SEC v. CHRISTOPHER SLAGA a/k/a KEITH RENKO; Q4 CAPITAL GROUP, LLC; J4 CAPITAL ADVISORS LLC; and HAYDEN GREENE, No. 8:23-cv-01425, Central District of California (Aug. 7, 2023) — Complaint

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JASON P. REINSCH (Texas Bar No. 24040120)
pro hac vice pending
Email:  [email protected]

Attorney for Plaintiff
Securities and Exchange Commission
801 Cherry St., Suite 1900
Fort Worth, Texas 76102
Telephone: (817) 900-2601
Facsimile: (817) 978-4927

LOCAL COUNSEL
DANIEL S. LIM (Cal. Bar. No. 292406)
Email:  [email protected]
444 S. Flower Street, Suite 900
Los Angeles, California 90071
Tel: (323) 965-3957
Fax: (213) 443-1904

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,

vs.
CHRISTOPHER SLAGA a/k/a KEITH
RENKO, Q4 CAPITAL GROUP,
LLC, J4 CAPITAL ADVISORS LLC,
and HAYDEN GREENE,
Defendants.

    Case No.  8:23-cv-01425

COMPLAINT

Plaintiff Securities and Exchange Commission (“Commission” or “SEC”) files

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this Complaint against Defendants Christopher Slaga a/k/a Keith Renko (“Slaga”),
Q4 Capital Group, LLC (“Q4 Capital”), J4 Capital Advisors LLC (“J4 Capital”), and
Hayden Greene (“Greene”) (collectively, “Defendant(s)”), and alleges as follows:
JURISDICTION AND VENUE
1. The Commission brings this action against Defendants pursuant to
authority conferred upon it by Sections 20(b) and 20(d) of the Securities Act of 1933
(“Securities Act”) [15 U.S.C. §§ 77t(b) and 77t(d)] and Sections 21(d) and 21(e) of
the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. §§ 78u(d) and
78u(e)].  This Court has jurisdiction over this action pursuant to Section 22(a) of the
Securities Act [15 U.S.C. § 77v(a)] and Sections 21(d), 21(e), and 27 of the Exchange
Act [15 U.S.C. §§ 78u(d), (e), and 78aa].
2. Defendants have, directly or indirectly, made use of the means or
instrumentalities of interstate commerce, of the mails, or of the facilities of a national
securities exchange in connection with the transactions, acts, practices, and courses of
business alleged in this complaint.
3. Venue is proper in this district pursuant to Section 22(a) of the Securities
Act [15 U.S.C. § 77v(a)] and Section 27(a) of the Exchange Act [15 U.S.C. §
78aa(a)], because certain of the transactions, acts, practices, and courses of conduct
constituting violations of the federal securities laws occurred within this district.  In
addition, venue is proper because Greene resides in Costa Mesa, California, which is
served by this division.
SUMMARY
4. This case concerns Defendants’ scheme that raised approximately $3.5
million from at least 17 investors through a fraudulent and unregistered securities
offering.  From in or around 2018 to at least 2022, Slaga—through Q4 Capital and J4
Capital, each of which he controlled—sold to investors interests in three purported
investment vehicles (each, an “Investment Fund”).   Using his alias “Keith Renko,”
Slaga represented to investors that he would use their funds to generate profits by

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trading marketable securities utilizing his “proprietary computer based quantitative
and statistical algorithms.”
5. However, there were no investment vehicles or proprietary computer
algorithms.  Instead, once Slaga received investor funds, he misappropriated the vast
majority of the money to fund his lavish lifestyle.  Of the approximately $3.5 million
of investor funds that Defendants raised, Slaga used nearly $2.9 million on personal
expenses including, among other things, travel, jewelry, and rent for properties in
Florida, the Bahamas, and Barbados.  Slaga also used a portion of these investor
funds to trade securities in his personal brokerage account for his own benefit and
incurred trading losses of more than $450,000.
6. To conceal his fraud, Slaga provided investors with forged account
statements purporting to show the Investment Funds maintaining large balances at
well-known financial institutions and earning substantial returns.  In truth, neither
Slaga nor the entities he controlled nor the Investment Funds held accounts with these
institutions.  Slaga also made some distributions to investors to further the façade that
the Investment Funds were profitable.  However, those purported distributions were
merely the return of the investors’ own capital disguised as profits.
7. For his part, Greene solicited investors who purchased approximately
$1.4 million in interests in the Investment Funds.  Slaga rewarded Greene’s success
by paying him sales commissions to the detriment of the investors.
8. By engaging in this conduct, Defendants violated, and unless restrained
and enjoined by the Court will continue to violate, the federal securities laws.
Specifically, Slaga, Q4 Capital, and J4 Capital violated Sections 5(a), 5(c), and 17(a)
of the Securities Act [15 U.S.C. §§ 77e(a), 77e(c), and 77q(a)], and 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].  Greene violated Section 15(a) of the Exchange Act.
9. In the interest of protecting the public from any further fraudulent
activity and harm, the Commission brings this action against Defendants seeking:  (a)

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permanent injunctive relief against all Defendants; (b) an order requiring Slaga, Q4
Capital, and J4 Capital, jointly and severally, to disgorge their ill-gotten gains, along
with pre-judgment interest; (c) an order requiring Greene to disgorge his ill-gotten
gains, along with pre-judgment interest; (d) the imposition of civil penalties against
Slaga, Q4 Capital, and J4 Capital; (e) an officer-and-director bar against Slaga; and
(f) all other equitable and ancillary relief to which the Court determines the
Commission is entitled.
THE DEFENDANTS
10. Slaga (also known as Keith Renko), age 49, resides in Barbados.  He is
president and sole owner of Q4 Capital and J4 Capital.  In October 2002, Slaga
pleaded guilty to federal wire fraud charges in connection with a scheme in which he
raised over $19 million from investors.  See United States v. Slaga, No. 4:02-cr-
00654 (S.D. Tex.) (the “2002 Criminal Action”).   Investors in that scheme believed
that they were investing their money in funds managed by Slaga and were provided
false investment returns and fabricated investment account statements.  In reality,
Slaga used investor funds to purchase of a home, luxury items, and for investments in
entities controlled by close friends and family.  In February 2003, he was sentenced
to 48 months in prison and ordered to pay more than $20.3 million in restitution.
11. Q4 Capital is a Delaware limited liability company with its purported
principal place of business in Stamford, Connecticut.  Q4 Capital purports to be the
managing member of Q4 Capital Group FX Opportunity Fund LLC (“Q4 FX Fund”)
and Q4 Capital Group Macro Growth Fund LLC (“Q4 Macro Fund”), each defined
above as an “Investment Fund.”  Neither Q4 Capital nor its securities are registered
with the Commission.
12. J4 Capital purports to be a limited liability company with its principal
place of business in Stamford, Connecticut.  However, J4 Capital is not registered as
an entity in any U.S. jurisdiction.  J4 Capital purports to be the managing member of
J4 Capital, LLC (defined above as an “Investment Fund”).  Neither J4 Capital nor its

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securities are registered with the Commission.
13. Greene, age 32, resides in Mission Viejo, California.  Greene worked
for Q4 Capital from 2019 to 2022, soliciting investors to purchase units in the
Investment Funds and performing market research for the Investment Funds managed
by Q4 Capital.
RELATED ENTITIES
14. J4 Capital, LLC (the “J4 Fund,” and defined above as an “Investment
Fund”) purports to be a limited liability company with its principal place of business
in Stamford, Connecticut.  Slaga never formed the J4 Fund or registered it as an
entity.  Neither the J4 Fund nor its securities are registered with the Commission.
15. Q4 Capital Group FX Opportunity Fund, LLC (the “Q4 FX Fund,”
and defined above as an “Investment Fund”) purports to be a limited liability
company with its principal place of business in Stamford, Connecticut.  Slaga never
formed the Q4 FX Fund or registered it as an entity.  Neither the Q4 FX Fund nor its
securities are registered with the Commission.
16. Q4 Capital Group Macro Growth Fund, LLC (the “Q4 Macro Fund,”
and defined above as an “Investment Fund”) purports to be a limited liability
company with its principal place of business in Stamford, Connecticut.  Slaga never
formed the Q4 Marco Fund or registered it as an entity.  Neither the Q4 Macro Fund
nor its securities are registered with the Commission.
FACTUAL ALLEGATIONS
A. Slaga’s Alias and the Origins of the Investment Funds
17. In or around February 2018, Slaga created a LinkedIn account using his
alias, Keith Renko.  On information and belief, Slaga used the Renko alias, inter alia,
to conceal from the public his criminal record from the 2002 Criminal Action.
18. Soon thereafter, Slaga began using the Renko LinkedIn account to solicit
investments in the J4 Fund.  In offering documents, Slaga claimed that the J4 Fund
was a private investment fund managed by J4 Capital and Renko, whom Slaga

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dubbed “a seasoned trader.”  Slaga stated that the J4 Fund would trade in marketable
securities using “proprietary computer based quantitative and statistical algorithms”
in order to maximize asset appreciation.
19. In or around 2019, a preexisting and unrelated entity also named “J4
Capital, LLC” raised concerns with LinkedIn regarding Renko’s LinkedIn profile,
where Slaga (posing as Renko) held himself out as president of “J4 Capital, LLC.”
Slaga thereafter launched a new management company, Q4 Capital, and began
offering units in two new funds: the Q4 FX Fund and the Q4 Macro Fund.
20. Slaga never formed or registered as entities any of the Investment Funds.
B. The Investment Funds’ Offering Materials
21. In order to solicit investments in the Investment Funds from prospective
investors, Slaga created various offering materials.  He prepared a private placement
memorandum (“PPM”) and a subscription agreement for each of the Investment
Funds.  He also drafted a PowerPoint presentation (“Slide Deck”) that touted the
purported benefits of Slaga’s investment scheme.
22. The PPMs and subscription agreements for all three Investment Funds
contained almost identical language, stating that the objective of each Investment
Fund was to:
maximize total return on capital by seeking capital appreciation
and, from time to time, current income, through the development
and   management   of   a   portfolio   of   marketable   securities,
including   currencies,   equity   instruments,   debt   instruments,
futures contracts, option contracts and swap contracts.
Each PPM identified the Managing Member of the respective Investment Fund to be
Renko, Slaga’s alias.  The PPMs further indicated that Slaga would use his
“proprietary computer based quantitative and statistical algorithms” to generate
profits and limit risk for the investor funds.
23. The Slide Deck supplemented the statements in the PPMs for the Q4 FX

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Fund and the Q4 Macro Fund.  Slaga predicted a forthcoming “catastrophic” event in
the global debt and equity markets and claimed that his trading strategy would profit
from these events.  Slaga compared his approach to a famous book and movie that
chronicled the 2008 Financial Crisis:
Have you seen or read “the Big Short”?  The coming credit crisis
will likely be even more significant, and the opportunity to play
contrarian  and  profit  immensely  during  the  crisis  are  not  well
documented in the financial media.
The Slide Deck also regurgitated the fabricated background of Slaga’s alias, Renko,
noting that he was a “devout statistician” that “attended Dartmouth and went on to
build a reputation as an experienced and successful trader at several well-known Wall
Street institutions.”
24. Slaga, or persons working at his direction, provided prospective
investors in each of the Investment Funds with a PPM and the respective subscription
agreement, typically by email.  In the course of the Q4 FX Fund and the Q4 Macro
Fund offerings, these persons also provided the Slide Deck to some prospective
investors.
25. Slaga, and those working on his behalf, solicited investors through the
internet (including LinkedIn) and email, among other means.  In particular, Slaga,
and those working on his behalf, reached out through LinkedIn messages to
prospective investors with whom they had no prior connections.  Investors in the
Investment Funds had no prior relationship with Slaga.  Indeed, these investors were
under the impression they were dealing with Renko, not Slaga.  Slaga also published
the offering documents for the J4 Fund on J4 Capital’s website.  The general public
could review the offering documents freely without the need for a password.
26. In total, Slaga raised approximately $3.5 million from 17 investors
residing in at least four states and Canada.

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C. Misrepresentations by Slaga, J4 Capital, and Q4 Capital
27. Slaga, J4 Capital, and Q4 Capital made several misrepresentations to
prospective investors in the Investment Funds.
1. Use of the Renko Alias
28. Slaga misrepresented his true identity in the PPMs and the Slide Deck by
identifying the manager of the Investment Funds as Renko.  In an effort to create
credibility, Slaga claimed in his LinkedIn profile and in the Slide Deck to have
graduated from Dartmouth College and to have been a successful trader at multiple
Wall Street firms.  None of these representations were true.  Slaga never worked at
any Wall Street firms and he briefly attended, and did not graduate from, the
University of Houston.  By using his alias, Slaga also concealed his criminal record
resulting from the 2002 Criminal Action.
2. Slaga’s Fabricated Capital Contribution
29. Slaga misrepresented in the PPMs that the managing members of each
management company (i.e., J4 Capital and Q4 Capital) had made capital
commitments of $2,000,000 to each Investment Fund, to be funded personally by
Renko.  These representations were designed to mislead prospective investors into
believing that Slaga’s interests were aligned with theirs because Slaga and his
management companies had “skin in the game.”  But these representations were also
untrue.  Neither Slaga nor Q4 Capital nor J4 Capital ever funded any such purported
capital commitments.
3. Existing Investment Capital
30. Slaga represented in the J4 Fund PPM that the J4 Fund had already
received $125 million in commitments from institutional and other investors.  This
representation was intended to add legitimacy to the J4 Fund.  However, Slaga never
obtained these commitments, and the J4 Fund was never funded—much less formed.
Instead of funding the J4 Fund, as alleged below, Slaga misappropriated investor
funds.

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4. Association with Well-known Financial Entities and
Gatekeepers
31. Slaga made misrepresentations about well-known third parties that were
purportedly involved with the Investment Funds.  These misrepresentations also had
the effect of lending an air of legitimacy to Slaga and the Investment Funds.
32. In this regard, Slaga represented to prospective investors in email
communications that the Investment Funds were audited by a Big Four accounting
firm, Deloitte & Touche LLP (“Deloitte”).  To further cement this lie, Slaga sent to
certain investors a forged letter on the Deloitte’s letterhead stating that it had
conducted a “review” of certain Investment Fund accounts.  The forged letter from
the Deloitte also contained statements that created the impression that a certain well-
known financial institution, Goldman Sachs & Co, LLC (“Goldman”), was the prime
broker for the Q4 Macro Fund.  Further, Slaga sent investors forged account
statements purporting to show the Investment Funds maintaining assets and securities
at another well-known financial institution, J.P. Morgan Securities, LLC (“JP
Morgan”)
33. In truth, Deloitte, Goldman, and JP Morgan had no relationship and did
not perform any services for Slaga, Q4 Capital, J4 Capital, or the Investment Funds.
Rather, Slaga used a portion of investor funds to trade securities for his own benefit
in his personal online brokerage account.
5. Fabricated Investment Performance
34. Slaga misrepresented the performance of the Investment Funds.  The
forged account statements, as well as the forged letter from Deloitte, showed
Investment Fund account balances that far exceeded net asset values that could be
imputed to the Investment Funds.
35. Slaga also provided investors with periodic status reports (“Investor
Updates”) that communicated the fabricated performance of the Investment Funds.
For example, in at least one update that Slaga emailed to investors in or around 2020,

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he represented the performance of the Investment Funds for the first quarter of 2020
as being between 68% and 100%.  However, Slaga did not trade on behalf of the
Investment Funds.
D. Misuse of Investor Funds by Slaga, J4 Capital, and Q4 Capital.
36. The PPMs for the Investment Funds represented that the Investment
Funds’ assets would be used to “invest and trade in a broad range of marketable
securities . . . .”  The PPMs further provided that the managing member (J4 Capital or
Q4 Capital, as applicable) would be allocated 25 percent of the Investment Funds’
gains, that the managing member would bear its own organizational and offering
expenses, and that the Investment Funds would bear certain administrative expenses.
The PPMs did not provide for the managing member to be compensated in any other
way.
37. Slaga, individually and on behalf of J4 Capital and Q4 Capital, misused
investor funds.  Initially, he commingled all investor funds in bank accounts in the
name of JMC 4, LLC (an entity that Slaga controlled) and Q4 Capital.  Slaga
transferred investor funds into various accounts, including his personal bank accounts
and his personal brokerage account.  Of the approximately $3.5 million of investor
funds that Slaga raised, he used $2,893,934.32 on personal expenses, which included,
among other things, travel, restaurants, jewelry, and rent for properties in Florida, the
Bahamas, and Barbados.  He also used a portion of that money to fund an online
trading account in his own name and for his own benefit.  Slaga ultimately realized a
loss of more than $450,000 through his trading activity.
38. Slaga’s scheme ended in or around 2022 as Slaga was unable to lure new
investors and as existing investors became aware of the Commission’s investigation
that preceded the filing of this action.
E. Greene’s Role
39. Slaga employed Greene from 2019 through 2022.  Posing as Renko,
Slaga recruited Greene on LinkedIn, leading Greene to believe that he was being

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hired to help Renko solicit investors, and, as he learned the business, assist him in
executing trading strategies on behalf of the Investment Funds.  Greene had previous
experience in the financial services industry.
40. Greene’s titles during his employment with Q4 Capital were “Operator
of Newport Beach Trading Desk” and later “VP of Trading.”  However, Greene never
made any trades or reviewed any brokerage statements for the Investment Funds.
Instead, Greene provided trading ideas to Slaga, who assigned Greene trading
research tasks.  At all times, Greene believed he was dealing with Renko and had
never heard of Slaga.  Based on his interactions with Slaga, Greene believed that
investor funds were being used to trade as disclosed in the offering documents, and
that Renko was doing so profitably.
41. From 2019 to 2021, Greene solicited at least eight investors who
invested a total of approximately $1.4 million in the Investment Funds.  In soliciting
investors, Greene advised some of them on the merits of investing in the Investment
Funds and provided to investors his own account statements of units he believed he
held in the Investment Funds for the purpose of showing the net asset value and
performance of the Investment Funds.  Over the course of Greene’s employment,
Slaga paid Greene approximately $85,000 in transaction-based compensation.
42. Greene’s involvement with Q4 Capital ended in 2022.
F. The Investments Offered and Sold by Defendants Were Securities
43. Based on Slaga’s, Q4 Capital’s, and J4 Capital’s misrepresentations,
investors invested money into one or more Investment Funds controlled by Slaga in
order to receive returns in the form of profits purportedly generated from Slaga’s
securities trading.
44. Slaga pooled the investor funds—which investors believed would be
used solely for the investment—together in two bank accounts.  The investor funds
were managed entirely by Slaga.
45. Whether investors would profit from their investments was entirely

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dependent on Slaga and the performance of his purported securities trading strategy.
Indeed, both investors on one hand, and Slaga, Q4 Capital, and J4 Capital on the
other, would profit if Slaga’s purported securities trading strategy was successful; in
this way, their fortunes were linked.

FIRST CLAIM FOR RELIEF
Fraud in the Offer or Sale of Securities
Violations of Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]
(Against Slaga, Q4 Capital, and J4 Capital)
46. Plaintiff re-alleges and incorporates paragraphs 1 through __ of this
Complaint by reference as if set forth verbatim in this Claim.
47. Among other things, Slaga, Q4 Capital, and J4 Capital made various
misrepresentations and omissions to investors in the PPMs, Slide Deck, and Investor
Updates.   Slaga, Q4 Capital, and J4 Capital misrepresented Slaga’s true identity
through the use of the Renko alias.  They also falsely claimed that Renko, on behalf
of Q4 Capital and J4 Capital, made $2,000,000 in capital contributions to the
respective Investment Funds, and that, in the case of the J4 Fund, that fund had
already closed on $125 million of commitments from institutional and other
investors.  Slaga, Q4 Capital, and J4 Capital also misrepresented to investors that the
Deloitte, Goldman, and JP Morgan had relationships with and provided services for
Slaga, Q4 Capital, J4 Capital, and the Investment Funds.  Slaga, Q4 Capital, and J4
Capital also provided to investors forged account statements, as well as the forged
letter from Deloitte, falsely showing grossly inflated account balances for the
Investment Funds.  Finally, Slaga misused nearly $2.9 million of investor funds for
personal uses including, among other things, travel, restaurants, jewelry, and rent for
properties in Florida, the Bahamas, and Barbados.
48. By engaging in the acts and conduct alleged herein, Slaga, Q4 Capital,
and J4 Capital, directly or indirectly, in the offer or sale of a security, by the use of

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any means or instruments of transportation or communication in interstate commerce
or by use of the mails, have:
a. knowingly or recklessly employed a device, scheme, or artifice to
defraud; and/or
b. knowingly, recklessly, or negligently obtained money or property
by means of an untrue statement of a material fact or an omission
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. knowingly, recklessly, or negligently engaged in a transaction,
practice, or course of business which operated or would operate as
a fraud or deceit upon the purchaser.
49. By reason of the foregoing, Slaga, Q4 Capital, and J4 Capital have
violated, and unless enjoined will continue to violate, Section 17(a) of the Securities
Act [15 U.S.C. § 77q(a)].

SECOND CLAIM FOR RELIEF
Fraud in Connection with the Purchase or Sale of Securities
Violations of 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]
(Against Slaga, Q4 Capital, and J4 Capital)
50. Plaintiff re-alleges and incorporates paragraphs 1 through __ of this
Complaint by reference as if set forth verbatim in this Claim.
51. Among other things, Slaga, Q4 Capital, and J4 Capital made various
misrepresentations and omissions to investors in the PPMs, Slide Deck, and Investor
Updates.  Slaga, Q4 Capital, and J4 Capital misrepresented Slaga’s true identity
through the use of the Renko alias.  They also falsely claimed that Renko, on behalf
of Q4 Capital and J4 Capital, made $2,000,000 in capital contributions to the

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respective Investment Funds, and that, in the case of the J4 Fund, that fund had
already closed on $125 million of commitments from institutional and other
investors.  Slaga, Q4 Capital, and J4 Capital also misrepresented to investors that the
Deloitte, Goldman, and JP Morgan had relationships with and provided services for
the Slaga, Q4 Capital, J4 Capital, and the Investment Funds.  Slaga, Q4 Capital, and
J4 Capital also provided to investors forged account statements, as well as the forged
letter from Deloitte, falsely showing grossly inflated account balances for the
Investment Funds.  Finally, Slaga misused nearly $2.9 million of investor funds for
personal uses including, among other things, travel, restaurants, jewelry, and rent for
properties in Florida, the Bahamas, and Barbados.
52. By engaging in the acts and conduct alleged herein, Slaga, Q4 Capital,
and J4 Capital, directly or indirectly, in connection with the purchase or sale of
securities, by the use of any means or instrumentality of interstate commerce, or of
the mails, or of any facility of any national securities exchange, knowingly or
recklessly:
(a) employed devices, schemes, or artifices to defraud; and/or
(b) made untrue statements of material facts, or omitted to state
material facts 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.
53. By reason of the foregoing, Slaga, Q4 Capital, and J4 Capital violated,
and unless enjoined will continue to violate, 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].

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THIRD CLAIM FOR RELIEF
Unregistered Offer and Sale of Securities
Violations of Sections 5(a) and (c) of the Securities Act
[15 U.S.C. §§ 77e(a) & (c)]
(Against Slaga, Q4 Capital, and J4 Capital)
54. Plaintiff re-alleges and incorporates paragraphs 1 through __ of this
Complaint by reference as if set forth verbatim in this Claim.
55. Between December 2017 and June 2019, Slaga, Q4 Capital, and J4
Capital collectively raised approximately $3.5 million by offering and selling
interests in the Investment Funds to persons throughout the United States.  However,
Defendants never registered these securities offerings the offer and sale of these
interests with the Commission, and no exemption from registration applied.
56. By engaging in the conduct described herein, Slaga, Q4 Capital, and J4
Capital, directly or indirectly:
a. made use of the means or instruments of transportation or
communication in interstate commerce or of the mails to sell,
through the use or medium of any prospectus or otherwise,
securities as to which no registration statement was in effect;
b. for the purpose of sale or delivery after sale, carried or caused to
be carried through the mails or interstate commerce, by means or
instruments of transportation, securities as to which no registration
statement was in effect; and/or
c. made use of means or instruments of transportation or
communication in interstate commerce or of the mails to offer to
sell, through the use or medium of any prospectus or otherwise,
securities as to which no registration statement had been filed.
57. By reason of the foregoing, Slaga, Q4 Capital, and J4 Capital have
violated, and unless enjoined will continue to violate, Sections 5(a) and 5(c) of the

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Securities Act [15 U.S.C. §§ 77e(a) and (c)].

FOURTH CLAIM FOR RELIEF
Offer and Sale of Securities by an Unregistered Broker
Violations of Section 15(a) of the Exchange Act [15 U.S.C § 78o(a)]
(Against Greene)
58. Plaintiff re-alleges and incorporates paragraphs 1 through 4__ of this
Complaint by reference as if set forth verbatim in this Claim.
59. Between 2019 and 2022, Greene solicited investors to purchase interests
in the Investment Funds.  In return for successfully soliciting investors, Greene was
paid sales commissions.  He also gave investment advice and provided to investors
his own account statements as a way of conveying information about the net asset
value and performance of the Investment Funds.
60. During the relevant period, Greene was not registered with, or an
associated person of, a firm registered with the SEC.
61. By engaging in the conduct described above, Greene acted as a broker
within the meaning of Section 3(a)(4) of the Exchange Act [15 U.S.C. § 78c(4)], and
made use of the mails or the means or instrumentality of interstate commerce to effect
transactions in, or to induce or attempt to induce the purchase or sale of, a security
without being registered in accordance with Section 15(b) of the Exchange Act.
62. By engaging in the conduct described above, Greene violated, and unless
enjoined will continue to violate, Section 15(a) of the Exchange Act [15 U.S.C. §
78o(a)].

PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that the Court enter a
judgment:
a. Making findings of fact and conclusions of law that Defendants

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committed the alleged violations;
b. Permanently enjoining Slaga, Q4 Capital, and J4 Capital from violating
Sections 5(a), 5(c), and 17(a) of the Securities Act [15 U.S.C. §§ 77e(a),
77e(c), 77q(a)] and 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];
c. Permanently enjoining Greene from violating Section 15(a) of the
Exchange Act [15 U.S.C. § 78o(a)];
d. Permanently enjoining Slaga, from directly or indirectly, including, but
not limited to, through any entity owned or controlled by him,
participating in the issuance, purchase, offer, or sale of any security;
provided, however, that such injunction shall not prevent him from
purchasing or selling securities for his own personal account;
e. Permanently enjoining Q4 Capital and J4 Capital, from directly or
indirectly, including, but not limited to, through any entity owned or
controlled by either of them, participating in the issuance, purchase,
offer, or sale of any security;
f. Barring Slaga, pursuant to Section 20(e) of the Securities Act [15 U.S.C.
§ 77t(e)] and Sections 2l(d)(2) of the Exchange Act [15 U.S.C. §
78u(d)(2)], from acting as an officer or director of any issuer that has a
class of securities registered pursuant to Section 12 of the Exchange Act
[15 U.S.C. § 78l] or that is required to file reports pursuant to Section
15(d) of the Exchange Act [15 U.S.C. § 78o(d)];
g. Ordering Slaga, Q4 Capital, and J4 Capital to disgorge, jointly and
severally, all ill-gotten gains they received as a result of the conduct
alleged herein, together with pre-judgment interest, pursuant to the
Court’s equitable powers and Sections 21(d)(3), 21(d)(5), and 21(d)(7)
of the Exchange Act [15 U.S.C. §§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)];
h. Ordering Greene to disgorge all ill-gotten gains he received as a result of

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the conduct alleged herein, together with pre-judgment interest, pursuant
to the Court’s equitable powers and Sections 21(d)(3), 21(d)(5), and
21(d)(7) of the Exchange Act [15 U.S.C. §§ 78u(d)(3), 78u(d)(5), and
78u(d)(7)];
i. Ordering Slaga, Q4 Capital, and J4 Capital to pay civil penalties under
Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section
21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)];
j. Retaining jurisdiction of this action in accordance with the principles of
equity and the Federal Rules of Civil Procedure in order to implement
and carry out the terms of all orders and decrees that may be entered, or
to entertain any suitable application or motion for additional relief within
the jurisdiction of this Court; and
k. Granting such other and further relief as this Court may determine to be
just and necessary.

Dated:  August 7, 2023      /s/ Jason P. Reinsch
Jason P. Reinsch
Attorney for Plaintiff
Securities and Exchange Commission

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JASON P. REINSCH (Texas Bar No. 24040120)   
pro hac vice pending 
Email:  [email protected] 
 
Attorney for Plaintiff 
Securities and Exchange Commission 
801 Cherry St., Suite 1900 
Fort Worth, Texas 76102 
Telephone: (817) 900-2601 
Facsimile: (817) 978-4927 
 
LOCAL COUNSEL  
DANIEL S. LIM (Cal. Bar. No. 292406)  
Email:  [email protected]  
444 S. Flower Street, Suite 900  
Los Angeles, California 90071  
Tel: (323) 965-3957  
Fax: (213) 443-1904 

 
UNITED STATES DISTRICT COURT 

 
CENTRAL DISTRICT OF CALIFORNIA 

 

SECURITIES AND EXCHANGE 
COMMISSION, 

Plaintiff, 
 

vs. 

CHRISTOPHER SLAGA a/k/a KEITH 
RENKO, Q4 CAPITAL GROUP, 
LLC, J4 CAPITAL ADVISORS LLC, 
and HAYDEN GREENE, 

Defendants. 
 

 Case No.  8:23-cv-01425 
 
 
COMPLAINT 
 
 

 
 

Plaintiff Securities and Exchange Commission (“Commission” or “SEC”) files 

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this Complaint against Defendants Christopher Slaga a/k/a Keith Renko (“Slaga”), 

Q4 Capital Group, LLC (“Q4 Capital”), J4 Capital Advisors LLC (“J4 Capital”), and 

Hayden Greene (“Greene”) (collectively, “Defendant(s)”), and alleges as follows: 

JURISDICTION AND VENUE 

1. The Commission brings this action against Defendants pursuant to 

authority conferred upon it by Sections 20(b) and 20(d) of the Securities Act of 1933 

(“Securities Act”) [15 U.S.C. §§ 77t(b) and 77t(d)] and Sections 21(d) and 21(e) of 

the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. §§ 78u(d) and 

78u(e)].  This Court has jurisdiction over this action pursuant to Section 22(a) of the 

Securities Act [15 U.S.C. § 77v(a)] and Sections 21(d), 21(e), and 27 of the Exchange 

Act [15 U.S.C. §§ 78u(d), (e), and 78aa]. 

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

instrumentalities of interstate commerce, of the mails, or of the facilities of a national 

securities exchange in connection with the transactions, acts, practices, and courses of 

business alleged in this complaint. 

3. Venue is proper in this district pursuant to Section 22(a) of the Securities 

Act [15 U.S.C. § 77v(a)] and Section 27(a) of the Exchange Act [15 U.S.C. § 

78aa(a)], because certain of the transactions, acts, practices, and courses of conduct 

constituting violations of the federal securities laws occurred within this district.  In 

addition, venue is proper because Greene resides in Costa Mesa, California, which is 

served by this division. 

SUMMARY 

4. This case concerns Defendants’ scheme that raised approximately $3.5 

million from at least 17 investors through a fraudulent and unregistered securities 

offering.  From in or around 2018 to at least 2022, Slaga—through Q4 Capital and J4 

Capital, each of which he controlled—sold to investors interests in three purported 

investment vehicles (each, an “Investment Fund”).   Using his alias “Keith Renko,” 

Slaga represented to investors that he would use their funds to generate profits by 

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trading marketable securities utilizing his “proprietary computer based quantitative 

and statistical algorithms.” 

5. However, there were no investment vehicles or proprietary computer 

algorithms.  Instead, once Slaga received investor funds, he misappropriated the vast 

majority of the money to fund his lavish lifestyle.  Of the approximately $3.5 million 

of investor funds that Defendants raised, Slaga used nearly $2.9 million on personal 

expenses including, among other things, travel, jewelry, and rent for properties in 

Florida, the Bahamas, and Barbados.  Slaga also used a portion of these investor 

funds to trade securities in his personal brokerage account for his own benefit and 

incurred trading losses of more than $450,000. 

6. To conceal his fraud, Slaga provided investors with forged account 

statements purporting to show the Investment Funds maintaining large balances at 

well-known financial institutions and earning substantial returns.  In truth, neither 

Slaga nor the entities he controlled nor the Investment Funds held accounts with these 

institutions.  Slaga also made some distributions to investors to further the façade that 

the Investment Funds were profitable.  However, those purported distributions were 

merely the return of the investors’ own capital disguised as profits. 

7. For his part, Greene solicited investors who purchased approximately 

$1.4 million in interests in the Investment Funds.  Slaga rewarded Greene’s success 

by paying him sales commissions to the detriment of the investors.  

8. By engaging in this conduct, Defendants violated, and unless restrained 

and enjoined by the Court will continue to violate, the federal securities laws.  

Specifically, Slaga, Q4 Capital, and J4 Capital violated Sections 5(a), 5(c), and 17(a) 

of the Securities Act [15 U.S.C. §§ 77e(a), 77e(c), and 77q(a)], and 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].  Greene violated Section 15(a) of the Exchange Act. 

9. In the interest of protecting the public from any further fraudulent 

activity and harm, the Commission brings this action against Defendants seeking:  (a) 

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permanent injunctive relief against all Defendants; (b) an order requiring Slaga, Q4 

Capital, and J4 Capital, jointly and severally, to disgorge their ill-gotten gains, along 

with pre-judgment interest; (c) an order requiring Greene to disgorge his ill-gotten 

gains, along with pre-judgment interest; (d) the imposition of civil penalties against 

Slaga, Q4 Capital, and J4 Capital; (e) an officer-and-director bar against Slaga; and 

(f) all other equitable and ancillary relief to which the Court determines the 

Commission is entitled.    

THE DEFENDANTS  

10. Slaga (also known as Keith Renko), age 49, resides in Barbados.  He is 

president and sole owner of Q4 Capital and J4 Capital.  In October 2002, Slaga 

pleaded guilty to federal wire fraud charges in connection with a scheme in which he 

raised over $19 million from investors.  See United States v. Slaga, No. 4:02-cr-

00654 (S.D. Tex.) (the “2002 Criminal Action”).   Investors in that scheme believed 

that they were investing their money in funds managed by Slaga and were provided 

false investment returns and fabricated investment account statements.  In reality, 

Slaga used investor funds to purchase of a home, luxury items, and for investments in 

entities controlled by close friends and family.  In February 2003, he was sentenced 

to 48 months in prison and ordered to pay more than $20.3 million in restitution.   

11. Q4 Capital is a Delaware limited liability company with its purported 

principal place of business in Stamford, Connecticut.  Q4 Capital purports to be the 

managing member of Q4 Capital Group FX Opportunity Fund LLC (“Q4 FX Fund”) 

and Q4 Capital Group Macro Growth Fund LLC (“Q4 Macro Fund”), each defined 

above as an “Investment Fund.”  Neither Q4 Capital nor its securities are registered 

with the Commission. 

12. J4 Capital purports to be a limited liability company with its principal 

place of business in Stamford, Connecticut.  However, J4 Capital is not registered as 

an entity in any U.S. jurisdiction.  J4 Capital purports to be the managing member of 

J4 Capital, LLC (defined above as an “Investment Fund”).  Neither J4 Capital nor its 

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securities are registered with the Commission. 

13. Greene, age 32, resides in Mission Viejo, California.  Greene worked 

for Q4 Capital from 2019 to 2022, soliciting investors to purchase units in the 

Investment Funds and performing market research for the Investment Funds managed 

by Q4 Capital.   

RELATED ENTITIES 

14. J4 Capital, LLC (the “J4 Fund,” and defined above as an “Investment 

Fund”) purports to be a limited liability company with its principal place of business 

in Stamford, Connecticut.  Slaga never formed the J4 Fund or registered it as an 

entity.  Neither the J4 Fund nor its securities are registered with the Commission. 

15. Q4 Capital Group FX Opportunity Fund, LLC (the “Q4 FX Fund,” 

and defined above as an “Investment Fund”) purports to be a limited liability 

company with its principal place of business in Stamford, Connecticut.  Slaga never 

formed the Q4 FX Fund or registered it as an entity.  Neither the Q4 FX Fund nor its 

securities are registered with the Commission. 

16. Q4 Capital Group Macro Growth Fund, LLC (the “Q4 Macro Fund,” 

and defined above as an “Investment Fund”) purports to be a limited liability 

company with its principal place of business in Stamford, Connecticut.  Slaga never 

formed the Q4 Marco Fund or registered it as an entity.  Neither the Q4 Macro Fund 

nor its securities are registered with the Commission. 

FACTUAL ALLEGATIONS 

A. Slaga’s Alias and the Origins of the Investment Funds 

17. In or around February 2018, Slaga created a LinkedIn account using his 

alias, Keith Renko.  On information and belief, Slaga used the Renko alias, inter alia, 

to conceal from the public his criminal record from the 2002 Criminal Action.   

18. Soon thereafter, Slaga began using the Renko LinkedIn account to solicit 

investments in the J4 Fund.  In offering documents, Slaga claimed that the J4 Fund 

was a private investment fund managed by J4 Capital and Renko, whom Slaga 

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dubbed “a seasoned trader.”  Slaga stated that the J4 Fund would trade in marketable 

securities using “proprietary computer based quantitative and statistical algorithms” 

in order to maximize asset appreciation. 

19. In or around 2019, a preexisting and unrelated entity also named “J4 

Capital, LLC” raised concerns with LinkedIn regarding Renko’s LinkedIn profile, 

where Slaga (posing as Renko) held himself out as president of “J4 Capital, LLC.”  

Slaga thereafter launched a new management company, Q4 Capital, and began 

offering units in two new funds: the Q4 FX Fund and the Q4 Macro Fund.   

20. Slaga never formed or registered as entities any of the Investment Funds. 

B. The Investment Funds’ Offering Materials 

21. In order to solicit investments in the Investment Funds from prospective 

investors, Slaga created various offering materials.  He prepared a private placement 

memorandum (“PPM”) and a subscription agreement for each of the Investment 

Funds.  He also drafted a PowerPoint presentation (“Slide Deck”) that touted the 

purported benefits of Slaga’s investment scheme. 

22. The PPMs and subscription agreements for all three Investment Funds 

contained almost identical language, stating that the objective of each Investment 

Fund was to: 

maximize total return on capital by seeking capital appreciation 

and, from time to time, current income, through the development 

and management of a portfolio of marketable securities, 

including currencies, equity instruments, debt instruments, 

futures contracts, option contracts and swap contracts.  

Each PPM identified the Managing Member of the respective Investment Fund to be 

Renko, Slaga’s alias.  The PPMs further indicated that Slaga would use his 

“proprietary computer based quantitative and statistical algorithms” to generate 

profits and limit risk for the investor funds. 

23. The Slide Deck supplemented the statements in the PPMs for the Q4 FX 

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Fund and the Q4 Macro Fund.  Slaga predicted a forthcoming “catastrophic” event in 

the global debt and equity markets and claimed that his trading strategy would profit 

from these events.  Slaga compared his approach to a famous book and movie that 

chronicled the 2008 Financial Crisis:  

Have you seen or read “the Big Short”?  The coming credit crisis 

will likely be even more significant, and the opportunity to play 

contrarian and profit immensely during the crisis are not well 

documented in the financial media. 

The Slide Deck also regurgitated the fabricated background of Slaga’s alias, Renko, 

noting that he was a “devout statistician” that “attended Dartmouth and went on to 

build a reputation as an experienced and successful trader at several well-known Wall 

Street institutions.” 

24. Slaga, or persons working at his direction, provided prospective 

investors in each of the Investment Funds with a PPM and the respective subscription 

agreement, typically by email.  In the course of the Q4 FX Fund and the Q4 Macro 

Fund offerings, these persons also provided the Slide Deck to some prospective 

investors. 

25. Slaga, and those working on his behalf, solicited investors through the 

internet (including LinkedIn) and email, among other means.  In particular, Slaga, 

and those working on his behalf, reached out through LinkedIn messages to 

prospective investors with whom they had no prior connections.  Investors in the 

Investment Funds had no prior relationship with Slaga.  Indeed, these investors were 

under the impression they were dealing with Renko, not Slaga.  Slaga also published 

the offering documents for the J4 Fund on J4 Capital’s website.  The general public 

could review the offering documents freely without the need for a password. 

26. In total, Slaga raised approximately $3.5 million from 17 investors 

residing in at least four states and Canada.   

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C. Misrepresentations by Slaga, J4 Capital, and Q4 Capital 

27. Slaga, J4 Capital, and Q4 Capital made several misrepresentations to 

prospective investors in the Investment Funds.   

1. Use of the Renko Alias 

28. Slaga misrepresented his true identity in the PPMs and the Slide Deck by 

identifying the manager of the Investment Funds as Renko.  In an effort to create 

credibility, Slaga claimed in his LinkedIn profile and in the Slide Deck to have 

graduated from Dartmouth College and to have been a successful trader at multiple 

Wall Street firms.  None of these representations were true.  Slaga never worked at 

any Wall Street firms and he briefly attended, and did not graduate from, the 

University of Houston.  By using his alias, Slaga also concealed his criminal record 

resulting from the 2002 Criminal Action. 

2. Slaga’s Fabricated Capital Contribution 

29. Slaga misrepresented in the PPMs that the managing members of each 

management company (i.e., J4 Capital and Q4 Capital) had made capital 

commitments of $2,000,000 to each Investment Fund, to be funded personally by 

Renko.  These representations were designed to mislead prospective investors into 

believing that Slaga’s interests were aligned with theirs because Slaga and his 

management companies had “skin in the game.”  But these representations were also 

untrue.  Neither Slaga nor Q4 Capital nor J4 Capital ever funded any such purported 

capital commitments. 

3. Existing Investment Capital 

30. Slaga represented in the J4 Fund PPM that the J4 Fund had already 

received $125 million in commitments from institutional and other investors.  This 

representation was intended to add legitimacy to the J4 Fund.  However, Slaga never 

obtained these commitments, and the J4 Fund was never funded—much less formed. 

Instead of funding the J4 Fund, as alleged below, Slaga misappropriated investor 

funds. 

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4. Association with Well-known Financial Entities and 

Gatekeepers 

31. Slaga made misrepresentations about well-known third parties that were 

purportedly involved with the Investment Funds.  These misrepresentations also had 

the effect of lending an air of legitimacy to Slaga and the Investment Funds.   

32. In this regard, Slaga represented to prospective investors in email 

communications that the Investment Funds were audited by a Big Four accounting 

firm, Deloitte & Touche LLP (“Deloitte”).  To further cement this lie, Slaga sent to 

certain investors a forged letter on the Deloitte’s letterhead stating that it had 

conducted a “review” of certain Investment Fund accounts.  The forged letter from 

the Deloitte also contained statements that created the impression that a certain well-

known financial institution, Goldman Sachs & Co, LLC (“Goldman”), was the prime 

broker for the Q4 Macro Fund.  Further, Slaga sent investors forged account 

statements purporting to show the Investment Funds maintaining assets and securities 

at another well-known financial institution, J.P. Morgan Securities, LLC (“JP 

Morgan”)   

33. In truth, Deloitte, Goldman, and JP Morgan had no relationship and did 

not perform any services for Slaga, Q4 Capital, J4 Capital, or the Investment Funds.  

Rather, Slaga used a portion of investor funds to trade securities for his own benefit 

in his personal online brokerage account. 

5. Fabricated Investment Performance 

34. Slaga misrepresented the performance of the Investment Funds.  The 

forged account statements, as well as the forged letter from Deloitte, showed 

Investment Fund account balances that far exceeded net asset values that could be 

imputed to the Investment Funds.   

35. Slaga also provided investors with periodic status reports (“Investor 

Updates”) that communicated the fabricated performance of the Investment Funds.  

For example, in at least one update that Slaga emailed to investors in or around 2020, 

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he represented the performance of the Investment Funds for the first quarter of 2020 

as being between 68% and 100%.  However, Slaga did not trade on behalf of the 

Investment Funds.   

D. Misuse of Investor Funds by Slaga, J4 Capital, and Q4 Capital. 

36. The PPMs for the Investment Funds represented that the Investment 

Funds’ assets would be used to “invest and trade in a broad range of marketable 

securities . . . .”  The PPMs further provided that the managing member (J4 Capital or 

Q4 Capital, as applicable) would be allocated 25 percent of the Investment Funds’ 

gains, that the managing member would bear its own organizational and offering 

expenses, and that the Investment Funds would bear certain administrative expenses.  

The PPMs did not provide for the managing member to be compensated in any other 

way.   

37. Slaga, individually and on behalf of J4 Capital and Q4 Capital, misused 

investor funds.  Initially, he commingled all investor funds in bank accounts in the 

name of JMC 4, LLC (an entity that Slaga controlled) and Q4 Capital.  Slaga 

transferred investor funds into various accounts, including his personal bank accounts 

and his personal brokerage account.  Of the approximately $3.5 million of investor 

funds that Slaga raised, he used $2,893,934.32 on personal expenses, which included, 

among other things, travel, restaurants, jewelry, and rent for properties in Florida, the 

Bahamas, and Barbados.  He also used a portion of that money to fund an online 

trading account in his own name and for his own benefit.  Slaga ultimately realized a 

loss of more than $450,000 through his trading activity. 

38. Slaga’s scheme ended in or around 2022 as Slaga was unable to lure new 

investors and as existing investors became aware of the Commission’s investigation 

that preceded the filing of this action. 

E. Greene’s Role 

39. Slaga employed Greene from 2019 through 2022.  Posing as Renko, 

Slaga recruited Greene on LinkedIn, leading Greene to believe that he was being 

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hired to help Renko solicit investors, and, as he learned the business, assist him in 

executing trading strategies on behalf of the Investment Funds.  Greene had previous 

experience in the financial services industry. 

40. Greene’s titles during his employment with Q4 Capital were “Operator 

of Newport Beach Trading Desk” and later “VP of Trading.”  However, Greene never 

made any trades or reviewed any brokerage statements for the Investment Funds. 

Instead, Greene provided trading ideas to Slaga, who assigned Greene trading 

research tasks.  At all times, Greene believed he was dealing with Renko and had 

never heard of Slaga.  Based on his interactions with Slaga, Greene believed that 

investor funds were being used to trade as disclosed in the offering documents, and 

that Renko was doing so profitably. 

41. From 2019 to 2021, Greene solicited at least eight investors who 

invested a total of approximately $1.4 million in the Investment Funds.  In soliciting 

investors, Greene advised some of them on the merits of investing in the Investment 

Funds and provided to investors his own account statements of units he believed he 

held in the Investment Funds for the purpose of showing the net asset value and 

performance of the Investment Funds.  Over the course of Greene’s employment, 

Slaga paid Greene approximately $85,000 in transaction-based compensation.   

42. Greene’s involvement with Q4 Capital ended in 2022.   

F. The Investments Offered and Sold by Defendants Were Securities 

43. Based on Slaga’s, Q4 Capital’s, and J4 Capital’s misrepresentations, 

investors invested money into one or more Investment Funds controlled by Slaga in 

order to receive returns in the form of profits purportedly generated from Slaga’s 

securities trading. 

44. Slaga pooled the investor funds—which investors believed would be 

used solely for the investment—together in two bank accounts.  The investor funds 

were managed entirely by Slaga.  

45. Whether investors would profit from their investments was entirely 

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dependent on Slaga and the performance of his purported securities trading strategy.  

Indeed, both investors on one hand, and Slaga, Q4 Capital, and J4 Capital on the 

other, would profit if Slaga’s purported securities trading strategy was successful; in 

this way, their fortunes were linked. 

 

FIRST CLAIM FOR RELIEF 

Fraud in the Offer or Sale of Securities 

Violations of Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]  

(Against Slaga, Q4 Capital, and J4 Capital) 

46. Plaintiff re-alleges and incorporates paragraphs 1 through __ of this 

Complaint by reference as if set forth verbatim in this Claim. 

47. Among other things, Slaga, Q4 Capital, and J4 Capital made various 

misrepresentations and omissions to investors in the PPMs, Slide Deck, and Investor 

Updates.   Slaga, Q4 Capital, and J4 Capital misrepresented Slaga’s true identity 

through the use of the Renko alias.  They also falsely claimed that Renko, on behalf 

of Q4 Capital and J4 Capital, made $2,000,000 in capital contributions to the 

respective Investment Funds, and that, in the case of the J4 Fund, that fund had 

already closed on $125 million of commitments from institutional and other 

investors.  Slaga, Q4 Capital, and J4 Capital also misrepresented to investors that the 

Deloitte, Goldman, and JP Morgan had relationships with and provided services for 

Slaga, Q4 Capital, J4 Capital, and the Investment Funds.  Slaga, Q4 Capital, and J4 

Capital also provided to investors forged account statements, as well as the forged 

letter from Deloitte, falsely showing grossly inflated account balances for the 

Investment Funds.  Finally, Slaga misused nearly $2.9 million of investor funds for 

personal uses including, among other things, travel, restaurants, jewelry, and rent for 

properties in Florida, the Bahamas, and Barbados. 

48. By engaging in the acts and conduct alleged herein, Slaga, Q4 Capital, 

and J4 Capital, directly or indirectly, in the offer or sale of a security, by the use of 

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any means or instruments of transportation or communication in interstate commerce 

or by use of the mails, have: 

a. knowingly or recklessly employed a device, scheme, or artifice to 

defraud; and/or 

b. knowingly, recklessly, or negligently obtained money or property 

by means of an untrue statement of a material fact or an omission 

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. knowingly, recklessly, or negligently engaged in a transaction, 

practice, or course of business which operated or would operate as 

a fraud or deceit upon the purchaser. 

49. By reason of the foregoing, Slaga, Q4 Capital, and J4 Capital have 

violated, and unless enjoined will continue to violate, Section 17(a) of the Securities 

Act [15 U.S.C. § 77q(a)]. 

 

SECOND CLAIM FOR RELIEF 

Fraud in Connection with the Purchase or Sale of Securities  

Violations of 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] 

(Against Slaga, Q4 Capital, and J4 Capital) 

50. Plaintiff re-alleges and incorporates paragraphs 1 through __ of this 

Complaint by reference as if set forth verbatim in this Claim. 

51. Among other things, Slaga, Q4 Capital, and J4 Capital made various 

misrepresentations and omissions to investors in the PPMs, Slide Deck, and Investor 

Updates.  Slaga, Q4 Capital, and J4 Capital misrepresented Slaga’s true identity 

through the use of the Renko alias.  They also falsely claimed that Renko, on behalf 

of Q4 Capital and J4 Capital, made $2,000,000 in capital contributions to the 

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respective Investment Funds, and that, in the case of the J4 Fund, that fund had 

already closed on $125 million of commitments from institutional and other 

investors.  Slaga, Q4 Capital, and J4 Capital also misrepresented to investors that the 

Deloitte, Goldman, and JP Morgan had relationships with and provided services for 

the Slaga, Q4 Capital, J4 Capital, and the Investment Funds.  Slaga, Q4 Capital, and 

J4 Capital also provided to investors forged account statements, as well as the forged 

letter from Deloitte, falsely showing grossly inflated account balances for the 

Investment Funds.  Finally, Slaga misused nearly $2.9 million of investor funds for 

personal uses including, among other things, travel, restaurants, jewelry, and rent for 

properties in Florida, the Bahamas, and Barbados. 

52. By engaging in the acts and conduct alleged herein, Slaga, Q4 Capital, 

and J4 Capital, directly or indirectly, in connection with the purchase or sale of 

securities, by the use of any means or instrumentality of interstate commerce, or of 

the mails, or of any facility of any national securities exchange, knowingly or 

recklessly: 

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

(b) made untrue statements of material facts, or omitted to state 

material facts 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. 

53. By reason of the foregoing, Slaga, Q4 Capital, and J4 Capital violated, 

and unless enjoined will continue to violate, 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]. 

 

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THIRD CLAIM FOR RELIEF 

Unregistered Offer and Sale of Securities 

Violations of Sections 5(a) and (c) of the Securities Act  

[15 U.S.C. §§ 77e(a) & (c)] 

(Against Slaga, Q4 Capital, and J4 Capital) 

54. Plaintiff re-alleges and incorporates paragraphs 1 through __ of this 

Complaint by reference as if set forth verbatim in this Claim. 

55. Between December 2017 and June 2019, Slaga, Q4 Capital, and J4 

Capital collectively raised approximately $3.5 million by offering and selling 

interests in the Investment Funds to persons throughout the United States.  However, 

Defendants never registered these securities offerings the offer and sale of these 

interests with the Commission, and no exemption from registration applied.   

56. By engaging in the conduct described herein, Slaga, Q4 Capital, and J4 

Capital, directly or indirectly: 

a. made use of the means or instruments of transportation or 

communication in interstate commerce or of the mails to sell, 

through the use or medium of any prospectus or otherwise, 

securities as to which no registration statement was in effect;  

b. for the purpose of sale or delivery after sale, carried or caused to 

be carried through the mails or interstate commerce, by means or 

instruments of transportation, securities as to which no registration 

statement was in effect; and/or 

c. made use of means or instruments of transportation or 

communication in interstate commerce or of the mails to offer to 

sell, through the use or medium of any prospectus or otherwise, 

securities as to which no registration statement had been filed. 

57. By reason of the foregoing, Slaga, Q4 Capital, and J4 Capital have 

violated, and unless enjoined will continue to violate, Sections 5(a) and 5(c) of the 

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Securities Act [15 U.S.C. §§ 77e(a) and (c)]. 

 

FOURTH CLAIM FOR RELIEF 

Offer and Sale of Securities by an Unregistered Broker 

Violations of Section 15(a) of the Exchange Act [15 U.S.C § 78o(a)] 

(Against Greene) 

58. Plaintiff re-alleges and incorporates paragraphs 1 through 4__ of this 

Complaint by reference as if set forth verbatim in this Claim. 

59. Between 2019 and 2022, Greene solicited investors to purchase interests 

in the Investment Funds.  In return for successfully soliciting investors, Greene was 

paid sales commissions.  He also gave investment advice and provided to investors 

his own account statements as a way of conveying information about the net asset 

value and performance of the Investment Funds.   

60. During the relevant period, Greene was not registered with, or an 

associated person of, a firm registered with the SEC. 

61. By engaging in the conduct described above, Greene acted as a broker 

within the meaning of Section 3(a)(4) of the Exchange Act [15 U.S.C. § 78c(4)], and 

made use of the mails or the means or instrumentality of interstate commerce to effect 

transactions in, or to induce or attempt to induce the purchase or sale of, a security 

without being registered in accordance with Section 15(b) of the Exchange Act. 

62. By engaging in the conduct described above, Greene violated, and unless 

enjoined will continue to violate, Section 15(a) of the Exchange Act [15 U.S.C. § 

78o(a)]. 

 

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that the Court enter a 

judgment: 

a. Making findings of fact and conclusions of law that Defendants 

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committed the alleged violations; 

b. Permanently enjoining Slaga, Q4 Capital, and J4 Capital from violating 

Sections 5(a), 5(c), and 17(a) of the Securities Act [15 U.S.C. §§ 77e(a), 

77e(c), 77q(a)] and 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]; 

c. Permanently enjoining Greene from violating Section 15(a) of the 

Exchange Act [15 U.S.C. § 78o(a)]; 

d. Permanently enjoining Slaga, from directly or indirectly, including, but 

not limited to, through any entity owned or controlled by him, 

participating in the issuance, purchase, offer, or sale of any security; 

provided, however, that such injunction shall not prevent him from 

purchasing or selling securities for his own personal account; 

e. Permanently enjoining Q4 Capital and J4 Capital, from directly or 

indirectly, including, but not limited to, through any entity owned or 

controlled by either of them, participating in the issuance, purchase, 

offer, or sale of any security; 

f. Barring Slaga, pursuant to Section 20(e) of the Securities Act [15 U.S.C. 

§ 77t(e)] and Sections 2l(d)(2) of the Exchange Act [15 U.S.C. § 

78u(d)(2)], from acting as an officer or director of any issuer that has a 

class of securities registered pursuant to Section 12 of the Exchange Act 

[15 U.S.C. § 78l] or that is required to file reports pursuant to Section 

15(d) of the Exchange Act [15 U.S.C. § 78o(d)]; 

g. Ordering Slaga, Q4 Capital, and J4 Capital to disgorge, jointly and 

severally, all ill-gotten gains they received as a result of the conduct 

alleged herein, together with pre-judgment interest, pursuant to the 

Court’s equitable powers and Sections 21(d)(3), 21(d)(5), and 21(d)(7) 

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

h. Ordering Greene to disgorge all ill-gotten gains he received as a result of 

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the conduct alleged herein, together with pre-judgment interest, pursuant 

to the Court’s equitable powers and Sections 21(d)(3), 21(d)(5), and 

21(d)(7) of the Exchange Act [15 U.S.C. §§ 78u(d)(3), 78u(d)(5), and 

78u(d)(7)]; 

i. Ordering Slaga, Q4 Capital, and J4 Capital to pay civil penalties under 

Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 

21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)]; 

j. Retaining jurisdiction of this action in accordance with the principles of 

equity and the Federal Rules of Civil Procedure in order to implement 

and carry out the terms of all orders and decrees that may be entered, or 

to entertain any suitable application or motion for additional relief within 

the jurisdiction of this Court; and 

k. Granting such other and further relief as this Court may determine to be 

just and necessary. 

 

Dated:  August 7, 2023   /s/ Jason P. Reinsch   
Jason P. Reinsch 
Attorney for Plaintiff 
Securities and Exchange Commission 

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