SEC v. Anthony Caine; Anish Parvatani; LJM Funds Management, Ltd.; and LJM Partners, Ltd., No. 1:21-cv-02859, Northern District of Illinois (July 1, 2025) — Judgment

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

SECURITIES AND EXCHANGE
COMMISSION,

Plaintiff,

v. Case No. 1:21-cv-02859

ANTHONY CAINE,
ANISH PARVATANENI,
LJM FUNDS MANAGEMENT, LTD.,
Honorable Keri Holleb Hotaling

and LJM PARTNERS, LTD.,

Defendants.

FINAL JUDGMENT AS TO DEFENDANTS ANTHONY CAINE,
LJM FUNDS MANAGEMENT, LTD., AND LJM PARTNERS, LTD.
The  Securities  and  Exchange  Commission  having  filed  a  Complaint  and  Defendants
Anthony  Caine  (“Caine”),  LJM  Funds  Management,  Ltd.  (“LJMFM”),  and  LJM  Partners,  Ltd.
(“LJM Partners”) (together, “Defendants”) having entered a general appearance; consented to the
Court’s jurisdiction over Defendants and the subject matter of this action; consented to entry of
this Final Judgment without admitting or denying the allegations of the Complaint (except as to
jurisdiction  and  except  as  otherwise  provided  herein  in  paragraph  XII);  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 each of the Defendants
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

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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;
(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.
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  otherwise:  (a)  Defendants’  officers,
agents, servants, employees, and attorneys; and (b) other persons in active concert or participation
with Defendants or with anyone described in (a).
II.
IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that each of the
Defendants is permanently restrained and enjoined from violating Section 17(a) of the Securities
Act of 1933 (the “Securities Act”) [15 U.S.C. § 77q(a)] in the offer or sale of any security by the
use of any means or instruments of transportation or communication in interstate commerce or by
use of the mails, directly or indirectly:
(a) to employ any device, scheme, or artifice to defraud;
(b) to obtain money or property by means of any untrue statement of a material fact or any
omission of a material fact necessary in order to make the statements made, in light of
the circumstances under which they were made, not misleading; or

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(c) to engage in any transaction, practice, or course of business which operates or would
operate as a fraud or deceit upon the purchaser.
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  otherwise:  (a)  Defendants’  officers,
agents, servants, employees, and attorneys; and (b) other persons in active concert or participation
with Defendants or with anyone described in (a).
III.
IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that each of the
Defendants is permanently restrained and enjoined from violating Sections 206(1) and 206(2) of
the  Investment  Advisers  Act  of  1940  (“Advisers  Act”)  [15  U.S.C.  §80b-6(1),  (2)],  by,  as  an
investment  adviser,  using  the  mails  or  any  means  or  instrumentality  of  interstate  commerce,
directly or indirectly:
(a) to employ any device, scheme, or artifice to defraud any client or prospective client; or
(b) to engage in any transaction, practice, or course of business which operates as a fraud
or deceit upon any client or prospection client.
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  otherwise:  (a)  Defendants’  officers,
agents, servants, employees, and attorneys; and (b) other persons in active concert or participation
with Defendants or with anyone described in (a).

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IV.
IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendants
Caine and LJMFM are permanently restrained and enjoined from violating Section 206(4) of the
Advisers  Act  [15  U.S.C.  §  80b-6(4)]  and  Rule  206(4)-8  promulgated  thereunder  [17  C.F.R.  §
275.206(4)-8] by, as an investment adviser to a pooled investment vehicle, using the mails, or any
means or instrumentality of interstate commerce, directly or indirectly:
(a) to make any untrue statement of a material fact or to omit to state a material fact
necessary  to  make  the  statements  made,  in  the  light  of  the  circumstances  under
which they were made, not misleading, to any investor or prospective investors in
the pooled investment vehicle; or
(b) otherwise  engage  in  any  act,  practice,  or  course  of  business  that  is  fraudulent,
deceptive, or manipulative with respect to any investor or prospective investor in
the pooled investment vehicle.
 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 otherwise: (a) Defendant Caine’s and
Defendant LJMFM’s officers, agents, servants, employees, and attorneys; and (b) other persons in
active  concert  or  participation  with  Defendant Caine  or  Defendant  LJMFM,  or  with  anyone
described in (a).
V.
IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant
LJMFM is permanently restrained and enjoined from violating Section 206(4) of the Advisers Act
[15  U.S.C.  §  80b-6(4)]  and  Rule  206(4)-7  thereunder  [17  C.F.R.  §  275.206(4)-7]  by  use  of  the

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mails or any means or instrumentality of interstate commerce, directly or indirectly, while acting
as an investment adviser registered or required to be registered with the Commission, to provide
investment advice to clients without adopting and implementing written policies and procedures
reasonably  designed  to  prevent  violation,  by  LJMFM  or  LJMFM’s  supervised  persons,  of  the
Advisers Act and the rules the Commission has adopted under the Advisers Act.
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  otherwise:  (a)  Defendant  LJMFM’s
officers,  agents,  servants,  employees,  and  attorneys;  and  (b)  other  persons  in  active  concert  or
participation with Defendant LJMFM or with anyone described in (a).
VI.
IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant
LJMFM  is  permanently  restrained  and  enjoined  from  violating
 Section 15(c)  of  the  Investment
Company Act of 1940 (“Investment Company Act”) [15 U.S.C. § 80a-15(c)] by failing to furnish
the  directors  of  any  registered  investment  company  such  information  as  may  be  reasonably
necessary for the directors to evaluate the terms of any contract whereby LJMFM undertakes to
serve or act as investment adviser of such company.
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  otherwise:  (a)  Defendant  LJMFM’s
officers,  agents,  servants,  employees,  and  attorneys;  and  (b)  other  persons  in  active  concert  or
participation with Defendant LJMFM or with anyone described in (a).

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VII.
IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant
LJMFM  is  permanently  restrained  and  enjoined  from  violating
 Section  34(b)  of  the  Investment
Company Act [15 U.S.C. § 80a-33(b)], directly or indirectly, by making any untrue statement of a
material fact in any registration statement, application, report, account, record, or other document
filed  or  transmitted  pursuant  to  the  Investment  Company  Act,  or  omitting  to  state  in  any  such
document any fact necessary in order to make the statements made, in light of the circumstances
under which they are made, not materially misleading.
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  otherwise:  (a)  Defendant  LJMFM’s
officers,  agents,  servants,  employees,  and  attorneys;  and  (b)  other  persons  in  active  concert  or
participation with Defendant LJMFM or with anyone described in (a).
VIII.
IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that pursuant to
Sections 21(d)(1) and 21(d)(5) of the Exchange Act [15 U.S.C. § 78u(d)(1) and (5)], Section 20(b)
of the Securities Act [15 U.S.C. § 77t(b)],  and Section 209(d) of the Advisers Act [15 U.S.C. §
80b-9(d)], Defendant Caine is enjoined, for a period of three years, from managing or advising on
securities investments for, or acting as or being associated with an investment adviser to, any third-
party, except for his wife and children.
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  otherwise:  (a)  Defendant  Caine’s

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officers,  agents,  servants,  employees,  and  attorneys;  and  (b)  other  persons  in  active  concert  or
participation with Defendant Caine or with anyone described in (a).
IX.
IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that LJMFM and Caine are
jointly  and  severally  liable  for  disgorgement  of  $1,720,317 together  with  prejudgment  interest
thereon in the amount of $699,129, for a total of $2,419,446; LJM Partners and Caine are jointly
and severally liable for disgorgement of $1,567,713 together with prejudgment interest thereon in
the amount of $637,112, for a total of $2,204,825; and Caine is further liable for a civil monetary
penalty in the amount of $500,000 pursuant to Section 21(d)(3) of the Exchange Act [15 U.S.C. §
78u(d)(3)],  Section  20(d)  of  the  Securities  Act  [15  U.S.C.  § 77t(d)],  and  Section  209(e)  of  the
Advisers  Act  [15  U.S.C.  § 80b-9(e)]. Defendants shall  satisfy  the  foregoing obligations  of
disgorgement (representing net profits gained as a result of the conduct alleged in the Complaint)
and  prejudgment  interest  by  paying  $4,624,271 to  the  Securities  and  Exchange  Commission
pursuant to the terms of the payment schedule set forth in paragraph X below.  Caine shall satisfy
the foregoing civil monetary penalty obligation by paying $500,000 to the Securities and Exchange
Commission within 30 days after entry of this Final Judgment.
Defendants 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
.  Defendants  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

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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; Caine, LJMFM, and/or LJM Partners, as a defendant in this action; and specifying that
payment is made pursuant to this Final Judgment.
Defendants  shall  simultaneously  transmit  photocopies  of  evidence  of  payment  and  case
identifying information to the Commission’s counsel in this action.  By making such payment(s),
Defendants relinquish all legal and equitable right, title, and interest in such funds and no part of
the funds shall be returned to Defendant(s).
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.  Defendants 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.  The Commission shall hold the
funds, together with any interest and income earned thereon (collectively, the “Fund”), pending
further order of the Court.
The Commission may propose a plan to distribute the Fund subject to the Court’s approval.
Such a plan may provide that the Fund shall be distributed pursuant to the Fair Fund provisions of
Section  308(a)  of  the  Sarbanes-Oxley  Act  of  2002.    The Court shall retain jurisdiction over the
administration of any distribution of the Fund and the Fund may only be disbursed pursuant to an
Order of the Court.

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Regardless of whether any such Fair Fund distribution is made, amounts ordered to be paid
as civil penalties pursuant to this Judgment shall be treated as penalties paid to the government for
all  purposes,  including  all  tax  purposes.  To  preserve  the  deterrent  effect  of  the  civil monetary
penalty,  Defendant  Caine  shall  not,  after  offset  or  reduction  of  any  award  of  compensatory
damages in any Related Investor Action based on his payment of disgorgement in this action, argue
that  he  is  entitled  to,  nor  shall  he  further  benefit  by,  offset  or  reduction  of  such  compensatory
damages award by the amount of any part of his payment of a civil monetary penalty in this action
(“Penalty Offset”).  If the court in any Related Investor Action grants such a Penalty Offset, Caine
shall,  within  30  days  after  entry  of  a  final  order  granting  the  Penalty  Offset,  notify  the
Commission’s counsel in this action and pay the amount of the Penalty Offset to the United States
Treasury or to a Fair Fund, as the Commission directs. Such a payment shall not be deemed an
additional civil penalty and shall not be deemed to change the amount of the civil penalties imposed
in  this  Judgment.    For  purposes  of  this  paragraph,  a  “Related  Investor  Action”  means  a  private
damages action brought against Defendant(s) by or on behalf of one or more investors based on
substantially the same facts as alleged in the Complaint in this action.
X.
Defendants LJMFM and Caine shall pay the total of disgorgement and prejudgment interest
due, jointly and severally, of $2,419,446 in four installments to the Commission according to the
following schedule: $250,000 within 30 days of entry of this Final Judgment; $723,148.67 within
120  days  of  entry  of  this  Final  Judgment;  $723,148.67 within  210  days  of  entry  of  this  Final
Judgment; and $723,148.66 (plus accrued post-judgment interest) within 300 days of entry of this
Final  Judgment.   Defendants  LJM  Partners and  Caine  shall  pay  the  total  of  disgorgement  and
prejudgment  interest  due,  jointly  and  severally, of $2,204,825 in four  installments  to  the

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Commission according to the following schedule: $250,000 within 30 days of entry of this Final
Judgment; $651,608.33 within 120 days of entry of this Final Judgment; $651,608.33 within 210
days of entry of this Final Judgment; and $651,608.34 (plus accrued post-judgment interest) within
300 days of entry of this Final Judgment.  Payments shall be deemed made on the date they are
received  by  the  Commission  and  shall  be  applied  first  to  post-judgment  interest,  which  accrues
pursuant  to  28  U.S.C.  §  1961  on  any  unpaid  amounts  due  after  30  days  of  the  entry  of  Final
Judgment.  Prior to making the final payments set forth herein, Defendants shall contact the staff
of the Commission for the amount due for the final payment.
If Defendants fail to make any payment by the date agreed and/or in the amount agreed
according  to  the  schedule  set  forth  above,  all  outstanding  payments  under  this  Final  Judgment,
including  post-judgment  interest,  minus  any  payments  made,  shall  become  due  and  payable
immediately  at  the  discretion  of  the  staff  of  the  Commission  without  further  application  to  the
Court.
XI.

 IT  IS  FURTHER  ORDERED,  ADJUDGED,  AND  DECREED  that  the  Consent  is
incorporated herein with the same force and effect as if fully set forth herein, and that Defendants
shall comply with all of the undertakings and agreements set forth therein.
XII.

IT
 IS FURTHER ORDERED, ADJUDGED, AND DECREED that, solely 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 Caine, and further, any debt for
disgorgement, prejudgment interest, civil monetary penalty or other amounts due by Caine under
this Final Judgment or any other judgment, order, consent order, decree or settlement agreement

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entered  in  connection  with  this  proceeding,  is  a  debt  for  the  violation  by  Caine of  the  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).
XIII.
 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that this Court shall retain
jurisdiction of this matter for the purposes of enforcing the terms of this Final Judgment.
XIV.
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:  June 30, 2025
____________________________________
KERI L. HOLLEB HOTALING
UNITED STATES MAGISTRATE JUDGE

UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 
 
  
SECURITIES AND EXCHANGE 
COMMISSION, 

 

  
Plaintiff,  

  
v. Case No. 1:21-cv-02859 

   
ANTHONY CAINE,  
ANISH PARVATANENI, 
LJM FUNDS MANAGEMENT, LTD.,  

Honorable Keri Holleb Hotaling 
 

and LJM PARTNERS, LTD., 
 

 

Defendants.  
  

  
FINAL JUDGMENT AS TO DEFENDANTS ANTHONY CAINE,  

LJM FUNDS MANAGEMENT, LTD., AND LJM PARTNERS, LTD. 

The Securities and Exchange Commission having filed a Complaint and Defendants 

Anthony Caine (“Caine”), LJM Funds Management, Ltd. (“LJMFM”), and LJM Partners, Ltd. 

(“LJM Partners”) (together, “Defendants”) having entered a general appearance; consented to the 

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

this Final Judgment without admitting or denying the allegations of the Complaint (except as to 

jurisdiction and except as otherwise provided herein in paragraph XII); 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 each of the Defendants 

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 

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2 
 

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;  

(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. 

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 otherwise: (a) Defendants’ officers, 

agents, servants, employees, and attorneys; and (b) other persons in active concert or participation 

with Defendants or with anyone described in (a). 

II. 

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that each of the 

Defendants is permanently restrained and enjoined from violating Section 17(a) of the Securities 

Act of 1933 (the “Securities Act”) [15 U.S.C. § 77q(a)] in the offer or sale of any security by the 

use of any means or instruments of transportation or communication in interstate commerce or by 

use of the mails, directly or indirectly: 

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

(b) to obtain money or property by means of any untrue statement of a material fact or any 

omission of a material fact necessary in order to make the statements made, in light of 

the circumstances under which they were made, not misleading; or  

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3 
 

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

operate as a fraud or deceit upon the purchaser. 

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 otherwise: (a) Defendants’ officers, 

agents, servants, employees, and attorneys; and (b) other persons in active concert or participation 

with Defendants or with anyone described in (a). 

III. 

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that each of the 

Defendants is permanently restrained and enjoined from violating Sections 206(1) and 206(2) of 

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

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

directly or indirectly:  

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

(b) to engage in any transaction, practice, or course of business which operates as a fraud 

or deceit upon any client or prospection client. 

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 otherwise: (a) Defendants’ officers, 

agents, servants, employees, and attorneys; and (b) other persons in active concert or participation 

with Defendants or with anyone described in (a). 

  

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4 
 

IV. 

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendants 

Caine and LJMFM are permanently restrained and enjoined from violating Section 206(4) of the 

Advisers Act [15 U.S.C. § 80b-6(4)] and Rule 206(4)-8 promulgated thereunder [17 C.F.R. § 

275.206(4)-8] by, as an investment adviser to a pooled investment vehicle, using the mails, or any 

means or instrumentality of interstate commerce, directly or indirectly: 

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

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

which they were made, not misleading, to any investor or prospective investors in 

the pooled investment vehicle; or 

(b) otherwise engage in any act, practice, or course of business that is fraudulent, 

deceptive, or manipulative with respect to any investor or prospective investor in 

the pooled investment vehicle. 

 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 otherwise: (a) Defendant Caine’s and 

Defendant LJMFM’s officers, agents, servants, employees, and attorneys; and (b) other persons in 

active concert or participation with Defendant Caine or Defendant LJMFM, or with anyone 

described in (a). 

V. 

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant 

LJMFM is permanently restrained and enjoined from violating Section 206(4) of the Advisers Act 

[15 U.S.C. § 80b-6(4)] and Rule 206(4)-7 thereunder [17 C.F.R. § 275.206(4)-7] by use of the 

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5 
 

mails or any means or instrumentality of interstate commerce, directly or indirectly, while acting 

as an investment adviser registered or required to be registered with the Commission, to provide 

investment advice to clients without adopting and implementing written policies and procedures 

reasonably designed to prevent violation, by LJMFM or LJMFM’s supervised persons, of the 

Advisers Act and the rules the Commission has adopted under the Advisers Act. 

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 otherwise: (a) Defendant LJMFM’s 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendant LJMFM or with anyone described in (a). 

VI. 

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant 

LJMFM is permanently restrained and enjoined from violating Section 15(c) of the Investment 

Company Act of 1940 (“Investment Company Act”) [15 U.S.C. § 80a-15(c)] by failing to furnish 

the directors of any registered investment company such information as may be reasonably 

necessary for the directors to evaluate the terms of any contract whereby LJMFM undertakes to 

serve or act as investment adviser of such company. 

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 otherwise: (a) Defendant LJMFM’s 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendant LJMFM or with anyone described in (a). 

  

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6 
 

VII. 

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant 

LJMFM is permanently restrained and enjoined from violating Section 34(b) of the Investment 

Company Act [15 U.S.C. § 80a-33(b)], directly or indirectly, by making any untrue statement of a 

material fact in any registration statement, application, report, account, record, or other document 

filed or transmitted pursuant to the Investment Company Act, or omitting to state in any such 

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

under which they are made, not materially misleading. 

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 otherwise: (a) Defendant LJMFM’s 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendant LJMFM or with anyone described in (a). 

VIII. 

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that pursuant to 

Sections 21(d)(1) and 21(d)(5) of the Exchange Act [15 U.S.C. § 78u(d)(1) and (5)], Section 20(b) 

of the Securities Act [15 U.S.C. § 77t(b)], and Section 209(d) of the Advisers Act [15 U.S.C. § 

80b-9(d)], Defendant Caine is enjoined, for a period of three years, from managing or advising on 

securities investments for, or acting as or being associated with an investment adviser to, any third-

party, except for his wife and children. 

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 otherwise: (a) Defendant Caine’s 

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7 
 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendant Caine or with anyone described in (a). 

IX. 

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that LJMFM and Caine are 

jointly and severally liable for disgorgement of $1,720,317 together with prejudgment interest 

thereon in the amount of $699,129, for a total of $2,419,446; LJM Partners and Caine are jointly 

and severally liable for disgorgement of $1,567,713 together with prejudgment interest thereon in 

the amount of $637,112, for a total of $2,204,825; and Caine is further liable for a civil monetary 

penalty in the amount of $500,000 pursuant to Section 21(d)(3) of the Exchange Act [15 U.S.C. § 

78u(d)(3)], Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)], and Section 209(e) of the 

Advisers Act [15 U.S.C. § 80b-9(e)]. Defendants shall satisfy the foregoing obligations of 

disgorgement (representing net profits gained as a result of the conduct alleged in the Complaint) 

and prejudgment interest by paying $4,624,271 to the Securities and Exchange Commission 

pursuant to the terms of the payment schedule set forth in paragraph X below.  Caine shall satisfy 

the foregoing civil monetary penalty obligation by paying $500,000 to the Securities and Exchange 

Commission within 30 days after entry of this Final Judgment. 

Defendants 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. Defendants 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 

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http://www.sec.gov/about/offices/ofm.htm


8 
 

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; Caine, LJMFM, and/or LJM Partners, as a defendant in this action; and specifying that 

payment is made pursuant to this Final Judgment.   

Defendants shall simultaneously transmit photocopies of evidence of payment and case 

identifying information to the Commission’s counsel in this action.  By making such payment(s), 

Defendants relinquish all legal and equitable right, title, and interest in such funds and no part of 

the funds shall be returned to Defendant(s).   

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.  Defendants 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.  The Commission shall hold the 

funds, together with any interest and income earned thereon (collectively, the “Fund”), pending 

further order of the Court. 

The Commission may propose a plan to distribute the Fund subject to the Court’s approval.  

Such a plan may provide that the Fund shall be distributed pursuant to the Fair Fund provisions of 

Section 308(a) of the Sarbanes-Oxley Act of 2002.  The Court shall retain jurisdiction over the 

administration of any distribution of the Fund and the Fund may only be disbursed pursuant to an 

Order of the Court. 

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Regardless of whether any such Fair Fund distribution is made, amounts ordered to be paid 

as civil penalties pursuant to this Judgment shall be treated as penalties paid to the government for 

all purposes, including all tax purposes. To preserve the deterrent effect of the civil monetary 

penalty, Defendant Caine shall not, after offset or reduction of any award of compensatory 

damages in any Related Investor Action based on his payment of disgorgement in this action, argue 

that he is entitled to, nor shall he further benefit by, offset or reduction of such compensatory 

damages award by the amount of any part of his payment of a civil monetary penalty in this action 

(“Penalty Offset”).  If the court in any Related Investor Action grants such a Penalty Offset, Caine 

shall, within 30 days after entry of a final order granting the Penalty Offset, notify the 

Commission’s counsel in this action and pay the amount of the Penalty Offset to the United States 

Treasury or to a Fair Fund, as the Commission directs. Such a payment shall not be deemed an 

additional civil penalty and shall not be deemed to change the amount of the civil penalties imposed 

in this Judgment.  For purposes of this paragraph, a “Related Investor Action” means a private 

damages action brought against Defendant(s) by or on behalf of one or more investors based on 

substantially the same facts as alleged in the Complaint in this action. 

X. 

Defendants LJMFM and Caine shall pay the total of disgorgement and prejudgment interest 

due, jointly and severally, of $2,419,446 in four installments to the Commission according to the 

following schedule: $250,000 within 30 days of entry of this Final Judgment; $723,148.67 within 

120 days of entry of this Final Judgment; $723,148.67 within 210 days of entry of this Final 

Judgment; and $723,148.66 (plus accrued post-judgment interest) within 300 days of entry of this 

Final Judgment.  Defendants LJM Partners and Caine shall pay the total of disgorgement and 

prejudgment interest due, jointly and severally, of $2,204,825 in four installments to the 

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10 
 

Commission according to the following schedule: $250,000 within 30 days of entry of this Final 

Judgment; $651,608.33 within 120 days of entry of this Final Judgment; $651,608.33 within 210 

days of entry of this Final Judgment; and $651,608.34 (plus accrued post-judgment interest) within 

300 days of entry of this Final Judgment.  Payments shall be deemed made on the date they are 

received by the Commission and shall be applied first to post-judgment interest, which accrues 

pursuant to 28 U.S.C. § 1961 on any unpaid amounts due after 30 days of the entry of Final 

Judgment.  Prior to making the final payments set forth herein, Defendants shall contact the staff 

of the Commission for the amount due for the final payment. 

If Defendants fail to make any payment by the date agreed and/or in the amount agreed 

according to the schedule set forth above, all outstanding payments under this Final Judgment, 

including post-judgment interest, minus any payments made, shall become due and payable 

immediately at the discretion of the staff of the Commission without further application to the 

Court. 

XI.  
 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Consent is 

incorporated herein with the same force and effect as if fully set forth herein, and that Defendants 

shall comply with all of the undertakings and agreements set forth therein. 

XII.  
 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, solely 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 Caine, and further, any debt for 

disgorgement, prejudgment interest, civil monetary penalty or other amounts due by Caine under 

this Final Judgment or any other judgment, order, consent order, decree or settlement agreement 

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entered in connection with this proceeding, is a debt for the violation by Caine of the 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). 

XIII. 

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

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

XIV. 

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:  June 30, 2025 

____________________________________ 
KERI L. HOLLEB HOTALING 
UNITED STATES MAGISTRATE JUDGE 

 

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