SEC v. Doron A. Tavlin, No. 0:22-cv-01723, District of Minnesota (Aug. 6, 2025) — Judgment

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA

Securities and Exchange Commission,

   Plaintiff

v.

Doron A. Tavlin, Afshin Farahan and
David J. Gantman,

                                 Defendants
Civil No. 22-1723 (DWF/JFD)

FINAL JUDGMENT AS TO
DEFENDANT DORON A. TAVLIN
ONLY

The Securities and Exchange Commission having filed a Complaint and
Defendant Doron A. Tavlin having entered a general appearance; consented to the
Court’s jurisdiction over Defendant and the subject matter of this action; consented to
entry of this Final Judgment; waived findings of fact and conclusions of law; and waived
any right to appeal from this Final Judgment (Doc. No. 71);
IT IS HEREBY ORDERED that:
1. Defendant is permanently restrained and enjoined from violating, directly
or indirectly, Section 10(b) of the Securities Exchange Act of 1934 (the “Exchange Act”)
[15 U.S.C. § 78j(b)] and Rule 10b-5 promulgated thereunder [17 C.F.R. § 240.10b-5], by
using any means or instrumentality of interstate commerce, or of the mails, or of any
facility of any national securities exchange, in connection with the purchase or sale of
any security:
(a) to employ any device, scheme, or artifice to defraud;

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(b) to make any untrue statement of a material fact or to omit 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) to engage in any act, practice, or course of business which operates
or would operate as a fraud or deceit upon any person by:
(i) buying or selling a security of any issuer, on the basis of
material nonpublic information, in breach of a fiduciary duty or other duty
of trust or confidence that is owed directly, indirectly, or derivatively, to the
issuer of that security or the shareholders of that issuer, or to any other
person who is the source of the information; or
(ii) by communicating material nonpublic information about a
security or issuer, in breach of a fiduciary duty or other duty of trust or
confidence, to another person or persons for purposes of buying or selling
any security.
As provided in Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph
also binds the following who receive actual notice of this Final Judgment by personal
service or otherwise:  (a) Defendant’s officers, agents, servants, employees, and
attorneys; and (b) other persons in active concert or participation with Defendant or with
anyone described in (a).
2. Pursuant to Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)],
Defendant is prohibited 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

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that is required to file reports pursuant to Section 15(d) of the Exchange Act [15 U.S.C. §
78o(d)].
3. Defendant is liable for disgorgement of $25,000, representing net profits
gained as a result of the conduct alleged in the Complaint, together with prejudgment
interest thereon in the amount of $7,875.47.  The Court finds that sending the disgorged
funds to the United States Treasury, as ordered below, is consistent with equitable
principles.  Defendant shall satisfy these obligations by paying $32,875.47 to the
Securities and Exchange Commission within 30 days after entry of this Final Judgment.
Defendant may transmit payment electronically to the Commission, which will
provide detailed ACH transfer/Fedwire instructions upon request.  Payment may also be
made directly from a bank account via Pay.gov through the SEC website at
http://www.sec.gov/about/offices/ofm.htm.  Defendant may also pay by certified check,
bank cashier’s check, or United States postal money order payable to the Securities and
Exchange Commission, which shall be delivered or mailed to
Enterprise Services Center
Accounts Receivable Branch
6500 South MacArthur Boulevard
Oklahoma City, OK 73169

and shall be accompanied by a letter identifying the case title, civil action number, and
name of this Court; Doron A. Tavlin as a defendant in this action; and specifying that
payment is made pursuant to this Final Judgment.
Defendant shall simultaneously transmit photocopies of evidence of payment and
case identifying information to the Commission’s counsel in this action.  By making this

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payment, Defendant relinquishes all legal and equitable right, title, and interest in such
funds and no part of the funds shall be returned to Defendant.  The Commission shall
send the funds paid pursuant to this Final Judgment to the United States Treasury.
The Commission may enforce the Court’s judgment for disgorgement and
prejudgment interest by using all collection procedures authorized by law, including, but
not limited to, moving for civil contempt at any time after 30 days following entry of this
Final Judgment.  The Commission may enforce the Court’s judgment for penalties by the
use of all collection procedures authorized by law, including the Federal Debt Collection
Procedures Act, 28 U.S.C. § 3001 et seq., and moving for civil contempt for the violation
of any Court orders issued in this action.
Defendant shall pay post judgment interest on any amounts due after 30 days of
the entry of this Final Judgment pursuant to 28 U.S.C. § 1961.
4. The Consent is incorporated herein with the same force and effect as if fully
set forth herein, and that Defendant shall comply with all of the undertakings and
agreements set forth therein.
5. For purposes of exceptions to discharge set forth in Section 523 of the
Bankruptcy Code, 11 U.S.C. §523, the allegations in the complaint are true and admitted
by Defendant, and further, any debt for disgorgement, prejudgment interest, civil penalty
or other amounts due by Defendant under this Final Judgment or any other judgment,
order, consent order, decree or settlement agreement entered in connection with this
proceeding, is a debt for the violation by Defendant of the federal securities laws or any

5
regulation or order issued under such laws, as set forth in Section 523(a)(19) of the
Bankruptcy Code, 11 U.S.C. §523(a)(19).
6. This Court shall retain jurisdiction of this matter for the purposes of
enforcing the terms of this Final Judgment.
7. There being no just reason for delay, pursuant to Rule 54(b) of the Federal
Rules of Civil Procedure, the Clerk is ordered to enter this Final Judgment forthwith and
without further notice.

Dated:  July 25, 2025             s/Donovan           W.           Frank
DONOVAN W. FRANK
United States District Judge

UNITED STATES DISTRICT COURT 
DISTRICT OF MINNESOTA 

 
 
Securities and Exchange Commission, 
 
   Plaintiff 
 
v. 
 
Doron A. Tavlin, Afshin Farahan and 
David J. Gantman,  
 
   Defendants 

Civil No. 22-1723 (DWF/JFD) 
 
 
 

FINAL JUDGMENT AS TO 
DEFENDANT DORON A. TAVLIN 

ONLY 

 
 

The Securities and Exchange Commission having filed a Complaint and 

Defendant Doron A. Tavlin having entered a general appearance; consented to the 

Court’s jurisdiction over Defendant and the subject matter of this action; consented to 

entry of this Final Judgment; waived findings of fact and conclusions of law; and waived 

any right to appeal from this Final Judgment (Doc. No. 71); 

IT IS HEREBY ORDERED that: 

1. Defendant is permanently restrained and enjoined from violating, directly 

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

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

using any means or instrumentality of interstate commerce, or of the mails, or of any 

facility of any national securities exchange, in connection with the purchase or sale of 

any security: 

(a) to employ any device, scheme, or artifice to defraud; 

CASE 0:22-cv-01723-DWF-JFD     Doc. 73     Filed 07/25/25     Page 1 of 5



2 

(b) to make any untrue statement of a material fact or to omit 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) to engage in any act, practice, or course of business which operates 

or would operate as a fraud or deceit upon any person by: 

(i) buying or selling a security of any issuer, on the basis of 

material nonpublic information, in breach of a fiduciary duty or other duty 

of trust or confidence that is owed directly, indirectly, or derivatively, to the 

issuer of that security or the shareholders of that issuer, or to any other 

person who is the source of the information; or 

(ii) by communicating material nonpublic information about a 

security or issuer, in breach of a fiduciary duty or other duty of trust or 

confidence, to another person or persons for purposes of buying or selling 

any security. 

As provided in Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph 

also binds the following who receive actual notice of this Final Judgment by personal 

service or otherwise:  (a) Defendant’s officers, agents, servants, employees, and 

attorneys; and (b) other persons in active concert or participation with Defendant or with 

anyone described in (a). 

2. Pursuant to Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)], 

Defendant is prohibited 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 

CASE 0:22-cv-01723-DWF-JFD     Doc. 73     Filed 07/25/25     Page 2 of 5



3 

that is required to file reports pursuant to Section 15(d) of the Exchange Act [15 U.S.C. § 

78o(d)]. 

3. Defendant is liable for disgorgement of $25,000, representing net profits 

gained as a result of the conduct alleged in the Complaint, together with prejudgment 

interest thereon in the amount of $7,875.47.  The Court finds that sending the disgorged 

funds to the United States Treasury, as ordered below, is consistent with equitable 

principles.  Defendant shall satisfy these obligations by paying $32,875.47 to the 

Securities and Exchange Commission within 30 days after entry of this Final Judgment. 

Defendant may transmit payment electronically to the Commission, which will 

provide detailed ACH transfer/Fedwire instructions upon request.  Payment may also be 

made directly from a bank account via Pay.gov through the SEC website at 

http://www.sec.gov/about/offices/ofm.htm.  Defendant may also pay by certified check, 

bank cashier’s check, or United States postal money order payable to the Securities and 

Exchange Commission, which shall be delivered or mailed to  

Enterprise Services Center 
Accounts Receivable Branch 
6500 South MacArthur Boulevard 
Oklahoma City, OK 73169 

 
and shall be accompanied by a letter identifying the case title, civil action number, and 

name of this Court; Doron A. Tavlin as a defendant in this action; and specifying that 

payment is made pursuant to this Final Judgment.   

Defendant shall simultaneously transmit photocopies of evidence of payment and 

case identifying information to the Commission’s counsel in this action.  By making this 

CASE 0:22-cv-01723-DWF-JFD     Doc. 73     Filed 07/25/25     Page 3 of 5



4 

payment, Defendant relinquishes all legal and equitable right, title, and interest in such 

funds and no part of the funds shall be returned to Defendant.  The Commission shall 

send the funds paid pursuant to this Final Judgment to the United States Treasury.   

The Commission may enforce the Court’s judgment for disgorgement and 

prejudgment interest by using all collection procedures authorized by law, including, but 

not limited to, moving for civil contempt at any time after 30 days following entry of this 

Final Judgment.  The Commission may enforce the Court’s judgment for penalties by the 

use of all collection procedures authorized by law, including the Federal Debt Collection 

Procedures Act, 28 U.S.C. § 3001 et seq., and moving for civil contempt for the violation 

of any Court orders issued in this action.  

Defendant shall pay post judgment interest on any amounts due after 30 days of 

the entry of this Final Judgment pursuant to 28 U.S.C. § 1961. 

4. The Consent is incorporated herein with the same force and effect as if fully 

set forth herein, and that Defendant shall comply with all of the undertakings and 

agreements set forth therein. 

5. For purposes of exceptions to discharge set forth in Section 523 of the 

Bankruptcy Code, 11 U.S.C. §523, the allegations in the complaint are true and admitted 

by Defendant, and further, any debt for disgorgement, prejudgment interest, civil penalty 

or other amounts due by Defendant under this Final Judgment or any other judgment, 

order, consent order, decree or settlement agreement entered in connection with this 

proceeding, is a debt for the violation by Defendant of the federal securities laws or any 

CASE 0:22-cv-01723-DWF-JFD     Doc. 73     Filed 07/25/25     Page 4 of 5



5 

regulation or order issued under such laws, as set forth in Section 523(a)(19) of the 

Bankruptcy Code, 11 U.S.C. §523(a)(19). 

6. This Court shall retain jurisdiction of this matter for the purposes of 

enforcing the terms of this Final Judgment. 

7. There being no just reason for delay, pursuant to Rule 54(b) of the Federal 

Rules of Civil Procedure, the Clerk is ordered to enter this Final Judgment forthwith and 

without further notice. 

 
Dated:  July 25, 2025   s/Donovan W. Frank  

DONOVAN W. FRANK 
United States District Judge 

CASE 0:22-cv-01723-DWF-JFD     Doc. 73     Filed 07/25/25     Page 5 of 5