SEC v. Doron A. Tavlin; Afshin Farahan; and David J. Gantman, No. 0:22-cv-01723, District of Minnesota (Aug. 6, 2025) — Complaint

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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MINNESOTA

SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,

vs.
DORON A. TAVLIN, AFSHIN
FARAHAN, and DAVID J.
GANTMAN,
Defendants.

Civil Action No.______

COMPLAINT

Plaintiff Securities and Exchange Commission (“SEC”) alleges as follows:
SUMMARY OF THE ACTION
1. This case involves unlawful insider trading by Defendants Doron A.
Tavlin (“Tavlin”), Afshin Farahan (“Farahan”), and David J. Gantman (“Gantman”)
(collectively, “Defendants”) in the securities of Mazor Robotics Ltd. (“Mazor”).
While working as a Mazor executive, Tavlin was involved in discussions regarding
the potential acquisition of Mazor by Medtronic PLC (“Medtronic”)  (the “Mazor
Acquisition”).  In August 2018, Tavlin tipped material nonpublic information to  his
friend, Farahan, regarding the Mazor Acquisition in violation of the duty of trust and
confidence that Tavlin owed to Mazor.  Tavlin encouraged Farahan to buy Mazor
securities quickly and to invest money on Tavlin’s behalf.
2. Farahan then tipped his friend, Gantman, about the Mazor Acquisition.
Over the next several weeks, Farahan and Gantman made multiple purchases of
Mazor securities, including stock and call options.

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3. On the evening of September 20, 2018, Medtronic announced its plan to
acquire Mazor (the “Announcement”), and Mazor’s stock price rose by 10% the next
day.  Farahan and Gantman realized approximately $500,000 in combined trading
profits.  Farahan later gave Tavlin a $25,000 kickback in exchange for the Mazor
information.
4. Following the trading, Tavlin, Farahan, and Gantman took steps to
conceal their illegal conduct.  Months later, in response to an inquiry into potential
insider trading, Tavlin concealed his relationship with Farahan and notified Farahan
about the inquiry.  Farahan also notified Gantman of the inquiry.  During the SEC’s
pre-filing investigation, Gantman concealed his relationship with Tavlin.
5. By engaging in the conduct alleged in this complaint, Defendants Tavlin,
Farahan, and Gantman violated the antifraud provisions of the federal securities laws,
specifically, Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”),
15 U.S.C. § 78j(b), and Rule 10b-5 promulgated under the Exchange Act, 17 C.F.R. §
240.10b-5.
JURISDICTION AND VENUE
6. The Court has jurisdiction over this action pursuant to Sections 21(d)(1),
21(d)(3)(A), 21A and 27(a) of the Exchange Act, 15 U.S.C. §§ 78u(d), 78u-1 & 78aa.
7. The SEC brings this action under Section 21(d) and 21A of the
Exchange Act, 15 U.S.C. §§ 78u(d) and 78u-1.  Defendants, directly or indirectly,
made use of the means or instrumentalities of interstate commerce, of the mails, or of
the facilities of a national securities exchange in connection with the transactions,
acts, practices and courses of business alleged in this complaint.
8. Venue is proper in this district pursuant to Section 27(a) of the Exchange
Act, 15 U.S.C. § 78aa(a), because certain of the transactions, acts, practices and
courses of conduct constituting violations of the federal securities laws occurred
within this district.  In addition, venue is proper in this district because Defendants
Gantman and Tavlin reside in this district.

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DEFENDANTS
9. Doron A. Tavlin, age 67, resides in Minneapolis, Minnesota.  Tavlin
was a consultant supporting Medtronic’s Ventures and Corporate Development Team
between January 2016 and October 2017; was Mazor’s Vice President, Business
Development from October 2017 through early 2019; and is currently an executive
for a medical device company.
10. A
fshin Farahan, age 55, resides in Pacific Palisades, California, and
owns and operates rug businesses in Minnesota.
11. D
avid J. Gantman, age 56, resides in Mendota Heights, Minnesota, and
is a licensed insurance agent and senior benefits consultant at a large insurance
company.
OTHER RELEVANT ENTITIES
12. Mazor Robotics Ltd. was a medical device company headquartered in
Israel with a U.S. location in Orlando, Florida.  Its securities were quoted on
NASDAQ under the symbol, “MZOR,” until December 2018, when it was acquired
by Medtronic.
13. M
edtronic Public Limited Company, is a medical technology
company headquartered in Ireland, with its primary operational offices in
Minneapolis, Minnesota.  Medtronic’s common stock is listed on the New York
Stock Exchange under the symbol “MDT.”
FACTS
A. Background
1. Relationships Among the Defendants
14. Tavlin and Farahan met in or around the early 2000s, when Tavlin came
into Farahan’s Minneapolis-area rug store and the two men discussed the fact that
Tavlin knew Farahan’s father.  Tavlin and Farahan formed a close personal friendship
over the next several years.  Farahan has provided money to Tavlin’s adult son at
Tavlin’s request, and has employed Tavlin’s godchild for several years.

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15. At all times relevant to this complaint, Farahan lived in the Los Angeles
area, but traveled to Minnesota because he continued to operate rug businesses in the
Minneapolis area.  Tavlin resided in the Minneapolis area, but traveled to Los
Angeles to visit his son.  When Farahan traveled to Minnesota, he stayed at Tavlin’s
home, and when Tavlin traveled to Los Angeles, he stayed at Farahan’s home.
16. Farahan and Gantman met in the early 1990s when Gantman came into
Farahan’s rug store.  Their relationship grew deeper over the years, and by the early
2010s, they were close enough that Farahan gave Gantman money when Gantman
was struggling financially.  In or around 2011, Farahan gave Gantman approximately
$10,000, and in or around 2017, he gave Gantman $5,000.  In both instances,
Gantman later paid him back.  During their friendship, Farahan and Gantman
exchanged stock trading ideas.
17. Gantman and Tavlin met through Farahan on several occasions, and at
times exchanged direct e-mail correspondence.
2. Tavlin’s Employment at Mazor and Medtronic
18. In January 2016, Tavlin signed a consulting agreement with Medtronic
that outlined several services he would provide, including managing Medtronic’s
Israeli investments.
19. In or around May 2016, Medtronic and Mazor entered into an Exclusive
Lead Sharing and Distribution Agreement.  Tavlin’s work for Medtronic included
discussions with Mazor executives regarding the relationship between the two
companies.
20. In October 2017, Tavlin left Medtronic and joined Mazor as its Vice
President, Business Development reporting to its CEO.  Mazor announced Tavlin’s
appointment to the newly created position in a press release attached to a Form 6-K
filed with the SEC on October 13, 2017.
B. Tavlin Owed a Duty of Trust and Confidence to Mazor
21. As an officer of Mazor, Tavlin owed a duty of trust and confidence to

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the company.  He was also subject to Mazor’s insider trading policy, which specified
that “neither an [employee] nor any of his/her relatives may buy or sell any securities
of the [c]ompany or engage in any other action to take advantage of, or pass on to
others, [material non-public information].”

(emphasis added).
22. Tavlin was aware of these policies and his duty of trust and confidence
to Mazor.  Upon accepting his offer of employment from Mazor, Tavlin
acknowledged in writing that he had received, understood and agreed to comply with
Mazor’s Employee Handbook, which included the insider trading policy.
C. The Mazor Acquisition
23. One of Tavlin’s key responsibilities as Mazor’s Vice President,  Business
Development was “[i]dentifying and developing Business Development Activities to
enrich the Mazor and Medtronic partnership.”  Because of his position at Mazor, he
was significantly involved in discussions between Mazor and Medtronic regarding
the Mazor Acquisition.  In fact,  in October 2018, he stated in an e-mail that he “led
the Mazor transaction with Medtronic.”
24. Beginning no later than January 10, 2018, Tavlin knew that information
regarding the Mazor Acquisition was material nonpublic information.  In addition to
having already received and acknowledged Mazor’s insider trading policy, Mazor’s
CEO e-mailed Tavlin and another Mazor executive on January 10, 2018 regarding the
Mazor Acquisition, stating in his first bullet point, “[t]he process must be managed in
extreme confidentiality.”
25. On July 29, 2018, Mazor’s CEO reported to Mazor’s board of directors
that he expected Medtronic executives to present a proposed transaction with Mazor
to Medtronic’s board of directors in August 2018.
26. On August 9, 2018, Tavlin sent Mazor’s CEO an e-mail with the subject
line, “Call me.”  In the e-mail, Tavlin explained that he had met with Medtronic’s
Vice President of Corporate Development, one of the primary Medtronic executives
responsible for negotiating the terms of the Mazor Acquisition, and that the meeting

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was “very important.”
D. Tavlin Tipped Farahan in Breach of His Duty to Mazor
27. On Friday, August 10, 2018, Farahan flew to Minneapolis and stayed at
Tavlin’s home until he flew back to Los Angeles on Thursday, August 16, 2018.
28. During his stay, Tavlin tipped Farahan that Mazor was about to be
acquired, that Farahan should purchase shares quickly, and that the information was
confidential.  Tavlin told Farahan he could be fired for providing Farahan with this
information.  Tavlin also asked Farahan to invest in Mazor on Tavlin’s behalf.
29. At the time, Farahan knew that Tavlin was a Mazor executive.  Based on
the source and nature of the information Tavlin provided to Farahan, Farahan
understood that Tavlin was sharing material nonpublic information, and understood
that he would be required to pay Tavlin for the Mazor information in the future.
30. After Tavlin told Farahan about the Mazor Acquisition, but before
Farahan went back to Los Angeles, Gantman visited Farahan at Farahan’s rug store
and the two men began discussing stocks.  Farahan told Gantman about the Mazor
Acquisition.  He also told Gantman that Tavlin was the source of information, that
Tavlin worked at Mazor, and that the information was confidential.  Based on his
relationship with Farahan, Gantman already knew that Tavlin and Farahan were close
friends.
E. Trading in Advance of the Mazor Announcement
31. Farahan placed illegal trades on the basis of the material nonpublic
information that Tavlin had tipped to him.  Gantman also used the material nonpublic
information he obtained from Farahan to place illegal trades.
32. On Monday, August 13, 2018 at approximately 10:08 a.m. CST, Farahan
purchased 2,000 shares of Mazor stock for $95,000.
33. The same day, at approximately 2:39 p.m. CST, Tavlin and Farahan had
a three-minute phone conversation.  Immediately following the phone conversation,
at approximately 2:43 p.m. CST, Farahan purchased another 2,000 Mazor shares for

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$93,500.
34. Two days later, on Wednesday, August 15, 2018 at approximately 9:41
a.m. CST, Gantman made a one-minute call to Farahan.  Farahan called him back at
approximately 11:33 a.m. CST, and the two men spoke for seven minutes.
35. A few hours later, beginning at 2:06 p.m. CST, Gantman purchased
5,000 Mazor shares for $213,850.
36. Between August 16 and September 17, 2018, Farahan continued to buy
Mazor stock in his personal brokerage account and in an account in the name of one
of his rug businesses.  In total, he purchased $1,031,597 of Mazor stock in advance of
the Announcement.  He bought 15,000 shares for $ 702,597 using his personal
account, and 7,000 shares for $329,000 using the business account.
37. Between August 17 and September 10, 2018, Gantman continued to buy
Mazor securities, but instead of buying more stock, he purchased call options –
betting that Mazor’s stock price would go up in the near term.  By doing so, he
increased his chances of a bigger return if the stock price went up, but also increased
the risk of losing money if Mazor’s stock price did not rise enough by the time his
options expired.
38. Gantman purchased options with expiration dates of September 21,
October 19, and November 16, 2018, all with $50 strike prices, and all at times when
Mazor stock was trading lower than $50 per share.  This meant that the call options
Gantman purchased were “out-of-the-money” at the time of purchase, and therefore
cheaper and riskier than other options.
39. In total, Gantman purchased $287,083 worth of Mazor securities,
spending $213,850 on stock and $73,233 on out-of-the-money call options.
F. The A nnouncement
40. On September 20, 2018, at approximately 5:57 p.m. CST, Mazor
announced that it had agreed to be acquired by Medtronic for $58.50 per share.  The
next morning, Mazor’s stock price opened at $58, up more than 10% from the prior

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day’s closing price of $52.75.
41. Farahan sold all of his Mazor shares on September 21, 2018.  His total
trading profits were approximately $247,500, consisting of $169,503 from his
personal account and $78,050 from the business account.
42. After the Announcement, Gantman sold all of the Mazor securities in his
account on September 21, 2018.  His total profits were approximately $255,562,
consisting of $76,975 from trading Mazor stock and $178,587 from trading Mazor
options.
G. Defendants’ Efforts to Conceal Their Fraud
1. Tavlin Denies Knowing Farahan During a FINRA Inquiry
43. On October 4, 2018 at 10:14 a.m. CST, one of Tavlin’s colleagues at
Mazor sent him an e-mail regarding an inquiry by the Financial Industry Regulatory
Authority (“FINRA”) into trading around the Announcement.  The colleague
informed Tavlin of the inquiry and asked him to supply his home address and
additional detail about the chronology of events leading up to the Announcement.
44. Approximately six minutes later, at 10:20 a.m. CST, Tavlin called
Farahan and the call lasted for four minutes.  At 10:52 a.m. CST, Farahan called
Gantman and the call lasted for one minute.  Gantman called Farahan back at 1:45
p.m. CST, and the call lasted for one minute.

45. On December 19, 2018, FINRA provided Mazor’s outside counsel with
a list that included the names of certain traders who had purchased Mazor securities
before the Announcement (the “Name Recognition List”),  and asked that everyone
who had knowledge of the Mazor Acquisition in advance of the Announcement
review the list and identify anyone they knew.  Both Farahan and Gantman were on
the list.
46. On January 8, 2019 at 2:57 a.m. CST, Mazor’s Israel-based in -house
counsel sent an e-mail to designated Mazor personnel, including Tavlin, with the
Name Recognition List attached.  The e-mail instructed each recipient to respond,

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either confirming that they knew no individuals or entities on the list or providing
additional information if they did.
47. The same morning, at 10:37 a.m. CST, Tavlin called Farahan.  Farahan
called Tavlin back at 10:41 a.m. CST, and the two spoke for eight minutes.  Tavlin
told Farahan that Farahan’s name was on the list, and that Tavlin did not plan on
identifying him as someone he knew.  Tavlin then sent Farahan the list via text or e-
mail.
48. About an hour after the call with Farahan, Tavlin responded to the e-mail
from Mazor’s legal counsel stating that he did not have relationships with any
“entities” on the list, concealing his relationship with Farahan and Gantman.
49. When Farahan reviewed the Name Recognition List, he recognized
Gantman’s name.  He then called Gantman and informed Gantman that he was on the
list.
50. On January 16, 2019, Mazor’s outside counsel provided FINRA with the
names of all Mazor employees who reported knowing anyone on the Name
Recognition List.  Tavlin’s name was not included.
2. Farahan Gives Tavlin a Kickback for the Tip
51. In or around October 2019, during breakfast at a restaurant in Minnesota,
Tavlin told Farahan he needed money and asked Farahan for money in exchange for
the Mazor Acquisition information that Tavlin had provided to Farahan in August
2018.  Farahan used one of his company accounts to write Tavlin a check for
$25,000.  The check was dated October 25, 2019, and Tavlin cashed it on October 28,
2019.
3. Gantman Conceals His Relationship with Tavlin
52. Gantman provided conflicting statements regarding his relationship with
Tavlin.  On January 27, 2021, he represented to SEC staff that he had “not had any
correspondence, e-mails, or conversations with Doron Tavlin.”
53. But during his March 2, 2021 testimony with the staff, Gantman

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admitted that Farahan had introduced him to Tavlin, and that he had spoken with
Tavlin in person several times in the past, but not for six or seven years.  He went on
to explain that he knew Tavlin was in the medical field because he had looked him up
on LinkedIn around the time Farahan introduced them.  He also stated, “I can make
one thing certain to you and on the record.  I never had any communications with Mr.
Tavlin.  So I will be very clear about that.”
54. However, Gantman had in fact e-mailed Tavlin in December 2017,
introducing Tavlin to another person.  In the e-mail addressed to Tavlin and the other
person, Gantman wrote, “[y]ou’re two of my friends that will likely share some
common interests and good conversation.”
55. On January 28, 2022, Gantman changed his story again, representing to
SEC staff that he “had no direct or indirect communication with Doron Tavlin since
2014 or prior,” and “had no knowledge of Doron Tavlin’s professional occupation
just before or after [he] purchased Mazor stock.”
FIRST CLAIM FOR RELIEF
Violations of Section 10(b) of the Exchange Act and Rule 10b-5
(Against All Defendants)
56. The SEC realleges and incorporates by reference paragraphs 1 through
55 above.
57. Tavlin learned material nonpublic information through his work as a
Mazor executive.  Tavlin knew or was reckless in not knowing, that the information
he possessed concerning the potential acquisition of Mazor was material nonpublic
information.
58. At all relevant times, Tavlin had a relationship of trust and confidence
with Mazor that required him to keep nonpublic information regarding the Mazor
Acquisition confidential.  Tavlin knew, consciously avoided knowing, or was
reckless in not knowing, that he owed Mazor a duty of trust or confidence to keep the
material nonpublic information he possessed concerning the potential acquisition of

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Mazor confidential.  Tavlin breached that duty by tipping his close friend Farahan
about the Mazor Acquisition, by encouraging Farahan to purchase Mazor securities
quickly, and by asking Farahan to trade on his behalf.
59. Tavlin tipped Farahan concerning the Mazor Acquisition with the intent
to benefit his close friend, Farahan.  Tavlin also expected a monetary benefit from
Farahan in exchange for the material nonpublic information, which Tavlin later
received in the form of a $25,000 check.
60. At the time he traded in the securities of Mazor and tipped his friend
Gantman, Farahan knew or was reckless in not knowing, that he was in possession of
material nonpublic information.
61. Farahan also knew, consciously avoided knowing, or was reckless in not
knowing, the material nonpublic information about the Mazor Acquisition that Tavlin
had disclosed to him was disclosed in breach of a fiduciary duty, or similar
relationship of trust and confidence.
62. Farahan tipped Gantman with the intention that Gantman would use the
information to trade Mazor securities and knew, consciously avoided knowing, or
was reckless in not knowing, that Gantman would trade.
63. Farahan received a personal benefit from tipping Gantman because he
made a gift of information to a close friend.
64. Gantman knew or was reckless in not knowing that the information
Farahan tipped to him was material and nonpublic.  Gantman also knew, consciously
avoided knowing, or was reckless in not knowing that the information was passed in
breach of a duty or relationship of trust and confidence.
65. By engaging in the conduct described above, Defendants Tavlin,
Farahan, and Gantman, directly or indirectly, in connection with the purchase or sale
of a security, by the use of means or instrumentalities of interstate commerce, of the
mails, or of the facilities of a national securities exchange: (a) employed devices,
schemes, or artifices to defraud; (b) made untrue statements of a material fact or

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omitted to state a material fact necessary in order to make the statements made, in the
light of the circumstances under which they were made, not misleading; or (c)
engaged in acts, practices, or courses of business which operated or would operate as
a fraud or deceit upon other persons.
66. By engaging in the conduct described above, Defendants Tavlin,
Farahan, and Gantman violated, and unless restrained and enjoined will continue to
violate, Section 10(b) of the Exchange Act, 15 U.S.C. § 78j(b), and Rules 10b-5
thereunder, 17 C.F.R. § 240.10b-5.
PRAYER FOR RELIEF
WHEREFORE, the SEC respectfully requests that the Court:
I.
Issue findings of fact and conclusions of law that Defendants committed the
alleged violations.
II.
Issue judgments, in forms consistent with Rule 65(d) of the Federal Rules of
Civil Procedure permanently enjoining Defendants Tavlin, Farahan, and Gantman
and their officers, agents, servants, employees and attorneys, and those persons in
active concert or participation with any of them, who receive actual notice of the
judgment by personal service or otherwise, and each of them, from violating 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.
III.
Order Defendants Tavlin, Farahan, and Gantman to disgorge all funds received
from their illegal conduct, together with prejudgment interest thereon pursuant to
Exchange Act Sections 21(d)(5) and 21(d)(7) [15 U.S.C. §§ 78u(d)(5) and 78u(d)(7)].
IV.
Order Defendants Tavlin, Farahan, and Gantman to pay a civil penalty under
Section 21A of the Exchange Act, 15 U.S.C. § 78u-1.

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V.
Enter an order against Defendant Tavlin pursuant to Section 21(d)(2) of the
Exchange Act, 15 U.S.C. § 78u(d)(2), prohibiting him from acting as an officer or
director of any issuer that has a class of securities registered pursuant to Section 12 of
the Exchange Act, 15 U.S.C. § 78l, or that is required to file reports pursuant to
Section 15(d) of the Exchange Act, 78 U.S.C. § 78o(d).
VI.
Retain jurisdiction of this action in accordance with the principles of equity and
the Federal Rules of Civil Procedure in order to implement and carry out the terms of
all orders and decrees that may be entered, or to entertain any suitable application or
motion for additional relief within the jurisdiction of this Court.

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VII.
Grant such other and further relief as this Court may determine to be just and
necessary.
Dated:  July 6 , 2022 Respectfully Submitted,

 Stephen Kam (Cal. Bar No. 327576)
Sara Kalin (Cal. Bar No. 212156)
Securities and Exchange Commission
444 S. Flower St., Ste. 900
Los Angeles, CA 90071
Tel: (323) 965-3998
Fax: (213) 443-1902
[email protected]
[email protected]
Attorneys for Plaintiff Securities and
Exchange Commission

/s/    Craig Baune
Craig Baune (MN Bar No. 331727)
Assistant United States Attorney
District of Minnesota
600 U.S. Courthouse
300 South Fourth Street
Minneapolis, MN 55414
Telephone: (612) 664-5600
[email protected]
Local Counsel

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1  

 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF MINNESOTA 

 

SECURITIES AND EXCHANGE 
COMMISSION, 

Plaintiff, 
 

vs. 

DORON A. TAVLIN, AFSHIN 
FARAHAN, and DAVID J. 
GANTMAN, 

Defendants. 
 

  
 
 
 
Civil Action No.______  
 
 
COMPLAINT 
 
 

 
 

Plaintiff Securities and Exchange Commission (“SEC”) alleges as follows: 

SUMMARY OF THE ACTION 

1. This case involves unlawful insider trading by Defendants Doron A. 

Tavlin (“Tavlin”), Afshin Farahan (“Farahan”), and David J. Gantman (“Gantman”) 

(collectively, “Defendants”) in the securities of Mazor Robotics Ltd. (“Mazor”).  

While working as a Mazor executive, Tavlin was involved in discussions regarding 

the potential acquisition of Mazor by Medtronic PLC (“Medtronic”) (the “Mazor 

Acquisition”).  In August 2018, Tavlin tipped material nonpublic information to his 

friend, Farahan, regarding the Mazor Acquisition in violation of the duty of trust and 

confidence that Tavlin owed to Mazor.  Tavlin encouraged Farahan to buy Mazor 

securities quickly and to invest money on Tavlin’s behalf.   

2. Farahan then tipped his friend, Gantman, about the Mazor Acquisition.  

Over the next several weeks, Farahan and Gantman made multiple purchases of 

Mazor securities, including stock and call options.   

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3. On the evening of September 20, 2018, Medtronic announced its plan to 

acquire Mazor (the “Announcement”), and Mazor’s stock price rose by 10% the next 

day.  Farahan and Gantman realized approximately $500,000 in combined trading 

profits.  Farahan later gave Tavlin a $25,000 kickback in exchange for the Mazor 

information. 

4. Following the trading, Tavlin, Farahan, and Gantman took steps to 

conceal their illegal conduct.  Months later, in response to an inquiry into potential 

insider trading, Tavlin concealed his relationship with Farahan and notified Farahan 

about the inquiry.  Farahan also notified Gantman of the inquiry.  During the SEC’s 

pre-filing investigation, Gantman concealed his relationship with Tavlin.   

5. By engaging in the conduct alleged in this complaint, Defendants Tavlin,  

Farahan, and Gantman violated the antifraud provisions of the federal securities laws, 

specifically, Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”), 

15 U.S.C. § 78j(b), and Rule 10b-5 promulgated under the Exchange Act, 17 C.F.R. § 

240.10b-5. 

JURISDICTION AND VENUE 

6. The Court has jurisdiction over this action pursuant to Sections 21(d)(1), 

21(d)(3)(A), 21A and 27(a) of the Exchange Act, 15 U.S.C. §§ 78u(d), 78u-1 & 78aa. 

7. The SEC brings this action under Section 21(d) and 21A of the 

Exchange Act, 15 U.S.C. §§ 78u(d) and 78u-1.  Defendants, directly or indirectly, 

made use of the means or instrumentalities of interstate commerce, of the mails, or of 

the facilities of a national securities exchange in connection with the transactions, 

acts, practices and courses of business alleged in this complaint.  

8. Venue is proper in this district pursuant to Section 27(a) of the Exchange 

Act, 15 U.S.C. § 78aa(a), because certain of the transactions, acts, practices and 

courses of conduct constituting violations of the federal securities laws occurred 

within this district.  In addition, venue is proper in this district because Defendants 

Gantman and Tavlin reside in this district. 

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DEFENDANTS 

9. Doron A. Tavlin, age 67, resides in Minneapolis, Minnesota.  Tavlin 

was a consultant supporting Medtronic’s Ventures and Corporate Development Team 

between January 2016 and October 2017; was Mazor’s Vice President, Business 

Development from October 2017 through early 2019; and is currently an executive 

for a medical device company. 

10. Afshin Farahan, age 55, resides in Pacific Palisades, California, and 

owns and operates rug businesses in Minnesota.   

11. David J. Gantman, age 56, resides in Mendota Heights, Minnesota, and 

is a licensed insurance agent and senior benefits consultant at a large insurance 

company. 

OTHER RELEVANT ENTITIES 

12. Mazor Robotics Ltd. was a medical device company headquartered in 

Israel with a U.S. location in Orlando, Florida.  Its securities were quoted on 

NASDAQ under the symbol, “MZOR,” until December 2018, when it was acquired 

by Medtronic.     

13. Medtronic Public Limited Company, is a medical technology 

company headquartered in Ireland, with its primary operational offices in 

Minneapolis, Minnesota.  Medtronic’s common stock is listed on the New York 

Stock Exchange under the symbol “MDT.”   

FACTS 

A. Background 

1. Relationships Among the Defendants 

14. Tavlin and Farahan met in or around the early 2000s, when Tavlin came 

into Farahan’s Minneapolis-area rug store and the two men discussed the fact that 

Tavlin knew Farahan’s father.  Tavlin and Farahan formed a close personal friendship 

over the next several years.  Farahan has provided money to Tavlin’s adult son at 

Tavlin’s request, and has employed Tavlin’s godchild for several years. 

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15. At all times relevant to this complaint, Farahan lived in the Los Angeles 

area, but traveled to Minnesota because he continued to operate rug businesses in the 

Minneapolis area.  Tavlin resided in the Minneapolis area, but traveled to Los 

Angeles to visit his son.  When Farahan traveled to Minnesota, he stayed at Tavlin’s 

home, and when Tavlin traveled to Los Angeles, he stayed at Farahan’s home. 

16. Farahan and Gantman met in the early 1990s when Gantman came into 

Farahan’s rug store.  Their relationship grew deeper over the years, and by the early 

2010s, they were close enough that Farahan gave Gantman money when Gantman 

was struggling financially.  In or around 2011, Farahan gave Gantman approximately 

$10,000, and in or around 2017, he gave Gantman $5,000.  In both instances, 

Gantman later paid him back.  During their friendship, Farahan and Gantman 

exchanged stock trading ideas.   

17. Gantman and Tavlin met through Farahan on several occasions, and at 

times exchanged direct e-mail correspondence. 

2. Tavlin’s Employment at Mazor and Medtronic 

18. In January 2016, Tavlin signed a consulting agreement with Medtronic 

that outlined several services he would provide, including managing Medtronic’s 

Israeli investments.   

19. In or around May 2016, Medtronic and Mazor entered into an Exclusive 

Lead Sharing and Distribution Agreement.  Tavlin’s work for Medtronic included 

discussions with Mazor executives regarding the relationship between the two 

companies.     

20. In October 2017, Tavlin left Medtronic and joined Mazor as its Vice 

President, Business Development reporting to its CEO.  Mazor announced Tavlin’s 

appointment to the newly created position in a press release attached to a Form 6-K 

filed with the SEC on October 13, 2017.  

B. Tavlin Owed a Duty of Trust and Confidence to Mazor 

21. As an officer of Mazor, Tavlin owed a duty of trust and confidence to 

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the company.  He was also subject to Mazor’s insider trading policy, which specified 

that “neither an [employee] nor any of his/her relatives may buy or sell any securities 

of the [c]ompany or engage in any other action to take advantage of, or pass on to 

others, [material non-public information].” (emphasis added). 

22. Tavlin was aware of these policies and his duty of trust and confidence 

to Mazor.  Upon accepting his offer of employment from Mazor, Tavlin 

acknowledged in writing that he had received, understood and agreed to comply with 

Mazor’s Employee Handbook, which included the insider trading policy.   

C. The Mazor Acquisition 

23. One of Tavlin’s key responsibilities as Mazor’s Vice President, Business 

Development was “[i]dentifying and developing Business Development Activities to 

enrich the Mazor and Medtronic partnership.”  Because of his position at Mazor, he 

was significantly involved in discussions between Mazor and Medtronic regarding 

the Mazor Acquisition.  In fact, in October 2018, he stated in an e-mail that he “led 

the Mazor transaction with Medtronic.” 

24. Beginning no later than January 10, 2018, Tavlin knew that information 

regarding the Mazor Acquisition was material nonpublic information.  In addition to 

having already received and acknowledged Mazor’s insider trading policy, Mazor’s 

CEO e-mailed Tavlin and another Mazor executive on January 10, 2018 regarding the 

Mazor Acquisition, stating in his first bullet point, “[t]he process must be managed in 

extreme confidentiality.” 

25. On July 29, 2018, Mazor’s CEO reported to Mazor’s board of directors 

that he expected Medtronic executives to present a proposed transaction with Mazor 

to Medtronic’s board of directors in August 2018.   

26. On August 9, 2018, Tavlin sent Mazor’s CEO an e-mail with the subject 

line, “Call me.”  In the e-mail, Tavlin explained that he had met with Medtronic’s 

Vice President of Corporate Development, one of the primary Medtronic executives 

responsible for negotiating the terms of the Mazor Acquisition, and that the meeting 

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was “very important.”   

D. Tavlin Tipped Farahan in Breach of His Duty to Mazor 

27. On Friday, August 10, 2018, Farahan flew to Minneapolis and stayed at 

Tavlin’s home until he flew back to Los Angeles on Thursday, August 16, 2018. 

28. During his stay, Tavlin tipped Farahan that Mazor was about to be 

acquired, that Farahan should purchase shares quickly, and that the information was 

confidential.  Tavlin told Farahan he could be fired for providing Farahan with this 

information.  Tavlin also asked Farahan to invest in Mazor on Tavlin’s behalf.   

29. At the time, Farahan knew that Tavlin was a Mazor executive.  Based on 

the source and nature of the information Tavlin provided to Farahan, Farahan   

understood that Tavlin was sharing material nonpublic information, and understood 

that he would be required to pay Tavlin for the Mazor information in the future.   

30. After Tavlin told Farahan about the Mazor Acquisition, but before 

Farahan went back to Los Angeles, Gantman visited Farahan at Farahan’s rug store 

and the two men began discussing stocks.  Farahan told Gantman about the Mazor 

Acquisition.  He also told Gantman that Tavlin was the source of information, that 

Tavlin worked at Mazor, and that the information was confidential.  Based on his 

relationship with Farahan, Gantman already knew that Tavlin and Farahan were close 

friends. 

E. Trading in Advance of the Mazor Announcement 

31. Farahan placed illegal trades on the basis of the material nonpublic 

information that Tavlin had tipped to him.  Gantman also used the material nonpublic 

information he obtained from Farahan to place illegal trades.  

32. On Monday, August 13, 2018 at approximately 10:08 a.m. CST, Farahan 

purchased 2,000 shares of Mazor stock for $95,000. 

33. The same day, at approximately 2:39 p.m. CST, Tavlin and Farahan had 

a three-minute phone conversation.  Immediately following the phone conversation, 

at approximately 2:43 p.m. CST, Farahan purchased another 2,000 Mazor shares for 

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$93,500. 

34. Two days later, on Wednesday, August 15, 2018 at approximately 9:41 

a.m. CST, Gantman made a one-minute call to Farahan.  Farahan called him back at 

approximately 11:33 a.m. CST, and the two men spoke for seven minutes. 

35. A few hours later, beginning at 2:06 p.m. CST, Gantman purchased 

5,000 Mazor shares for $213,850. 

36. Between August 16 and September 17, 2018, Farahan continued to buy 

Mazor stock in his personal brokerage account and in an account in the name of one 

of his rug businesses.  In total, he purchased $1,031,597 of Mazor stock in advance of 

the Announcement.  He bought 15,000 shares for $702,597 using his personal 

account, and 7,000 shares for $329,000 using the business account. 

37. Between August 17 and September 10, 2018, Gantman continued to buy 

Mazor securities, but instead of buying more stock, he purchased call options – 

betting that Mazor’s stock price would go up in the near term.  By doing so, he 

increased his chances of a bigger return if the stock price went up, but also increased 

the risk of losing money if Mazor’s stock price did not rise enough by the time his 

options expired. 

38. Gantman purchased options with expiration dates of September 21, 

October 19, and November 16, 2018, all with $50 strike prices, and all at times when 

Mazor stock was trading lower than $50 per share.  This meant that the call options 

Gantman purchased were “out-of-the-money” at the time of purchase, and therefore 

cheaper and riskier than other options. 

39. In total, Gantman purchased $287,083 worth of Mazor securities, 

spending $213,850 on stock and $73,233 on out-of-the-money call options.  

F. The Announcement 

40. On September 20, 2018, at approximately 5:57 p.m. CST, Mazor 

announced that it had agreed to be acquired by Medtronic for $58.50 per share.  The 

next morning, Mazor’s stock price opened at $58, up more than 10% from the prior 

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day’s closing price of $52.75.   

41. Farahan sold all of his Mazor shares on September 21, 2018.  His total 

trading profits were approximately $247,500, consisting of $169,503 from his 

personal account and $78,050 from the business account. 

42. After the Announcement, Gantman sold all of the Mazor securities in his 

account on September 21, 2018.  His total profits were approximately $255,562, 

consisting of $76,975 from trading Mazor stock and $178,587 from trading Mazor 

options. 

G. Defendants’ Efforts to Conceal Their Fraud 

1. Tavlin Denies Knowing Farahan During a FINRA Inquiry  

43. On October 4, 2018 at 10:14 a.m. CST, one of Tavlin’s colleagues at 

Mazor sent him an e-mail regarding an inquiry by the Financial Industry Regulatory 

Authority (“FINRA”) into trading around the Announcement.  The colleague 

informed Tavlin of the inquiry and asked him to supply his home address and 

additional detail about the chronology of events leading up to the Announcement. 

44. Approximately six minutes later, at 10:20 a.m. CST, Tavlin called 

Farahan and the call lasted for four minutes.  At 10:52 a.m. CST, Farahan called 

Gantman and the call lasted for one minute.  Gantman called Farahan back at 1:45 

p.m. CST, and the call lasted for one minute.  

45. On December 19, 2018, FINRA provided Mazor’s outside counsel with 

a list that included the names of certain traders who had purchased Mazor securities 

before the Announcement (the “Name Recognition List”), and asked that everyone 

who had knowledge of the Mazor Acquisition in advance of the Announcement 

review the list and identify anyone they knew.  Both Farahan and Gantman were on 

the list. 

46. On January 8, 2019 at 2:57 a.m. CST, Mazor’s Israel-based in-house 

counsel sent an e-mail to designated Mazor personnel, including Tavlin, with the 

Name Recognition List attached.  The e-mail instructed each recipient to respond, 

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either confirming that they knew no individuals or entities on the list or providing 

additional information if they did.       

47. The same morning, at 10:37 a.m. CST, Tavlin called Farahan.  Farahan 

called Tavlin back at 10:41 a.m. CST, and the two spoke for eight minutes.  Tavlin 

told Farahan that Farahan’s name was on the list, and that Tavlin did not plan on 

identifying him as someone he knew.  Tavlin then sent Farahan the list via text or e-

mail. 

48. About an hour after the call with Farahan, Tavlin responded to the e-mail 

from Mazor’s legal counsel stating that he did not have relationships with any 

“entities” on the list, concealing his relationship with Farahan and Gantman.   

49. When Farahan reviewed the Name Recognition List, he recognized 

Gantman’s name.  He then called Gantman and informed Gantman that he was on the 

list.    

50. On January 16, 2019, Mazor’s outside counsel provided FINRA with the 

names of all Mazor employees who reported knowing anyone on the Name 

Recognition List.  Tavlin’s name was not included.    

2. Farahan Gives Tavlin a Kickback for the Tip 

51. In or around October 2019, during breakfast at a restaurant in Minnesota, 

Tavlin told Farahan he needed money and asked Farahan for money in exchange for 

the Mazor Acquisition information that Tavlin had provided to Farahan in August 

2018.  Farahan used one of his company accounts to write Tavlin a check for 

$25,000.  The check was dated October 25, 2019, and Tavlin cashed it on October 28, 

2019.    

3. Gantman Conceals His Relationship with Tavlin 

52. Gantman provided conflicting statements regarding his relationship with 

Tavlin.  On January 27, 2021, he represented to SEC staff that he had “not had any 

correspondence, e-mails, or conversations with Doron Tavlin.” 

53. But during his March 2, 2021 testimony with the staff, Gantman 

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admitted that Farahan had introduced him to Tavlin, and that he had spoken with 

Tavlin in person several times in the past, but not for six or seven years.  He went on 

to explain that he knew Tavlin was in the medical field because he had looked him up 

on LinkedIn around the time Farahan introduced them.  He also stated, “I can make 

one thing certain to you and on the record.  I never had any communications with Mr. 

Tavlin.  So I will be very clear about that.”    

54. However, Gantman had in fact e-mailed Tavlin in December 2017, 

introducing Tavlin to another person.  In the e-mail addressed to Tavlin and the other 

person, Gantman wrote, “[y]ou’re two of my friends that will likely share some 

common interests and good conversation.”    

55. On January 28, 2022, Gantman changed his story again, representing to 

SEC staff that he “had no direct or indirect communication with Doron Tavlin since 

2014 or prior,” and “had no knowledge of Doron Tavlin’s professional occupation 

just before or after [he] purchased Mazor stock.”  

FIRST CLAIM FOR RELIEF 

Violations of Section 10(b) of the Exchange Act and Rule 10b-5 

(Against All Defendants) 

56. The SEC realleges and incorporates by reference paragraphs 1 through 

55 above. 

57. Tavlin learned material nonpublic information through his work as a 

Mazor executive.  Tavlin knew or was reckless in not knowing, that the information 

he possessed concerning the potential acquisition of Mazor was material nonpublic 

information. 

58. At all relevant times, Tavlin had a relationship of trust and confidence 

with Mazor that required him to keep nonpublic information regarding the Mazor 

Acquisition confidential.  Tavlin knew, consciously avoided knowing, or was 

reckless in not knowing, that he owed Mazor a duty of trust or confidence to keep the 

material nonpublic information he possessed concerning the potential acquisition of 

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Mazor confidential.  Tavlin breached that duty by tipping his close friend Farahan 

about the Mazor Acquisition, by encouraging Farahan to purchase Mazor securities 

quickly, and by asking Farahan to trade on his behalf.   

59. Tavlin tipped Farahan concerning the Mazor Acquisition with the intent 

to benefit his close friend, Farahan.  Tavlin also expected a monetary benefit from 

Farahan in exchange for the material nonpublic information, which Tavlin later 

received in the form of a $25,000 check. 

60. At the time he traded in the securities of Mazor and tipped his friend 

Gantman, Farahan knew or was reckless in not knowing, that he was in possession of 

material nonpublic information.  

61. Farahan also knew, consciously avoided knowing, or was reckless in not 

knowing, the material nonpublic information about the Mazor Acquisition that Tavlin 

had disclosed to him was disclosed in breach of a fiduciary duty, or similar 

relationship of trust and confidence. 

62. Farahan tipped Gantman with the intention that Gantman would use the 

information to trade Mazor securities and knew, consciously avoided knowing, or 

was reckless in not knowing, that Gantman would trade. 

63. Farahan received a personal benefit from tipping Gantman because he 

made a gift of information to a close friend. 

64. Gantman knew or was reckless in not knowing that the information 

Farahan tipped to him was material and nonpublic.  Gantman also knew, consciously 

avoided knowing, or was reckless in not knowing that the information was passed in 

breach of a duty or relationship of trust and confidence.   

65. By engaging in the conduct described above, Defendants Tavlin, 

Farahan, and Gantman, directly or indirectly, in connection with the purchase or sale 

of a security, by the use of means or instrumentalities of interstate commerce, of the 

mails, or of the facilities of a national securities exchange: (a) employed devices, 

schemes, or artifices to defraud; (b) made untrue statements of a material fact or 

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omitted to state a material fact necessary in order to make the statements made, in the 

light of the circumstances under which they were made, not misleading; or (c) 

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

a fraud or deceit upon other persons. 

66. By engaging in the conduct described above, Defendants Tavlin, 

Farahan, and Gantman violated, and unless restrained and enjoined will continue to 

violate, Section 10(b) of the Exchange Act, 15 U.S.C. § 78j(b), and Rules 10b-5 

thereunder, 17 C.F.R. § 240.10b-5. 

PRAYER FOR RELIEF 

WHEREFORE, the SEC respectfully requests that the Court: 

I. 

Issue findings of fact and conclusions of law that Defendants committed the 

alleged violations. 

II. 

Issue judgments, in forms consistent with Rule 65(d) of the Federal Rules of 

Civil Procedure permanently enjoining Defendants Tavlin, Farahan, and Gantman 

and their officers, agents, servants, employees and attorneys, and those persons in 

active concert or participation with any of them, who receive actual notice of the 

judgment by personal service or otherwise, and each of them, from violating 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. 

III. 

Order Defendants Tavlin, Farahan, and Gantman to disgorge all funds received 

from their illegal conduct, together with prejudgment interest thereon pursuant to 

Exchange Act Sections 21(d)(5) and 21(d)(7) [15 U.S.C. §§ 78u(d)(5) and 78u(d)(7)].  

IV. 

Order Defendants Tavlin, Farahan, and Gantman to pay a civil penalty under 

Section 21A of the Exchange Act, 15 U.S.C. § 78u-1.  

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V. 

Enter an order against Defendant Tavlin pursuant to Section 21(d)(2) of the 

Exchange Act, 15 U.S.C. § 78u(d)(2), prohibiting him from acting as an officer or 

director of any issuer that has a class of securities registered pursuant to Section 12 of 

the Exchange Act, 15 U.S.C. § 78l, or that is required to file reports pursuant to 

Section 15(d) of the Exchange Act, 78 U.S.C. § 78o(d).  

VI. 

Retain jurisdiction of this action in accordance with the principles of equity and 

the Federal Rules of Civil Procedure in order to implement and carry out the terms of 

all orders and decrees that may be entered, or to entertain any suitable application or 

motion for additional relief within the jurisdiction of this Court. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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VII. 

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

necessary. 

Dated:  July 6, 2022 Respectfully Submitted, 
 

 Stephen Kam (Cal. Bar No. 327576) 
Sara Kalin (Cal. Bar No. 212156) 
Securities and Exchange Commission 
444 S. Flower St., Ste. 900 
Los Angeles, CA 90071 
Tel: (323) 965-3998 
Fax: (213) 443-1902 
[email protected] 
[email protected] 
Attorneys for Plaintiff Securities and 
Exchange Commission 
 
/s/ Craig Baune   
Craig Baune (MN Bar No. 331727) 
Assistant United States Attorney 
District of Minnesota 
600 U.S. Courthouse 
300 South Fourth Street 
Minneapolis, MN 55414 
Telephone: (612) 664-5600 
[email protected] 
Local Counsel 
 
 
 

 
 

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CASE 0:22-cv-01723   Doc. 1-1   Filed 07/06/22   Page 1 of 2



JS 44 Reverse (Rev  04/21)

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VII.  Requested in Complaint.  Class Action.  Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P. 
Demand.  In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction. 
Jury Demand.  Check the appropriate box to indicate whether or not a jury is being demanded. 

VIII.   Related Cases.   This section of the JS 44 is used to reference related pending cases, if any.  If there are related pending cases, insert the docket  
numbers and the corresponding judge names for such cases. 

Date and Attorney Signature.  Date and sign the civil cover sheet. 

CASE 0:22-cv-01723   Doc. 1-1   Filed 07/06/22   Page 2 of 2