SEC v. Bluesky Eagle Capital Management Ltd., No. 1:25-cv-09507-AS, Southern District of New York (Feb. 19, 2026) — Complaint

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

___________________________________________
)

SECURITIES AND EXCHANGE )
COMMISSION, )

)
Plaintiff,   )

)  Civil Action No.
v. )

)
BLUESKY EAGLE CAPITAL )
MANAGEMENT LTD., )

)
Defendant. )

___________________________________________ )

COMPLAINT

Plaintiff Securities and Exchange Commission (“the Commission”) files this Complaint

against Defendant Bluesky Eagle Capital Management Ltd. (“Bluesky”) and alleges as follows:

SUMMARY

1. This case concerns material misrepresentations and statements that could not be

substantiated made by Bluesky, a purported investment adviser, in a form filed with the

Commission and made available to the public on December 12, 2023, about Bluesky’s

organization, office location, assets under management, and clients.

2. Specifically, Bluesky represented in its Form ADV (a form used by investment

advisers to register with both the Commission and state securities regulators) that it is a public

company operating out of office space on the 52nd floor of 140 Broadway, New York, New

York 10005 (“140 Broadway”); that Joshua Troy Hunt serves as both its Chief Executive

Officer (“CEO”) and Chief Operating Officer (“COO”); that it manages $10 million in assets in

the United States; that it advises a private fund (with the same name as the defendant: Bluesky

25-cv-9507

2

Eagle Capital Management Ltd.); and that a separate registered investment adviser (“RIA”)

reports information about this private fund to the Commission on its own Form ADV.

3. Contrary to Bluesky’s representations, the current real estate manager of 140

Broadway has no knowledge of Bluesky or its purported CEO/COO, and the separate RIA has

not reported information about the purported private fund. Moreover, the Commission has not

found any reporting of information about the private fund on other filings made with the

Commission, and a search of the Commission’s public company database yields no information

on Bluesky.

4. In addition, Bluesky failed to respond to a request by Commission attorneys to

provide records to substantiate the information on the Form ADV, including the amount of

private fund assets under management in the United States.

5. By engaging in the conduct described in this Complaint, Bluesky violated, and

unless enjoined will continue to violate, Sections 204(a) and 207 of the Investment Advisers

Act of 1940 (the “Advisers Act”) [15 U.S.C. §§ 80b-4(a), 80b-7].

NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT

6. The Commission brings this action under enforcement authority conferred by

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

7. The Commission seeks a final judgment: (a) permanently enjoining Bluesky

from violating the federal securities laws this Complaint alleges it has violated; (b) permanently

enjoining Bluesky, its owners, and its executive officers, from filing a Form ADV as an exempt

reporting adviser; (c) ordering Bluesky to pay a civil money penalty under Section 209(e) of the

Advisers Act [15 U.S.C. § 80b-209(e)]; and (d) ordering any other and further relief the Court

may deem just and proper.

3

JURISDICTION AND VENUE

8. This Court has jurisdiction over this action under Section 214 of the Advisers

Act [15 U.S.C. § 80b-14].

9. Defendant, directly or indirectly, made use of the means or instrumentalities of

interstate commerce or of the mails in connection with the transactions, acts, practices, and

course of business alleged.

10. Venue is proper in the Southern District of New York under Section 214 of the

Advisers Act [15 U.S.C. § 80b-14]. Certain of the acts, practices, transactions, and courses of

business alleged in this Complaint occurred within this District. Specifically, Bluesky

represented on corporate filings with both the Commission and the New York Department of

State, Division of Corporations, that its primary business address is 140 Broadway, which is

located in the District.

DEFENDANT

11. Bluesky Eagle Capital Management Ltd. claims that it is a New York

corporation with a principal place of business at 140 Broadway. On December 5, 2023, Bluesky

filed a certificate of incorporation with the New York Department of State, Division of

Corporations, in which it used the name “Joshua Troy Hunt” as the filer and incorporator, and

listed 140 Broadway as Hunt’s address. The certificate of incorporation designated the

Secretary of State of New York as the agent of the corporation upon whom process may be

served.

FACTS

I. Investment Adviser Registration and Commission Form ADV

12. The Commission regulates investment advisers, primarily under the Advisers Act

and the rules adopted under that statute. One of the central elements of the regulatory program

is the requirement that an “investment adviser” under the Advisers Act register with the

4

Commission, unless exempt or prohibited from registration. Generally, only larger advisers that

have $100 million or more of regulatory assets under management, or that provide advice to

investment company clients, are permitted to register with the Commission. Smaller advisers

register under state law with state securities authorities.

13. Exempt reporting advisers (“ERAs”) are a category of investment advisers who

would otherwise be required to register with the Commission under the Advisers Act but for the

specific exemptions outlined in Section 203 of the Advisers Act. ERAs include an adviser to

private funds with less than $150 million in assets under management in the United States. The

registration exemption for such private fund advisers is Section 203(m) of the Advisers Act and

Rule 203(m)-1 thereunder.

14. While ERAs are exempt from the registration requirements, any books or records

they do maintain are subject to examination by the Commission under Section 204(a) of the

Advisers Act.

15. Form ADV is the form used by investment advisers to register with the

Commission and with state securities authorities. It consists of two parts, both of which are

required to be filed with the Commission, and both of which are publicly available once filed:

Form ADV Part 1 and Form ADV Part 2.

16. ERAs, while exempt from registration, are still required to file certain items in

Form ADV Part 1. ERAs do not complete Part 2.

17. Part 1 asks for information about, among other things, an adviser’s business,

amount of assets under management, ownership, and clients.

18. Form ADV is filed electronically with the Commission through the Investment

Adviser Registration Depository (“IARD”), a secure Internet based filing system that collects

and maintains the registration, reporting, and disclosure information for investment advisers.

The Financial Industry Regulatory Authority (“FINRA”), under contract with the Commission,

5

is the developer and operator of the IARD system. Once filed, the Form ADV is available to the

public through the Commission’s Investment Adviser Public Disclosure database, located at

https://adviserinfo.sec.gov.

II. Bluesky Made Material Misstatements and Statements in its Form ADV Filed with
the Commission That Could Not Be Substantiated.

19. On December 12, 2023, Bluesky filed its Form ADV with the Commission as an

ERA. In that filing, Bluesky claims that it qualifies for a registration exemption because it acts

solely as an adviser to private funds and has assets under management in the United States of

less than $150 million.

20. In the Form ADV, Bluesky lists the 52nd floor of 140 Broadway as its principal

office and place of business, and states that Joshua Troy Hunt serves as both its CEO and COO.

Bluesky also provides a telephone number with a (205) area code as the main number for its

New York office, even though (205) is the area code for the Birmingham, Alabama area.

21. In the Form ADV section titled “Direct Owners and Executive Officers,”

Bluesky identifies its “Executive Officers” and its direct owner as itself (that is, Bluesky Eagle

Capital Management Ltd.). Bluesky also (i) states that it is a public reporting company (often

referred to as a “public company”), meaning that it must file certain disclosure reports,

including annual, quarterly, and current reports, with the Commission on an ongoing basis, and

(ii) provides two Central Index Key (“CIK”) numbers, which are numbers that the Commission

assigns to a public reporting company and that can be searched on the Commission’s computer

systems to identify corporations and individuals required to file disclosure information.

22. The Form ADV represents that the amount of Bluesky’s private fund assets

under management in the United States is $10 million.

23. In addition, the Form ADV represents that Bluesky advises a private fund, also

named “Bluesky Eagle Capital Management Ltd.,” and lists a private fund identification

6

number. The private fund identification number is a unique identification number assigned to a

private fund.

24. Bluesky further states in its Form ADV that a separate RIA “provides

information” about Bluesky’s private fund on its own Form ADV filing.

25. Contrary to Bluesky’s representations in the Form ADV:

a. the individual who has served as the real estate manager of 140

Broadway for the last 12 years has no knowledge of Bluesky or Joshua Troy Hunt as building

tenants, subtenants, or otherwise. Moreover, 140 Broadway is a 51-story building. The 52nd

floor does not house tenants, as it is used solely for mechanical purposes;

b. the third-party RIA has not reported the Bluesky private fund on its Form

ADV filings. Further, the Commission has not found reporting of the private fund or the

associated identification number on other filings; and

c. a search for either Bluesky or its purported CIK numbers on the

Commission’s public reporting company database yields no information.

III. Bluesky Failed to Produce Records for Examination.

26. Section 204(a) of the Advisers Act provides that all records of investment

advisers are “subject at any time, or from time to time, to such reasonable periodic, special, or

other examinations by representatives of the Commission as the Commission deems necessary

or appropriate in the public interest or for the protection of investors.” 15 U.S.C. § 80b-4(a).

27. Although ERAs are exempt from the registration requirements, any books and

records they do maintain are subject to examination under Section 204(a).

28. Since November 13, 2024, Commission attorneys have attempted to obtain

books and records from Bluesky that it is required to produce under the Advisers Act.

29. On November 13, 2024 and December 4, 2024, a Commission attorney emailed

Bluesky a letter requesting production of books and records regarding the information on the

7

Form ADV, including its organizational information and the private fund assets under

management in the United States. Although the Form ADV itself does not contain an email

address for Bluesky, the Commission attorney used email addresses that Bluesky provided to (i)

FINRA in connection with the Form ADV filing process and (ii) the New York Department of

State in connection with filing its incorporation documents.

30. On November 21, 2024, Commission attorneys called telephone numbers that

Bluesky provided on the Form ADV and to FINRA in connection with the Form ADV filing

process. The calls went to busy tones unanswered.

31. On April 15, 2025, a Commission attorney again emailed Bluesky at the same

addresses that Bluesky provided to FINRA and the New York Department of State. To date,

Bluesky has not responded to any emails.

32. In sum, the Form ADV materially misrepresented information about Bluesky’s

primary business location, status as a public reporting company, and reporting of private fund

clients; and it provided information about its CEO/COO and the amount of private fund assets

under management in the United States that (1) could not be substantiated, (2) Bluesky failed to

provide information about when requested, and (3) is likely false. Further, Bluesky failed to

respond to Commission requests to produce books and records subject to examination.

33. Given the above facts, a reasonable investor would have considered it important

in making their decision to invest with Bluesky to know complete and accurate information

about its organizational structure and management personnel, office location, amount of assets

under management in the United States, and private fund clients.

FIRST CLAIM FOR RELIEF
Violation of Advisers Act Section 204(a)

34. The Commission realleges and incorporates by reference here the allegations in

paragraphs 1 through 33.

8

35. Bluesky failed to make its books and records available to Commission attorneys

for examination.

36. By reason of the foregoing, Bluesky has violated and, unless enjoined, will again

violate Section 204(a) of the Advisers Act [15 U.S.C. § 80b-4(a)].

SECOND CLAIM FOR RELIEF
Violation of Advisers Act Section 207

37. The Commission realleges and incorporates by reference here the allegations in

paragraphs 1 through 33.

38. Bluesky, by use of the mails, and the means and instruments of interstate

commerce, directly and indirectly, willfully made untrue statements of material fact in, and

omitted to state material facts required to be stated in, reports filed with the Commission.

39. By reason of the foregoing, Bluesky, directly or indirectly, has violated and,

unless enjoined, will again violate Section 207 of the Advisers Act [15 U.S.C. § 80b-7].

PRAYER FOR RELIEF

WHEREFORE, the Commission requests that this Court enter a Final Judgment:

I.

 Permanently restraining and enjoining Bluesky and its agents, servants, employees and

attorneys and all persons in active concert or participation with any of them from violating,

directly or indirectly, Sections 204(a) and 207 of the Advisers Act [15 U.S.C. §§ 80b-4(a); 80b-

7].

II.

Permanently restraining and enjoining Bluesky, its owners, and its executive officers,

from filing a Form ADV as an ERA.

9

III.

Ordering Bluesky to pay a civil monetary penalty under Section 209(e) of the Advisers

Act [15 U.S.C. § 80b-9(e)].

IV.

Granting any other and further relief this Court may deem just and proper.

JURY DEMAND

Under Rule 38 of the Federal Rules of Civil Procedure, Plaintiff demands that this case

be tried to a jury.

Dated: November 13, 2025  Respectfully submitted,

/s/ Amy Harman Burkart
Amy Harman Burkart (Attorney Bar Code No. 4090262)
*David H. London (Mass. Bar No. 638789)
*Alexandra Lavin (Mass. Bar No. 687785)
*Xinyue Angela Lin (Mass. Bar. No. 672786)
*Sarah McAteer (Mass. Bar No. 706403)
*Dahlia Rin (Mass. Bar No. 674137)
Attorneys for Plaintiff
U.S. SECURITIES AND EXCHANGE COMMISSION
Boston Regional Office
33 Arch Street, 24th Floor
Boston, MA 02110
Phone: 617-573-8997 (London)
Email: [email protected]

*Not admitted in the S.D.N.Y.

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 

___________________________________________ 
) 

SECURITIES AND EXCHANGE ) 
COMMISSION, ) 

) 
Plaintiff,   ) 

)  Civil Action No. 
v. ) 

) 
BLUESKY EAGLE CAPITAL ) 
MANAGEMENT LTD., ) 

) 
Defendant. ) 

___________________________________________ ) 

COMPLAINT 

Plaintiff Securities and Exchange Commission (“the Commission”) files this Complaint 

against Defendant Bluesky Eagle Capital Management Ltd. (“Bluesky”) and alleges as follows: 

SUMMARY 

1. This case concerns material misrepresentations and statements that could not be

substantiated made by Bluesky, a purported investment adviser, in a form filed with the 

Commission and made available to the public on December 12, 2023, about Bluesky’s 

organization, office location, assets under management, and clients. 

2. Specifically, Bluesky represented in its Form ADV (a form used by investment

advisers to register with both the Commission and state securities regulators) that it is a public 

company operating out of office space on the 52nd floor of 140 Broadway, New York, New 

York 10005 (“140 Broadway”); that Joshua Troy Hunt serves as both its Chief Executive 

Officer (“CEO”) and Chief Operating Officer (“COO”); that it manages $10 million in assets in 

the United States; that it advises a private fund (with the same name as the defendant: Bluesky 

25-cv-9507

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2 

Eagle Capital Management Ltd.); and that a separate registered investment adviser (“RIA”) 

reports information about this private fund to the Commission on its own Form ADV. 

3. Contrary to Bluesky’s representations, the current real estate manager of 140 

Broadway has no knowledge of Bluesky or its purported CEO/COO, and the separate RIA has 

not reported information about the purported private fund. Moreover, the Commission has not 

found any reporting of information about the private fund on other filings made with the 

Commission, and a search of the Commission’s public company database yields no information 

on Bluesky. 

4. In addition, Bluesky failed to respond to a request by Commission attorneys to 

provide records to substantiate the information on the Form ADV, including the amount of 

private fund assets under management in the United States. 

5. By engaging in the conduct described in this Complaint, Bluesky violated, and 

unless enjoined will continue to violate, Sections 204(a) and 207 of the Investment Advisers 

Act of 1940 (the “Advisers Act”) [15 U.S.C. §§ 80b-4(a), 80b-7]. 

NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT 

6. The Commission brings this action under enforcement authority conferred by 

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

7. The Commission seeks a final judgment: (a) permanently enjoining Bluesky 

from violating the federal securities laws this Complaint alleges it has violated; (b) permanently 

enjoining Bluesky, its owners, and its executive officers, from filing a Form ADV as an exempt 

reporting adviser; (c) ordering Bluesky to pay a civil money penalty under Section 209(e) of the 

Advisers Act [15 U.S.C. § 80b-209(e)]; and (d) ordering any other and further relief the Court 

may deem just and proper. 

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3 

JURISDICTION AND VENUE 

8. This Court has jurisdiction over this action under Section 214 of the Advisers 

Act [15 U.S.C. § 80b-14]. 

9. Defendant, directly or indirectly, made use of the means or instrumentalities of 

interstate commerce or of the mails in connection with the transactions, acts, practices, and 

course of business alleged. 

10. Venue is proper in the Southern District of New York under Section 214 of the 

Advisers Act [15 U.S.C. § 80b-14]. Certain of the acts, practices, transactions, and courses of 

business alleged in this Complaint occurred within this District. Specifically, Bluesky 

represented on corporate filings with both the Commission and the New York Department of 

State, Division of Corporations, that its primary business address is 140 Broadway, which is 

located in the District. 

DEFENDANT 

11. Bluesky Eagle Capital Management Ltd. claims that it is a New York 

corporation with a principal place of business at 140 Broadway. On December 5, 2023, Bluesky 

filed a certificate of incorporation with the New York Department of State, Division of 

Corporations, in which it used the name “Joshua Troy Hunt” as the filer and incorporator, and 

listed 140 Broadway as Hunt’s address. The certificate of incorporation designated the 

Secretary of State of New York as the agent of the corporation upon whom process may be 

served. 

FACTS 

I. Investment Adviser Registration and Commission Form ADV 

12. The Commission regulates investment advisers, primarily under the Advisers Act 

and the rules adopted under that statute. One of the central elements of the regulatory program 

is the requirement that an “investment adviser” under the Advisers Act register with the 

Case 1:25-cv-09507     Document 1     Filed 11/13/25     Page 3 of 9



4 

Commission, unless exempt or prohibited from registration. Generally, only larger advisers that 

have $100 million or more of regulatory assets under management, or that provide advice to 

investment company clients, are permitted to register with the Commission. Smaller advisers 

register under state law with state securities authorities. 

13. Exempt reporting advisers (“ERAs”) are a category of investment advisers who 

would otherwise be required to register with the Commission under the Advisers Act but for the 

specific exemptions outlined in Section 203 of the Advisers Act. ERAs include an adviser to 

private funds with less than $150 million in assets under management in the United States. The 

registration exemption for such private fund advisers is Section 203(m) of the Advisers Act and 

Rule 203(m)-1 thereunder. 

14. While ERAs are exempt from the registration requirements, any books or records 

they do maintain are subject to examination by the Commission under Section 204(a) of the 

Advisers Act. 

15. Form ADV is the form used by investment advisers to register with the 

Commission and with state securities authorities. It consists of two parts, both of which are 

required to be filed with the Commission, and both of which are publicly available once filed: 

Form ADV Part 1 and Form ADV Part 2. 

16. ERAs, while exempt from registration, are still required to file certain items in 

Form ADV Part 1. ERAs do not complete Part 2. 

17. Part 1 asks for information about, among other things, an adviser’s business, 

amount of assets under management, ownership, and clients. 

18. Form ADV is filed electronically with the Commission through the Investment 

Adviser Registration Depository (“IARD”), a secure Internet based filing system that collects 

and maintains the registration, reporting, and disclosure information for investment advisers. 

The Financial Industry Regulatory Authority (“FINRA”), under contract with the Commission, 

Case 1:25-cv-09507     Document 1     Filed 11/13/25     Page 4 of 9



5 

is the developer and operator of the IARD system. Once filed, the Form ADV is available to the 

public through the Commission’s Investment Adviser Public Disclosure database, located at 

https://adviserinfo.sec.gov. 

II. Bluesky Made Material Misstatements and Statements in its Form ADV Filed with 
the Commission That Could Not Be Substantiated. 
 
19. On December 12, 2023, Bluesky filed its Form ADV with the Commission as an 

ERA. In that filing, Bluesky claims that it qualifies for a registration exemption because it acts 

solely as an adviser to private funds and has assets under management in the United States of 

less than $150 million. 

20. In the Form ADV, Bluesky lists the 52nd floor of 140 Broadway as its principal 

office and place of business, and states that Joshua Troy Hunt serves as both its CEO and COO. 

Bluesky also provides a telephone number with a (205) area code as the main number for its 

New York office, even though (205) is the area code for the Birmingham, Alabama area. 

21. In the Form ADV section titled “Direct Owners and Executive Officers,” 

Bluesky identifies its “Executive Officers” and its direct owner as itself (that is, Bluesky Eagle 

Capital Management Ltd.). Bluesky also (i) states that it is a public reporting company (often 

referred to as a “public company”), meaning that it must file certain disclosure reports, 

including annual, quarterly, and current reports, with the Commission on an ongoing basis, and 

(ii) provides two Central Index Key (“CIK”) numbers, which are numbers that the Commission 

assigns to a public reporting company and that can be searched on the Commission’s computer 

systems to identify corporations and individuals required to file disclosure information. 

22. The Form ADV represents that the amount of Bluesky’s private fund assets 

under management in the United States is $10 million. 

23. In addition, the Form ADV represents that Bluesky advises a private fund, also 

named “Bluesky Eagle Capital Management Ltd.,” and lists a private fund identification 

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6 

number. The private fund identification number is a unique identification number assigned to a 

private fund. 

24. Bluesky further states in its Form ADV that a separate RIA “provides 

information” about Bluesky’s private fund on its own Form ADV filing.  

25. Contrary to Bluesky’s representations in the Form ADV: 

a. the individual who has served as the real estate manager of 140 

Broadway for the last 12 years has no knowledge of Bluesky or Joshua Troy Hunt as building 

tenants, subtenants, or otherwise. Moreover, 140 Broadway is a 51-story building. The 52nd 

floor does not house tenants, as it is used solely for mechanical purposes; 

b. the third-party RIA has not reported the Bluesky private fund on its Form 

ADV filings. Further, the Commission has not found reporting of the private fund or the 

associated identification number on other filings; and 

c. a search for either Bluesky or its purported CIK numbers on the 

Commission’s public reporting company database yields no information. 

III. Bluesky Failed to Produce Records for Examination. 

26. Section 204(a) of the Advisers Act provides that all records of investment 

advisers are “subject at any time, or from time to time, to such reasonable periodic, special, or 

other examinations by representatives of the Commission as the Commission deems necessary 

or appropriate in the public interest or for the protection of investors.” 15 U.S.C. § 80b-4(a). 

27. Although ERAs are exempt from the registration requirements, any books and 

records they do maintain are subject to examination under Section 204(a). 

28. Since November 13, 2024, Commission attorneys have attempted to obtain 

books and records from Bluesky that it is required to produce under the Advisers Act.  

29. On November 13, 2024 and December 4, 2024, a Commission attorney emailed 

Bluesky a letter requesting production of books and records regarding the information on the 

Case 1:25-cv-09507     Document 1     Filed 11/13/25     Page 6 of 9



7 

Form ADV, including its organizational information and the private fund assets under 

management in the United States. Although the Form ADV itself does not contain an email 

address for Bluesky, the Commission attorney used email addresses that Bluesky provided to (i) 

FINRA in connection with the Form ADV filing process and (ii) the New York Department of 

State in connection with filing its incorporation documents. 

30. On November 21, 2024, Commission attorneys called telephone numbers that 

Bluesky provided on the Form ADV and to FINRA in connection with the Form ADV filing 

process. The calls went to busy tones unanswered. 

31. On April 15, 2025, a Commission attorney again emailed Bluesky at the same 

addresses that Bluesky provided to FINRA and the New York Department of State. To date, 

Bluesky has not responded to any emails. 

32. In sum, the Form ADV materially misrepresented information about Bluesky’s 

primary business location, status as a public reporting company, and reporting of private fund 

clients; and it provided information about its CEO/COO and the amount of private fund assets 

under management in the United States that (1) could not be substantiated, (2) Bluesky failed to 

provide information about when requested, and (3) is likely false. Further, Bluesky failed to 

respond to Commission requests to produce books and records subject to examination.  

33. Given the above facts, a reasonable investor would have considered it important 

in making their decision to invest with Bluesky to know complete and accurate information 

about its organizational structure and management personnel, office location, amount of assets 

under management in the United States, and private fund clients. 

FIRST CLAIM FOR RELIEF 
Violation of Advisers Act Section 204(a) 

 
34. The Commission realleges and incorporates by reference here the allegations in 

paragraphs 1 through 33. 

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8 

35. Bluesky failed to make its books and records available to Commission attorneys 

for examination. 

36. By reason of the foregoing, Bluesky has violated and, unless enjoined, will again 

violate Section 204(a) of the Advisers Act [15 U.S.C. § 80b-4(a)]. 

SECOND CLAIM FOR RELIEF 
Violation of Advisers Act Section 207 

 
37. The Commission realleges and incorporates by reference here the allegations in 

paragraphs 1 through 33. 

38. Bluesky, by use of the mails, and the means and instruments of interstate 

commerce, directly and indirectly, willfully made untrue statements of material fact in, and 

omitted to state material facts required to be stated in, reports filed with the Commission. 

39. By reason of the foregoing, Bluesky, directly or indirectly, has violated and, 

unless enjoined, will again violate Section 207 of the Advisers Act [15 U.S.C. § 80b-7]. 

PRAYER FOR RELIEF 

WHEREFORE, the Commission requests that this Court enter a Final Judgment: 

I. 

 Permanently restraining and enjoining Bluesky and its agents, servants, employees and 

attorneys and all persons in active concert or participation with any of them from violating, 

directly or indirectly, Sections 204(a) and 207 of the Advisers Act [15 U.S.C. §§ 80b-4(a); 80b-

7]. 

II. 

Permanently restraining and enjoining Bluesky, its owners, and its executive officers, 

from filing a Form ADV as an ERA. 

 

 

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9 

III. 

Ordering Bluesky to pay a civil monetary penalty under Section 209(e) of the Advisers 

Act [15 U.S.C. § 80b-9(e)]. 

IV. 

Granting any other and further relief this Court may deem just and proper. 

JURY DEMAND 

Under Rule 38 of the Federal Rules of Civil Procedure, Plaintiff demands that this case 

be tried to a jury.  

 

 

Dated: November 13, 2025  Respectfully submitted, 

/s/ Amy Harman Burkart   
Amy Harman Burkart (Attorney Bar Code No. 4090262) 
*David H. London (Mass. Bar No. 638789) 
*Alexandra Lavin (Mass. Bar No. 687785) 
*Xinyue Angela Lin (Mass. Bar. No. 672786) 
*Sarah McAteer (Mass. Bar No. 706403) 
*Dahlia Rin (Mass. Bar No. 674137) 
Attorneys for Plaintiff 
U.S. SECURITIES AND EXCHANGE COMMISSION 
Boston Regional Office 
33 Arch Street, 24th Floor 
Boston, MA 02110 
Phone: 617-573-8997 (London) 
Email: [email protected] 
 
*Not admitted in the S.D.N.Y. 
 

 
 

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