SEC v. Supreme Power Capital Management Ltd., No. 1:25-cv-09505, Southern District of New York (Nov. 17, 2025) — Complaint

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
___________________________________________
)
SECURITIES AND EXCHANGE )
COMMISSION, )
)
Plaintiff,          )
)    Civil Action No.
v. )
)
SUPREME POWER CAPITAL )
MANAGEMENT LTD., )
)
Defendant. )
___________________________________________ )
COMPLAINT
Plaintiff Securities and Exchange Commission (“the Commission”) files this Complaint
against Defendant Supreme Power Capital Management Ltd. (“Supreme Power”) and alleges as
follows:
SUMMARY
1.   This case concerns material misrepresentations and statements that could not be
substantiated made by Supreme Power, a purported investment adviser, in a form filed with the
Commission and made available to the public on December 12, 2023, about Supreme Power’s
organization, office location, assets under management, and clients.
2.   Specifically, Supreme Power 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 66th floor of One World Trade Center,
New York, New York 10007 (“One WTC”); that David Smith 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
25- cv - 9505

2

defendant: Supreme Power 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 Supreme Power’s representations, the current real estate manager of
One WTC has no knowledge of Supreme Power 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 Supreme Power.
4. In addition, Supreme Power 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, Supreme Power
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 Supreme
Power from violating the federal securities laws this Complaint alleges it has violated; (b)
permanently enjoining Supreme Power, its owners, and its executive officers, from filing a
Form ADV as an exempt reporting adviser; (c) ordering Supreme Power 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, Supreme Power
represented on corporate filings with both the Commission and the New York Department of
State, Division of Corporations, that its primary business address is One WTC, which is located
in the District.
DEFENDANT
11. Supreme Power Capital Management Ltd. claims that it is a New York
corporation with a principal place of business at One WTC. On December 5, 2023, Supreme
Power filed a certificate of incorporation with the New York Department of State, Division of
Corporations, in which it used the name “David Smith” as the filer and incorporator, and listed
One WTC as Smith’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
Commission, unless exempt or prohibited from registration. Generally, only larger advisers that

4

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

5

public through the Commission’s Investment Adviser Public Disclosure database, located at
https://adviserinfo.sec.gov.
II. Supreme Power Made Material Misstatements and Statements in its Form ADV
Filed with the Commission That Could Not Be Substantiated.

19. On December 12, 2023, Supreme Power filed its Form ADV with the
Commission as an ERA. In that filing, Supreme Power 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, Supreme Power lists the 66th floor of One WTC as its
principal office and place of business, and states that David Smith serves as both its CEO and
COO. Supreme Power also provides a telephone number with a (210) area code as the main
number for its New York office, even though (210) is the area code for San Antonio, Texas.
21. In the Form ADV section titled “Direct Owners and Executive Officers,”
Supreme Power identifies its “Executive Officers” and its direct owner as itself (that is,
Supreme Power Capital Management Ltd.). Supreme Power 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 three 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 Supreme Power’s private fund
assets under management in the United States is $10 million.
23. In addition, the Form ADV represents that Supreme Power advises a private
fund, also named “Supreme Power Capital Management Ltd.,” and lists a private fund

6

identification number. The private fund identification number is a unique identification number
assigned to a private fund.
24. Supreme Power further states in its Form ADV that a separate RIA “provides
information” about Supreme Power’s private fund on its own Form ADV filing.
25. Contrary to Supreme Power’s representations in the Form ADV:
a. the individual who has served as the “Senior Vice President of Business
& Strategic Partnership” for the office building located at One WTC for the last 13 years stated
that no entity named Supreme Power has been affiliated with that building, including as tenant,
subtenant, or otherwise, and that he is aware of no individual by the name of David Smith that
has served as the CEO or COO of any entity named Supreme Power;
b. the third-party RIA has not reported the Supreme Power 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 Supreme Power or its purported CIK numbers on the
Commission’s public reporting company database yields no information.
III. Supreme Power 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 Supreme Power that it is required to produce under the Advisers Act.

7

29. On November 13, 2024 and December 4, 2024, a Commission attorney emailed
Supreme Power 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 Supreme Power, the Commission attorney used email addresses that Supreme
Power 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
Supreme Power 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 Supreme Power at the
same addresses that Supreme Power provided to FINRA and the New York Department of
State. To date, Supreme Power has not responded to any emails.
32. In sum, the Form ADV materially misrepresented information about Supreme
Power’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)
Supreme Power failed to provide information about when requested, and (3) is likely false.
Further, Supreme Power 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 Supreme Power 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.

8

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. Supreme Power failed to make its books and records available to Commission
attorneys for examination.
36. By reason of the foregoing, Supreme Power 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. Supreme Power, 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, Supreme Power, 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 Supreme Power 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].

9

II.
Permanently restraining and enjoining Supreme Power, its owners, and its executive
officers, from filing a Form ADV as an ERA.
III.
Ordering Supreme Power 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.

S
ECURITIES AND
E
XCHANGE
C
OMMISSION

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. ) 

) 
SUPREME POWER CAPITAL ) 
MANAGEMENT LTD., ) 

) 
Defendant. ) 

___________________________________________ ) 

COMPLAINT 

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

against Defendant Supreme Power Capital Management Ltd. (“Supreme Power”) and alleges as 

follows:  

SUMMARY 

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

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

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

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

2. Specifically, Supreme Power 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 66th floor of One World Trade Center, 

New York, New York 10007 (“One WTC”); that David Smith 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 

25- cv - 9505

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2 

defendant: Supreme Power 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 Supreme Power’s representations, the current real estate manager of 

One WTC has no knowledge of Supreme Power 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 Supreme Power. 

4. In addition, Supreme Power 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, Supreme Power 

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 Supreme 

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

permanently enjoining Supreme Power, its owners, and its executive officers, from filing a 

Form ADV as an exempt reporting adviser; (c) ordering Supreme Power 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, Supreme Power 

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

State, Division of Corporations, that its primary business address is One WTC, which is located 

in the District. 

DEFENDANT 

11. Supreme Power Capital Management Ltd. claims that it is a New York 

corporation with a principal place of business at One WTC. On December 5, 2023, Supreme 

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

Corporations, in which it used the name “David Smith” as the filer and incorporator, and listed 

One WTC as Smith’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 

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

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4 

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, 

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

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5 

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

https://adviserinfo.sec.gov. 

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

Commission as an ERA. In that filing, Supreme Power 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, Supreme Power lists the 66th floor of One WTC as its 

principal office and place of business, and states that David Smith serves as both its CEO and 

COO. Supreme Power also provides a telephone number with a (210) area code as the main 

number for its New York office, even though (210) is the area code for San Antonio, Texas. 

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

Supreme Power identifies its “Executive Officers” and its direct owner as itself (that is, 

Supreme Power Capital Management Ltd.). Supreme Power 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 three 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 Supreme Power’s private fund 

assets under management in the United States is $10 million. 

23. In addition, the Form ADV represents that Supreme Power advises a private 

fund, also named “Supreme Power Capital Management Ltd.,” and lists a private fund 

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6 

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

assigned to a private fund. 

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

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

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

a. the individual who has served as the “Senior Vice President of Business 

& Strategic Partnership” for the office building located at One WTC for the last 13 years stated 

that no entity named Supreme Power has been affiliated with that building, including as tenant, 

subtenant, or otherwise, and that he is aware of no individual by the name of David Smith that 

has served as the CEO or COO of any entity named Supreme Power; 

b. the third-party RIA has not reported the Supreme Power 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 Supreme Power or its purported CIK numbers on the 

Commission’s public reporting company database yields no information. 

III. Supreme Power 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 Supreme Power that it is required to produce under the Advisers Act.  

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7 

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

Supreme Power 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 Supreme Power, the Commission attorney used email addresses that Supreme 

Power 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 

Supreme Power 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 Supreme Power at the 

same addresses that Supreme Power provided to FINRA and the New York Department of 

State. To date, Supreme Power has not responded to any emails. 

32. In sum, the Form ADV materially misrepresented information about Supreme 

Power’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) 

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

Further, Supreme Power 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 Supreme Power 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. 

 

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8 

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. Supreme Power failed to make its books and records available to Commission 

attorneys for examination. 

36. By reason of the foregoing, Supreme Power 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. Supreme Power, 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, Supreme Power, 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 Supreme Power 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]. 

 

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9 

II. 

Permanently restraining and enjoining Supreme Power, its owners, and its executive 

officers, from filing a Form ADV as an ERA. 

III. 

Ordering Supreme Power 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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