SEC v. Robert Brian Thompson, No. 3:24-cv-00800-MHL, Eastern District of Virginia (July 21, 2025) — Judgment

IN THEUNITEDSTATESDISTRICTCOURT
FORTHEEASTERNDISTRICTOFVIRGINIA
RICHMONDDIVISION
SECURITIESANDEXCHANGECOMMISSION,
Plaintiff,
C.A.No.3:24-cv-00800-MHL
V.
ROBERTBRIANTHOMPSON,
Defendant.
FINALJUDGMENTAS TO
DEFENDANTROBERTBRIANTHOMPSON
The Securitiesand ExchangeCommissionhavingfileda Complaintand Defendant
RobertBrianThompsonhavingentereda generalappearance;consentedto the Court’s
jurisdictionoverDefendantand the subjectmatterof this action;consentedto entryof this Final
Judgment;waivedfindingsof fact and conclusionsof law; and waivedany rightto appealfrom
this FinalJudgment:
I.
IT IS HEREBYORDERED,ADJUDGED,ANDDECREEDthat Defendantis
permanentlyrestrainedand enjoinedfromviolating,directlyor indirectly.Section10(b)of the
SecuritiesExchangeAct of 1934(the “ExchangeAct”)[15 U.S.C.§ 78j(b)]and RulelOb-5
promulgatedthereunder[17 C.F.R.§ 240.1Ob-5],by usingany meansor instrumentalityof
interstatecommerce,or of the mails,or of any facilityof any nationalsecuritiesexchange,in
connectionwiththe purchaseor sale of any security:
to employany device,scheme,or artificeto defraud;
(a)

to makeany untruestatementof a materialfact or to omitto statea materialfact
(b)
necessaryin orderto makethe statementsmade,in the lightof the circumstances
underwhichtheyweremade,not misleading;or
to engagein any act, practice,or courseof businesswhichoperatesor would
(c)
operateas a fraudor deceituponany person
by: (i) buyingor sellinga securityof any issuer,on the basisof materialnonpublicinformation,
in breachof a fiduciarydutyor otherdutyof trustor confidencethat is oweddirectly,indirectly.
or derivatively,to the issuerof that securityor the shareholdersof that issuer,or to any other
personwhois the sourceof the information;or (ii) communicatingmaterialnonpublic
informationabouta securityor issuer,in breachof a fiduciarydutyor otherdutyof trustor
confidence,to anotherpersonor personsfor purposesof buyingor sellingany security.
IT IS FURTHERORDERED,ADJUDGED,ANDDECREEDthat,
as providedin
FederalRuleof CivilProcedure65(d)(2),the foregoingparagraphalso bindsthe followingwho
receiveactualnoticeof this FinalJudgmentby personalserviceor otheiwise:(a) Defendant’s
officers,agents,servants,employees,and attorneys;and (b) otherpersonsin activeconcertor
participationwithDefendantor withanyonedescribedin (a).
II.
IT IS FURTHERORDERED,ADJUDGED,ANDDECREEDthat Defendantis liable
for disgorgementin the amountof $584,873and prejudgmentinterestin tlie amountof $67,750.
Disgorgementand prejudgmentinterestare deemedsatisfiedby the ConsentOrderof Forfeiture
enteredagainstThompsonon December5, 2024,and incorporatedin the Judgmentin a Criminal
CaseenteredagainstThompsonon March26, 2025,in UnitedStatesv. Thompson,No. 3:24-cr-
00164-MHL(E.D.Va.)(ECFNos.17, 27 and 28).
2

III.
IT IS FURTHERORDERED,ADJUDGED,ANDDECREEDthat Defendant’sConsent
to the entryof this FinalJudgmentis incoiporatedhereinwiththe sameforceand effectas if
fullyset forthherein,and that Defendantshallcomplywithall of the undertakingsand
agreementsset forththerein.
IV.
IT IS FURTHERORDERED,ADJUDGED,ANDDECREEDthat,
for purposesof
exceptionsto dischargeset forthin Section523 of the BankmptcyCode,11 U.S.C.§ 523,tlic
allegationsin the complaintare true and admittedby Defendant,and further,any debtfor
disgorgement,prejudgmentinterest,civilpenaltyor otheramountsdue by Defendantunderthis
FinalJudgmentor any otherjudgment,order,consentorder,decreeor settlementagreement
enteredin connectionwiththis proceeding,is a debtfor the violationby Defendantof tlie federal
securitieslawsor any regulationor orderissuedundersuchlaws,as set forthin Section
523(a)(19)of the BankruptcyCode,11 U.S.C.§ 523(a)(19).
V.
IT IS FURTHERORDERED,ADJUDGED,ANDDECREEDthatthis Couitshallretain
jurisdictionof this matterfor the purposesof enforcingthe termsof this FinalJudgment.
VI.
Therebeingno just reasonfor delay,pursuantto Rule54(b)of the FederalRulesof Civil
Procedure,the Clerkis orderedto enterthis Final
Judgmentforthwithand withoutfurtliernotice.
M. HannahLauck' T^—
UnitedStates DistrictJudj/'
/s/
Dated:^ iy 18
M.HANNAHLAUCK
UNITEDSTATESDISTRICTJUDGE
3

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

SECURITIES AND EXCHANGE COMMISSION,

Plaintiff,
C.A. No. 3:24-cv-00800-MHL

V.

ROBERT BRIAN THOMPSON,

Defendant.

FINAL JUDGMENT AS TO

DEFENDANT ROBERT BRIAN THOMPSON

The Securities and Exchange Commission having filed a Complaint and Defendant

Robert Brian Thompson 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:

I.

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that 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 lOb-5

promulgated thereunder [17 C.F.R. § 240.1 Ob-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:

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

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to make any untrue statement of a material fact or to omit to state a material fact(b)

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

under which they were made, not misleading; or

to engage in any act, practice, or course of business which operates or would(c)

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) 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.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, 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 otheiwise: (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).

II.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant is liable

for disgorgement in the amount of $584,873 and prejudgment interest in tlie amount of $67,750.

Disgorgement and prejudgment interest are deemed satisfied by the Consent Order of Forfeiture

entered against Thompson on December 5, 2024, and incorporated in the Judgment in a Criminal

Case entered against Thompson on March 26, 2025, in United States v. Thompson, No. 3:24-cr-

00164-MHL (E.D. Va.) (ECF Nos. 17, 27 and 28).

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III.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant’s Consent

to the entry of this Final Judgment is incoiporated 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.

IV.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, for purposes of

exceptions to discharge set forth in Section 523 of the Bankmptcy Code, 11 U.S.C. § 523, tlic

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 tlie federal

securities laws or any 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).

V.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that this Couit shall retain

jurisdiction of this matter for the purposes of enforcing the terms of this Final Judgment.

VI.

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 furtlier notice.

M. HannahLauck ' T ^—
United States District Judj/ ' 			

/s/

Dated: ^ iy 18

M. HANNAH LAUCK

UNITED STATES DISTRICT JUDGE

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