SEC v. Sanjay Bhandari; Vinod Singhi; and Rakesh Jain, No. LR-25989, Eastern District of Virginia (Apr. 30, 2024) — Press Release

U.S. SECURITIES AND EXCHANGE COMMISSION Litigation Release No. 25989 / April 30, 2024 Securities and Exchange Commission v. Sanjay Bhandari et al., No. 1:24-cv-00710 (E.D. Va. filed Apr. 30, 2024) SEC Charges Virginia Resident and Two Friends with Insider Trading The Securities and Exchange Commission filed insider trading charges today against Sanjay Bhandari, Vinod Singhi, and Rakesh Jain, who collectively made about $70,000 in profits from trading in advance of the January 19, 2022 announcement that Zogenix Inc. would be acquired by another company. They each offered to settle the SEC's action, including by agreeing to pay disgorgement, interest, and penalties totaling over $170,000. According to the SEC's complaint, Virginia resident Bhandari learned of the acquisition on January 18, 2022, the day before the first public announcement of the acquisition, during a phone conversation with an individual who worked at Zogenix. As alleged in the complaint, the individual had a close personal relationship with Bhandari and told Bhandari about the acquisition in the context of seeking career advice. The complaint alleges that Bhandari began buying Zogenix stock while still on the phone with the individual at Zogenix, and then provided the material, nonpublic acquisition news to his friend and New York resident Singhi, who in turn provided it to their mutual friend and California resident Jain. As alleged, Singhi and Jain each then purchased Zogenix stock before the public announcement, and Bhandari, Singhi, and Jain then sold all of their stock before noon on January 19, 2022, after the acquisition announcement was made public and the price of Zogenix stock had increased over 60% in value. The SEC alleges that Bhandari made about $49,000 on his Zogenix trades, Singhi made about $10,500, and Jain made about $9,500. The SEC's complaint, filed in U.S. District Court for the Eastern District of Virginia, charges Bhandari, Singhi, and Jain with violating the antifraud provisions of the federal securities laws. Without admitting or denying the allegations, Bhandari, Singhi, and Jain consented to judgments permanently enjoining them from future violations of Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder; ordering Bhandari to pay disgorgement of $49,015, prejudgment interest of $7,020, and a civil penalty of $73,523; ordering Singhi to pay disgorgement of $10,555, prejudgment interest of $1,512, and a civil penalty of $10,555; and ordering Jain to pay disgorgement of $9,570, prejudgment interest of $1,371, and a civil penalty of $9,570. The judgments are subject to court approval. The SEC's investigation was conducted by Jonathan Allen, Magdalena Ellis, David D'Addio, and Amy Gwiazda of the SEC's Boston Regional Office. The SEC appreciates the assistance of the Financial Industry Regulatory Authority. SEC Complaint

U.S. SECURITIES AND EXCHANGE COMMISSION Litigation Release No. 25989 / April 30, 2024 Securities and Exchange Commission v. Sanjay Bhandari et al., No. 1:24-cv-00710 (E.D. Va. filed Apr. 30, 2024) SEC Charges Virginia Resident and Two Friends with Insider Trading The Securities and Exchange Commission filed insider trading charges today against Sanjay Bhandari, Vinod Singhi, and Rakesh Jain, who collectively made about $70,000 in profits from trading in advance of the January 19, 2022 announcement that Zogenix Inc. would be acquired by another company. They each offered to settle the SEC's action, including by agreeing to pay disgorgement, interest, and penalties totaling over $170,000. According to the SEC's complaint, Virginia resident Bhandari learned of the acquisition on January 18, 2022, the day before the first public announcement of the acquisition, during a phone conversation with an individual who worked at Zogenix. As alleged in the complaint, the individual had a close personal relationship with Bhandari and told Bhandari about the acquisition in the context of seeking career advice. The complaint alleges that Bhandari began buying Zogenix stock while still on the phone with the individual at Zogenix, and then provided the material, nonpublic acquisition news to his friend and New York resident Singhi, who in turn provided it to their mutual friend and California resident Jain. As alleged, Singhi and Jain each then purchased Zogenix stock before the public announcement, and Bhandari, Singhi, and Jain then sold all of their stock before noon on January 19, 2022, after the acquisition announcement was made public and the price of Zogenix stock had increased over 60% in value. The SEC alleges that Bhandari made about $49,000 on his Zogenix trades, Singhi made about $10,500, and Jain made about $9,500. The SEC's complaint, filed in U.S. District Court for the Eastern District of Virginia, charges Bhandari, Singhi, and Jain with violating the antifraud provisions of the federal securities laws. Without admitting or denying the allegations, Bhandari, Singhi, and Jain consented to judgments permanently enjoining them from future violations of Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder; ordering Bhandari to pay disgorgement of $49,015, prejudgment interest of $7,020, and a civil penalty of $73,523; ordering Singhi to pay disgorgement of $10,555, prejudgment interest of $1,512, and a civil penalty of $10,555; and ordering Jain to pay disgorgement of $9,570, prejudgment interest of $1,371, and a civil penalty of $9,570. The judgments are subject to court approval. The SEC's investigation was conducted by Jonathan Allen, Magdalena Ellis, David D'Addio, and Amy Gwiazda of the SEC's Boston Regional Office. The SEC appreciates the assistance of the Financial Industry Regulatory Authority. SEC Complaint