announcement”).  Prior  to  the  Announcement,  Baugh  misappropriated
material,  non-public  information  regarding  the  Announcement  from  a  family  member,  a  senior
employee at ADT, with whom he shared a long relationship of trust and confidence.
2. In  breach  of  his  duty  of  trust  and  confidence  to  his  family  member,  Baugh
misused  this  material,  non-public  information  to  purchase  $66,000  worth  of  ADT  call  options
using five  different  online  brokerage  accounts.    After  the  Announcement,  Baugh  sold  all  of  his
ADT call options at a profit of $320,908, earning over a 600% return.

 2
3. In  addition,  Defendant  also  told  a  relative to  purchase  ADT  options,  resulting  in  a
profit to this other relative of $76,376.
4. By  engaging  in  the  conduct  alleged  in  this  Complaint,  Baugh violated and,  unless
enjoined will continue to violate, 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].  Accordingly,  the
Commission seeks a permanent injunction against Baugh, and an order directing him to disgorge his
illicit profits, with prejudgment interest thereon, and to pay a civil penalty.
II. JURISDICTION AND VENUE
5. This Court has jurisdiction over this action pursuant to Sections 21(d), 21(e), 21A
and 27 of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), 78u-1 and 78aa].
6. This Court has personal jurisdiction over the Defendant and venue is proper in the
Southern  District  of  Florida  because  the  Defendant  engaged  in  acts,  transactions,  practices,  and
courses  of  conduct  in  this  District  constituting  violations  of  the  Exchange  Act.  In  addition,  the
Defendant resides in this District.
7. In connection with the conduct alleged in this Complaint, the Defendant, directly
and  indirectly,  made  use  of  the  means  and  instrumentalities  of  interstate  commerce,  the  means
and instruments of transportation and communication in interstate commerce, and the mails.
III.   DEFENDANT AND RELEVANT ENTITY
A. Defendant
8. Baugh, age 58, is a United States citizen and a resident of Boca Raton, Florida.
B. Relevant Entity
9. ADT is  a  company  that  provides  residential  and  small  business  electronic
security,  fire  protection,  and  other  related  alarm  monitoring  services  throughout  the  United

 3
States.    ADT  is  incorporated  in  Delaware  and  headquartered  in  Boca  Raton,  Florida.   ADT’s
common  stock  was  registered  with  the  Commission  pursuant  to  Section  12(b)  of  the  Exchange
Act [15  U.S.C. §  78l(b)].  ADT  shares  are listed  on  the  New  York  Stock  Exchange  under  the
symbol  “ADT.”   ADT’s  options  are listed  on  the  Chicago  Board  of  Options  Exchange,  NYSE
Arca, Intercontinental Exchange, and the Philadelphia Stock Exchange.
IV.   FACTUAL ALLEGATIONS
A. ADT Negotiations with Google and the August 3, 2020 Announcement
10. ADT  and  Google  started  discussing  a  possible  partnership  in  2019,  in  order  to
leverage Google’s award-winning Nest home security hardware with ADT’s security installation
and monitoring services.  The two companies held several preliminary meetings throughout that
year  until  early  2020,  when  discussions  advanced  to  Google  making  a  substantial  equity
investment in ADT.
11. In  early  February  2020,  ADT’s  board  discussed  the  proposed  investment  by
Google and, on February 25, ADT and Google executed a non-disclosure agreement concerning
the  proposed  partnership  and  Google  investment.  Beginning  in  May  2020,  Google  and  its
advisors conducted due diligence of ADT. By mid-July in 2020, Google presented an agreement
and a  proposed  equity  investment  in  ADT  to  its  board.  The  parties  continued  negotiations  and
during the last few days of July 2020, ADT and Google finalized the partnership agreement and
investment terms.
12. On  August  3,  2020, prior  to  the  opening  of  trading  on  the  stock  market,  ADT
announced that it was entering into a long-term partnership agreement with Google “to create the
next  generation  of  smart  security  home  offerings.”
1
  The  news  release  stated  that  Google  was

1
News Release available at ADT and Google Partner To Create Leading Smart Home Security Offering - ADT (last
visited May 8, 2024).

 4
investing  $450  million  to  acquire  6.6%  ownership  in  ADT,  and  that  each  company  would
commit $150 million for co-marketing, product development, technology and employee training.
ADT’s  news  release  explained  that  “[t]he  partnership  will  combine  Nest’s  award-winning
hardware   and   services,   powered   by   Google’s   machine   learning   technology,   with   ADT’s
installation,  service  and  professional  monitoring  network  to  create  a  more  helpful  smart  home
and integrated experience for customers across the United States.”
13. On the last day of trading before the Announcement, ADT’s stock closed at $8.61
per share.  On August 3, 2020, the day of the Announcement, ADT’s stock price closed at $13.48
per share.
B. Baugh Obtains Material, Non-Public Information About the Announcement
14. Baugh’s family member was employed at ADT as a senior employee since before
2019. The family member learned about the negotiations between ADT and Google in or around
May 2020, when he was asked to sign a non-disclosure agreement and, thereafter, learned about
possible equipment changes due to the potential partnership with Google.
15. Baugh  and  his  family  member  shared  a  close  familial  relationship.  The  two
frequently visited each other’s home, often spent time together and celebrated holidays together.
The family  member  often  consulted  Baugh,  whom  he  considered  a  close  confidant,  on  life
decisions  and  general  financial  advice.  The  two  regularly  confided  in  each  other  concerning
personal  issues,  often  discussing  matters  that  they  would  not  share  with  other  members  of  the
family.
16. During  a  Fourth of  July  family  gathering in  2020,  Baugh  learned  material,  non-
public  information  regarding  the  possible  partnership  between  ADT  and  Google  through his
family  member.  In  a  private  conversation  between  Baugh  and  his  family  member,  Baugh

 5
inquired  about  the  family  member’s  work  at  ADT.  The  family  member  confided  to  Baugh  that
Google was exploring making an investment in ADT, and the family member shared his personal
excitement about the potential partnership between the two companies.
17. Because  of  their  close  family relationship  and  history  of  sharing  personal
confidences, Baugh’s family  member  had  an  expectation  of  trust  and  confidence  that  the
information he shared with Baugh about Google’s interest in ADT would be kept confidential.
18. Given his  family  member’s  senior  role  at  ADT,  Baugh  knew,  or  was  reckless  in
not knowing, that the information regarding the potential partnership between ADT and Google,
and Google’s investment in ADT, was material,  non-public information that Baugh had a duty to
keep confidential.
C. Baugh’s Trading on the Basis of Material, Non-public Information
19.  On July 6, 2020, when the market reopened after the Independence Day holiday
weekend, Baugh began  to  make  purchases  of  ADT  call  options  without  his  family  member’s
knowledge.  Over the course of several days in July 2020, Baugh placed separate orders to buy
ADT  call  options
2
  in five  different online  brokerage  accounts,  at  a  total  cost  of  approximately
$66,000. Before  these  transactions,  while  Baugh  had  experience  trading  securities  and  options,
Baugh had at least no recent history of trading ADT stock or ADT options.
20. Immediately after the Announcement on August 3, 2020, Baugh began selling his
ADT call positions.  He sold all his ADT call positions by August 4, 2020, for a realized profit of
$320,908 – nearly a 500% return on his $66,000 investment.

2
 A stock option is an equity derivative, specifically, a financial contract that gives an investor the right – but not the
obligation – to buy or sell a stock at an agreed upon price and date.  Call options give the buyer the right to purchase
a stock, bond, or other asset as a specified price within a specific period.  Each call option typically provides the
holder with the right to purchase 100 shares of the underlying stock at the stated price, which is typically a small
premium in relation to the price of the underlying stock. A call buyer profits when the underlying stock increases in
price, such as when positive company news is released.

 6
21. Baugh also persuaded a relative to   purchase ADT options.  This other relative was
also an options trader and had a history of taking investment advice from Baugh.  This relative
often traded in a similar pattern as Baugh, except in smaller amounts. Baugh did not disclose to
this  relative  material,  non-public  information,  but  rather,  simply  told  this  relative  that  he  was
purchasing ADT call options.
22. Upon Baugh’s recommendation, commencing on July 15, 2020, Baugh’s relative
also  purchased  ADT  call  options  and  continued  to  do  so  in  multiple  accounts  throughout  July
2020, totaling approximately $14,000.  This relative also purchased approximately $8,000 worth
of  ADT  common  stock.  After  the  Announcement,  the  relative  began  to  sell  his  ADT  call
positions  and  stock,  completing  his  sales  by  August  31,  2020.    The  relative realized  profits  of
$76,376 from the sale of his ADT securities.
23. Baugh did not inform his family member about any of the ADT options purchases
he  made  for  himself,  nor  did  he  inform  his family  member  that  he  told  another  relative to
purchase ADT options in advance of the Announcement.
24. The aggregate amount of illicit profits from the trades Baugh placed or persuaded
others to place was $397,284.
V. CLAIM FOR RELIEF
Violation of Section 10(b) of the Exchange Act and Rule 10b-5 Thereunder
(Insider Trading)

25. The Commission repeats and realleges Paragraphs 1 through 24 of this Complaint
as if fully set forth herein.
26. From  at  least  July  2020  to  at  least  September  2020,  by  engaging  in  the  acts  and
conduct alleged herein, Baugh, directly or indirectly, in connection with the purchase or sale of

 7
securities, and by use of the means or instrumentalities of interstate commerce, or of the mails, or
a facility of a national securities exchange, has knowingly or recklessly:
a. employed devices, schemes, or artifices to defraud; and/or
b. made  an  untrue  statement  of  material  fact,  or  omitted  to  state  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
c. engaged in acts, practices, or courses of business which operated or would operate
as a fraud or deceit upon any person.
27. By  reason  of  the  foregoing,  Baugh violated,  and  unless  enjoined,  is  reasonably
likely  to  continue  to  violate,  Section  10(b)  of  the  Exchange  Act  [15  U.S.C.  §  78j(b)],   and
Exchange Act Rule 10b-5 [17 C.F.R. § 240.10b-5].
VI.   RELIEF REQUESTED
 WHEREFORE, the Commission respectfully requests that the Court:
A. Permanent Injunctive Relief
 Issue  a  Permanent  Injunction,  restraining  and  enjoining  the  Defendant,  his  agents,
servants,   employees,   attorneys,   and   representatives,   and   all   persons   in   active   concert   or
participation with him, and each of them, from violating Section 10(b) of the Exchange Act, [15
U.S.C. § 78j(b)] and Exchange Act Rule 10b-5 [17 C.F.R. § 240.10b-5]  .
B. Disgorgement and Prejudgment Interest Thereon
Issue an Order directing the Defendant to disgorge all ill-gotten gains,  with prejudgment
interest, received as a result of the acts and/or courses of conduct complained of herein.

 8
C. Civil Money Penalty
 Issue an Order directing the Defendant to pay a civil money penalty pursuant to Section
21A of the Exchange Act, [  15 U.S.C. §§ 78u(d) and 78u-1]  .
D. Retention of Jurisdiction
The  Commission  respectfully  requests  the  Court  retain  jurisdiction  over  this  action  in
order to implement and carry out the terms of all orders and decrees that may hereby be entered,
or to entertain any suitable application or motion by the Commission for additional relief within
the jurisdiction of this Court.
E. Further Relief
 Grant such other and further relief as this Court may deem just, equitable, or necessary.
Dated:   July 30, 2024   Respectfully submitted,
     By: Teresa J. Verges
      Teresa J. Verges, Esq.
Florida Bar No. 997651

Attorney for Plaintiff
U.S. Securities and Exchange Commission
      801 Brickell Avenue, Suite 1950
Miami, Florida 33131
Direct Dial: (305) 982-6376
      Facsimile: (305) 536-4154
      E-mail: [email protected]

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 

            
__________________________________________ 
       : 
SECURITIES AND EXCHANGE   : 
COMMISSION,     : 
       : CASE NO.: 
  Plaintiff,    : 
       :   
 v.      :   
       : 
CHARLES BAUGH,    : 
       : 
  Defendant.    : 
__________________________________________: 
 

COMPLAINT 
 
 Plaintiff Securities and Exchange Commission (“Commission”) alleges: 

I. INTRODUCTION 

1. This case involves unlawful insider trading by Defendant Charles Baugh 

(“Baugh” or “Defendant”) in the securities of ADT, Inc. (“ADT”), a publicly traded company 

that provides residential and small business electronic security and alarm monitoring services 

throughout the United States. On August 3, 2020, ADT announced that it had entered into a 

long-term partnership with Google LLC (“Google”) to create the next generation of smart home 

security services (the “Announcement”). Prior to the Announcement, Baugh misappropriated 

material, non-public information regarding the Announcement from a family member, a senior 

employee at ADT, with whom he shared a long relationship of trust and confidence. 

2. In breach of his duty of trust and confidence to his family member, Baugh 

misused this material, non-public information to purchase $66,000 worth of ADT call options 

using five different online brokerage accounts.  After the Announcement, Baugh sold all of his 

ADT call options at a profit of $320,908, earning over a 600% return.   

Case 9:24-cv-80919-XXXX   Document 1   Entered on FLSD Docket 07/30/2024   Page 1 of 8



 2 

3. In addition, Defendant also told a relative to purchase ADT options, resulting in a 

profit to this other relative of $76,376.  

4. By engaging in the conduct alleged in this Complaint, Baugh violated and, unless 

enjoined will continue to violate, 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]. Accordingly, the 

Commission seeks a permanent injunction against Baugh, and an order directing him to disgorge his 

illicit profits, with prejudgment interest thereon, and to pay a civil penalty.  

II. JURISDICTION AND VENUE 

5. This Court has jurisdiction over this action pursuant to Sections 21(d), 21(e), 21A 

and 27 of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), 78u-1 and 78aa]. 

6. This Court has personal jurisdiction over the Defendant and venue is proper in the 

Southern District of Florida because the Defendant engaged in acts, transactions, practices, and 

courses of conduct in this District constituting violations of the Exchange Act. In addition, the 

Defendant resides in this District. 

7. In connection with the conduct alleged in this Complaint, the Defendant, directly 

and indirectly, made use of the means and instrumentalities of interstate commerce, the means 

and instruments of transportation and communication in interstate commerce, and the mails. 

III.   DEFENDANT AND RELEVANT ENTITY 

A. Defendant 

8. Baugh, age 58, is a United States citizen and a resident of Boca Raton, Florida.   

B. Relevant Entity 

9. ADT is a company that provides residential and small business electronic 

security, fire protection, and other related alarm monitoring services throughout the United 

Case 9:24-cv-80919-XXXX   Document 1   Entered on FLSD Docket 07/30/2024   Page 2 of 8



 3 

States.  ADT is incorporated in Delaware and headquartered in Boca Raton, Florida. ADT’s 

common stock was registered with the Commission pursuant to Section 12(b) of the Exchange 

Act [15 U.S.C. § 78l(b)]. ADT shares are listed on the New York Stock Exchange under the 

symbol “ADT.” ADT’s options are listed on the Chicago Board of Options Exchange, NYSE 

Arca, Intercontinental Exchange, and the Philadelphia Stock Exchange. 

IV.   FACTUAL ALLEGATIONS 

A. ADT Negotiations with Google and the August 3, 2020 Announcement 

10. ADT and Google started discussing a possible partnership in 2019, in order to 

leverage Google’s award-winning Nest home security hardware with ADT’s security installation 

and monitoring services.  The two companies held several preliminary meetings throughout that 

year until early 2020, when discussions advanced to Google making a substantial equity 

investment in ADT.   

11. In early February 2020, ADT’s board discussed the proposed investment by 

Google and, on February 25, ADT and Google executed a non-disclosure agreement concerning 

the proposed partnership and Google investment. Beginning in May 2020, Google and its 

advisors conducted due diligence of ADT. By mid-July in 2020, Google presented an agreement 

and a proposed equity investment in ADT to its board. The parties continued negotiations and 

during the last few days of July 2020, ADT and Google finalized the partnership agreement and 

investment terms.   

12. On August 3, 2020, prior to the opening of trading on the stock market, ADT 

announced that it was entering into a long-term partnership agreement with Google “to create the 

next generation of smart security home offerings.”1 The news release stated that Google was 

 
1News Release available at ADT and Google Partner To Create Leading Smart Home Security Offering - ADT (last 
visited May 8, 2024).  

Case 9:24-cv-80919-XXXX   Document 1   Entered on FLSD Docket 07/30/2024   Page 3 of 8

https://newsroom.adt.com/corporate-news/adt-and-google-partner-create-leading-smart-home-security


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investing $450 million to acquire 6.6% ownership in ADT, and that each company would 

commit $150 million for co-marketing, product development, technology and employee training. 

ADT’s news release explained that “[t]he partnership will combine Nest’s award-winning 

hardware and services, powered by Google’s machine learning technology, with ADT’s 

installation, service and professional monitoring network to create a more helpful smart home 

and integrated experience for customers across the United States.”   

13. On the last day of trading before the Announcement, ADT’s stock closed at $8.61 

per share.  On August 3, 2020, the day of the Announcement, ADT’s stock price closed at $13.48 

per share. 

B. Baugh Obtains Material, Non-Public Information About the Announcement 

14. Baugh’s family member was employed at ADT as a senior employee since before 

2019. The family member learned about the negotiations between ADT and Google in or around 

May 2020, when he was asked to sign a non-disclosure agreement and, thereafter, learned about 

possible equipment changes due to the potential partnership with Google.    

15. Baugh and his family member shared a close familial relationship. The two 

frequently visited each other’s home, often spent time together and celebrated holidays together. 

The family member often consulted Baugh, whom he considered a close confidant, on life 

decisions and general financial advice. The two regularly confided in each other concerning 

personal issues, often discussing matters that they would not share with other members of the 

family.  

16. During a Fourth of July family gathering in 2020, Baugh learned material, non-

public information regarding the possible partnership between ADT and Google through his 

family member. In a private conversation between Baugh and his family member, Baugh 

Case 9:24-cv-80919-XXXX   Document 1   Entered on FLSD Docket 07/30/2024   Page 4 of 8



 5 

inquired about the family member’s work at ADT. The family member confided to Baugh that 

Google was exploring making an investment in ADT, and the family member shared his personal 

excitement about the potential partnership between the two companies.   

17. Because of their close family relationship and history of sharing personal 

confidences, Baugh’s family member had an expectation of trust and confidence that the 

information he shared with Baugh about Google’s interest in ADT would be kept confidential.  

18. Given his family member’s senior role at ADT, Baugh knew, or was reckless in 

not knowing, that the information regarding the potential partnership between ADT and Google, 

and Google’s investment in ADT, was material, non-public information that Baugh had a duty to 

keep confidential.  

C. Baugh’s Trading on the Basis of Material, Non-public Information 

19.  On July 6, 2020, when the market reopened after the Independence Day holiday 

weekend, Baugh began to make purchases of ADT call options without his family member’s 

knowledge.  Over the course of several days in July 2020, Baugh placed separate orders to buy 

ADT call options2 in five different online brokerage accounts, at a total cost of approximately 

$66,000. Before these transactions, while Baugh had experience trading securities and options, 

Baugh had at least no recent history of trading ADT stock or ADT options.   

20. Immediately after the Announcement on August 3, 2020, Baugh began selling his 

ADT call positions.  He sold all his ADT call positions by August 4, 2020, for a realized profit of 

$320,908 – nearly a 500% return on his $66,000 investment.   

 
2 A stock option is an equity derivative, specifically, a financial contract that gives an investor the right – but not the 
obligation – to buy or sell a stock at an agreed upon price and date.  Call options give the buyer the right to purchase 
a stock, bond, or other asset as a specified price within a specific period.  Each call option typically provides the 
holder with the right to purchase 100 shares of the underlying stock at the stated price, which is typically a small 
premium in relation to the price of the underlying stock. A call buyer profits when the underlying stock increases in 
price, such as when positive company news is released.   

Case 9:24-cv-80919-XXXX   Document 1   Entered on FLSD Docket 07/30/2024   Page 5 of 8



 6 

21. Baugh also persuaded a relative to purchase ADT options.  This other relative was 

also an options trader and had a history of taking investment advice from Baugh.  This relative 

often traded in a similar pattern as Baugh, except in smaller amounts. Baugh did not disclose to 

this relative material, non-public information, but rather, simply told this relative that he was 

purchasing ADT call options.  

22. Upon Baugh’s recommendation, commencing on July 15, 2020, Baugh’s relative 

also purchased ADT call options and continued to do so in multiple accounts throughout July 

2020, totaling approximately $14,000.  This relative also purchased approximately $8,000 worth 

of ADT common stock. After the Announcement, the relative began to sell his ADT call 

positions and stock, completing his sales by August 31, 2020.  The relative realized profits of 

$76,376 from the sale of his ADT securities. 

23. Baugh did not inform his family member about any of the ADT options purchases 

he made for himself, nor did he inform his family member that he told another relative to 

purchase ADT options in advance of the Announcement.  

24. The aggregate amount of illicit profits from the trades Baugh placed or persuaded 

others to place was $397,284. 

V. CLAIM FOR RELIEF 

Violation of Section 10(b) of the Exchange Act and Rule 10b-5 Thereunder 
(Insider Trading) 

 
25. The Commission repeats and realleges Paragraphs 1 through 24 of this Complaint 

as if fully set forth herein. 

26. From at least July 2020 to at least September 2020, by engaging in the acts and 

conduct alleged herein, Baugh, directly or indirectly, in connection with the purchase or sale of 

Case 9:24-cv-80919-XXXX   Document 1   Entered on FLSD Docket 07/30/2024   Page 6 of 8



 7 

securities, and by use of the means or instrumentalities of interstate commerce, or of the mails, or 

a facility of a national securities exchange, has knowingly or recklessly: 

a. employed devices, schemes, or artifices to defraud; and/or   

b. made an untrue statement of material fact, or omitted to state 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 

c. engaged in acts, practices, or courses of business which operated or would operate 

as a fraud or deceit upon any person.  

27. By reason of the foregoing, Baugh violated, and unless enjoined, is reasonably 

likely to continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)], and 

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

VI.   RELIEF REQUESTED 

 WHEREFORE, the Commission respectfully requests that the Court:  

A. Permanent Injunctive Relief 

 Issue a Permanent Injunction, restraining and enjoining the Defendant, his agents, 

servants, employees, attorneys, and representatives, and all persons in active concert or 

participation with him, and each of them, from violating Section 10(b) of the Exchange Act, [15 

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

B. Disgorgement and Prejudgment Interest Thereon 

Issue an Order directing the Defendant to disgorge all ill-gotten gains, with prejudgment 

interest, received as a result of the acts and/or courses of conduct complained of herein. 

Case 9:24-cv-80919-XXXX   Document 1   Entered on FLSD Docket 07/30/2024   Page 7 of 8



 8 

C. Civil Money Penalty 

 Issue an Order directing the Defendant to pay a civil money penalty pursuant to Section 

21A of the Exchange Act, [15 U.S.C. §§ 78u(d) and 78u-1]. 

D. Retention of Jurisdiction 

The Commission respectfully requests the Court retain jurisdiction over this action in 

order to implement and carry out the terms of all orders and decrees that may hereby be entered, 

or to entertain any suitable application or motion by the Commission for additional relief within 

the jurisdiction of this Court. 

E. Further Relief 

 Grant such other and further relief as this Court may deem just, equitable, or necessary.  

Dated:  July 30, 2024   Respectfully submitted, 

     By: Teresa J. Verges  
      Teresa J. Verges, Esq.     

Florida Bar No. 997651  
    
Attorney for Plaintiff 
U.S. Securities and Exchange Commission 

      801 Brickell Avenue, Suite 1950 
Miami, Florida 33131  
Direct Dial: (305) 982-6376 

      Facsimile: (305) 536-4154 
      E-mail: [email protected]  

 
       

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