SEC v. Pathyam Patel, No. 7:25-cv-01603, Northern District of Alabama (Sept. 22, 2025) — Complaint

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ALABAMA
UNITED STATES SECURITIES AND
EXCHANGE COMMISSION,
Plaintiff,
C.A. No. __-____
v.
PATHYAM PATEL, JURY TRIAL DEMANDED
Defendant.
COMPLAINT
P
laintiff United States Securities and Exchange Commission (the “Commission” or
“SEC”) files this Complaint against Defendant Pathyam Patel (“Patel”) and alleges as follows:
SUMMARY
1.From at least January 2019 through March 2023 (the “Relevant Period”), Patel
perpetrated a fraudulent investment scheme in which he induced at least 15 individuals, many of
whom were college students, to invest more than $430,000 in principal and purported fee
payments with his purported company, Infinity Wealth Management, LLC (“Infinity”).
2.Patel deceived clients and prospective clients by making materially false and
misleading claims about: (i) his and Infinity’s qualifications, licensure, and endorsement by the
Commission, (ii) how he would invest their funds and the profitability of the investments, and
(iii)their principal investments being guaranteed.
3.For example, Patel deceived prospective clients by telling them Infinity was
“licensed” with the Commission as an investment adviser that offered investment portfolio

FILED

 2025 Sep-19  AM 11:37
U.S. DISTRICT COURT
N.D. OF ALABAMA

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management services to a wide range of clients, including a hedge fund.  He also told clients that
he would invest their money in stocks and options as well as crypto assets.
4. However, neither Patel nor Infinity was registered with or endorsed by the
Commission; and neither Patel nor Infinity ever formed or managed a hedge fund.
5. In reality, Infinity existed in name only.  It had no bank accounts, brokerage
accounts, office space, employees, or assets of any kind.
6. Instead of investing his clients’ money as promised, Patel misappropriated most
of their money to pay for his personal expenses and to make Ponzi-like payments to other clients.
7. Patel further injured his clients by charging them thousands of dollars in bogus
“fees” relating to their investments, including what Patel described as “transfer fees” or fees he
claimed the clients owed the SEC, IRS, and Virginia State Corporation Commission.  These fees
did not exist.
8. By engaging in the conduct described in this Complaint, Patel violated, and unless
enjoined will continue to violate, Section 17(a) of the Securities Act of 1933 (“Securities Act”)
[15 U.S.C. § 77q(a)], Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”)
[15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5], and Sections 206(1)
and (2) of the Investment Advisers Act of 1940 (“Advisers Act”) [15 U.S.C. § 80b-6(1) and (2)].
JURISDICTION AND VENUE
9. The Court has jurisdiction over this action pursuant to Sections 20(b) and 22(a) of
the Securities Act [15 U.S.C. §§ 77t(b) and 77v(a)], Sections 21(d) and 27(a) of the Exchange
Act [15 U.S.C. § 78(u)(d) and 78aa], and Sections 209(d) and 214(a) of the Advisers Act [15
U.S.C. §§ 80b-9(d) and 80b-14(a)].

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10. The Court has personal jurisdiction over Patel.  During the Relevant Period, Patel
resided in the Northern District of Alabama and many of the acts and transactions constituting
violations of the Securities Act, Exchange Act, and Advisers Act alleged in this Complaint
occurred in the Northern District of Alabama.  Many of the victims of Patel’s fraud also resided
within this District during the Relevant Period.
11. Venue is proper in the Northern District of Alabama pursuant to Section 22(a) of
the Securities Act [15 U.S.C. § 77v(a)], Section 27(a) of the Exchange Act [15 U.S.C. § 78aa(a)],
and Section 214(a) of the Advisers Act [15 U.S.C. § 80b-14(a)].  Transactions, acts, practices
and courses of conduct constituting violations of the federal securities laws occurred within this
District.  Patel and many of his clients also resided within the Northern District of Alabama
during the Relevant Period.
12. In connection with the conduct described in this Complaint, Patel made use of the
means or instrumentalities of interstate commerce, of the mails, or of the facilities of a national
securities exchange.  Among other things, Patel used email messages, telephones, the mails, and
bank wires to perpetrate his scheme.
DEFENDANT
13. Patel, age 25, is a resident of Chantilly, Virginia.  During the Relevant Period, he
resided in Tuscaloosa, Alabama.  Patel has never been registered or licensed in any capacity with
the Commission or any state securities agencies.
FACTS
14. During the Relevant Period, Patel solicited at least 15 people, including college
and high school friends and their family members, to become clients of his purported company,
Infinity.

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15. However, Infinity existed in name only.  It had no employees, staff, or office
space.  And, it had no bank accounts, brokerage accounts, or other assets.
16. Patel lied to clients and potential clients about his experience managing
investments of others, purported licensure and endorsements, how he would invest their money,
his actual use of their money, guaranteeing their principal, and “fees” purportedly charged by
third parties.
17. Many of Patel’s clients invested less than $15,000 with him, but a few invested
larger amounts, with the largest client providing more than $100,000 for Patel to invest on their
behalf.  Most of the clients sent money to Patel to invest for them multiple times, transferring as
little as $100 at a time.
A. Patel Misrepresented His And Infinity’s Qualifications,
Licensure, And Endorsement By The Commission.

18. Patel made false or misleading statements to potential and existing clients about
Infinity’s status as a “licensed” entity and his qualifications and experience.
19. For example, Patel provided clients with a document he prepared and titled the
“Infinity Wealth Management Business Plan” (the “Infinity Wealth Plan”).  This document
states, in part:
As a revolutionary firm, however, with a revolutionary investment strategy, we
can throw out the traditional client base and strategy almost completely.  This
does not mean that we are not accredited and a licensed hedge fund management
firm; Infinity Wealth Management will offer a wide range of investment
portfolio management services hence we are well trained and equipped to service
a wide range of clientele base. (emphasis in original)

20. The Infinity Wealth Plan further claims “management staff and owners of the
business will be considered gurus.  They are core professionals and licensed and highly qualified

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portfolio management experts in the United States.”  Patel also told one or more clients that Patel
was “registered,” a “certified investor” and had been “endorsed” by the Commission.
21. Patel also created and provided clients with investment advisory agreements he
captioned “Investor Contracts.”  On some Investor Contracts, Patel printed the official seal of the
Commission, falsely implying that the Commission had endorsed the investment, Patel, or both.
22. In reality, Patel and Infinity did not employ anyone, let alone anyone with the
qualifications claimed in the Infinity Wealth Plan.  Patel and Infinity had no state or federal
licenses or registrations related to securities, and they had no training or relevant employment
experience related to investments in securities or portfolio management.  And they were not
endorsed by the Commission.  Patel knew or was reckless in now knowing that the above
statements suggesting otherwise were false or misleading.
B. Patel Misrepresented How He Would Use Clients’ Money And
Lied About Generating Profits On Their Investments.

23. Patel falsely told clients and prospective clients that he would invest their money
and generate profits of “80-110%” yearly for them by investing their portfolios in “blue chip
stocks,” options, other equity securities, and crypto assets.
24. Those representations were false.  Over the course of the fraud, Patel received
approximately $430,000 from at least 15 clients.  While Patel transferred some of the money he
received from clients to his personal accounts at securities trading platforms and crypto
exchanges and subsequently used the money to trade equities and purchase crypto assets, he
misappropriated the majority of the money he received from clients.
25. Patel spent most of the money for personal uses – such as online sports betting
and living expenses – and to make Ponzi-like payments to other clients.  Moreover, the little
investing Patel did was not profitable; he lost almost all of the money he used for investing.

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26. In addition to not investing funds as he promised, on multiple occasions during
the Relevant Period, Patel falsely told clients that he had profitably invested money on their
behalf and that the investments had generated profits.
27. For example, in August 2020, Patel texted one client that the client’s initial
investment of $2,050 generated a profit of $238.16—more than 10%.  However, Patel never
invested the client’s money.  Instead, Patel spent it on fast food and cash withdrawals, and to
make payments to others.  Following Patel’s false claim of generating profits for the client on
this initial investment, the client sent Patel additional money to invest on his behalf.
28. In November 2020, Patel again texted this client and falsely claimed that his now
$8,500 investment earned a profit of $2,735.66.  Again, Patel had not invested this client’s
money, and no profit was earned.  Instead, Patel spent the money the client invested on personal
expenses and payments to other clients.
29. Similarly, Patel sent text messages to another client, encouraging them to invest
and claiming that he generated profits for them.  In one text message, Patel wrote:
I have an idea instead of a trial period where I tell you an amount which isn’t the
best, you could get in like 2500-5k for the week then withdraw next week and
send the money back with profits... Cause that way: 1. You’ll make good profits
this week.  2. You’ll get to see I’m legit when you see actual cash coming back to
you instead of just disappearing to some random guy lol.

30. After this client transferred money to Patel, Patel sent him another text message,
stating:
Initial Investment: $25,000.00
Profits: $1,983.91
Commission (10.5%): $208.31
TOTAL: $26,775.60

As with the previous example, these numbers were fictitious.

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31. Similarly, Patel told other clients that their accounts were increasing in value
when they were not.
C. Patel Falsely Told Clients That He Guaranteed Their Principal.

32. The Investor Contracts, which Patel wrote and provided to his clients, falsely
guaranteed their initial investments, stating: “[t]here is a solidified verbal and written agreement
in returning the initial investment no matter the circumstances, if necessary.”
33. In some Investor Contracts, Patel promised to return the client’s principal in “2-3
weeks at the latest;” in others he promised repayment of principal in “1-2 weeks at the latest.”
34. Some clients also received a “Bill of Sale” from Patel confirming that Patel
“guarantee[d]” the client could get the principal amount of their investments back whenever the
client deemed necessary.
35. At the time Patel made these promises, he knew or was reckless in not knowing
that there was no reasonable basis for him to believe that he could return his clients’ money upon
demand.  Patel was not investing the money in securities and crypto assets, as he had
represented.  Instead, he was using it for himself and to make Ponzi-like payments to other
clients.
D. Patel Also Lied To Clients Regarding Required “Fees.”

36. In the Investor Contracts he wrote, Patel described a “commission/fee” schedule
Infinity would collect from clients depending on the amount of money the client provided
Infinity to manage.  According to the schedule, the more an individual provided Patel to manage,
the lower the so-called “commission/fee” would be.  The agreements further provided that the
client “agrees to dispose of a certain percentage of profit, based on the initial investment.”

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37. Patel’s limited trading did not generate profits, therefore no fees should have been
charged to clients.
38. Despite this fact, beginning at least as early as January 2021, Patel misrepresented
to clients that they owed him “fees” in an effort to convince them to send him additional money.
39. Patel told multiple clients that if they wanted to receive their principal investment
amounts back, they were required to pay what he called, among other things, SEC fees,
withdrawal fees, Virginia State Corporation Commission fees, and IRS fees.
40. In reality, none of these investors owed any such fees; and there were no fees
relating to these clients from the SEC, the Virigina State Corporation Commission, or the IRS.
41. Collectively, clients paid Patel at least $89,000 in phony “fees.”
42. At least three clients paid Patel significantly more in fictitious fees than the
amount of money they sent to Patel to invest on their behalf.
E. Patel Violated The Federal Securities Laws.

43. During the Relevant Period, Patel perpetrated a fraud on clients and potential
clients.
44. Patel employed a device, scheme, or artifice to defraud and engaged in acts,
transactions, or courses of business that operated as a fraud or deceit upon clients.
45. Patel made false statements of material fact and omitted to state material facts
necessary to make statements made not misleading.
46. Patel had ultimate authority for false and misleading statements made to existing
clients and potential clients in written materials.
47. All of the misrepresentations and omissions set forth herein, individually and in
the aggregate, are material.

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48. Patel obtained money or property by means of false statements to clients,
including money that he misappropriated.
49. Patel acted knowingly and/or recklessly in making the above false and misleading
statements and in undertaking the deceptive conduct.
50. Patel acted as an investment adviser during the Relevant Period by providing
investment advisory services for a fee.
51. In perpetrating the fraud, Patel used the means or instruments of interstate
commerce or of the mails, or the facility of a national securities exchange, including by sending
numerous false statements via text.
52. The conduct alleged herein was in connection with the offer, purchase, or sale of
securities.
53. On information and belief, an order requiring payments to investors arose from
the Alabama Securities Commission’s parallel investigation.
FIRST CLAIM FOR RELIEF
Violations of Section 17(a) of the Securities Act

54. The Commission realleges and incorporates by reference paragraphs 1 through 53
as though fully set forth herein.
55. By engaging in the conduct alleged herein, Patel knowingly or recklessly, in the
offer or sale of securities, directly or indirectly, by the use of means or instruments of
transportation or communication in interstate commerce or by use of the mails:
a. employed devices, schemes, or artifices to defraud:
b. obtained money or property by means of untrue statements of material fact or
omissions to state material facts necessary in order to make the statements made,
in light of the circumstances under which they were made, not misleading; and/or

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c. engaged in transactions, practices, or courses of business which operated or would
operate as a fraud or deceit upon purchasers of securities.
56. By engaging in the foregoing conduct, Patel violated, and unless enjoined, will
continue to violate Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)].
SECOND CLAIM FOR RELIEF
(Violations of Section 10(b) of the Exchange Act and Rule 10b-5 Thereunder)
57. The Commission realleges and incorporates by reference paragraphs 1 through 53
as though fully set forth herein.
58. By engaging in the conduct alleged herein, Patel knowingly or recklessly, in
connection with the purchase or sale of securities, directly or indirectly, by the use of means or
instruments of interstate commerce, or by use of the mails, or of any national securities
exchange:
a. employed devices, schemes, or artifices to defraud:
b. made untrue statements of material fact or omitted to state material facts
necessary in order to make the statements made, in light of the circumstances
under which they were made, not misleading; and/or
c. engaged in acts, practices, or courses of business which operated or would operate
as a fraud or deceit upon any person.
59. By engaging in the conduct described above, Patel violated, and unless enjoined,
will continue to 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].

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THIRD CLAIM FOR RELIEF
(Violations of Section 206(1) and 206(2) of the Advisors Act)
60. The Commission realleges and incorporates by reference paragraphs 1 through 53
as though fully set forth herein.
61. By engaging in the conduct alleged herein, Patel knowingly or recklessly or, with
respect to subpart b below, negligently, as an investment adviser, directly or indirectly, by use of
the means or instrumentality of interstate commerce or of the mails:
a. employed devices, schemes or artifices to defraud any client or prospective client;
and
b. engaged in transactions, practices, or courses of business which operated or would
operate as a fraud or deceit upon any client or prospective client.
62. By engaging in the conduct described above, Patel violated, and unless enjoined
will continue to violate, Sections 206(1) and 206(2) of the Advisers Act [15 U.S.C. §§ 80b-6(1)
and 80b-6(2)].
PRAYER FOR RELIEF
 WHEREFORE, the Commission respectfully requests that the Court enter a final
judgment:
I.
 Permanently restraining and enjoining Defendant Patel from violating Section 17(a) of
the Securities Act [15 U.S.C. § 77q(a)]; 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]; and Sections 206(1) and 206(2) of the
Advisers Act [15 U.S.C. §§ 80b-6(1) and 80(b)-6(2)];
II.
 For a period of five years, restraining and enjoining Defendant Patel from, directly or

12

indirectly, including, but not limited to, through any entity owned or controlled by Defendant,
participating in the issuance, purchase, offer, or sale of any security; provided, however, that
such injunction shall not prevent Defendant from purchasing or selling securities for his own
personal accounts.
III.
 For a period of five years, restraining and enjoining Defendant Patel from, directly or
indirectly, acting as or being associated with any investment adviser.
IV.
 Ordering Defendant Patel to disgorge any and all ill-gotten gains, together with
prejudgment interest, derived from the activities set forth in this Complaint; and
V.
 Granting such other and further relief as this Court may determine to be just and
necessary.
JURY DEMAND

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff demands that this
case be tried to a jury.

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      Respectfully submitted,

     By: s/ John V. Donnelly III
John V. Donnelly III, Esq.
Gregory Bockin, Esq.
Kingdon Kase, Esq.
Jennifer Miller, Esq.
United States Securities and Exchange
Commission
 1617 JFK Blvd., Suite 520
 Philadelphia, PA 19103
 Telephone: (215) 597-3100
 Facsimile: (215) 597-2740
Email:  [email protected]

ATTORNEYS FOR PLAINTIFF UNITED
STATES SECURITIES AND EXCHANGE
COMMISSION
      (Appearing pursuant to Local Rule 83.1(c))
Dated:  September 19, 2025

JS 44   (Rev. 03/24)
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purpose of initiating the civil docket sheet.    (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
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INTELLECTUAL
United States Securities and Exchange Commission
John V. Donnelly III, U.S. Securities and Exchange
Commission, 1617 JFK Blvd., Suite 520, Phila., PA
19103 Telephone: (215) 597-3100
Pathyam Patel
William White, Esq., Boles Holmes White, LLC
1929 3rd Ave North; Suite 500, Birmingham, AL 35203
Telephone: (205) 502-2000
✖
✖
15 U.S.C. § 77q(a); 15 U.S.C. § 78j(b); 15 U.S.C. § 80b-6(1) and (2); and 17 C.F.R. § 240.10b-5
Violation of federal securities laws.
✖
✖
9/19/2025s / John V. Donnelly III

1 

IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF ALABAMA 

UNITED STATES SECURITIES AND 
EXCHANGE COMMISSION, 

Plaintiff, 
C.A. No. __-____

v. 

PATHYAM PATEL, JURY TRIAL DEMANDED 

Defendant. 

COMPLAINT 

Plaintiff United States Securities and Exchange Commission (the “Commission” or 

“SEC”) files this Complaint against Defendant Pathyam Patel (“Patel”) and alleges as follows: 

SUMMARY 

1. From at least January 2019 through March 2023 (the “Relevant Period”), Patel

perpetrated a fraudulent investment scheme in which he induced at least 15 individuals, many of 

whom were college students, to invest more than $430,000 in principal and purported fee 

payments with his purported company, Infinity Wealth Management, LLC (“Infinity”).   

2. Patel deceived clients and prospective clients by making materially false and

misleading claims about: (i) his and Infinity’s qualifications, licensure, and endorsement by the 

Commission, (ii) how he would invest their funds and the profitability of the investments, and 

(iii) their principal investments being guaranteed.

3. For example, Patel deceived prospective clients by telling them Infinity was

“licensed” with the Commission as an investment adviser that offered investment portfolio 

 FILED 
 2025 Sep-19  AM 11:37
U.S. DISTRICT COURT

N.D. OF ALABAMA

Case 7:25-cv-01603-ACA     Document 1     Filed 09/19/25     Page 1 of 14



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management services to a wide range of clients, including a hedge fund.  He also told clients that 

he would invest their money in stocks and options as well as crypto assets. 

4. However, neither Patel nor Infinity was registered with or endorsed by the 

Commission; and neither Patel nor Infinity ever formed or managed a hedge fund. 

5. In reality, Infinity existed in name only.  It had no bank accounts, brokerage 

accounts, office space, employees, or assets of any kind. 

6. Instead of investing his clients’ money as promised, Patel misappropriated most 

of their money to pay for his personal expenses and to make Ponzi-like payments to other clients. 

7. Patel further injured his clients by charging them thousands of dollars in bogus 

“fees” relating to their investments, including what Patel described as “transfer fees” or fees he 

claimed the clients owed the SEC, IRS, and Virginia State Corporation Commission.  These fees 

did not exist. 

8. By engaging in the conduct described in this Complaint, Patel violated, and unless 

enjoined will continue to violate, Section 17(a) of the Securities Act of 1933 (“Securities Act”) 

[15 U.S.C. § 77q(a)], Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) 

[15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5], and Sections 206(1) 

and (2) of the Investment Advisers Act of 1940 (“Advisers Act”) [15 U.S.C. § 80b-6(1) and (2)]. 

JURISDICTION AND VENUE 

9. The Court has jurisdiction over this action pursuant to Sections 20(b) and 22(a) of 

the Securities Act [15 U.S.C. §§ 77t(b) and 77v(a)], Sections 21(d) and 27(a) of the Exchange 

Act [15 U.S.C. § 78(u)(d) and 78aa], and Sections 209(d) and 214(a) of the Advisers Act [15 

U.S.C. §§ 80b-9(d) and 80b-14(a)].  

Case 7:25-cv-01603-ACA     Document 1     Filed 09/19/25     Page 2 of 14



3 
 

10. The Court has personal jurisdiction over Patel.  During the Relevant Period, Patel 

resided in the Northern District of Alabama and many of the acts and transactions constituting 

violations of the Securities Act, Exchange Act, and Advisers Act alleged in this Complaint 

occurred in the Northern District of Alabama.  Many of the victims of Patel’s fraud also resided 

within this District during the Relevant Period.  

11. Venue is proper in the Northern District of Alabama pursuant to Section 22(a) of 

the Securities Act [15 U.S.C. § 77v(a)], Section 27(a) of the Exchange Act [15 U.S.C. § 78aa(a)], 

and Section 214(a) of the Advisers Act [15 U.S.C. § 80b-14(a)].  Transactions, acts, practices 

and courses of conduct constituting violations of the federal securities laws occurred within this 

District.  Patel and many of his clients also resided within the Northern District of Alabama 

during the Relevant Period. 

12. In connection with the conduct described in this Complaint, Patel made use of the 

means or instrumentalities of interstate commerce, of the mails, or of the facilities of a national 

securities exchange.  Among other things, Patel used email messages, telephones, the mails, and 

bank wires to perpetrate his scheme. 

DEFENDANT 

13. Patel, age 25, is a resident of Chantilly, Virginia.  During the Relevant Period, he 

resided in Tuscaloosa, Alabama.  Patel has never been registered or licensed in any capacity with 

the Commission or any state securities agencies. 

FACTS 

14. During the Relevant Period, Patel solicited at least 15 people, including college 

and high school friends and their family members, to become clients of his purported company, 

Infinity.   

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4 
 

15. However, Infinity existed in name only.  It had no employees, staff, or office 

space.  And, it had no bank accounts, brokerage accounts, or other assets. 

16. Patel lied to clients and potential clients about his experience managing 

investments of others, purported licensure and endorsements, how he would invest their money, 

his actual use of their money, guaranteeing their principal, and “fees” purportedly charged by 

third parties.   

17. Many of Patel’s clients invested less than $15,000 with him, but a few invested 

larger amounts, with the largest client providing more than $100,000 for Patel to invest on their 

behalf.  Most of the clients sent money to Patel to invest for them multiple times, transferring as 

little as $100 at a time.   

A. Patel Misrepresented His And Infinity’s Qualifications, 
Licensure, And Endorsement By The Commission. 
 
18. Patel made false or misleading statements to potential and existing clients about 

Infinity’s status as a “licensed” entity and his qualifications and experience. 

19. For example, Patel provided clients with a document he prepared and titled the 

“Infinity Wealth Management Business Plan” (the “Infinity Wealth Plan”).  This document 

states, in part: 

As a revolutionary firm, however, with a revolutionary investment strategy, we 
can throw out the traditional client base and strategy almost completely.  This 
does not mean that we are not accredited and a licensed hedge fund management 
firm; Infinity Wealth Management will offer a wide range of investment 
portfolio management services hence we are well trained and equipped to service 
a wide range of clientele base. (emphasis in original) 
 
20. The Infinity Wealth Plan further claims “management staff and owners of the 

business will be considered gurus.  They are core professionals and licensed and highly qualified 

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portfolio management experts in the United States.”  Patel also told one or more clients that Patel 

was “registered,” a “certified investor” and had been “endorsed” by the Commission.   

21. Patel also created and provided clients with investment advisory agreements he 

captioned “Investor Contracts.”  On some Investor Contracts, Patel printed the official seal of the 

Commission, falsely implying that the Commission had endorsed the investment, Patel, or both. 

22. In reality, Patel and Infinity did not employ anyone, let alone anyone with the 

qualifications claimed in the Infinity Wealth Plan.  Patel and Infinity had no state or federal 

licenses or registrations related to securities, and they had no training or relevant employment 

experience related to investments in securities or portfolio management.  And they were not 

endorsed by the Commission.  Patel knew or was reckless in now knowing that the above 

statements suggesting otherwise were false or misleading.   

B. Patel Misrepresented How He Would Use Clients’ Money And 
Lied About Generating Profits On Their Investments. 
 
23. Patel falsely told clients and prospective clients that he would invest their money 

and generate profits of “80-110%” yearly for them by investing their portfolios in “blue chip 

stocks,” options, other equity securities, and crypto assets.     

24. Those representations were false.  Over the course of the fraud, Patel received 

approximately $430,000 from at least 15 clients.  While Patel transferred some of the money he 

received from clients to his personal accounts at securities trading platforms and crypto 

exchanges and subsequently used the money to trade equities and purchase crypto assets, he 

misappropriated the majority of the money he received from clients. 

25. Patel spent most of the money for personal uses – such as online sports betting 

and living expenses – and to make Ponzi-like payments to other clients.  Moreover, the little 

investing Patel did was not profitable; he lost almost all of the money he used for investing.   

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26. In addition to not investing funds as he promised, on multiple occasions during 

the Relevant Period, Patel falsely told clients that he had profitably invested money on their 

behalf and that the investments had generated profits.   

27. For example, in August 2020, Patel texted one client that the client’s initial 

investment of $2,050 generated a profit of $238.16—more than 10%.  However, Patel never 

invested the client’s money.  Instead, Patel spent it on fast food and cash withdrawals, and to 

make payments to others.  Following Patel’s false claim of generating profits for the client on 

this initial investment, the client sent Patel additional money to invest on his behalf. 

28. In November 2020, Patel again texted this client and falsely claimed that his now 

$8,500 investment earned a profit of $2,735.66.  Again, Patel had not invested this client’s 

money, and no profit was earned.  Instead, Patel spent the money the client invested on personal 

expenses and payments to other clients.   

29. Similarly, Patel sent text messages to another client, encouraging them to invest 

and claiming that he generated profits for them.  In one text message, Patel wrote:  

I have an idea instead of a trial period where I tell you an amount which isn’t the 
best, you could get in like 2500-5k for the week then withdraw next week and 
send the money back with profits… Cause that way: 1. You’ll make good profits 
this week.  2. You’ll get to see I’m legit when you see actual cash coming back to 
you instead of just disappearing to some random guy lol.   

 
30. After this client transferred money to Patel, Patel sent him another text message, 

stating: 

Initial Investment: $25,000.00 
Profits: $1,983.91 
Commission (10.5%): $208.31 
TOTAL: $26,775.60 
 

As with the previous example, these numbers were fictitious. 

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31. Similarly, Patel told other clients that their accounts were increasing in value 

when they were not.  

C. Patel Falsely Told Clients That He Guaranteed Their Principal. 
 

32. The Investor Contracts, which Patel wrote and provided to his clients, falsely 

guaranteed their initial investments, stating: “[t]here is a solidified verbal and written agreement 

in returning the initial investment no matter the circumstances, if necessary.”   

33. In some Investor Contracts, Patel promised to return the client’s principal in “2-3 

weeks at the latest;” in others he promised repayment of principal in “1-2 weeks at the latest.”   

34. Some clients also received a “Bill of Sale” from Patel confirming that Patel 

“guarantee[d]” the client could get the principal amount of their investments back whenever the 

client deemed necessary.   

35. At the time Patel made these promises, he knew or was reckless in not knowing 

that there was no reasonable basis for him to believe that he could return his clients’ money upon 

demand.  Patel was not investing the money in securities and crypto assets, as he had 

represented.  Instead, he was using it for himself and to make Ponzi-like payments to other 

clients.     

D. Patel Also Lied To Clients Regarding Required “Fees.” 
 
36. In the Investor Contracts he wrote, Patel described a “commission/fee” schedule 

Infinity would collect from clients depending on the amount of money the client provided 

Infinity to manage.  According to the schedule, the more an individual provided Patel to manage, 

the lower the so-called “commission/fee” would be.  The agreements further provided that the 

client “agrees to dispose of a certain percentage of profit, based on the initial investment.”   

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37. Patel’s limited trading did not generate profits, therefore no fees should have been 

charged to clients.      

38. Despite this fact, beginning at least as early as January 2021, Patel misrepresented 

to clients that they owed him “fees” in an effort to convince them to send him additional money. 

39. Patel told multiple clients that if they wanted to receive their principal investment 

amounts back, they were required to pay what he called, among other things, SEC fees, 

withdrawal fees, Virginia State Corporation Commission fees, and IRS fees. 

40. In reality, none of these investors owed any such fees; and there were no fees 

relating to these clients from the SEC, the Virigina State Corporation Commission, or the IRS.  

41. Collectively, clients paid Patel at least $89,000 in phony “fees.”   

42. At least three clients paid Patel significantly more in fictitious fees than the 

amount of money they sent to Patel to invest on their behalf.  

E. Patel Violated The Federal Securities Laws. 
 
43. During the Relevant Period, Patel perpetrated a fraud on clients and potential 

clients. 

44. Patel employed a device, scheme, or artifice to defraud and engaged in acts, 

transactions, or courses of business that operated as a fraud or deceit upon clients. 

45. Patel made false statements of material fact and omitted to state material facts 

necessary to make statements made not misleading. 

46. Patel had ultimate authority for false and misleading statements made to existing 

clients and potential clients in written materials. 

47. All of the misrepresentations and omissions set forth herein, individually and in 

the aggregate, are material. 

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9 
 

48. Patel obtained money or property by means of false statements to clients, 

including money that he misappropriated. 

49. Patel acted knowingly and/or recklessly in making the above false and misleading 

statements and in undertaking the deceptive conduct. 

50. Patel acted as an investment adviser during the Relevant Period by providing 

investment advisory services for a fee. 

51. In perpetrating the fraud, Patel used the means or instruments of interstate 

commerce or of the mails, or the facility of a national securities exchange, including by sending 

numerous false statements via text. 

52. The conduct alleged herein was in connection with the offer, purchase, or sale of 

securities. 

53. On information and belief, an order requiring payments to investors arose from 

the Alabama Securities Commission’s parallel investigation. 

FIRST CLAIM FOR RELIEF 
Violations of Section 17(a) of the Securities Act 

 
54. The Commission realleges and incorporates by reference paragraphs 1 through 53 

as though fully set forth herein. 

55. By engaging in the conduct alleged herein, Patel knowingly or recklessly, in the 

offer or sale of securities, directly or indirectly, by the use of means or instruments of 

transportation or communication in interstate commerce or by use of the mails: 

a. employed devices, schemes, or artifices to defraud: 

b. obtained money or property by means of untrue statements of material fact or 

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

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

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10 
 

c. engaged in transactions, practices, or courses of business which operated or would 

operate as a fraud or deceit upon purchasers of securities. 

56. By engaging in the foregoing conduct, Patel violated, and unless enjoined, will 

continue to violate Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]. 

SECOND CLAIM FOR RELIEF 
(Violations of Section 10(b) of the Exchange Act and Rule 10b-5 Thereunder) 

57. The Commission realleges and incorporates by reference paragraphs 1 through 53 

as though fully set forth herein. 

58. By engaging in the conduct alleged herein, Patel knowingly or recklessly, in 

connection with the purchase or sale of securities, directly or indirectly, by the use of means or 

instruments of interstate commerce, or by use of the mails, or of any national securities 

exchange: 

a. employed devices, schemes, or artifices to defraud: 

b. made untrue statements of material fact or omitted to state material facts 

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

under which they were made, not misleading; and/or 

c. engaged in acts, practices, or courses of business which operated or would operate 

as a fraud or deceit upon any person. 

59. By engaging in the conduct described above, Patel violated, and unless enjoined, 

will continue to 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]. 

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11 
 

THIRD CLAIM FOR RELIEF 
(Violations of Section 206(1) and 206(2) of the Advisors Act) 

60. The Commission realleges and incorporates by reference paragraphs 1 through 53 

as though fully set forth herein. 

61. By engaging in the conduct alleged herein, Patel knowingly or recklessly or, with 

respect to subpart b below, negligently, as an investment adviser, directly or indirectly, by use of 

the means or instrumentality of interstate commerce or of the mails: 

a. employed devices, schemes or artifices to defraud any client or prospective client; 

and 

b. engaged in transactions, practices, or courses of business which operated or would 

operate as a fraud or deceit upon any client or prospective client. 

62. By engaging in the conduct described above, Patel violated, and unless enjoined 

will continue to violate, Sections 206(1) and 206(2) of the Advisers Act [15 U.S.C. §§ 80b-6(1) 

and 80b-6(2)]. 

PRAYER FOR RELIEF 

 WHEREFORE, the Commission respectfully requests that the Court enter a final 

judgment: 

I. 

 Permanently restraining and enjoining Defendant Patel from violating Section 17(a) of 

the Securities Act [15 U.S.C. § 77q(a)]; 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]; and Sections 206(1) and 206(2) of the 

Advisers Act [15 U.S.C. §§ 80b-6(1) and 80(b)-6(2)]; 

II. 

 For a period of five years, restraining and enjoining Defendant Patel from, directly or 

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12 
 

indirectly, including, but not limited to, through any entity owned or controlled by Defendant, 

participating in the issuance, purchase, offer, or sale of any security; provided, however, that 

such injunction shall not prevent Defendant from purchasing or selling securities for his own 

personal accounts.  

III. 

 For a period of five years, restraining and enjoining Defendant Patel from, directly or 

indirectly, acting as or being associated with any investment adviser.  

IV. 

 Ordering Defendant Patel to disgorge any and all ill-gotten gains, together with 

prejudgment interest, derived from the activities set forth in this Complaint; and  

V. 

 Granting such other and further relief as this Court may determine to be just and 

necessary. 

JURY DEMAND 
 

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff demands that this 

case be tried to a jury. 

 
       

  

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13 
 

      Respectfully submitted, 

 

     By: s/ John V. Donnelly III 

John V. Donnelly III, Esq. 
Gregory Bockin, Esq. 
Kingdon Kase, Esq. 
Jennifer Miller, Esq. 
United States Securities and Exchange 
Commission 

 1617 JFK Blvd., Suite 520 
 Philadelphia, PA 19103 

 Telephone: (215) 597-3100 
 Facsimile: (215) 597-2740 

Email:  [email protected] 
 

ATTORNEYS FOR PLAINTIFF UNITED 
STATES SECURITIES AND EXCHANGE 
COMMISSION 

      (Appearing pursuant to Local Rule 83.1(c)) 

Dated:  September 19, 2025 

Case 7:25-cv-01603-ACA     Document 1     Filed 09/19/25     Page 13 of 14



JS 44   (Rev. 03/24) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as 
provided by local rules of court.  This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the 
purpose of initiating the civil docket sheet.    (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF 
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

II.  BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff 
and One Box for Defendant) (For Diversity Cases Only)

1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4

of Business In This State

2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6 6
Foreign Country

IV.  NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury  - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC 
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))
140 Negotiable Instrument Liability 367 Health Care/ 400 State Reapportionment
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust

& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking
151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce
152 Recovery of Defaulted Liability 368 Asbestos Personal 835 Patent - Abbreviated 460 Deportation

Student Loans 340 Marine Injury Product New Drug Application 470 Racketeer Influenced and
(Excludes Veterans) 345 Marine Product Liability 840 Trademark Corrupt Organizations

153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR 880 Defend Trade Secrets 480 Consumer Credit
of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards Act of 2016 (15 USC 1681 or 1692)

160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending Act 485 Telephone Consumer
190 Other Contract Product Liability 380 Other Personal 720 Labor/Management SOCIAL SECURITY Protection Act
195 Contract Product Liability 360 Other Personal Property Damage Relations 861 HIA (1395ff) 490 Cable/Sat TV
196 Franchise Injury 385 Property Damage 740 Railway Labor Act 862 Black Lung (923) 850 Securities/Commodities/

362 Personal Injury - Product Liability 751 Family and Medical 863 DIWC/DIWW (405(g)) Exchange
Medical Malpractice Leave Act 864 SSID Title XVI 890 Other Statutory Actions

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation 865 RSI (405(g)) 891 Agricultural Acts
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 893 Environmental Matters
220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act FEDERAL TAX SUITS 895 Freedom of Information
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 870 Taxes (U.S. Plaintiff Act
240 Torts to Land 443 Housing/ Sentence or Defendant) 896 Arbitration
245 Tort Product Liability Accommodations 530 General 871 IRS—Third Party 899 Administrative Procedure
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION Act/Review or Appeal of

Employment Other: 462 Naturalization Application Agency Decision
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration 950 Constitutionality of

Other 550 Civil Rights Actions State Statutes
448 Education 555 Prison Condition

560 Civil Detainee -
Conditions of 
Confinement

V.  ORIGIN (Place an “X” in One Box Only)
1 Original

Proceeding 
2 Removed from

State Court
3 Remanded from

Appellate Court 
4 Reinstated or

Reopened
5 Transferred from

Another District
(specify)

6 Multidistrict
Litigation - 
Transfer

8  Multidistrict
Litigation -
Direct File

VI.  CAUSE OF ACTION
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

Brief description of cause:

VII.  REQUESTED IN
COMPLAINT:

CHECK IF THIS IS A CLASS ACTION
UNDER RULE 23, F.R.Cv.P. 

DEMAND $ CHECK YES only if demanded in complaint:
JURY DEMAND: Yes No

VIII.  RELATED CASE(S) 
          IF ANY (See instructions):

JUDGE DOCKET NUMBER

DATE SIGNATURE OF ATTORNEY OF RECORD

FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

26 USC 7609

INTELLECTUAL

United States Securities and Exchange Commission

John V. Donnelly III, U.S. Securities and Exchange 
Commission, 1617 JFK Blvd., Suite 520, Phila., PA 
19103 Telephone: (215) 597-3100

Pathyam Patel

William White, Esq., Boles Holmes White, LLC 
1929 3rd Ave North; Suite 500, Birmingham, AL 35203 
Telephone: (205) 502-2000

✖

✖

15 U.S.C. § 77q(a); 15 U.S.C. § 78j(b); 15 U.S.C. § 80b-6(1) and (2); and 17 C.F.R. § 240.10b-5 

Violation of federal securities laws.

✖

✖

9/19/2025 s / John V. Donnelly III

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