SEC v. AI INVESTMENT EDUCATION FOUNDATION LTD., No. 1:25-cv-03650, District of Colorado (Nov. 17, 2025) — Complaint

 
 
1 
 
UNITED STATES DISTRICT COURT 
DISTRICT OF COLORADO 
 
Case No.  
 
SECURITIES AND EXCHANGE COMMISSION, 
 
Plaintiff, 
 
v. 
 
AI INVESTMENT EDUCATION FOUNDATION LTD. 
 
Defendant. 
 
 
COMPLAINT AND JURY TRIAL DEMAND 
 
 
Plaintiff Securities and Exchange Commission (the “SEC”),  for its Complaint against AI 
Investment Education Foundation Ltd. (“AI Investment”), a  lleges as follows: 
SUMMARY OF ALLEGATIONS 
 
1. This case concerns material misrepresentations and statements that could not be 
substantiated made by AI Investment, a purported investment adviser, in a form filed with the 
Commission and made available to the public on June 27, 2024, about AI Investment’s 
organization, office location, assets under management, and clients. 
2. Specifically, AI Investment represented in its Form ADV (a form used by investment 
advisers to register with both the Commission and state securities regulators) that it operates out of 
office space at 1312 17th Street, Suite 600, Denver, Colorado 80202 (“1312 17th Street”); that Peng 
Denggao serves as its Chief Executive Officer (“CEO”); that it manages $1 million in assets in the 
United States; that it advises a private fund with the name “AI Investment Education;” and that a 
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separate registered investment adviser (“RIA”) reports information about this private fund to the 
Commission on its own Form ADV. 
3. Contrary to AI Investment’s representations, the current business occupant of 1312 
17th Street has no knowledge of AI Investment or its purported CEO, 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. 
4. In addition, AI Investment 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, AI Investment 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 AI Investment 
from violating the federal securities laws this Complaint alleges it has violated; (b) permanently 
enjoining AI Investment, its owners, and its executive officers, from filing a Form ADV as an 
exempt reporting adviser; (c) ordering AI Investment 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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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 District of Colorado 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, AI Investment represented on corporate 
filings with both the Commission and the Colorado Secretary of State that its primary business 
address is 1312 17th Street, which is located in the District. 
DEFENDANT 
11. AI Investment Education Foundation Ltd. claims that it is a Colorado corporation. 
On June 23, 2024, AI Investment filed a certificate of incorporation with the Colorado Secretary of 
State, in which it used the name “Denggao Peng” as the filer and incorporator. On the certificate of 
incorporation, AI Investment listed 1312 17th Street as both its principal office address and Peng’s 
address. 
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 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 
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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, is the 
developer and operator of the IARD system. Once filed, the Form ADV is available to the public 
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through the Commission’s Investment Adviser Public Disclosure database, located at 
https://adviserinfo.sec.gov. 
II. AI Investment Made Material Misstatements and Statements in its Form ADV Filed 
with the Commission That Could Not Be Substantiated. 
 
19. On June 27, 2024, AI Investment filed its Form ADV with the Commission as an 
ERA. In that filing, AI Investment 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, AI Investment lists 1312 17th Street as its principal office and 
place of business, and states that Peng Denggao serves as its CEO. AI Investment also provides a 
telephone number with an (830) area code as the main number for its Colorado office, even though 
(830) is the area code for most of San Antonio, Texas’s suburbs. 
21. In the Form ADV, AI Investment 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 certain disclosure information. 
22. The Form ADV represents that the amount of AI Investment’s private fund assets 
under management in the United States is $1 million. 
23. In addition, the Form ADV represents that AI Investment advises a private fund, also 
named “AI Investment Education,” and lists a private fund identification number. The private fund 
identification number is a unique identification number assigned to a private fund. 
24. AI Investment further states in its Form ADV that a separate RIA “provides 
information” about AI Investment’s private fund on its own Form ADV filing.  
25. Contrary to AI Investment’s representations in the Form ADV: 
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a. the individual who owns the business located at 1312 17th Street stated that 
he has no records of AI Investment or Peng Denggao; 
b. the third-party RIA has not reported the AI Investment Foundation 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 AI Investment or its purported CIK numbers on the 
Commission’s public reporting company database yields no information. 
III. AI Investment 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 AI Investment that it is required to produce under the Advisers Act.  
29. On November 13, November 19, and November 21, 2024, a Commission attorney 
emailed AI Investment a letter requesting production of books and records regarding the 
information on the 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 AI Investment, the Commission attorney used email addresses that AI Investment 
provided to (i) FINRA in connection with the Form ADV filing process and (ii) the Colorado 
Department of State in connection with filing its incorporation documents. 
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30. On November 21, 2024, Commission attorneys called telephone numbers that AI 
Investment provided on the Form ADV and to FINRA in connection with the Form ADV filing 
process. One number went to a busy tone; the other number reached a voicemail recording and the 
Commission attorney left a message that was never returned. 
31. On April 15, 2025, a Commission attorney again emailed AI Investment at the same 
addresses that AI Investment provided to FINRA and the Colorado Department of State. To date, 
AI Investment has not responded to any emails or returned the voicemail message. 
32. In sum, the Form ADV materially misrepresented information about AI Investment’s 
primary business location and reporting of private fund clients; and it provided information about 
its CEO and the amount of private fund assets under management in the United States that (1) could 
not be substantiated, (2) AI Investment failed to provide information about when requested, and (3) 
is likely false. Further, AI Investment 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 AI Investment 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. 
35. AI Investment failed to make its books and records available to Commission 
attorneys for examination. 
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36. By reason of the foregoing, AI Investment 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. AI Investment, 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, AI Investment, 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 AI Investment 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 AI Investment, its owners, and its executive officers, 
from filing a Form ADV as an ERA. 
III. 
Ordering AI Investment to pay a civil monetary penalty under Section 209(e) of the 
Advisers Act [15 U.S.C. § 80b-9(e)]. 
 
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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/  David H. London    
David H. London 
Alexandra Lavin 
Xinyue Angela Lin 
Sarah McAteer 
Dahlia Rin 
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] 
 
 
 
 
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UNITED STATES DISTRICT COURT 
DISTRICT OF COLORADO 

 
Case No.  

 
SECURITIES AND EXCHANGE COMMISSION, 

 
Plaintiff, 

 
v. 

 
AI INVESTMENT EDUCATION FOUNDATION LTD. 

 
Defendant. 

 
 

COMPLAINT AND JURY TRIAL DEMAND 
 
 

Plaintiff Securities and Exchange Commission (the “SEC”), for its Complaint against AI 

Investment Education Foundation Ltd. (“AI Investment”), alleges as follows: 

SUMMARY OF ALLEGATIONS 
 

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

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

Commission and made available to the public on June 27, 2024, about AI Investment’s 

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

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

advisers to register with both the Commission and state securities regulators) that it operates out of 

office space at 1312 17th Street, Suite 600, Denver, Colorado 80202 (“1312 17th Street”); that Peng 

Denggao serves as its Chief Executive Officer (“CEO”); that it manages $1 million in assets in the 

United States; that it advises a private fund with the name “AI Investment Education;” and that a 

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separate registered investment adviser (“RIA”) reports information about this private fund to the 

Commission on its own Form ADV. 

3. Contrary to AI Investment’s representations, the current business occupant of 1312 

17th Street has no knowledge of AI Investment or its purported CEO, 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. 

4. In addition, AI Investment 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, AI Investment 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 AI Investment 

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

enjoining AI Investment, its owners, and its executive officers, from filing a Form ADV as an 

exempt reporting adviser; (c) ordering AI Investment 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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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 District of Colorado 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, AI Investment represented on corporate 

filings with both the Commission and the Colorado Secretary of State that its primary business 

address is 1312 17th Street, which is located in the District. 

DEFENDANT 

11. AI Investment Education Foundation Ltd. claims that it is a Colorado corporation. 

On June 23, 2024, AI Investment filed a certificate of incorporation with the Colorado Secretary of 

State, in which it used the name “Denggao Peng” as the filer and incorporator. On the certificate of 

incorporation, AI Investment listed 1312 17th Street as both its principal office address and Peng’s 

address. 

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 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 

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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, is the 

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

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

https://adviserinfo.sec.gov. 

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

 
19. On June 27, 2024, AI Investment filed its Form ADV with the Commission as an 

ERA. In that filing, AI Investment 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, AI Investment lists 1312 17th Street as its principal office and 

place of business, and states that Peng Denggao serves as its CEO. AI Investment also provides a 

telephone number with an (830) area code as the main number for its Colorado office, even though 

(830) is the area code for most of San Antonio, Texas’s suburbs. 

21. In the Form ADV, AI Investment 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 certain disclosure information. 

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

under management in the United States is $1 million. 

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

named “AI Investment Education,” and lists a private fund identification number. The private fund 

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

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

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

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

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a. the individual who owns the business located at 1312 17th Street stated that 

he has no records of AI Investment or Peng Denggao; 

b. the third-party RIA has not reported the AI Investment Foundation 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 AI Investment or its purported CIK numbers on the 

Commission’s public reporting company database yields no information. 

III. AI Investment 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 AI Investment that it is required to produce under the Advisers Act.  

29. On November 13, November 19, and November 21, 2024, a Commission attorney 

emailed AI Investment a letter requesting production of books and records regarding the 

information on the 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 AI Investment, the Commission attorney used email addresses that AI Investment 

provided to (i) FINRA in connection with the Form ADV filing process and (ii) the Colorado 

Department of State in connection with filing its incorporation documents. 

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

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

process. One number went to a busy tone; the other number reached a voicemail recording and the 

Commission attorney left a message that was never returned. 

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

addresses that AI Investment provided to FINRA and the Colorado Department of State. To date, 

AI Investment has not responded to any emails or returned the voicemail message. 

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

primary business location and reporting of private fund clients; and it provided information about 

its CEO and the amount of private fund assets under management in the United States that (1) could 

not be substantiated, (2) AI Investment failed to provide information about when requested, and (3) 

is likely false. Further, AI Investment 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 AI Investment 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. 

35. AI Investment failed to make its books and records available to Commission 

attorneys for examination. 

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36. By reason of the foregoing, AI Investment 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. AI Investment, 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, AI Investment, 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 AI Investment 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 AI Investment, its owners, and its executive officers, 

from filing a Form ADV as an ERA. 

III. 

Ordering AI Investment to pay a civil monetary penalty under Section 209(e) of the 

Advisers Act [15 U.S.C. § 80b-9(e)]. 

 

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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/ David H. London    
David H. London 
Alexandra Lavin 
Xinyue Angela Lin 
Sarah McAteer 
Dahlia Rin 
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] 

 
 
 

 

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mailto:[email protected]

	UNITED STATES DISTRICT COURT
	DISTRICT OF COLORADO
	SECURITIES AND EXCHANGE COMMISSION,
	AI INVESTMENT EDUCATION FOUNDATION LTD.
	COMPLAINT AND JURY TRIAL DEMAND
	SUMMARY OF ALLEGATIONS
	NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT
	JURISDICTION AND VENUE
	FACTS
	PRAYER FOR RELIEF