SEC v. ASHISH AGGARWAL; SHAHRIYAR BOLANDIAN; and KEVAN SADIGH, No. 2:15-cv-06460, Central District of California (Mar. 23, 2026) — Judgment

1
FINAL JUDGMENT AS TO KEVAN SADIGH, CASE NO. 2:15-CV-06460-TJH (MARX)

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

WESTERN DIVISION

SECURITIES AND EXCHANGE
COMMISSION,

Plaintiff,

v.

ASHISH AGGARWAL,
SHAHRIYAR BOLANDIAN, and
KEVAN SADIGH,

Defendants,

and

FARHAD BOLANDIAN and PARDIS
BOLANDIAN,

Relief Defendants.

Case No. 2:15-cv-06460-TJH (MARx)

FINAL JUDGMENT AS TO
DEFENDANT KEVAN SADIGH

Courtroom: 9C
Judge: Hon. Terry J. Hatter, Jr.
Magistrate:  Hon. Margo A. Rocconi.

#:1212

2
FINAL JUDGMENT AS TO KEVAN SADIGH, CASE NO. 2:15-CV-06460-TJH (MARX)

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

The Securities and Exchange Commission having filed an Amended

Complaint [ECF No. 92] and Defendant Kevan Sadigh (“Defendant”) having

entered a general appearance; consented to the Court’s jurisdiction over Defendant

and the subject matter of this action; consented to entry of this Final Judgment;

waived findings of fact and conclusions of law; and waived any right to appeal

from this Final Judgment:

I.

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Defendant

is permanently restrained and enjoined from violating, directly or indirectly,

Section 10(b) of the Securities Exchange Act of 1934 (the “Exchange Act”) [15

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

any means or instrumentality of interstate commerce, or of the mails, or of any

facility of any national securities exchange, in connection with the purchase or sale

of any security:

(a) to employ any device, scheme, or artifice to defraud;

(b) to make any untrue statement of a material fact, or to omit to

state a material fact necessary in order to make the statements

made, in the light of the circumstances under which they were

made, not misleading; or

(c) to engage in any act, practice, or course of business which

operates or would operate as a fraud or deceit upon any person;

by: (i) buying or selling a security of any issuer, on the basis of material nonpublic

information, in breach of a fiduciary duty or other duty of trust or confidence that

is owed directly, indirectly, or derivatively, to the issuer of that security or the

shareholders of that issuer, or to any other person who is the source of the

information; or (ii) by communicating material nonpublic information about a

#:1213

3
FINAL JUDGMENT AS TO KEVAN SADIGH, CASE NO. 2:15-CV-06460-TJH (MARX)

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

security or issuer, in breach of a fiduciary duty or other duty of trust or confidence,

to another person or persons for purposes of buying or selling any security.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as

provided in Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also

binds the following who receive actual notice of this Final Judgment by personal

service or otherwise: (a) Defendant’s officers, agents, servants, employees, and

attorneys; and (b) other persons in active concert or participation with Defendant

or with anyone described in (a).

II.

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED

that Defendant is permanently restrained and enjoined from violating Section 14(e)

of the Exchange Act [15 U.S.C. § 78n(e)] and Rule 14e-3 [17 C.F.R. § 240.14e-3]

promulgated thereunder, in connection with any tender offer or request or

invitation for tenders, from engaging in any fraudulent, deceptive, or manipulative

act or practice, by:

(a) purchasing or selling or causing to be purchased or sold the

securities sought or to be sought in such tender offer, securities

convertible into or exchangeable for any such securities or any

option or right to obtain or dispose of any of the foregoing

securities while in possession of material information relating

to such tender offer that Defendant knows or has reason to

know is nonpublic and knows or has reason to know has been

acquired directly or indirectly from the offering person; the

issuer of the securities sought or to be sought by such tender

offer; or any officer, director, partner, employee or other person

acting on behalf of the offering person or such issuer, unless

within a reasonable time prior to any such purchase or sale such

#:1214

4
FINAL JUDGMENT AS TO KEVAN SADIGH, CASE NO. 2:15-CV-06460-TJH (MARX)

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

information and its source are publicly disclosed by press

release or otherwise; or

(b) communicating material, nonpublic information relating to a

tender offer, which Defendant knows or has reason to know is

nonpublic and knows or has reason to know has been acquired

directly or indirectly from the offering person; the issuer of the

securities sought or to be sought by such tender offer; or any

officer, director, partner, employee, advisor, or other person

acting on behalf of the offering person of such issuer, to any

person under circumstances in which it is reasonably

foreseeable that such communication is likely to result in the

purchase or sale of securities in the manner described in

subparagraph (a) above, except that this paragraph shall not

apply to a communication made in good faith

(i) to the officers, directors, partners or employees of

the offering person, to its advisors or to other

persons, involved in the planning, financing,

preparation or execution of such tender offer;

(ii) to the issuer whose securities are sought or to be

sought by such tender offer, to its officers,

directors, partners, employees or advisors or to

other persons involved in the planning, financing,

preparation or execution of the activities of the

issuer with respect to such tender offer; or

(iii) to any person pursuant to a requirement of any

statute or rule or regulation promulgated

thereunder;

#:1215

5
FINAL JUDGMENT AS TO KEVAN SADIGH, CASE NO. 2:15-CV-06460-TJH (MARX)

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as

provided in Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also

binds the following who receive actual notice of this Final Judgment by personal

service or otherwise: (a) Defendant’s officers, agents, servants, employees, and

attorneys; and (b) other persons in active concert or participation with Defendant

or with anyone described in (a).

III.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that

Defendant is liable for disgorgement of $108,120, representing net profits gained

as a result of certain conduct alleged in the Amended Complaint, which amount is

deemed satisfied by the entry of the order of forfeiture in United States v. Sadigh,

No. 2:15-cr-00465-TJH (C.D. Cal.) (ECF No. 992).

IV.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the

Consent is incorporated herein with the same force and effect as if fully set forth

herein, and that Defendant shall comply with all of the undertakings and

agreements set forth therein.

V.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, for

purposes of exceptions to discharge set forth in Section 523 of the Bankruptcy

Code, 11 U.S.C. §523, the allegations in the Amended Complaint are true and

admitted by Defendant, and further, any debt for disgorgement, prejudgment

interest, civil penalty or other amounts due by Defendant under this Final

Judgment or any other judgment, order, consent order, decree or settlement

agreement entered in connection with this proceeding, is a debt for the violation by

Defendant of the federal securities laws or any regulation or order issued under

#:1216

#:1217

1 
FINAL JUDGMENT AS TO KEVAN SADIGH, CASE NO. 2:15-CV-06460-TJH (MARX) 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 

 

 

 

 

 

 

UNITED STATES DISTRICT COURT 
CENTRAL DISTRICT OF CALIFORNIA 

WESTERN DIVISION 

SECURITIES AND EXCHANGE 
COMMISSION, 

Plaintiff, 

v. 

ASHISH AGGARWAL, 
SHAHRIYAR BOLANDIAN, and 
KEVAN SADIGH, 

Defendants, 

and 

FARHAD BOLANDIAN and PARDIS 
BOLANDIAN, 

Relief Defendants. 

Case No. 2:15-cv-06460-TJH (MARx) 

FINAL JUDGMENT AS TO 
DEFENDANT KEVAN SADIGH 

Courtroom: 9C 
Judge: Hon. Terry J. Hatter, Jr. 
Magistrate:  Hon. Margo A. Rocconi. 

 

  

Case 2:15-cv-06460-TJH-MAR     Document 195     Filed 03/20/26     Page 1 of 6   Page ID
#:1212



 

2 
FINAL JUDGMENT AS TO KEVAN SADIGH, CASE NO. 2:15-CV-06460-TJH (MARX) 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

The Securities and Exchange Commission having filed an Amended 

Complaint [ECF No. 92] and Defendant Kevan Sadigh (“Defendant”) having 

entered a general appearance; consented to the Court’s jurisdiction over Defendant 

and the subject matter of this action; consented to entry of this Final Judgment; 

waived findings of fact and conclusions of law; and waived any right to appeal 

from this Final Judgment: 

I. 

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Defendant 

is permanently restrained and enjoined from violating, directly or indirectly, 

Section 10(b) of the Securities Exchange Act of 1934 (the “Exchange Act”) [15 

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

any means or instrumentality of interstate commerce, or of the mails, or of any 

facility of any national securities exchange, in connection with the purchase or sale 

of any security: 

(a) to employ any device, scheme, or artifice to defraud; 

(b) to make any untrue statement of a material fact, or to omit to 

state a material fact necessary in order to make the statements 

made, in the light of the circumstances under which they were 

made, not misleading; or 

(c) to engage in any act, practice, or course of business which 

operates or would operate as a fraud or deceit upon any person; 

by: (i) buying or selling a security of any issuer, on the basis of material nonpublic 

information, in breach of a fiduciary duty or other duty of trust or confidence that 

is owed directly, indirectly, or derivatively, to the issuer of that security or the 

shareholders of that issuer, or to any other person who is the source of the 

information; or (ii) by communicating material nonpublic information about a 

Case 2:15-cv-06460-TJH-MAR     Document 195     Filed 03/20/26     Page 2 of 6   Page ID
#:1213



 

3 
FINAL JUDGMENT AS TO KEVAN SADIGH, CASE NO. 2:15-CV-06460-TJH (MARX) 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

security or issuer, in breach of a fiduciary duty or other duty of trust or confidence, 

to another person or persons for purposes of buying or selling any security. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as 

provided in Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also 

binds the following who receive actual notice of this Final Judgment by personal 

service or otherwise: (a) Defendant’s officers, agents, servants, employees, and 

attorneys; and (b) other persons in active concert or participation with Defendant 

or with anyone described in (a). 

II. 

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED 

that Defendant is permanently restrained and enjoined from violating Section 14(e) 

of the Exchange Act [15 U.S.C. § 78n(e)] and Rule 14e-3 [17 C.F.R. § 240.14e-3] 

promulgated thereunder, in connection with any tender offer or request or 

invitation for tenders, from engaging in any fraudulent, deceptive, or manipulative 

act or practice, by: 

(a) purchasing or selling or causing to be purchased or sold the 

securities sought or to be sought in such tender offer, securities 

convertible into or exchangeable for any such securities or any 

option or right to obtain or dispose of any of the foregoing 

securities while in possession of material information relating 

to such tender offer that Defendant knows or has reason to 

know is nonpublic and knows or has reason to know has been 

acquired directly or indirectly from the offering person; the 

issuer of the securities sought or to be sought by such tender 

offer; or any officer, director, partner, employee or other person 

acting on behalf of the offering person or such issuer, unless 

within a reasonable time prior to any such purchase or sale such 

Case 2:15-cv-06460-TJH-MAR     Document 195     Filed 03/20/26     Page 3 of 6   Page ID
#:1214



 

4 
FINAL JUDGMENT AS TO KEVAN SADIGH, CASE NO. 2:15-CV-06460-TJH (MARX) 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

information and its source are publicly disclosed by press 

release or otherwise; or 

(b) communicating material, nonpublic information relating to a 

tender offer, which Defendant knows or has reason to know is 

nonpublic and knows or has reason to know has been acquired 

directly or indirectly from the offering person; the issuer of the 

securities sought or to be sought by such tender offer; or any 

officer, director, partner, employee, advisor, or other person 

acting on behalf of the offering person of such issuer, to any 

person under circumstances in which it is reasonably 

foreseeable that such communication is likely to result in the 

purchase or sale of securities in the manner described in 

subparagraph (a) above, except that this paragraph shall not 

apply to a communication made in good faith 

(i) to the officers, directors, partners or employees of 

the offering person, to its advisors or to other 

persons, involved in the planning, financing, 

preparation or execution of such tender offer; 

(ii) to the issuer whose securities are sought or to be 

sought by such tender offer, to its officers, 

directors, partners, employees or advisors or to 

other persons involved in the planning, financing, 

preparation or execution of the activities of the 

issuer with respect to such tender offer; or 

(iii) to any person pursuant to a requirement of any 

statute or rule or regulation promulgated 

thereunder; 

Case 2:15-cv-06460-TJH-MAR     Document 195     Filed 03/20/26     Page 4 of 6   Page ID
#:1215



 

5 
FINAL JUDGMENT AS TO KEVAN SADIGH, CASE NO. 2:15-CV-06460-TJH (MARX) 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as 

provided in Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also 

binds the following who receive actual notice of this Final Judgment by personal 

service or otherwise: (a) Defendant’s officers, agents, servants, employees, and 

attorneys; and (b) other persons in active concert or participation with Defendant 

or with anyone described in (a). 

III. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that 

Defendant is liable for disgorgement of $108,120, representing net profits gained 

as a result of certain conduct alleged in the Amended Complaint, which amount is 

deemed satisfied by the entry of the order of forfeiture in United States v. Sadigh, 

No. 2:15-cr-00465-TJH (C.D. Cal.) (ECF No. 992). 

 

IV. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the 

Consent is incorporated herein with the same force and effect as if fully set forth 

herein, and that Defendant shall comply with all of the undertakings and 

agreements set forth therein. 

V. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, for 

purposes of exceptions to discharge set forth in Section 523 of the Bankruptcy 

Code, 11 U.S.C. §523, the allegations in the Amended Complaint are true and 

admitted by Defendant, and further, any debt for disgorgement, prejudgment 

interest, civil penalty or other amounts due by Defendant under this Final 

Judgment or any other judgment, order, consent order, decree or settlement 

agreement entered in connection with this proceeding, is a debt for the violation by 

Defendant of the federal securities laws or any regulation or order issued under 

Case 2:15-cv-06460-TJH-MAR     Document 195     Filed 03/20/26     Page 5 of 6   Page ID
#:1216



Case 2:15-cv-06460-TJH-MAR     Document 195     Filed 03/20/26     Page 6 of 6   Page ID
#:1217