SEC v. GPL VENTURES LLC; GPL MANAGEMENT LLC; ALEXANDER J. DILLON; and COSMIN I. PANAIT, No. 1:21-cv-06814, Southern District of New York (May 24, 2023) — Judgment

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,
-against-
GPL
VENTURES LLC, et al.,
Defendants.
21-cv-6814 (AKH)
ff kOtlJJt38] FINAL JUDGMENT AS TO DEFENDANTS GPL VENTURES LLC,
GPL MANAGEMENT LLC, ALEXANDER J. DILLON, AND COSMIN I. PANAIT
The Securities and Exchange Commission (the "Commission") having filed a Complaint
and Defendants GPL Ventures LLC,
GPL Management LLC, Alexander J.  Dillon ("Dillon"),
and Cosmin I. Panait ("Panait") ( collectively "Defendants") having entered a general
appearance; consented to the Court's jurisdiction over Defendants and the subject matter of this
action; consented to entry
of this Final Judgment without admitting or denying the allegations of
the Complaint ( except as to jurisdiction and except as otherwise provided herein in paragraph
VIII); waived findings
of fact and conclusions of law; and waived any right to appeal from this
Final Judgment:
I.
IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Defendants are
permanently restrained and enjoined from violating Section 15(a)(l) of the Securities Exchange
Act of 1934 ("Exchange Act") [15 U.S.C. § 78o(a)(l)] by, while acting as a dealer [15 U.S.C. §
78c(a)(5)], making use of the mails or any means or instrumentality of interstate commerce to
effect any transactions in, or to induce
or attempt to induce the purchase or sale of, any security

(other than an exempted security pursuant to 17 C.F.R. § 240.15a-2 or commercial paper,
bankers' acceptances, or commercial bills) unless the Defendants are registered with the
Commission
as a dealer in accordance with Exchange Act Section 15(b) [15 U.S.C. § 78o(b)].
IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in
Federal Rule
of Civil Procedure 65( d)(2), the foregoing paragraph also binds the following who
receive actual notice
of this Final Judgment by personal service or otherwise: (a) Defendants'
members, managing members, officers, agents, servants, employees, and attorneys; and (b) other
persons in active concert or participation with Defendants or with anyone described in (a).
II.
IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Defendants are
permanently restrained and enjoined from violating, directly or indirectly, Section l0(b)
of the
Exchange Act [15 U.S.C. § 78j(b)] and Rule lOb-5 promulgated thereunder [17 C.F.R.
§ 240.1 0b-5], by using any means or instrumentality of interstate commerce, or of the mails, or
of any facility of any national securities exchange, in connection with the purchase or sale of any
security:
(a) to employ any device, scheme, or artifice to defraud;
(b) to make any untrue statement
of a material fact or to omit to state a material fact
necessary in order to make the statements made, in the light
of the circumstances
under which they were made, not misleading; or
(
c) to engage in any act, practice, or course of business which operates or would
operate
as a fraud or deceit upon any person.
IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in
Federal Rule
of Civil Procedure 65( d)(2), the foregoing paragraph also binds the following who
2

receive actual notice of this Final Judgment by personal service or otherwise: (a) Defendants'
officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or
participation with Defendants or with anyone described in (a).
III.
IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that
Defendants are permanently restrained and enjoined from violating Section l 7(a)
of the
Securities Act
of 1933 (the "Securities Act") [15 U.S.C. § 77q(a)] in the offer or sale of any
security
by the use of any means or instruments of transportation or communication in interstate
commerce or by use
of the mails, directly or indirectly:
(a) to employ any device, scheme, or artifice to defraud;
(b) to obtain money or property
by means of any untrue statement of a material fact
or any omission
of a material fact necessary in order to make the statements
made, in light
of the circumstances under which they were made, not misleading;
or
(
c) to engage in any transaction, practice, or course of business which operates or
would operate as a fraud or deceit upon the purchaser.
IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that, as
provided in Federal Rule
of Civil Procedure 65(d)(2), the foregoing paragraph also binds the
following who receive actual notice
of this Final Judgment by personal service or otherwise: (a)
Defendants' officers, agents, servants, employees, and attorneys; and (b) other persons in active
concert or participation with Defendants or with anyone described in (a).
3

IV.
IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that, for a
period
of five years from the date of entry of this Final Judgment, Defendants are barred from
participating in
an offering of penny stock, including engaging in activities with a broker, dealer,
or issuer for purposes of issuing, trading, or inducing or attempting to induce the purchase or sale
of any penny stock. A penny stock is  any equity security that has a price of less than five dollars,
except as provided in Rule 3a51-1 under the Exchange
Act [17 C.F.R. § 240.3a51-1].
V.
IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that
Defendants are
jointly and severally liable for disgorgement of $29,681,569, representing net
profits gained as a result of the conduct alleged in the Complaint, together with prejudgment
interest thereon in the amount
of $2,489,799, and Dillon and Panait are each liable for a civil
penalty in the amount
of $3,500,000 pursuant to Securities Act Section 20(d) [15 U.S.C.
§ 77t(d)] and Exchange
Act Section 21(d)(3) [15 U.S.C. § 78u(d)(3)], for a total of $39,171,368.
This obligation shall
be satisfied pursuant to the procedure set forth in paragraph VI below.
Defendants
may transmit payment electronically to the Commission, which will provide
detailed
ACH transfer/Fedwire instructions upon request. Payment may also be made directly
from a
bank account via Pay.gov through the SEC website at
http://www.sec.go
v/about/offices/ofm.htm. Defendants may also pay by certified check, bank
cashier's check, or United States postal money order payable to the Commission, which shall be
delivered or mailed to
Enterprise Services Center
Accounts Receivable
Branch
6500 South MacArthur Boulevard
Oklahoma City,
OK 73169
4

and shall be accompanied by a letter identifying the case title, civil action number, and name of
this Court; Defendants' names as Defendants in this action; and specifying that payment is  made
pursuant to this Final Judgment.
Defendants shall simultaneously transmit photocopies
of evidence of payment and case
identifying information
to the Commission's counsel in this action. By making this payment,
Defendants relinquish all legal and equitable right, title, and interest in such funds and no part
of
the funds shall be returned to Defendants.
The Commission may enforce the Court's judgment for disgorgement and prejudgment
interest by using all collection procedures authorized by law, including, but not limited to,
moving for civil contempt at any time after 30 days following entry
of this Final Judgment.
The Commission may enforce the Court's judgment for penalties by the use
of all
collection procedures authorized by law, including the Federal Debt Collection Procedures Act,
28 U.S.C. § 3001 et seq., and moving for civil contempt for the violation of any Court orders
issued in this action. Defendants shall pay post judgment interest on any amounts due after 30
days
of the entry of this Final Judgment pursuant to 28 U.S.C. § 1961. The Commission shall
hold the funds, together with any interest and income earned thereon (collectively, the "Fund"),
pending further order of the Court.
The Commission may propose a plan to distribute the Fund subject to the Court's
approval. Such a plan may provide that the Fund shall be distributed pursuant to the Fair Fund
provisions
of Section 308( a) of the Sarbanes-Oxley Act of 2002. The Court shall retain
jurisdiction over the administration
of any distribution of the Fund and the Fund may only be
disbursed pursuant to an Order
of the Court.
Regardless
of whether any such Fair Fund distribution are made, amounts ordered to be
5

paid as civil penalties pursuant to this Final Judgment shall be treated as penalties paid to the
government for all purposes, including all tax purposes. To preserve the deterrent effect
of the
civil penalty, Defendants shall not, after offset
or reduction of any award of compensatory
damages in any Related Investor Action based on Defendants' payment
of disgorgement in this
action, argue that they are entitled to,
nor shall they further benefit by, offset or reduction of such
compensatory damages award
by the amount of any part of Defendants' payment of a civil
penalty in this action ("Penalty Offset").
If the court in any Related Investor Action grants such
a Penalty Offset, Defendants shall, within 30 days after entry
of a final order granting the Penalty
Offset, notify the Commission's counsel in this action and pay the amount
of the Penalty Offset
to the United States Treasury
or to a Fair Fund, as the Commission directs. Such a payment shall
not be deemed an additional civil penalty and shall
not be deemed to change the amount of the
civil penalty imposed in this Final Judgment.
For purposes of this paragraph, a "Related Investor
Action" means a private damages action brought against Defendants
by or on behalf of one or
more investors based on substantially the same facts as alleged in the Complaint in this action.
VI.
IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that within 3 days after
being served
by the Commission with a copy of this Final Judgment, Flagstar Bank, N.A.
("Bank") shall transfer to the Commission $39,171,368, representing the full amount
of the Final
Judgment from the following
Bank account which was frozen pursuant to an Order of this Court:
Account Owner
Acct. Ending in:
GPL Ventures LLC
*8849
Bank may transmit payment electronically to the Commission, which will provide
detailed
ACH transfer/Fedwire instructions upon request. Payment may also be made directly
from a bank account via Pay.gov through the
SEC website at
6

http://www.sec.gov/about/offi ces/ofm.htm.  Bank also may transfer these funds by certified
check, bank cashier's check, or United States postal money payable to the Securities and
Exchange Commission, which shall be delivered or mailed to
Enterprise Services Center
Accounts Receivable Branch
6500 South MacArthur Boulevard
Oklahoma City,
OK 73169
and shall be accompanied by a letter identifying the case title, civil action number, and name
of
this Court; and specifying that payment is  made pursuant to this Final Judgment. After Bank
remits $39,171,368, representing the full amount
of the Final Judgment to the Commission, then
Bank may release any remaining balance to the account owner, GPL Ventures LLC.
VII.
IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Consents are
incorporated herein with the same force and effect as
if fully set forth herein, and that
Defendants shall comply with all
of the undertakings and agreements set forth therein, including
Defendants' agreements that within sixty ( 60) days after entry
of this Final Judgment,
Defendants shall surrender to the respective issuers all unconverted convertible notes in their
entirety associated with the issuers identified in Appendix A to the Consents for cancellation,
and provide proof
of same to the Commission.
VIII.
IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, solely for purposes of
exceptions to discharge set forth in Section 523 of the Bankruptcy Code, 11 U .S.C. § 523, the
allegations in the Complaint are true and admitted by Defendants, and further, any debt for
disgorgement, prejudgment interest, civil penalty or other amounts due by Defendants under this
Final Judgment or any other judgment, order, consent order, decree or settlement agreement
7

entered in connection with this proceeding, are a debt for the violation by Defendants of the
federal securities laws
or any regulation or order issued under such laws, as set forth in Section
523(a)(19) of the Bankruptcy Code, 11 U.S.C. § 523(a)(19).
IX.
IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Stipulation and
Order Granting Preliminary Injunction and Order Freezing Assets and Granting Other
Relief
(ECF No. 33) is  dissolved.
X.
IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that this Court shall retain
jurisdiction
of this matter for the purposes of enforcing the terms of this Final Judgment.
XI.
There being no just reason for delay, pursuant to Rule 54(b) of the Federal Rules of Civil
Procedure, the Clerk is  ordered to enter this Final Judgment forthwith and without further notice.
8

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 

SECURITIES AND EXCHANGE 
COMMISSION, 

Plaintiff, 

-against-

GPL VENTURES LLC, et al., 

Defendants. 

21-cv-6814 (AKH) 

ff kOtlJJt38] FINAL JUDGMENT AS TO DEFENDANTS GPL VENTURES LLC, 
GPL MANAGEMENT LLC, ALEXANDER J. DILLON, AND COSMIN I. PANAIT 

The Securities and Exchange Commission (the "Commission") having filed a Complaint 

and Defendants GPL Ventures LLC, GPL Management LLC, Alexander J. Dillon ("Dillon"), 

and Cosmin I. Panait ("Panait") ( collectively "Defendants") having entered a general 

appearance; consented to the Court's jurisdiction over Defendants and the subject matter of this 

action; consented to entry of this Final Judgment without admitting or denying the allegations of 

the Complaint ( except as to jurisdiction and except as otherwise provided herein in paragraph 

VIII); waived findings of fact and conclusions of law; and waived any right to appeal from this 

Final Judgment: 

I. 

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Defendants are 

permanently restrained and enjoined from violating Section 15(a)(l) of the Securities Exchange 

Act of 1934 ("Exchange Act") [15 U.S.C. § 78o(a)(l)] by, while acting as a dealer [15 U.S.C. § 

78c(a)(5)] , making use of the mails or any means or instrumentality of interstate commerce to 

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

Case 1:21-cv-06814-AKH   Document 127   Filed 05/02/23   Page 1 of 8



(other than an exempted security pursuant to 17 C.F.R. § 240.15a-2 or commercial paper, 

bankers' acceptances, or commercial bills) unless the Defendants are registered with the 

Commission as a dealer in accordance with Exchange Act Section 15(b) [15 U.S.C. § 78o(b)]. 

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

Federal Rule of Civil Procedure 65( d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Final Judgment by personal service or otherwise: (a) Defendants' 

members, managing members, officers, agents, servants, employees, and attorneys; and (b) other 

persons in active concert or participation with Defendants or with anyone described in (a). 

II. 

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Defendants are 

permanently restrained and enjoined from violating, directly or indirectly, Section l0(b) of the 

Exchange Act [15 U.S.C. § 78j(b)] and Rule lOb-5 promulgated thereunder [17 C.F.R. 

§ 240.1 0b-5] , by using any means or instrumentality of interstate commerce, or of the mails, or 

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

security: 

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

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

necessary in order to make the statements made, in the light of the circumstances 

under which they were made, not misleading; or 

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

operate as a fraud or deceit upon any person. 

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

Federal Rule of Civil Procedure 65( d)(2), the foregoing paragraph also binds the following who 

2 

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receive actual notice of this Final Judgment by personal service or otherwise: (a) Defendants' 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendants or with anyone described in (a). 

III. 

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that 

Defendants are permanently restrained and enjoined from violating Section l 7(a) of the 

Securities Act of 1933 (the "Securities Act") [15 U.S.C. § 77q(a)] in the offer or sale of any 

security by the use of any means or instruments of transportation or communication in interstate 

commerce or by use of the mails, directly or indirectly: 

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

(b) to obtain money or property by means of any untrue statement of a material fact 

or any omission of a material fact necessary in order to make the statements 

made, in light of the circumstances under which they were made, not misleading; 

or 

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

would operate as a fraud or deceit upon the purchaser. 

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

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

following who receive actual notice of this Final Judgment by personal service or otherwise: (a) 

Defendants' officers, agents, servants, employees, and attorneys; and (b) other persons in active 

concert or participation with Defendants or with anyone described in (a). 

3 

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IV. 

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

period of five years from the date of entry of this Final Judgment, Defendants are barred from 

participating in an offering of penny stock, including engaging in activities with a broker, dealer, 

or issuer for purposes of issuing, trading, or inducing or attempting to induce the purchase or sale 

of any penny stock. A penny stock is any equity security that has a price of less than five dollars, 

except as provided in Rule 3a51-1 under the Exchange Act [17 C.F.R. § 240.3a51-1]. 

V. 

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that 

Defendants are jointly and severally liable for disgorgement of $29,681,569, representing net 

profits gained as a result of the conduct alleged in the Complaint, together with prejudgment 

interest thereon in the amount of $2,489,799, and Dillon and Panait are each liable for a civil 

penalty in the amount of $3,500,000 pursuant to Securities Act Section 20(d) [15 U.S.C. 

§ 77t(d)] and Exchange Act Section 21(d)(3) [15 U.S.C. § 78u(d)(3)], for a total of $39,171,368. 

This obligation shall be satisfied pursuant to the procedure set forth in paragraph VI below. 

Defendants may transmit payment electronically to the Commission, which will provide 

detailed ACH transfer/Fedwire instructions upon request. Payment may also be made directly 

from a bank account via Pay.gov through the SEC website at 

http: //www.sec.gov/about/offices/ofm.htm. Defendants may also pay by certified check, bank 

cashier's check, or United States postal money order payable to the Commission, which shall be 

delivered or mailed to 

Enterprise Services Center 
Accounts Receivable Branch 
6500 South MacArthur Boulevard 
Oklahoma City, OK 73169 

4 

Case 1:21-cv-06814-AKH   Document 127   Filed 05/02/23   Page 4 of 8



and shall be accompanied by a letter identifying the case title, civil action number, and name of 

this Court; Defendants' names as Defendants in this action; and specifying that payment is made 

pursuant to this Final Judgment. 

Defendants shall simultaneously transmit photocopies of evidence of payment and case 

identifying information to the Commission's counsel in this action. By making this payment, 

Defendants relinquish all legal and equitable right, title, and interest in such funds and no part of 

the funds shall be returned to Defendants. 

The Commission may enforce the Court's judgment for disgorgement and prejudgment 

interest by using all collection procedures authorized by law, including, but not limited to, 

moving for civil contempt at any time after 30 days following entry of this Final Judgment. 

The Commission may enforce the Court's judgment for penalties by the use of all 

collection procedures authorized by law, including the Federal Debt Collection Procedures Act, 

28 U.S.C. § 3001 et seq., and moving for civil contempt for the violation of any Court orders 

issued in this action. Defendants shall pay post judgment interest on any amounts due after 30 

days of the entry of this Final Judgment pursuant to 28 U.S.C. § 1961. The Commission shall 

hold the funds, together with any interest and income earned thereon (collectively, the "Fund"), 

pending further order of the Court. 

The Commission may propose a plan to distribute the Fund subject to the Court's 

approval. Such a plan may provide that the Fund shall be distributed pursuant to the Fair Fund 

provisions of Section 308( a) of the Sarbanes-Oxley Act of 2002. The Court shall retain 

jurisdiction over the administration of any distribution of the Fund and the Fund may only be 

disbursed pursuant to an Order of the Court. 

Regardless of whether any such Fair Fund distribution are made, amounts ordered to be 

5 

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paid as civil penalties pursuant to this Final Judgment shall be treated as penalties paid to the 

government for all purposes, including all tax purposes. To preserve the deterrent effect of the 

civil penalty, Defendants shall not, after offset or reduction of any award of compensatory 

damages in any Related Investor Action based on Defendants' payment of disgorgement in this 

action, argue that they are entitled to, nor shall they further benefit by, offset or reduction of such 

compensatory damages award by the amount of any part of Defendants' payment of a civil 

penalty in this action ("Penalty Offset"). If the court in any Related Investor Action grants such 

a Penalty Offset, Defendants shall, within 30 days after entry of a final order granting the Penalty 

Offset, notify the Commission's counsel in this action and pay the amount of the Penalty Offset 

to the United States Treasury or to a Fair Fund, as the Commission directs. Such a payment shall 

not be deemed an additional civil penalty and shall not be deemed to change the amount of the 

civil penalty imposed in this Final Judgment. For purposes of this paragraph, a "Related Investor 

Action" means a private damages action brought against Defendants by or on behalf of one or 

more investors based on substantially the same facts as alleged in the Complaint in this action. 

VI. 

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that within 3 days after 

being served by the Commission with a copy of this Final Judgment, Flagstar Bank, N.A. 

("Bank") shall transfer to the Commission $39,171,368, representing the full amount of the Final 

Judgment from the following Bank account which was frozen pursuant to an Order of this Court: 

Account Owner Acct. Ending in: 

GPL Ventures LLC *8849 

Bank may transmit payment electronically to the Commission, which will provide 

detailed ACH transfer/Fedwire instructions upon request. Payment may also be made directly 

from a bank account via Pay.gov through the SEC website at 

6 

Case 1:21-cv-06814-AKH   Document 127   Filed 05/02/23   Page 6 of 8



http://www.sec.gov/about/offices/ofm.htm. Bank also may transfer these funds by certified 

check, bank cashier's check, or United States postal money payable to the Securities and 

Exchange Commission, which shall be delivered or mailed to 

Enterprise Services Center 
Accounts Receivable Branch 
6500 South MacArthur Boulevard 
Oklahoma City, OK 73169 

and shall be accompanied by a letter identifying the case title, civil action number, and name of 

this Court; and specifying that payment is made pursuant to this Final Judgment. After Bank 

remits $39,171,368, representing the full amount of the Final Judgment to the Commission, then 

Bank may release any remaining balance to the account owner, GPL Ventures LLC. 

VII. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Consents are 

incorporated herein with the same force and effect as if fully set forth herein, and that 

Defendants shall comply with all of the undertakings and agreements set forth therein, including 

Defendants' agreements that within sixty ( 60) days after entry of this Final Judgment, 

Defendants shall surrender to the respective issuers all unconverted convertible notes in their 

entirety associated with the issuers identified in Appendix A to the Consents for cancellation, 

and provide proof of same to the Commission. 

VIII. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, solely for purposes of 

exceptions to discharge set forth in Section 523 of the Bankruptcy Code, 11 U.S.C. § 523 , the 

allegations in the Complaint are true and admitted by Defendants, and further, any debt for 

disgorgement, prejudgment interest, civil penalty or other amounts due by Defendants under this 

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

7 

Case 1:21-cv-06814-AKH   Document 127   Filed 05/02/23   Page 7 of 8



entered in connection with this proceeding, are a debt for the violation by Defendants of the 

federal securities laws or any regulation or order issued under such laws, as set forth in Section 

523(a)(19) of the Bankruptcy Code, 11 U.S.C. § 523(a)(19). 

IX. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Stipulation and 

Order Granting Preliminary Injunction and Order Freezing Assets and Granting Other Relief 

(ECF No. 33) is dissolved. 

X. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that this Court shall retain 

jurisdiction of this matter for the purposes of enforcing the terms of this Final Judgment. 

XI. 

There being no just reason for delay, pursuant to Rule 54(b) of the Federal Rules of Civil 

Procedure, the Clerk is ordered to enter this Final Judgment forthwith and without further notice. 

8 

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