SEC v. Charles Parrino, No. 1:22-cv-03888, Northern District of Georgia (Sept. 28, 2022) — Complaint

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

                                                                                     )
SECURITIES AND EXCHANGE COMMISSION,  )
            )
    Plaintiff,        ) Civil Action No.
            )
v.      )
                     )
CHARLES PARRINO,           )
            )
    Defendant.          )
                                                                                     )

Plaintiff Securities and Exchange Commission (the “Commission”) files this
Complaint against Defendant Charles Parrino (“Parrino” or “Defendant”) and
alleges as follows:
SUMMARY
1. Between October 2017 and January 2020 (the “Relevant Period”),
Parrino participated in a fraudulent scheme to manipulate the market for securities
of publicly-traded companies by creating and disseminating false rumors designed
to cause the price of the target companies’    stock and call options to rise
temporarily.
2. Parrino, a day trader, drafted and edited the false rumors and shared
them with other scheme participants before the rumors were disseminated.  Most of

 2
the rumors were disseminated by the lead trader in the scheme (“Trader A”)  .
Trader A sent the rumors, timed to maximize impact on the price of the securities,
via instant messenger to numerous contacts at real-time financial news services,
financial chat rooms, and certain other financial news purveyors.  Some of these
contacts then immediately disseminated the rumors further through their news
services and in chat rooms and message boards.  As a result, the prices of the
companies’ securities were artificially inflated for a brief period until they were
corrected by the market.
3. During the Relevant Period, Parrino traded around the dissemination
of these false rumors at least 138 times, earning $982,690 in ill  -gotten gains.
4. By virtue of the conduct alleged herein, Parrino violated, and unless
restrained and enjoined will violate again, Section 17(a) of the Securities Act of
1933 (the “Securities Act”) [15 U.S.C. § 77q(a)]; Section 10(b) of the Securities
Exchange Act of 1934 (the “Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5
thereunder [17 C.F.R. § 240.10b-5].
5. The Commission brings this action pursuant to Section 20(d) of the
Securities Act [15 U.S.C. § 77t(d)] and Section 21(d) of the Exchange Act [15
U.S.C. §§ 78u(d) and 78u-1].  The Commission seeks a judgment (1) permanently
enjoining Parrino from engaging in the transactions, acts, practices, and courses of
business alleged in this Complaint; and (2) ordering Parrino to pay disgorgement
of $982,690, plus prejudgment interest of $158,208 and civil money penalties

 3
pursuant to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section
21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)] in an amount to be
determined by the Court upon motion of the Commission.  The Commission seeks
any other relief the Court may deem appropriate pursuant to Section 21(d)(5) of the
Exchange Act [15 U.S.C. § 78u(d)(5)].
JURISDICTION AND VENUE
6. This Court has jurisdiction over this action pursuant to Section 20 and
22 of the Securities Act [15 U.S.C. §§ 77t and 77v] and Sections 21(d), 21(e), and
27 of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), 78u-l, and 78aa].
7. Venue lies in this District pursuant to Section 22 of the Securities Act
[15 U.S.C. § 77v] and Section 27 of the Exchange Act [15 U.S.C. § 78aa].  In
particular, certain of the acts, practices, transactions, and courses of business
constituting the violations occurred within the Northern District of Georgia.
8. Defendant communicated regularly throughout the Relevant Period
with Trader A and another scheme participant (“Trader B”), both of whom, during
the time of the events described herein, resided within the Northern District of
Georgia.  Defendant’s communications with Trader A and Trader B included
communications containing the false rumors and enabled Defendant to execute
trades designed to profit from the price manipulation caused by the scheme.

 4
DEFENDANT
9. Parrino, age 56, currently resides in West Palm Beach, Florida and
resided in Palm Beach Gardens, Florida during the Relevant Period.  During much
of the Relevant Period, Parrino was a day trader associated with a registered
broker-dealer at which he traded securities for his own account.
FACTS
I. Parrino and the Other Scheme Participants Create and Disseminate
False Rumors.
10. Parrino has known Trader B and another scheme participant (“Trader
C”) for decades, having previously worked with both of them at securities trading
firms.  In approximately 2016, Parrino was introduced to Trader A by Trader C,
after which the scheme participants began regularly discussing trading ideas via
phone calls, instant messenger, and encrypted communications.
11. Beginning in late 2016, Parrino and the other scheme participants
discussed creating false rumors about publicly traded companies, utilizing their
knowledge of the markets to craft believable rumors, and trading around those
rumors in order to ensure themselves profitable trades.
12. Parrino, Trader B, and Trader C regularly discussed which companies
they considered to be good candidates for false rumors, and on many occasions,
they solicited Trader A’s opinions.  Parrino, Trader B, and Trader C specifically

 5
focused on companies with publicly-traded short-term call options to help
maximize the price impact on the companies’ securities and their own profits.
13. Based on those discussions, Parrino and Trader B composed rumors
about corporate mergers or acquisitions, large investments by hedge funds or
private equity firms, or other potential market-moving events.  After Parrino,
Trader B and/or Trader C reviewed and edited the rumors, one of them would send
the rumors to Trader A, who resided in northern Georgia.
14. Trader A then transmitted the false rumors via instant messenger to
his numerous contacts at real-time financial news services, subscription-based
financial chat rooms, and other financial news purveyors with sizable followings.
Within minutes, if not seconds, the false rumors began appearing as “chatter” –
i.e., the subject of discussion – on several of the financial news services and in the
chat rooms and message boards that had been contacted.  Trader A also shared the
rumors with Trader D, the host of a daily subscription based real-time trading
broadcast who was located in New Jersey.  Trader D shared information regarding
the false rumors on his trading broadcast.
15. In some instances, Parrino directly sent the rumor to his own financial
news industry contacts.
16. This process of creating and disseminating false rumors was repeated
numerous times over the Relevant Period.

 6
II. Parrino Trades Profitably around the False Rumors.
17. Before the false rumors were disseminated, Parrino, Trader A, Trader
B, Trader C, and Trader D purchased securities of the publicly-traded companies
that were the subject of the false rumors.
18. Parrino often purchased a combination of stock and short-term call
options that usually expired within a day or two.  His purchases typically occurred
from between several hours before to a few seconds after the rumors were
disseminated by Trader A.  On rare occasions, Parrino began purchasing securities
the day before Trader A disseminated the false rumors.
19. The spread of the false rumors through various news services and in
financial chat rooms, as well as the scheme participants’ own purchases, caused an
uptick in trading volume and typically resulted in an increase in the subject
companies’ securities prices.  Though the percentage increase in the companies’
stock prices   was usually modest, typically less than 2%, the percentage increase in
the price of the companies’ short-term call options was frequently significant,  often
exceeding 25%.
20. All of the scheme participants, including Parrino, almost always
began selling their positions within minutes, if not seconds, after Trader A pushed
the false rumors   out to his industry contacts.
21. Parrino traded at least 138 times around the false rumors, earning
$982,690 in ill-gotten gains during the Relevant Period.  An Appendix identifying

 7
the date and ticker symbol of the 138 instances, as well as the amount of ill  -gotten
gains Parrino earned from his trading in each instance is attached hereto.
III. Examples of Parrino’s Participation in the Market Manipulation Fraud
A. February 2018 Company A Rumor
22. On February 1, 2018 at 10:25:02 am, Parrino sent the following
proposed rumor to Trader B and Trader C:
A spokeswoman for the California Department of Forestry and
Fire Protection is stating that after thorough investigation it has
determined that the fires that decimated a Santa Rosa
neighborhood and killed 21 people was caused by electrical
equipment owned, installed, and maintained by a third party
exonerating [Company A] from all liability.
23. Trader B responded “seller let’s wait” and that “will let you know
when I buy.” At 11:37:09 am, Trader B messaged Parrino and Trader C that he had
purchased securities in Company A.  Thirty seconds later, Parrino messaged Trader
A to “pik [sic] up,” and at 11:40:57 am, Parrino sent the rumor to Trader A.  At
11:48:58 am, nearly eight minutes after he first received the rumor, Trader A
disseminated the rumor via instant messenger to his financial headline news
services and chatroom contacts.
24. Parrino began purchasing Company A stock and call options at
11:47:49 am, one minute before Trader A pushed the rumor, and continued
purchasing until 11:49:04   am, six seconds after Trader A pushed the rumor.

 8
25. The false rumor was repeated by the financial websites and chat
rooms and promptly caused an increase in the trading volume and price of
Company A’s stock and options.   The price increase was so significant that trading
in Company A securities was temporarily halted at 11:53 am and spokespersons
for Company A and the California Department of Forestry and Fire Protection each
subsequently issued respective statements that the rumor was false.
26. Parrino began selling his Company A securities at 11:49:53 am, less
than one minute after Trader A pushed the rumor, resulting in unlawful profits of
$58,063.  Trader A, Trader B, and Trader C also traded around the Company A
rumor, generating over $28,000 in unlawful profits.
B. July 2018 Company B Rumor
27. On July 25, 2018, Parrino sent a message to Trader B instructing him
to work on a rumor for Company B.  Parrino and Trader B discussed potential
rumors involving Company B, and at 9:28:58 am, Trader B sent Parrino the
following draft rumor:  “Hearing that [Company C] has made an offer to acquire
[Company B] for $50 a share.”  Later that day, Parrino, Trader B, and Trader C
discussed the timing for the Company B rumor, and decided to hold off sending the
rumor to Trader A because Parrino noted there was a “seller in [Company B].”
28. The next morning, July 26, 2018, at 8:55:31 am, Trader B sent Parrino
and Trader C the Company B rumor, to which Trader C responded “[Company B]
looks good.” At 10:48:59 am, Trader B sent the rumor to Trader A and informed

 9
Parrino and Trader C that “I sent” and “he is doing it.”  At 10:49:53 am,  Trader A
pushed the rumor to his financial headline news services and chatroom contacts.
29. Parrino purchased Company B stock and call options between
10:36:54 am, thirteen minutes before Trader A pushed the rumor, and 10:49:58 am,
five seconds after he pushed the rumor.
30. The financial websites and chat rooms repeated the false rumor, which
promptly caused an increase in the trading volume and price of Company B’   s stock
and options.
31. At 10:50:57 am, approximately one minute after Trader A
disseminated the rumor, Parrino began selling the Company B stock and call
options he had purchased, resulting in ill-gotten gains of $12,501.  The other four
scheme participants also traded profitably around the Company B rumor,
generating approximately $16,000 in ill-gotten gains.
FIRST CLAIM FOR RELIEF

Violation of Section 17(a) of the Securities Act
32. The Commission realleges and incorporates by reference paragraphs 1
through 32, as though fully set forth herein.
33. By virtue of the foregoing, Parrino, directly or indirectly, singly or in
concert with others, in the offer or sale of any security, with scienter, used the
means or instruments of transportation or communication in interstate commerce
or of the mails to: (a) employ any device, scheme, or artifice to defraud; (b) obtain

 10
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; and (c) engage
in any transaction, practice, or course of business which operated or would operate
as a fraud or deceit upon the purchaser.
34. By virtue of the foregoing, Parrino, directly or indirectly, violated and,
unless restrained and enjoined, will again violate, Section 17(a) of the Securities
Act [15 U.S.C. § 77q(a)].

SECOND CLAIM FOR RELIEF
Violation of Section 10(b) of the Exchange Act and Rules   10b-5(a), (b) and (c)
Thereunder

35. The Commission realleges and incorporates by reference paragraphs 1
through 35, as though fully set forth herein.
36. By virtue of the foregoing, Parrino, directly or indirectly, singly or in
concert with others, in connection with the purchase or sale of a security, with
scienter, used the means or instrumentalities of interstate commerce, or of the
mails, or of a facility of a national securities exchange to: (1) employ devices,
schemes, or artifices to defraud; (2) make untrue statements of a material fact or to
omit to state material facts necessary in order to make the statements made, in the
light of the circumstances under which they were made, not misleading; and (3)

 11
engage in acts, practices, or courses of business which operated or would operate
as a fraud or deceit upon others.
37. By virtue of the foregoing, Parrino, directly or indirectly, violated and,
unless restrained and enjoined, will again violate, Section 10(b) of the Exchange
Act [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. §   240.10b-5].
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that this Court enter
a Judgment:
I.
Finding that Parrino violated the provisions of the federal securities laws as
alleged herein;
II.
Permanently restraining and enjoining Parrino and his agents, servants,
employees, and attorneys and all persons in active concert or participation with
him who receive actual notice of the injunction by personal service or otherwise
from, directly or indirectly, engaging in conduct in violation of Section 17(a) of the
Securities Act [15 U.S.C. § 77q(a)] and Section 10(b) of the Exchange Act [15
U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5];

 12
III.
Ordering Parrino to pay disgorgement of $982,690, along with prejudgment
interest of $158,208 pursuant to Section 21(d)(7) of the Exchange Act [15 U.S.C. §
78u(d)(7)].
IV.
Ordering Parrino to pay a civil monetary penalty pursuant to Section 20(d)
of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange
Act [15 U.S.C. § 78u(d)(3)].  The Court shall determine the amounts of the civil
penalty upon motion of the Commission; and
V.
Granting such other and further relief as this Court may deem just and
proper.

Dated:  September 27, 2022
      /s/ James M. Carlson
      James M. Carlson
      Supervisory Trial Counsel
      D.C. Bar # 981364
      U.S. Securities and Exchange Commission
      100 F St. NE
SP3 –   Mail Stop 5971
      Washington, DC 20549
      Direct (202) 551-3711/Fax: (703) 813-9314
      [email protected]

 13
APPENDIX
PARRINO’S PROFITS FROM TRADING
AROUND THE DISSEMINATION OF FALSE RUMORS

Rumor/Trade Date Ticker Symbol Parrino's Trading Profits

1 12/12/2017 PRGO $2,932

2 12/13/2017 XLNX $2,544

3 12/20/2017 CBS $6,363

4 12/21/2017 ETFC $5,982

5 1/3/2018 HUM $6,633

6 1/8/2018 BBBY --

7 1/9/2018 CI $7,402

8 1/12/2018 YELP $10,468

9 1/18/2018 EA $8,114

10 1/18/2018 IP $3,924

11 1/19/2018 FOSL $6,571

12 1/19/2018 ULTA $7,783

13 1/22/2018 AMD $4,937

14 1/23/2018 PEP $6,658

15 1/25/2018 JD $173

16 1/29/2018 MOS $5,334

17 2/1/2018 PCG $58,063

18 2/13/2018 UPS $21,729

19 2/14/2018 TIF $1,528

20 2/15/2018 TMUS $20,366

21 2/16/2018 WYNN $20,556

22 2/20/2018 CREE --

23 2/22/2018 LLY $16

24 3/1/2018 TXT $8,955

25 3/6/2018 ON $4,880

26 3/7/2018 HFC $3,897

27 3/8/2018 DIS $6,884

28 3/9/2018 HIG $4,417

29 3/15/2018 AMAT $6,220

30 3/15/2018 GLW $1,079

31 3/23/2018 HES --

32 3/26/2018 TAP --

33 3/27/2018 FOSL $1,950

34 4/5/2018 SYF $9,589

35 4/10/2018 GRA $12,288

36 4/10/2018 WMB $3,902

 14

37 4/11/2018 LNG $9,975

38 4/12/2018 HOG $682

39 4/12/2018 LUV $26,482

40 4/13/2018 HAS $568

41 4/17/2018 EAT $7,199

42 4/18/2018 BEN $8,220

43 4/18/2018 FDX $4,262

44 4/19/2018 EA $6,455

45 4/20/2018 WDC $20,690

46 4/20/2018 W $884

47 4/24/2018 EOG --

48 4/24/2018 DISH --

49 4/25/2018 DKS --

50 5/1/2018 AZN $4,151

51 5/2/2018 CHKP --

52 5/3/2018 WDAY $6,763

53 5/4/2018 ALXN --

54 5/9/2018 ETFC $3,218

55 5/9/2018 CELG --

56 5/15/2018 FSLR $11,577

57 5/16/2018 SFM $13,013

58 5/17/2018 STX --

59 5/23/2018 PZZA $7,249

60 5/24/2018 IP $4,549

61 5/24/2018 AKAM --

62 5/30/2018 CL --

63 5/31/2018 AAL $10,711

64 6/5/2018 ETN $27,068

65 6/14/2018 TER --

66 6/15/2018 CAKE $20,437

67 6/20/2018 REGN $17,291

68 6/21/2018 WYNN $249

69 7/11/2018 MO $2,743

70 7/12/2018 NKE $20,109

71 7/20/2018 CELG $3,351

72 7/25/2018 RHT $6,525

73 7/26/2018 PFE $4

74 7/26/2018 YELP $12,501

75 7/31/2018 CAH $4,562

76 8/2/2018 EPC $741

77 8/3/2018 IBM $26,516

78 8/3/2018 OSTK --

 15

79 8/7/2018 LB --

80 8/8/2018 WYNN $34,075

81 8/9/2018 GM $16,124

82 8/15/2018 IBM --

83 8/16/2018 LYV --

84 8/22/2018 EA $25,862

85 8/22/2018 DE --

86 9/5/2018 LNC $3,129

87 9/21/2018 AGN $5,394

88 9/26/2018 IP --

89 9/27/2018 WDC --

90 11/9/2018 KBH $5,636

91 11/16/2018 V $9,017

92 11/27/2018 ETFC --

93 12/20/2018 ATVI $6,653

94 1/15/2019 SFIX $3,390

95 1/17/2019 SKX $16,760

96 1/30/2019 AA $2,520

97 2/6/2019 KMB $14,324

98 2/28/2019 SYF --

99 3/13/2019 HBI $2,797

100 3/27/2019 FOSL --

101 3/28/2019 DAL --

102 4/10/2019 URBN $3,908

103 5/16/2019 FDX $7,501

104 6/11/2019 BB $11,237

105 6/26/2019 DBX $2,405

106 8/1/2019 XLNX $5,055

107 8/15/2019 K $7,767

108 8/27/2019 YELP $4,350

109 9/5/2019 KSS $9,512

110 9/11/2019 SPLK $16,302

111 9/20/2019 TPR $5,374

112 9/25/2019 JNPR $959

113 9/26/2019 WYNN $9,995

114 9/27/2019 WHR $7,172

115 10/10/2019 GILD $10,530

116 10/16/2019 IP $9,316

117 10/17/2019 ULTA $8,487

118 10/24/2019 ATVI $4,607

119 10/25/2019 UPS $18,499

120 10/30/2019 BUD $8,910

 16

121 11/5/2019 CL $12,559

122 11/6/2019 YUM $11,819

123 11/8/2019 AAL $6,001

124 11/12/2019 TWLO $8,274

125 11/15/2019 DPZ $2,867

126 11/21/2019 AXP $10,382

127 12/9/2019 HLF --

128 12/10/2019 IBM $2,178

129 12/10/2019 HOG $2,814

130 12/11/2019 EXEL $2,459

131 12/18/2019 CREE $2,996

132 12/19/2019 NTAP $556

133 1/8/2020 FDX $14,245

134 1/9/2020 PINS $8,868

135 1/10/2020 EXAS $970

136 1/10/2020 WYNN $15,356

137 1/14/2020 COF $10,966

138 1/14/2020 UBER $10,931

  Total   $982,690

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 

 
                                                                                         
                                                                                     )   
SECURITIES AND EXCHANGE COMMISSION,  ) 
            ) 
    Plaintiff,        ) Civil Action No.  
            ) 

v.      )  
                    )  
CHARLES PARRINO,          )  
            ) 
    Defendant.        ) 
                                                                                     )     
 
 

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

Complaint against Defendant Charles Parrino (“Parrino” or “Defendant”) and 

alleges as follows: 

SUMMARY 

1. Between October 2017 and January 2020 (the “Relevant Period”), 

Parrino participated in a fraudulent scheme to manipulate the market for securities 

of publicly-traded companies by creating and disseminating false rumors designed 

to cause the price of the target companies’ stock and call options to rise 

temporarily. 

2. Parrino, a day trader, drafted and edited the false rumors and shared 

them with other scheme participants before the rumors were disseminated.  Most of 

Case 1:22-cv-03888-JPB   Document 1   Filed 09/27/22   Page 1 of 16



 

 2 

the rumors were disseminated by the lead trader in the scheme (“Trader A”).  

Trader A sent the rumors, timed to maximize impact on the price of the securities, 

via instant messenger to numerous contacts at real-time financial news services, 

financial chat rooms, and certain other financial news purveyors.  Some of these 

contacts then immediately disseminated the rumors further through their news 

services and in chat rooms and message boards.  As a result, the prices of the 

companies’ securities were artificially inflated for a brief period until they were 

corrected by the market.  

3. During the Relevant Period, Parrino traded around the dissemination 

of these false rumors at least 138 times, earning $982,690 in ill-gotten gains.   

4. By virtue of the conduct alleged herein, Parrino violated, and unless 

restrained and enjoined will violate again, Section 17(a) of the Securities Act of 

1933 (the “Securities Act”) [15 U.S.C. § 77q(a)]; Section 10(b) of the Securities 

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

thereunder [17 C.F.R. § 240.10b-5]. 

5. The Commission brings this action pursuant to Section 20(d) of the 

Securities Act [15 U.S.C. § 77t(d)] and Section 21(d) of the Exchange Act [15 

U.S.C. §§ 78u(d) and 78u-1].  The Commission seeks a judgment (1) permanently 

enjoining Parrino from engaging in the transactions, acts, practices, and courses of 

business alleged in this Complaint; and (2) ordering Parrino to pay disgorgement 

of $982,690, plus prejudgment interest of $158,208 and civil money penalties 

Case 1:22-cv-03888-JPB   Document 1   Filed 09/27/22   Page 2 of 16



 

 3 

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

21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)] in an amount to be 

determined by the Court upon motion of the Commission.  The Commission seeks 

any other relief the Court may deem appropriate pursuant to Section 21(d)(5) of the 

Exchange Act [15 U.S.C. § 78u(d)(5)]. 

JURISDICTION AND VENUE 

6. This Court has jurisdiction over this action pursuant to Section 20 and 

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

27 of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), 78u-l, and 78aa]. 

7. Venue lies in this District pursuant to Section 22 of the Securities Act 

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

particular, certain of the acts, practices, transactions, and courses of business 

constituting the violations occurred within the Northern District of Georgia. 

8. Defendant communicated regularly throughout the Relevant Period 

with Trader A and another scheme participant (“Trader B”), both of whom, during 

the time of the events described herein, resided within the Northern District of 

Georgia.  Defendant’s communications with Trader A and Trader B included 

communications containing the false rumors and enabled Defendant to execute 

trades designed to profit from the price manipulation caused by the scheme.      

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 4 

DEFENDANT 

9. Parrino, age 56, currently resides in West Palm Beach, Florida and 

resided in Palm Beach Gardens, Florida during the Relevant Period.  During much 

of the Relevant Period, Parrino was a day trader associated with a registered 

broker-dealer at which he traded securities for his own account.  

FACTS 

I. Parrino and the Other Scheme Participants Create and Disseminate 

False Rumors. 

10. Parrino has known Trader B and another scheme participant (“Trader 

C”) for decades, having previously worked with both of them at securities trading 

firms.  In approximately 2016, Parrino was introduced to Trader A by Trader C, 

after which the scheme participants began regularly discussing trading ideas via 

phone calls, instant messenger, and encrypted communications.   

11. Beginning in late 2016, Parrino and the other scheme participants 

discussed creating false rumors about publicly traded companies, utilizing their 

knowledge of the markets to craft believable rumors, and trading around those 

rumors in order to ensure themselves profitable trades.   

12. Parrino, Trader B, and Trader C regularly discussed which companies 

they considered to be good candidates for false rumors, and on many occasions, 

they solicited Trader A’s opinions.  Parrino, Trader B, and Trader C specifically 

Case 1:22-cv-03888-JPB   Document 1   Filed 09/27/22   Page 4 of 16



 

 5 

focused on companies with publicly-traded short-term call options to help 

maximize the price impact on the companies’ securities and their own profits. 

13. Based on those discussions, Parrino and Trader B composed rumors 

about corporate mergers or acquisitions, large investments by hedge funds or 

private equity firms, or other potential market-moving events.  After Parrino, 

Trader B and/or Trader C reviewed and edited the rumors, one of them would send 

the rumors to Trader A, who resided in northern Georgia. 

14. Trader A then transmitted the false rumors via instant messenger to 

his numerous contacts at real-time financial news services, subscription-based 

financial chat rooms, and other financial news purveyors with sizable followings.  

Within minutes, if not seconds, the false rumors began appearing as “chatter” – 

i.e., the subject of discussion – on several of the financial news services and in the 

chat rooms and message boards that had been contacted.  Trader A also shared the 

rumors with Trader D, the host of a daily subscription based real-time trading 

broadcast who was located in New Jersey.  Trader D shared information regarding 

the false rumors on his trading broadcast. 

15. In some instances, Parrino directly sent the rumor to his own financial 

news industry contacts.   

16. This process of creating and disseminating false rumors was repeated 

numerous times over the Relevant Period. 

Case 1:22-cv-03888-JPB   Document 1   Filed 09/27/22   Page 5 of 16



 

 6 

II. Parrino Trades Profitably around the False Rumors. 

17. Before the false rumors were disseminated, Parrino, Trader A, Trader 

B, Trader C, and Trader D purchased securities of the publicly-traded companies 

that were the subject of the false rumors.   

18. Parrino often purchased a combination of stock and short-term call 

options that usually expired within a day or two.  His purchases typically occurred 

from between several hours before to a few seconds after the rumors were 

disseminated by Trader A.  On rare occasions, Parrino began purchasing securities 

the day before Trader A disseminated the false rumors.   

19. The spread of the false rumors through various news services and in 

financial chat rooms, as well as the scheme participants’ own purchases, caused an 

uptick in trading volume and typically resulted in an increase in the subject 

companies’ securities prices.  Though the percentage increase in the companies’ 

stock prices was usually modest, typically less than 2%, the percentage increase in 

the price of the companies’ short-term call options was frequently significant, often 

exceeding 25%. 

20. All of the scheme participants, including Parrino, almost always 

began selling their positions within minutes, if not seconds, after Trader A pushed 

the false rumors out to his industry contacts.     

21. Parrino traded at least 138 times around the false rumors, earning 

$982,690 in ill-gotten gains during the Relevant Period.  An Appendix identifying 

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the date and ticker symbol of the 138 instances, as well as the amount of ill-gotten 

gains Parrino earned from his trading in each instance is attached hereto.  

III. Examples of Parrino’s Participation in the Market Manipulation Fraud 

A. February 2018 Company A Rumor 

22. On February 1, 2018 at 10:25:02 am, Parrino sent the following 

proposed rumor to Trader B and Trader C: 

A spokeswoman for the California Department of Forestry and 
Fire Protection is stating that after thorough investigation it has 
determined that the fires that decimated a Santa Rosa 
neighborhood and killed 21 people was caused by electrical 
equipment owned, installed, and maintained by a third party 
exonerating [Company A] from all liability. 

23. Trader B responded “seller let’s wait” and that “will let you know 

when I buy.” At 11:37:09 am, Trader B messaged Parrino and Trader C that he had 

purchased securities in Company A.  Thirty seconds later, Parrino messaged Trader 

A to “pik [sic] up,” and at 11:40:57 am, Parrino sent the rumor to Trader A.  At 

11:48:58 am, nearly eight minutes after he first received the rumor, Trader A 

disseminated the rumor via instant messenger to his financial headline news 

services and chatroom contacts. 

24. Parrino began purchasing Company A stock and call options at 

11:47:49 am, one minute before Trader A pushed the rumor, and continued 

purchasing until 11:49:04 am, six seconds after Trader A pushed the rumor. 

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25. The false rumor was repeated by the financial websites and chat 

rooms and promptly caused an increase in the trading volume and price of 

Company A’s stock and options.  The price increase was so significant that trading 

in Company A securities was temporarily halted at 11:53 am and spokespersons 

for Company A and the California Department of Forestry and Fire Protection each 

subsequently issued respective statements that the rumor was false. 

26. Parrino began selling his Company A securities at 11:49:53 am, less 

than one minute after Trader A pushed the rumor, resulting in unlawful profits of 

$58,063.  Trader A, Trader B, and Trader C also traded around the Company A 

rumor, generating over $28,000 in unlawful profits. 

B. July 2018 Company B Rumor 

27. On July 25, 2018, Parrino sent a message to Trader B instructing him 

to work on a rumor for Company B.  Parrino and Trader B discussed potential 

rumors involving Company B, and at 9:28:58 am, Trader B sent Parrino the 

following draft rumor:  “Hearing that [Company C] has made an offer to acquire 

[Company B] for $50 a share.”  Later that day, Parrino, Trader B, and Trader C 

discussed the timing for the Company B rumor, and decided to hold off sending the 

rumor to Trader A because Parrino noted there was a “seller in [Company B].”  

28. The next morning, July 26, 2018, at 8:55:31 am, Trader B sent Parrino 

and Trader C the Company B rumor, to which Trader C responded “[Company B] 

looks good.” At 10:48:59 am, Trader B sent the rumor to Trader A and informed 

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Parrino and Trader C that “I sent” and “he is doing it.”  At 10:49:53 am, Trader A 

pushed the rumor to his financial headline news services and chatroom contacts.  

29. Parrino purchased Company B stock and call options between 

10:36:54 am, thirteen minutes before Trader A pushed the rumor, and 10:49:58 am, 

five seconds after he pushed the rumor.   

30. The financial websites and chat rooms repeated the false rumor, which 

promptly caused an increase in the trading volume and price of Company B’s stock 

and options. 

31. At 10:50:57 am, approximately one minute after Trader A 

disseminated the rumor, Parrino began selling the Company B stock and call 

options he had purchased, resulting in ill-gotten gains of $12,501.  The other four 

scheme participants also traded profitably around the Company B rumor, 

generating approximately $16,000 in ill-gotten gains. 

FIRST CLAIM FOR RELIEF 
 

Violation of Section 17(a) of the Securities Act 

32. The Commission realleges and incorporates by reference paragraphs 1 

through 32, as though fully set forth herein. 

33. By virtue of the foregoing, Parrino, directly or indirectly, singly or in 

concert with others, in the offer or sale of any security, with scienter, used the 

means or instruments of transportation or communication in interstate commerce 

or of the mails to: (a) employ any device, scheme, or artifice to defraud; (b) obtain 

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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; and (c) engage 

in any transaction, practice, or course of business which operated or would operate 

as a fraud or deceit upon the purchaser. 

34. By virtue of the foregoing, Parrino, directly or indirectly, violated and, 

unless restrained and enjoined, will again violate, Section 17(a) of the Securities 

Act [15 U.S.C. § 77q(a)]. 

 
SECOND CLAIM FOR RELIEF 

Violation of Section 10(b) of the Exchange Act and Rules 10b-5(a), (b) and (c) 
Thereunder 

 
35. The Commission realleges and incorporates by reference paragraphs 1 

through 35, as though fully set forth herein. 

36. By virtue of the foregoing, Parrino, directly or indirectly, singly or in 

concert with others, in connection with the purchase or sale of a security, with 

scienter, used the means or instrumentalities of interstate commerce, or of the 

mails, or of a facility of a national securities exchange to: (1) employ devices, 

schemes, or artifices to defraud; (2) make untrue statements of a material fact or to 

omit to state material facts necessary in order to make the statements made, in the 

light of the circumstances under which they were made, not misleading; and (3) 

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engage in acts, practices, or courses of business which operated or would operate 

as a fraud or deceit upon others.  

37. By virtue of the foregoing, Parrino, directly or indirectly, violated and, 

unless restrained and enjoined, will again violate, Section 10(b) of the Exchange 

Act [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]. 

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that this Court enter 

a Judgment: 

I.  

Finding that Parrino violated the provisions of the federal securities laws as 

alleged herein; 

II.  

Permanently restraining and enjoining Parrino and his agents, servants, 

employees, and attorneys and all persons in active concert or participation with 

him who receive actual notice of the injunction by personal service or otherwise 

from, directly or indirectly, engaging in conduct in violation of Section 17(a) of the 

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

U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]; 

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III.  

Ordering Parrino to pay disgorgement of $982,690, along with prejudgment 

interest of $158,208 pursuant to Section 21(d)(7) of the Exchange Act [15 U.S.C. § 

78u(d)(7)].  

IV.  

Ordering Parrino to pay a civil monetary penalty pursuant to Section 20(d) 

of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange 

Act [15 U.S.C. § 78u(d)(3)].  The Court shall determine the amounts of the civil 

penalty upon motion of the Commission; and 

V.  

Granting such other and further relief as this Court may deem just and 

proper. 

 
 
 
Dated:  September 27, 2022 
      /s/ James M. Carlson  
      James M. Carlson 
      Supervisory Trial Counsel 
      D.C. Bar # 981364 
      U.S. Securities and Exchange Commission 
      100 F St. NE 

SP3 – Mail Stop 5971 
      Washington, DC 20549 
      Direct (202) 551-3711/Fax: (703) 813-9314 
      [email protected]    
 
 
 
  

Case 1:22-cv-03888-JPB   Document 1   Filed 09/27/22   Page 12 of 16

mailto:[email protected]


 

 13 

APPENDIX 
PARRINO’S PROFITS FROM TRADING  

AROUND THE DISSEMINATION OF FALSE RUMORS 
 

 

  Rumor/Trade Date Ticker Symbol Parrino's Trading Profits 
 1 12/12/2017 PRGO $2,932 
 2 12/13/2017 XLNX $2,544 
 3 12/20/2017 CBS $6,363 
 4 12/21/2017 ETFC $5,982 
 5 1/3/2018 HUM $6,633 
 6 1/8/2018 BBBY --     
 7 1/9/2018 CI $7,402 
 8 1/12/2018 YELP $10,468 
 9 1/18/2018 EA $8,114 
 10 1/18/2018 IP $3,924 
 11 1/19/2018 FOSL $6,571 
 12 1/19/2018 ULTA $7,783 
 13 1/22/2018 AMD $4,937 
 14 1/23/2018 PEP $6,658 
 15 1/25/2018 JD $173 
 16 1/29/2018 MOS $5,334 
 17 2/1/2018 PCG $58,063 
 18 2/13/2018 UPS $21,729 
 19 2/14/2018 TIF $1,528 
 20 2/15/2018 TMUS $20,366 
 21 2/16/2018 WYNN $20,556 
 22 2/20/2018 CREE --     
 23 2/22/2018 LLY $16 
 24 3/1/2018 TXT $8,955 
 25 3/6/2018 ON $4,880 
 26 3/7/2018 HFC $3,897 
 27 3/8/2018 DIS $6,884 
 28 3/9/2018 HIG $4,417 
 29 3/15/2018 AMAT $6,220 
 30 3/15/2018 GLW $1,079 
 31 3/23/2018 HES --     
 32 3/26/2018 TAP --     
 33 3/27/2018 FOSL $1,950 
 34 4/5/2018 SYF $9,589 
 35 4/10/2018 GRA $12,288 
 36 4/10/2018 WMB $3,902 

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 37 4/11/2018 LNG $9,975 
 38 4/12/2018 HOG $682 
 39 4/12/2018 LUV $26,482 
 40 4/13/2018 HAS $568 
 41 4/17/2018 EAT $7,199 
 42 4/18/2018 BEN $8,220 
 43 4/18/2018 FDX $4,262 
 44 4/19/2018 EA $6,455 
 45 4/20/2018 WDC $20,690 
 46 4/20/2018 W $884 
 47 4/24/2018 EOG --     
 48 4/24/2018 DISH --     
 49 4/25/2018 DKS --     
 50 5/1/2018 AZN $4,151 
 51 5/2/2018 CHKP --     
 52 5/3/2018 WDAY $6,763 
 53 5/4/2018 ALXN --     
 54 5/9/2018 ETFC $3,218 
 55 5/9/2018 CELG --     
 56 5/15/2018 FSLR $11,577 
 57 5/16/2018 SFM $13,013 
 58 5/17/2018 STX --     
 59 5/23/2018 PZZA $7,249 
 60 5/24/2018 IP $4,549 
 61 5/24/2018 AKAM --     
 62 5/30/2018 CL --     
 63 5/31/2018 AAL $10,711 
 64 6/5/2018 ETN $27,068 
 65 6/14/2018 TER --     
 66 6/15/2018 CAKE $20,437 
 67 6/20/2018 REGN $17,291 
 68 6/21/2018 WYNN $249 
 69 7/11/2018 MO $2,743 
 70 7/12/2018 NKE $20,109 
 71 7/20/2018 CELG $3,351 
 72 7/25/2018 RHT $6,525 
 73 7/26/2018 PFE $4 
 74 7/26/2018 YELP $12,501 
 75 7/31/2018 CAH $4,562 
 76 8/2/2018 EPC $741 
 77 8/3/2018 IBM $26,516 
 78 8/3/2018 OSTK --     

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 79 8/7/2018 LB --     
 80 8/8/2018 WYNN $34,075 
 81 8/9/2018 GM $16,124 
 82 8/15/2018 IBM --     
 83 8/16/2018 LYV --     
 84 8/22/2018 EA $25,862 
 85 8/22/2018 DE --     
 86 9/5/2018 LNC $3,129 
 87 9/21/2018 AGN $5,394 
 88 9/26/2018 IP --     
 89 9/27/2018 WDC --     
 90 11/9/2018 KBH $5,636 
 91 11/16/2018 V $9,017 
 92 11/27/2018 ETFC --     
 93 12/20/2018 ATVI $6,653 
 94 1/15/2019 SFIX $3,390 
 95 1/17/2019 SKX $16,760 
 96 1/30/2019 AA $2,520 
 97 2/6/2019 KMB $14,324 
 98 2/28/2019 SYF --     
 99 3/13/2019 HBI $2,797 
 100 3/27/2019 FOSL --     
 101 3/28/2019 DAL --     
 102 4/10/2019 URBN $3,908 
 103 5/16/2019 FDX $7,501 
 104 6/11/2019 BB $11,237 
 105 6/26/2019 DBX $2,405 
 106 8/1/2019 XLNX $5,055 
 107 8/15/2019 K $7,767 
 108 8/27/2019 YELP $4,350 
 109 9/5/2019 KSS $9,512 
 110 9/11/2019 SPLK $16,302 
 111 9/20/2019 TPR $5,374 
 112 9/25/2019 JNPR $959 
 113 9/26/2019 WYNN $9,995 
 114 9/27/2019 WHR $7,172 
 115 10/10/2019 GILD $10,530 
 116 10/16/2019 IP $9,316 
 117 10/17/2019 ULTA $8,487 
 118 10/24/2019 ATVI $4,607 
 119 10/25/2019 UPS $18,499 
 120 10/30/2019 BUD $8,910 

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 121 11/5/2019 CL $12,559 
 122 11/6/2019 YUM $11,819 
 123 11/8/2019 AAL $6,001 
 124 11/12/2019 TWLO $8,274 
 125 11/15/2019 DPZ $2,867 
 126 11/21/2019 AXP $10,382 
 127 12/9/2019 HLF --     
 128 12/10/2019 IBM $2,178 
 129 12/10/2019 HOG $2,814 
 130 12/11/2019 EXEL $2,459 
 131 12/18/2019 CREE $2,996 
 132 12/19/2019 NTAP $556 
 133 1/8/2020 FDX $14,245 
 134 1/9/2020 PINS $8,868 
 135 1/10/2020 EXAS $970 
 136 1/10/2020 WYNN $15,356 
 137 1/14/2020 COF $10,966 
 138 1/14/2020 UBER $10,931 
         
   Total   $982,690 

 

Case 1:22-cv-03888-JPB   Document 1   Filed 09/27/22   Page 16 of 16


	SUMMARY
	1. Between October 2017 and January 2020 (the “Relevant Period”), Parrino participated in a fraudulent scheme to manipulate the market for securities of publicly-traded companies by creating and disseminating false rumors designed to cause the price o...
	2. Parrino, a day trader, drafted and edited the false rumors and shared them with other scheme participants before the rumors were disseminated.  Most of the rumors were disseminated by the lead trader in the scheme (“Trader A”).  Trader A sent the r...
	3. During the Relevant Period, Parrino traded around the dissemination of these false rumors at least 138 times, earning $982,690 in ill-gotten gains.
	4. By virtue of the conduct alleged herein, Parrino violated, and unless restrained and enjoined will violate again, Section 17(a) of the Securities Act of 1933 (the “Securities Act”) [15 U.S.C. § 77q(a)]; Section 10(b) of the Securities Exchange Act ...
	5. The Commission brings this action pursuant to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d) of the Exchange Act [15 U.S.C. §§ 78u(d) and 78u-1].  The Commission seeks a judgment (1) permanently enjoining Parrino from en...

	JURISDICTION AND VENUE
	6. This Court has jurisdiction over this action pursuant to Section 20 and 22 of the Securities Act [15 U.S.C. §§ 77t and 77v] and Sections 21(d), 21(e), and 27 of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), 78u-l, and 78aa].
	7. Venue lies in this District pursuant to Section 22 of the Securities Act [15 U.S.C. § 77v] and Section 27 of the Exchange Act [15 U.S.C. § 78aa].  In particular, certain of the acts, practices, transactions, and courses of business constituting the...
	8. Defendant communicated regularly throughout the Relevant Period with Trader A and another scheme participant (“Trader B”), both of whom, during the time of the events described herein, resided within the Northern District of Georgia.  Defendant’s c...

	DEFENDANT
	9. Parrino, age 56, currently resides in West Palm Beach, Florida and resided in Palm Beach Gardens, Florida during the Relevant Period.  During much of the Relevant Period, Parrino was a day trader associated with a registered broker-dealer at which ...
	10. Parrino has known Trader B and another scheme participant (“Trader C”) for decades, having previously worked with both of them at securities trading firms.  In approximately 2016, Parrino was introduced to Trader A by Trader C, after which the sch...
	11. Beginning in late 2016, Parrino and the other scheme participants discussed creating false rumors about publicly traded companies, utilizing their knowledge of the markets to craft believable rumors, and trading around those rumors in order to ens...
	12. Parrino, Trader B, and Trader C regularly discussed which companies they considered to be good candidates for false rumors, and on many occasions, they solicited Trader A’s opinions.  Parrino, Trader B, and Trader C specifically focused on compani...
	13. Based on those discussions, Parrino and Trader B composed rumors about corporate mergers or acquisitions, large investments by hedge funds or private equity firms, or other potential market-moving events.  After Parrino, Trader B and/or Trader C r...
	14. Trader A then transmitted the false rumors via instant messenger to his numerous contacts at real-time financial news services, subscription-based financial chat rooms, and other financial news purveyors with sizable followings.  Within minutes, i...
	15. In some instances, Parrino directly sent the rumor to his own financial news industry contacts.
	16. This process of creating and disseminating false rumors was repeated numerous times over the Relevant Period.
	II. Parrino Trades Profitably around the False Rumors.
	17. Before the false rumors were disseminated, Parrino, Trader A, Trader B, Trader C, and Trader D purchased securities of the publicly-traded companies that were the subject of the false rumors.
	18. Parrino often purchased a combination of stock and short-term call options that usually expired within a day or two.  His purchases typically occurred from between several hours before to a few seconds after the rumors were disseminated by Trader ...
	19. The spread of the false rumors through various news services and in financial chat rooms, as well as the scheme participants’ own purchases, caused an uptick in trading volume and typically resulted in an increase in the subject companies’ securit...
	20. All of the scheme participants, including Parrino, almost always began selling their positions within minutes, if not seconds, after Trader A pushed the false rumors out to his industry contacts.
	21. Parrino traded at least 138 times around the false rumors, earning $982,690 in ill-gotten gains during the Relevant Period.  An Appendix identifying the date and ticker symbol of the 138 instances, as well as the amount of ill-gotten gains Parrino...
	III. Examples of Parrino’s Participation in the Market Manipulation Fraud
	A. February 2018 Company A Rumor
	22. On February 1, 2018 at 10:25:02 am, Parrino sent the following proposed rumor to Trader B and Trader C:
	A spokeswoman for the California Department of Forestry and Fire Protection is stating that after thorough investigation it has determined that the fires that decimated a Santa Rosa neighborhood and killed 21 people was caused by electrical equipment ...
	23. Trader B responded “seller let’s wait” and that “will let you know when I buy.” At 11:37:09 am, Trader B messaged Parrino and Trader C that he had purchased securities in Company A.  Thirty seconds later, Parrino messaged Trader A to “pik [sic] up...
	24. Parrino began purchasing Company A stock and call options at 11:47:49 am, one minute before Trader A pushed the rumor, and continued purchasing until 11:49:04 am, six seconds after Trader A pushed the rumor.
	25. The false rumor was repeated by the financial websites and chat rooms and promptly caused an increase in the trading volume and price of Company A’s stock and options.  The price increase was so significant that trading in Company A securities was...
	26. Parrino began selling his Company A securities at 11:49:53 am, less than one minute after Trader A pushed the rumor, resulting in unlawful profits of $58,063.  Trader A, Trader B, and Trader C also traded around the Company A rumor, generating ove...
	B. July 2018 Company B Rumor
	27. On July 25, 2018, Parrino sent a message to Trader B instructing him to work on a rumor for Company B.  Parrino and Trader B discussed potential rumors involving Company B, and at 9:28:58 am, Trader B sent Parrino the following draft rumor:  “Hear...
	28. The next morning, July 26, 2018, at 8:55:31 am, Trader B sent Parrino and Trader C the Company B rumor, to which Trader C responded “[Company B] looks good.” At 10:48:59 am, Trader B sent the rumor to Trader A and informed Parrino and Trader C tha...
	29. Parrino purchased Company B stock and call options between 10:36:54 am, thirteen minutes before Trader A pushed the rumor, and 10:49:58 am, five seconds after he pushed the rumor.
	30. The financial websites and chat rooms repeated the false rumor, which promptly caused an increase in the trading volume and price of Company B’s stock and options.
	31. At 10:50:57 am, approximately one minute after Trader A disseminated the rumor, Parrino began selling the Company B stock and call options he had purchased, resulting in ill-gotten gains of $12,501.  The other four scheme participants also traded ...

	First CLAIM FOR RELIEF
	Violation of Section 17(a) of the Securities Act
	32. The Commission realleges and incorporates by reference paragraphs 1 through 32, as though fully set forth herein.
	33. By virtue of the foregoing, Parrino, directly or indirectly, singly or in concert with others, in the offer or sale of any security, with scienter, used the means or instruments of transportation or communication in interstate commerce or of the m...
	34. By virtue of the foregoing, Parrino, directly or indirectly, violated and, unless restrained and enjoined, will again violate, Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)].
	35. The Commission realleges and incorporates by reference paragraphs 1 through 35, as though fully set forth herein.
	36. By virtue of the foregoing, Parrino, directly or indirectly, singly or in concert with others, in connection with the purchase or sale of a security, with scienter, used the means or instrumentalities of interstate commerce, or of the mails, or of...
	37. By virtue of the foregoing, Parrino, directly or indirectly, violated and, unless restrained and enjoined, will again violate, Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].

	PRAYER FOR RELIEF
	I.
	II.
	III.
	V.
	Granting such other and further relief as this Court may deem just and proper.