SEC v. Spartan Trading Company, LLC; Estate of Richard Myre; Estate of Dale Dahmen; and Estate of Dominick Dahmen, No. 0:23-cv-01997, District of Minnesota (July 5, 2023) — Complaint

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
                                                                               _
       )
U.S. SECURITIES AND EXCHANGE   )
COMMISSION,     )
       )
    Plaintiff,   ) Civil Action No.
       )
   v.    ) 23-CV-
       )
SPARTAN TRADING COMPANY, LLC, )
THE ESTATE OF RICHARD MYRE,  )
       )
    Defendants,   )
       )
   and        )
       )
THE ESTATE OF DALE DAHMEN, AND    )
THE ESTATE OF DOMINICK DAHMEN,   )
        )
    Relief Defendants.   )
                                                                      )

COMPLAINT

 Plaintiff U.S. Securities and Exchange Commission (“SEC”)    alleges as follows:
1. The SEC brings this action to enforce the Federal securities laws and, through
equitable relief, to recover funds invested by the victims of a fraudulent day-trading
scheme.
2. In 2019, Richard Myre, Dale Dahmen, and Dominick Dahmen founded
Spartan Trading Company,  LLC (“Spartan Trading” or the “Fund”). Spartan Trading
operated as an unregistered investment fund in which the Fund’s three promoters pooled
money from investors, purportedly for day trading activities in stocks. The Dahmens told

2

investors that Myre would be responsible for the trading, which would purportedly generate
profits for investors. Myre controlled the bank account into which investors deposited their
funds and Myre signed all checks written on the account.
3. From 2019 to 2023, Spartan Trading raised over $3.7 million from dozens
of investors in small communities such as Pierz and Belle Plaine, Minnesota and other
communities surrounding the Twin Cities. Investors included Myre’s and the Dahmens’
prior business contacts and friends.
4. The Fund was a sham that defrauded investors in multiple ways. For instance,
Spartan Trading, Myre, and the Dahmens raised money on the premise of pooled investing
but then failed to make the promised investments in stocks. Instead, for long periods, funds
sat idle in Spartan Trading accounts and were slowly eaten away as Myre withdrew money
for himself, the Dahmens, and investors in an attempt to keep the scheme going.
5. Spartan Trading, in statements sent to investors by Myre and bearing his
contact information, also provided investors with falsified accounting documents. These
statements falsely represented to investors that the Fund was earning consistently positive
returns. In actuality, the Fund engaged in very little investment activity at all and often lost
money on the trades it did make.
6. Myre, acting through Spartan Trading, misled investors to secure their initial
investments and then lied to retain them. In some cases, investors put additional money into
Spartan after receiving phony statements.

3

7. The Fund’s written agreements with investors permitted Spartan Trading to
receive, at most, half of all profits generated by Fund’s investments. But the Fund engaged
in very little investment activity and accordingly generated few profits.
8.  Nevertheless, Myre and the Dahmens regularly withdrew money from the
Fund. Overall, during the life of the Fund, Myre and the Dahmens received over $1.9
million of investor money. Of that, Myre received over $1.1 million, while Dale Dahmen
received approximately $649,000 and Dominick received $173,113.
9. On February 1, 2023, Myre and the Dahmens were found dead in what police
reported as a murder suicide.
10. The aftermath of the deaths has caused significant upheaval for investors.
This lawsuit seeks to freeze what remains in Spartan Trading’s accounts and to conduct
expedited discovery to determine where the investor funds went and what can be recovered
for defrauded investors.
JURISDICTION AND VENUE
11. The SEC brings this action under the Securities Act of 1933 (“Securities
Act”) Section 20(b) [15 U.S.C. §77t(b)], the Securities Exchange Act of 1934 (“Exchange
Act”) Sections 21(d) and (e) [15 U.S.C. §§78u(d) and 78u(e)] and the Investment
Advisers Act of 1940 (“Advisers Act”) Section 209 [15 U.S.C. §§ 80b-9].
12. This Court has jurisdiction over this action pursuant to Section 22 of the
Securities Act [15 U.S.C. § 77v], Section 27 of the Exchange Act [15 U.S.C. § 78aa], and

4

Sections 209(d), 209(e)(1), and 214 of the Advisers Act [15 U.S.C. §§ 80b-9(d), 80b-
9(e)(1), and 80b-14].
13. Venue is proper in this Court pursuant to Section 27 of the Exchange Act
[15 U.S.C. § 78aa] and Section 214 of the Advisers Act [15 U.S.C. § 80b-14] because
certain acts or transactions constituting the violations of the federal securities laws
detailed herein occurred in this district and because, at all relevant times, Spartan
Trading’s principal place of business was in Belle Plaine, Minnesota.
14. Defendants operated the fund from a home office at Richard Myre’s
residence in Belle Plaine. Defendants also offered and sold the securities described herein
to investors in the District of Minnesota.
15. Defendants directly and indirectly made use of the means and
instrumentalities of interstate commerce and of the mails in connection with the acts,
practices, and courses of business alleged herein.
DEFENDANTS
16. Spartan Trading Company, LLC, (“Spartan Trading” or “the Fund”) acted
as an unregistered investment fund operated by Richard Myre. Spartan Trading was
incorporated in Nevada in 2019 with its principal place of business in Richard Myre’s home
in Belle Plaine, Minnesota.
17. The Estate of Richard Myre is the successor in interest to Richard Myre,
who is deceased. As of this date, the executor of the Myre Estate is unknown. Richard Myre

5

was a resident of Belle Plaine, Minnesota. He was 44 years old at the time of death in
February 2023.
RELIEF DEFENDANTS
18. The Estate of Dale Dahmen is the successor in interest to Dale Dahmen who
is deceased. As of this date, the executor of the Dale Dahmen Estate is unknown. Dale
Dahmen was a resident of Buffalo, Minnesota. He was 55 years old at the time of death in
February 2023.
19. The Estate of Dominick Dahmen is the successor in interest to Dominick
Dahmen, who is deceased. As of this date, the executor of the Dominick Dahmen Estate is
unknown. Dominick Dahmen was a Buffalo, Minnesota native although he also spent
significant time in North Carolina where he worked as a musician. He was 25 years old at
the time of death in February 2023.
FACTS
20. In 2019, Myre and the Dahmens founded Spartan Trading Company, LLC.
Spartan Trading operated as an unregistered investment fund in which the Fund’s three
promoters pooled money from investors, purportedly for day trading of stocks.
21. Myre’s name was the only one listed on Spartan Trading’s incorporation
documents filed with the State of Nevada. Dale and Dominick Dahmen told Investors that
Myre would be responsible for the trading, which would generate profits for investors.
Myre controlled the bank account into which investors deposited their funds, and Myre
signed all known checks drawn on the account.

6

22. Beginning by at least 2020, Spartan Trading, Myre, and the Dahmens raised
over $3.7 million from dozens of investors. Investors included prior business contacts and
friends of Myre and the Dahmens. Investors made both cash investments, often in the tens
of thousands of dollars, and investments of retirement savings through an IRA custodian
firm, that sometimes totaled over $100,000.
23. Myre and the Dahmens, acting for Spartan Trading, required that the
investors in the Fund sign, a “Profit Participation Agreement.” The two-page Agreements
set out the principal amount and commencement date of the investor’s investment in the
Fund and provided a mechanism for sharing investment profits.
24. The Agreement guaranteed investors the first 2.5% of any profits generated
each month. Spartan Trading was entitled to the next 2.5% of profits, and any profits above
5% were to be split evenly between the investor and Spartan Trading. Investors were given
the option to leave profits in their investment accounts or to withdraw them monthly.
25. Myre provided investors with statements for their Spartan Trading accounts.
These statements summarized, as of the first of each month, the investment amount,
balance, previous month’s profit, and withdrawal amount per month for the investor’s
account.
26. For example, Myre reported to one investor that he had made at least 2.9% on
his investment each month, with consistently positive monthly returns.  Myre, acting on
behalf of Spartan Trading, reported similar returns to other investors.

7

27. Myre provided the investors with return information that was simply false. In
actuality, as explained below, Myre put some investor money in a Bank of America account
and transferred some to brokerage accounts, principally a TD Ameritrade account.
28. The activity in the TD Ameritrade account does not support the kind of
consistent monthly returns reported to investors. In fact, the TD Ameritrade account held
only cash until May of 2021 (meaning that it had no investment activity of any kind prior to
that time). At that point, Myre allocated a little over $100,000 to stock investments.
Myreinvested slightly more money in stocks over the next several months, peaking at about
$187,000 as of August 31, 2021. By contrast, as of that same date, the Fund’s TD
Ameritrade account had over $1 million simply sitting in cash.
29. In sum, Spartan Trading made profits of $80,697.69 from May to August of
2021. At most, under the Profit Participation Agreements, Myre, and the Dahmens would
have been entitled to half of those profits, or $40,348.98 (in actuality, because investors are
entitled to the first 2.5% of profits each month, Myre’s and the Dahmens’ entitlement is
likely even lower). For the rest of 2021, the Fund sustained losses on its investments,
meaning Myre and the Dahmens were entitled to nothing.
30. Bank and brokerage records indicate similar results in 2022. For example, the
total profits in the TD Ameritrade account for February and March 2022 (the only profitable
months in 2022 for the Fund’s TD Ameritrade investments were $571.73, meaning the
maximum entitlement of the Fund’s promoters was $285.87.

8

31. Disregarding the terms of the Profit Participation Agreement, Myre and the
Dahmens received much more out of the Fund than they were entitled to. During the entire
time of the fraud, Myre and the Dahmens withdrew approximately $1.9 million from the
Spartan Trading Bank of America account.
32. During 2021, Myre took $548,262.50 of investor funds from the account,
while Dale Dahmen received $183,055 and Dominick Dahmen received $81,561.59,
meaning that in total the three took $812,879.09 out of the account in 2021. Based on their
entitlement to half of overall profits, Spartan Trading would have needed to generate over
$1.6 million in profits in 2021 in order for those payments to be justified under the Profit
Participation Agreements. The Fund’s TD Ameritrade account actually generated only
$80,697.96 in profits in 2021 and sustained losses that far exceeded that amount.
33. The pattern for 2022 is similar. Myre continued to improperly take money
out of the Bank of America account. Myre took $345,000 of investor funds, while Dale
Dahmen received $275,192.15 and Dominick Dahmen received $81,751.51. Therefore,
the three misappropriated $701,943.66 of investors’ money in 2022. Again, far from the
$1.4 million in profits that would have been needed to justify those payments, during this
period, the Fund’s TD Ameritrade account shows a total of only $571.73 in investment
profits.
34. Overall, during the life of the Fund, Myre and the Dahmens took over $1.9
million of investor money from the Fund’s accounts for themselves. Of that, Myre took over

9

$1.1 million, while Dale Dahmen took approximately $649,000 and Dominick Dahmen
took $173,113.
35. The scheme continued in this vein until the fraud began to unravel in late
2022.
36. Beginning around that time, Myre and the Dahmens met concerning the
fund’s trading activity and organizational structure
37. On February 1, 2023, the three men met in a pick-up truck in the parking lot
of a restaurant in Bloomington, Minnesota. All three were later found dead of apparent
gunshot wounds inside the truck.
38. After news of the deaths became public, investors began to approach
Bloomington police and the SEC inquiring as to the status of the money they had invested
in Spartan Trading.
39. The aftermath has caused significant upheaval for investors. At least one
couple who had invested over $100,000 with Spartan Trading had to sell their home and
move out of state to be closer to family. Other investors have lost retirement savings and
inheritances.  Some face the prospect of paying off loans that they took out in order to
invest with Spartan Trading.
40. A review of available records for Spartan Trading-associated accounts shows
less than $6,000 remaining in the Bank of America account and approximately $400 in the
TD Ameritrade account.

10

41. The SEC now brings this action to freeze what funds remain in Spartan
Trading’s accounts, freeze any funds in the Fund promoters’ estates, and attempt to trace
the hundreds of thousands of dollars of investor funds taken out of the Fund with the goal
of returning funds to defrauded investors.
COUNT I

Violations of Section 10(b) of the Exchange Act and Exchange Act Rule 10b-5
(Against Spartan Trading and Myre Estate)
42. Paragraphs 1 through 41 are realleged and incorporated herein by reference.
43. Spartan Trading and Myre, in connection with the purchase and sale of
securities, by the use of the means and instrumentalities of interstate commerce and by the
use of the mails, directly and indirectly: used and employed devices, schemes and artifices
to defraud; made untrue statements of material fact and 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 engaged in acts, practices and courses of business
which operated or would have operated as a fraud and deceit upon purchasers and
prospective purchasers of securities.
44. Each acted with scienter in that they knowingly or recklessly made the
material misrepresentations and omissions and engaged in the fraudulent scheme
identified above.
45. By reason of the foregoing, Spartan Trading and Myre violated 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].

11

COUNT II

Violations of Section 17(a) of the Securities Act
(Against Spartan Trading and Myre Estate)
46. Paragraphs 1 through 41 are realleged and incorporated by reference as
though fully set forth herein.
47. Spartan Trading and Myre, in the offer and sale of securities, by the use of
the means and instruments of interstate commerce, directly or indirectly:
a. engaged in fraudulent devices, schemes, artifices, transactions, acts,
practices and courses of business;
b. obtained money or property by means of untrue statements of
material fact or by omitting 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
c. engaged in transactions, practices, or courses of business that
operated or would operate as a fraud or deceit upon the purchasers of
such securities.
48. Spartan Trading and Myre acted intentionally, with severe recklessness, and
at least negligently in the fraudulent conduct described above.
49. By reason of the foregoing, Spartan Trading and Myre violated Section
17(a) of the Securities Act [15 U.S.C. § 77q(a)].
COUNT III

Violations of Sections 206(1) and 206(2) of the Advisers Act
(Against Myre Estate)
50. Paragraphs 1 through 41 above are realleged and incorporated herein by
reference.

12

51. During the relevant time period, Myre acted as an investment adviser to
Spartan Trading within the meaning of Section 202(a)(11) of the Advisers Act [15 U.S.C.
§ 80b-2(a)(11)].
52. Myre, by use of the mails and the means and instrumentalities of interstate
commerce, directly or indirectly, while acting as an investment adviser, knowingly,
willfully, or recklessly: (a) employed devices, schemes, or artifices to defraud clients or
prospective clients; and (b) engaged in transactions, practices, and courses of business
that operated as a fraud or deceit upon clients or prospective clients.
53. By engaging in the conduct described above, Myre, directly or indirectly,
violated Sections 206(1) and (2) of the Advisers Act [15 U.S.C. § 80b-6(1) and 80b-6(2)].
COUNT IV

Violations of Section 206(4) of the Advisers Act and Rule 206(4)-8 Thereunder
(Against Myre Estate)
54. Paragraphs 1 through 41 above are realleged and incorporated herein by
reference.
55. By his conduct, Myre, while acting as an investment adviser to a pooled
investment vehicle, has made untrue statements of material fact or omitted to state a
material fact necessary to make, in light of the circumstances, the statements made not
misleading to an investor or prospective investor or has otherwise engaged in acts,
practices, or courses of business that were fraudulent, deceptive, or manipulative with
respect to an investor or prospective investor in the pooled investment vehicle.

13

56. By reason of the foregoing, Myre has violated Section 206(4) of the
Advisers Act [15 U.S.C. § 80b-6(4)] and Rule 206(4)-8 thereunder [17 C.F.R. §
275.206(4)-8].
COUNT V

Unjust Enrichment
(Against All Relief Defendants)
57. Paragraphs 1 through 41 above are realleged and incorporated herein by
reference.
58. Dale Dahmen and Dominick Dahmen obtained money, property, or assets to
which they have no legitimate claim because of the violations of the securities laws by
Myre and Spartan Trading.
59. Each of the Relief Defendants should be required to disgorge all ill-gotten
gains that inured to their benefit under the equitable doctrines of disgorgement, unjust
enrichment, and constructive trust.
RELIEF REQUESTED
 WHEREFORE, the SEC respectfully requests that this Court:
I.
 Issue findings of fact and conclusions of law that Spartan Trading and Myre
committed the violations charged and alleged herein.
II.
 Enter an Order of Permanent Injunction restraining and enjoining Defendant
Spartan Trading, its officers, agents, servants, employees, attorneys, and those persons in

14

active concert or participation with it who receive actual notice of the Order, by personal
service or otherwise, and each of them from, directly or indirectly, engaging in the
transactions, acts, practices or courses of business described above, or in conduct of
similar purport and object, in violation of Section 17(a) of the Securities Act of 1933
(“Securities Act”) [15 U.S.C. § 77q(a)] and Section 10(b) of the Securities Exchange Act
of 1934 (“Exchange Act”) [15 U.S.C. § 78j(b)], and Rule 10b-5 [17 C.F.R. §§ 240.10b-5]
thereunder, and Sections 206(1) [15 U.S.C. § 80b-6(1)], 206(2) of the Investment
Advisers Act of 1940 (“Advisers Act”) [15 U.S.C. § 80b-6(2)], 206(4) [15 U.S.C. § 80b-
6(4)] and Rule 206(4)-8 thereunder [17 C.F.R. § 275.206(4)-8].
III.
Issue an Order requiring Defendants and Relief Defendants to disgorge the ill-
gotten gains received as a result of the violations alleged in this Complaint pursuant to
Sections 21(d)(3), 21(d)(5), and 21(d)(7) of the Exchange Act [15 U.S.C. §§ 78u(d)(3),
(5) and (7)], including prejudgment interest.
IV.
 Retain jurisdiction of this action in accordance with the principals 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.
V.
 Grant such other relief as this Court deems appropriate.

15

Respectfully Submitted,

Dated: June 29, 2023     ____________________________
Charles J. Kerstetter
([email protected])
Lee Farnsworth
([email protected])
*pro hac vice pending
175 West Jackson Blvd., Suite 1450
Chicago, IL 60604
Phone:  (312) 353-7390
Facsimile: (312) 353-7398
Attorneys for Plaintiff
U.S. Securities and Exchange
Commission

Craig Baune
MN Bar No. 331727
Assistant United States Attorney
District of Minnesota
600 U.S. Courthouse
300 South Fourth Street
Minneapolis, MN 55414
Telephone: (612) 664-5600
Email: [email protected]

Local Counsel

UNITED STATES DISTRICT COURT                                   
DISTRICT OF MINNESOTA 

                                                                               _ 
       ) 
U.S. SECURITIES AND EXCHANGE   ) 
COMMISSION,     ) 
       )  
    Plaintiff,   ) Civil Action No. 
       )  
   v.    ) 23-CV- 
       )   
SPARTAN TRADING COMPANY, LLC, ) 
THE ESTATE OF RICHARD MYRE,  ) 
       ) 
    Defendants,  ) 
       ) 
   and    ) 
       ) 
THE ESTATE OF DALE DAHMEN, AND ) 
THE ESTATE OF DOMINICK DAHMEN, )  
        ) 
    Relief Defendants. )  
                                                                    ) 

 
COMPLAINT 

 
 Plaintiff U.S. Securities and Exchange Commission (“SEC”) alleges as follows:  

1. The SEC brings this action to enforce the Federal securities laws and, through 

equitable relief, to recover funds invested by the victims of a fraudulent day-trading 

scheme. 

2. In 2019, Richard Myre, Dale Dahmen, and Dominick Dahmen founded 

Spartan Trading Company, LLC (“Spartan Trading” or the “Fund”). Spartan Trading 

operated as an unregistered investment fund in which the Fund’s three promoters pooled 

money from investors, purportedly for day trading activities in stocks. The Dahmens told 

CASE 0:23-cv-01997   Doc. 1   Filed 06/29/23   Page 1 of 15



2 
 

investors that Myre would be responsible for the trading, which would purportedly generate 

profits for investors. Myre controlled the bank account into which investors deposited their 

funds and Myre signed all checks written on the account. 

3. From 2019 to 2023, Spartan Trading raised over $3.7 million from dozens 

of investors in small communities such as Pierz and Belle Plaine, Minnesota and other 

communities surrounding the Twin Cities. Investors included Myre’s and the Dahmens’ 

prior business contacts and friends. 

4. The Fund was a sham that defrauded investors in multiple ways. For instance, 

Spartan Trading, Myre, and the Dahmens raised money on the premise of pooled investing 

but then failed to make the promised investments in stocks. Instead, for long periods, funds 

sat idle in Spartan Trading accounts and were slowly eaten away as Myre withdrew money 

for himself, the Dahmens, and investors in an attempt to keep the scheme going.  

5. Spartan Trading, in statements sent to investors by Myre and bearing his 

contact information, also provided investors with falsified accounting documents. These 

statements falsely represented to investors that the Fund was earning consistently positive 

returns. In actuality, the Fund engaged in very little investment activity at all and often lost 

money on the trades it did make. 

6. Myre, acting through Spartan Trading, misled investors to secure their initial 

investments and then lied to retain them. In some cases, investors put additional money into 

Spartan after receiving phony statements.  

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7. The Fund’s written agreements with investors permitted Spartan Trading to 

receive, at most, half of all profits generated by Fund’s investments. But the Fund engaged 

in very little investment activity and accordingly generated few profits. 

8.  Nevertheless, Myre and the Dahmens regularly withdrew money from the 

Fund. Overall, during the life of the Fund, Myre and the Dahmens received over $1.9 

million of investor money. Of that, Myre received over $1.1 million, while Dale Dahmen 

received approximately $649,000 and Dominick received $173,113.  

9. On February 1, 2023, Myre and the Dahmens were found dead in what police 

reported as a murder suicide.  

10. The aftermath of the deaths has caused significant upheaval for investors. 

This lawsuit seeks to freeze what remains in Spartan Trading’s accounts and to conduct 

expedited discovery to determine where the investor funds went and what can be recovered 

for defrauded investors.    

JURISDICTION AND VENUE 

11. The SEC brings this action under the Securities Act of 1933 (“Securities 

Act”) Section 20(b) [15 U.S.C. §77t(b)], the Securities Exchange Act of 1934 (“Exchange 

Act”) Sections 21(d) and (e) [15 U.S.C. §§78u(d) and 78u(e)] and the Investment 

Advisers Act of 1940 (“Advisers Act”) Section 209 [15 U.S.C. §§ 80b-9]. 

12. This Court has jurisdiction over this action pursuant to Section 22 of the 

Securities Act [15 U.S.C. § 77v], Section 27 of the Exchange Act [15 U.S.C. § 78aa], and 

CASE 0:23-cv-01997   Doc. 1   Filed 06/29/23   Page 3 of 15



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Sections 209(d), 209(e)(1), and 214 of the Advisers Act [15 U.S.C. §§ 80b-9(d), 80b-

9(e)(1), and 80b-14]. 

13. Venue is proper in this Court pursuant to Section 27 of the Exchange Act 

[15 U.S.C. § 78aa] and Section 214 of the Advisers Act [15 U.S.C. § 80b-14] because 

certain acts or transactions constituting the violations of the federal securities laws 

detailed herein occurred in this district and because, at all relevant times, Spartan 

Trading’s principal place of business was in Belle Plaine, Minnesota. 

14. Defendants operated the fund from a home office at Richard Myre’s 

residence in Belle Plaine. Defendants also offered and sold the securities described herein 

to investors in the District of Minnesota. 

15. Defendants directly and indirectly made use of the means and 

instrumentalities of interstate commerce and of the mails in connection with the acts, 

practices, and courses of business alleged herein. 

DEFENDANTS 

16. Spartan Trading Company, LLC, (“Spartan Trading” or “the Fund”) acted 

as an unregistered investment fund operated by Richard Myre. Spartan Trading was 

incorporated in Nevada in 2019 with its principal place of business in Richard Myre’s home 

in Belle Plaine, Minnesota. 

17. The Estate of Richard Myre is the successor in interest to Richard Myre, 

who is deceased. As of this date, the executor of the Myre Estate is unknown. Richard Myre 

CASE 0:23-cv-01997   Doc. 1   Filed 06/29/23   Page 4 of 15



5 
 

was a resident of Belle Plaine, Minnesota. He was 44 years old at the time of death in 

February 2023. 

RELIEF DEFENDANTS 

18. The Estate of Dale Dahmen is the successor in interest to Dale Dahmen who 

is deceased. As of this date, the executor of the Dale Dahmen Estate is unknown. Dale 

Dahmen was a resident of Buffalo, Minnesota. He was 55 years old at the time of death in 

February 2023. 

19. The Estate of Dominick Dahmen is the successor in interest to Dominick 

Dahmen, who is deceased. As of this date, the executor of the Dominick Dahmen Estate is 

unknown. Dominick Dahmen was a Buffalo, Minnesota native although he also spent 

significant time in North Carolina where he worked as a musician. He was 25 years old at 

the time of death in February 2023. 

FACTS 

20. In 2019, Myre and the Dahmens founded Spartan Trading Company, LLC. 

Spartan Trading operated as an unregistered investment fund in which the Fund’s three 

promoters pooled money from investors, purportedly for day trading of stocks. 

21. Myre’s name was the only one listed on Spartan Trading’s incorporation 

documents filed with the State of Nevada. Dale and Dominick Dahmen told Investors that 

Myre would be responsible for the trading, which would generate profits for investors. 

Myre controlled the bank account into which investors deposited their funds, and Myre 

signed all known checks drawn on the account.   

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6 
 

22. Beginning by at least 2020, Spartan Trading, Myre, and the Dahmens raised 

over $3.7 million from dozens of investors. Investors included prior business contacts and 

friends of Myre and the Dahmens. Investors made both cash investments, often in the tens 

of thousands of dollars, and investments of retirement savings through an IRA custodian 

firm, that sometimes totaled over $100,000. 

23. Myre and the Dahmens, acting for Spartan Trading, required that the 

investors in the Fund sign, a “Profit Participation Agreement.” The two-page Agreements 

set out the principal amount and commencement date of the investor’s investment in the 

Fund and provided a mechanism for sharing investment profits.  

24. The Agreement guaranteed investors the first 2.5% of any profits generated 

each month. Spartan Trading was entitled to the next 2.5% of profits, and any profits above 

5% were to be split evenly between the investor and Spartan Trading. Investors were given 

the option to leave profits in their investment accounts or to withdraw them monthly. 

25. Myre provided investors with statements for their Spartan Trading accounts. 

These statements summarized, as of the first of each month, the investment amount, 

balance, previous month’s profit, and withdrawal amount per month for the investor’s 

account.  

26. For example, Myre reported to one investor that he had made at least 2.9% on 

his investment each month, with consistently positive monthly returns.  Myre, acting on 

behalf of Spartan Trading, reported similar returns to other investors. 

CASE 0:23-cv-01997   Doc. 1   Filed 06/29/23   Page 6 of 15



7 
 

27. Myre provided the investors with return information that was simply false. In 

actuality, as explained below, Myre put some investor money in a Bank of America account 

and transferred some to brokerage accounts, principally a TD Ameritrade account. 

28. The activity in the TD Ameritrade account does not support the kind of 

consistent monthly returns reported to investors. In fact, the TD Ameritrade account held 

only cash until May of 2021 (meaning that it had no investment activity of any kind prior to 

that time). At that point, Myre allocated a little over $100,000 to stock investments. 

Myreinvested slightly more money in stocks over the next several months, peaking at about 

$187,000 as of August 31, 2021. By contrast, as of that same date, the Fund’s TD 

Ameritrade account had over $1 million simply sitting in cash. 

29. In sum, Spartan Trading made profits of $80,697.69 from May to August of 

2021. At most, under the Profit Participation Agreements, Myre, and the Dahmens would 

have been entitled to half of those profits, or $40,348.98 (in actuality, because investors are 

entitled to the first 2.5% of profits each month, Myre’s and the Dahmens’ entitlement is 

likely even lower). For the rest of 2021, the Fund sustained losses on its investments, 

meaning Myre and the Dahmens were entitled to nothing.  

30. Bank and brokerage records indicate similar results in 2022. For example, the 

total profits in the TD Ameritrade account for February and March 2022 (the only profitable 

months in 2022 for the Fund’s TD Ameritrade investments were $571.73, meaning the 

maximum entitlement of the Fund’s promoters was $285.87. 

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31. Disregarding the terms of the Profit Participation Agreement, Myre and the 

Dahmens received much more out of the Fund than they were entitled to. During the entire 

time of the fraud, Myre and the Dahmens withdrew approximately $1.9 million from the 

Spartan Trading Bank of America account. 

32. During 2021, Myre took $548,262.50 of investor funds from the account, 

while Dale Dahmen received $183,055 and Dominick Dahmen received $81,561.59, 

meaning that in total the three took $812,879.09 out of the account in 2021. Based on their 

entitlement to half of overall profits, Spartan Trading would have needed to generate over 

$1.6 million in profits in 2021 in order for those payments to be justified under the Profit 

Participation Agreements. The Fund’s TD Ameritrade account actually generated only 

$80,697.96 in profits in 2021 and sustained losses that far exceeded that amount. 

33. The pattern for 2022 is similar. Myre continued to improperly take money 

out of the Bank of America account. Myre took $345,000 of investor funds, while Dale 

Dahmen received $275,192.15 and Dominick Dahmen received $81,751.51. Therefore, 

the three misappropriated $701,943.66 of investors’ money in 2022. Again, far from the 

$1.4 million in profits that would have been needed to justify those payments, during this 

period, the Fund’s TD Ameritrade account shows a total of only $571.73 in investment 

profits. 

34. Overall, during the life of the Fund, Myre and the Dahmens took over $1.9 

million of investor money from the Fund’s accounts for themselves. Of that, Myre took over 

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$1.1 million, while Dale Dahmen took approximately $649,000 and Dominick Dahmen 

took $173,113. 

35. The scheme continued in this vein until the fraud began to unravel in late 

2022. 

36. Beginning around that time, Myre and the Dahmens met concerning the 

fund’s trading activity and organizational structure 

37. On February 1, 2023, the three men met in a pick-up truck in the parking lot 

of a restaurant in Bloomington, Minnesota. All three were later found dead of apparent 

gunshot wounds inside the truck. 

38. After news of the deaths became public, investors began to approach 

Bloomington police and the SEC inquiring as to the status of the money they had invested 

in Spartan Trading. 

39. The aftermath has caused significant upheaval for investors. At least one 

couple who had invested over $100,000 with Spartan Trading had to sell their home and 

move out of state to be closer to family. Other investors have lost retirement savings and 

inheritances.  Some face the prospect of paying off loans that they took out in order to 

invest with Spartan Trading.  

40. A review of available records for Spartan Trading-associated accounts shows 

less than $6,000 remaining in the Bank of America account and approximately $400 in the 

TD Ameritrade account.  

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41. The SEC now brings this action to freeze what funds remain in Spartan 

Trading’s accounts, freeze any funds in the Fund promoters’ estates, and attempt to trace 

the hundreds of thousands of dollars of investor funds taken out of the Fund with the goal 

of returning funds to defrauded investors.  

COUNT I 
 

Violations of Section 10(b) of the Exchange Act and Exchange Act Rule 10b-5 
(Against Spartan Trading and Myre Estate) 

42. Paragraphs 1 through 41 are realleged and incorporated herein by reference. 

43. Spartan Trading and Myre, in connection with the purchase and sale of 

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

use of the mails, directly and indirectly: used and employed devices, schemes and artifices 

to defraud; made untrue statements of material fact and 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 engaged in acts, practices and courses of business 

which operated or would have operated as a fraud and deceit upon purchasers and 

prospective purchasers of securities. 

44. Each acted with scienter in that they knowingly or recklessly made the 

material misrepresentations and omissions and engaged in the fraudulent scheme 

identified above. 

45. By reason of the foregoing, Spartan Trading and Myre violated 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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COUNT II 
 

Violations of Section 17(a) of the Securities Act 
(Against Spartan Trading and Myre Estate) 

46. Paragraphs 1 through 41 are realleged and incorporated by reference as 

though fully set forth herein. 

47. Spartan Trading and Myre, in the offer and sale of securities, by the use of 

the means and instruments of interstate commerce, directly or indirectly: 

a. engaged in fraudulent devices, schemes, artifices, transactions, acts, 
practices and courses of business; 

b. obtained money or property by means of untrue statements of 
material fact or by omitting 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  

c. engaged in transactions, practices, or courses of business that 
operated or would operate as a fraud or deceit upon the purchasers of 
such securities. 

48. Spartan Trading and Myre acted intentionally, with severe recklessness, and 

at least negligently in the fraudulent conduct described above.   

49. By reason of the foregoing, Spartan Trading and Myre violated Section 

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

COUNT III 
 

Violations of Sections 206(1) and 206(2) of the Advisers Act 
(Against Myre Estate) 

50. Paragraphs 1 through 41 above are realleged and incorporated herein by 

reference. 

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51. During the relevant time period, Myre acted as an investment adviser to 

Spartan Trading within the meaning of Section 202(a)(11) of the Advisers Act [15 U.S.C. 

§ 80b-2(a)(11)]. 

52. Myre, by use of the mails and the means and instrumentalities of interstate 

commerce, directly or indirectly, while acting as an investment adviser, knowingly, 

willfully, or recklessly: (a) employed devices, schemes, or artifices to defraud clients or 

prospective clients; and (b) engaged in transactions, practices, and courses of business 

that operated as a fraud or deceit upon clients or prospective clients. 

53. By engaging in the conduct described above, Myre, directly or indirectly, 

violated Sections 206(1) and (2) of the Advisers Act [15 U.S.C. § 80b-6(1) and 80b-6(2)]. 

COUNT IV 
 

Violations of Section 206(4) of the Advisers Act and Rule 206(4)-8 Thereunder 
(Against Myre Estate) 

54. Paragraphs 1 through 41 above are realleged and incorporated herein by 

reference. 

55. By his conduct, Myre, while acting as an investment adviser to a pooled 

investment vehicle, has made untrue statements of material fact or omitted to state a 

material fact necessary to make, in light of the circumstances, the statements made not 

misleading to an investor or prospective investor or has otherwise engaged in acts, 

practices, or courses of business that were fraudulent, deceptive, or manipulative with 

respect to an investor or prospective investor in the pooled investment vehicle. 

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56. By reason of the foregoing, Myre has violated Section 206(4) of the 

Advisers Act [15 U.S.C. § 80b-6(4)] and Rule 206(4)-8 thereunder [17 C.F.R. § 

275.206(4)-8]. 

COUNT V 
 

Unjust Enrichment 
(Against All Relief Defendants) 

57. Paragraphs 1 through 41 above are realleged and incorporated herein by 

reference. 

58. Dale Dahmen and Dominick Dahmen obtained money, property, or assets to 

which they have no legitimate claim because of the violations of the securities laws by 

Myre and Spartan Trading. 

59. Each of the Relief Defendants should be required to disgorge all ill-gotten 

gains that inured to their benefit under the equitable doctrines of disgorgement, unjust 

enrichment, and constructive trust. 

RELIEF REQUESTED 

 WHEREFORE, the SEC respectfully requests that this Court: 

I.  

 Issue findings of fact and conclusions of law that Spartan Trading and Myre 

committed the violations charged and alleged herein. 

II.  

 Enter an Order of Permanent Injunction restraining and enjoining Defendant 

Spartan Trading, its officers, agents, servants, employees, attorneys, and those persons in 

CASE 0:23-cv-01997   Doc. 1   Filed 06/29/23   Page 13 of 15



14 
 

active concert or participation with it who receive actual notice of the Order, by personal 

service or otherwise, and each of them from, directly or indirectly, engaging in the 

transactions, acts, practices or courses of business described above, or in conduct of 

similar purport and object, in violation of Section 17(a) of the Securities Act of 1933 

(“Securities Act”) [15 U.S.C. § 77q(a)] and Section 10(b) of the Securities Exchange Act 

of 1934 (“Exchange Act”) [15 U.S.C. § 78j(b)], and Rule 10b-5 [17 C.F.R. §§ 240.10b-5] 

thereunder, and Sections 206(1) [15 U.S.C. § 80b-6(1)], 206(2) of the Investment 

Advisers Act of 1940 (“Advisers Act”) [15 U.S.C. § 80b-6(2)], 206(4) [15 U.S.C. § 80b-

6(4)] and Rule 206(4)-8 thereunder [17 C.F.R. § 275.206(4)-8]. 

III. 

Issue an Order requiring Defendants and Relief Defendants to disgorge the ill-

gotten gains received as a result of the violations alleged in this Complaint pursuant to 

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

(5) and (7)], including prejudgment interest. 

IV. 

 Retain jurisdiction of this action in accordance with the principals 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. 

V. 

 Grant such other relief as this Court deems appropriate. 

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Respectfully Submitted, 

 
Dated: June 29, 2023     ____________________________  

Charles J. Kerstetter 
([email protected]) 
Lee Farnsworth  
([email protected]) 
*pro hac vice pending 
175 West Jackson Blvd., Suite 1450 
Chicago, IL 60604 
Phone:  (312) 353-7390 
Facsimile: (312) 353-7398  
Attorneys for Plaintiff 
U.S. Securities and Exchange 
Commission 
 
 
Craig Baune 
MN Bar No. 331727 
Assistant United States Attorney 
District of Minnesota 
600 U.S. Courthouse 
300 South Fourth Street 
Minneapolis, MN 55414 
Telephone: (612) 664-5600 
Email: [email protected] 
 
Local Counsel 

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