SEC v. CHRISTOPHER SLAGA a/k/a KEITH RENKO, No. 8:23-cv-01425, Central District of California (Feb. 20, 2025) — Judgment
raw: SEC v. CHRISTOPHER SLAGA a/k/a
SEC v. CHRISTOPHER SLAGA a/k/a, No. 8:23-cv-01425 (Feb. 20, 2025)
Christopher Slaga, also known as Keith Renko, entered a consent judgment with the SEC to resolve allegations of securities fraud and unregistered offerings.
Christopher Slaga was ordered to pay a total of $5,880,363.95, comprising $2,808,934.32 in disgorgement, $262,495.31 in prejudgment interest, and a $2,808,934.32 civil penalty. The judgment addresses violations of the Securities Exchange Act of 1934 and the Securities Act of 1933. Slaga is permanently enjoined from future fraudulent schemes and the unregistered sale of securities.
The Securities and Exchange Commission obtained a consent judgment against Christopher Slaga, also known as Keith Renko, in the U.S. District Court for the Central District of California. The SEC's action involved allegations of fraud and violations of the Securities Exchange Act and Securities Act, specifically regarding fraudulent schemes and unregistered securities offerings. To resolve the charges, Slaga was ordered to pay $5,880,363.95, which includes $2,808,934.32 in disgorgement, $262,495.31 in prejudgment interest, and a $2,808,934.32 civil penalty. The judgment permanently restrains Slaga from employing any device or scheme to defraud or making untrue statements of material fact in connection with securities. Additionally, he is enjoined from the unregistered sale of securities and prohibited from serving as an officer or director of any reporting issuer. Slaga consented to the court's jurisdiction and waived his right to appeal the judgment.
Extracted insights
- $5.88M $5,880,363 $1M–$10M
- $2.81M $2,808,934 $1M–$10M
- $262K $262,495 $100K–$1M
- person christopher slaga
- agency Securities and Exchange Commission
- Securities And Exchange Commission filed a Complaint
- Christopher Slaga entered a General Appearance
- Christopher Slaga consented to the Court’s jurisdiction over Defendant
- Christopher Slaga consented to entry of this Judgment
- Christopher Slaga waived findings of fact and conclusions of law
- Christopher Slaga waived any right to appeal from this Judgment
- Christopher Slaga is restrained from violating Section 10(b) of the Securities Exchange Act of 1934
- Christopher Slaga is enjoined from employing any device, scheme, or artifice to defraud
- Christopher Slaga is restrained from making any untrue statement of a material fact or omitting a material fact
- Christopher Slaga is enjoined from engaging in any act, practice, or course of business that operates as a fraud or deceit
- Christopher Slaga is restrained from violating Section 17(a) of the Securities Act of 1933
- Christopher Slaga is enjoined from employing any device, scheme, or artifice to defraud under Section 17(a)
- Christopher Slaga is enjoined from obtaining money or property by any untrue statement of a material fact
- Christopher Slaga is restrained from engaging in any transaction, practice, or course of business that operates as a fraud or deceit upon the purchaser
- Defendant’s Officers are bound by the judgment
- Defendant’s Agents are bound by the judgment
1 2 3 4 5 6 7 8 9 1 0 11 1 2 1 3 14 1 5 1 6 17 1 8 1 9 2 0 21 2 2 2 3 24 2 5 2 6 2 7 2 8 UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA SECURITIES AND EXCHANGE COMMISSION, Plaintiff, v. CHRISTOPHER SLAGA a/k/a KEITH RENKO, Q4 CAPITAL GROUP, LLC, J4 CAPITAL ADVISORS LLC, and HAYDEN GREENE, Defendants. Case No. 8:23-cv-01425-JWH-DFMx JUDGMENT AS TO DEFENDANT CHRISTOPHER SLAGA A/K/A KEITH RENKO #:141 1 2 3 4 5 6 7 8 9 1 0 11 1 2 1 3 1 4 1 5 1 6 1 7 1 8 1 9 2 0 21 2 2 2 3 2 4 2 5 2 6 2 7 2 8 The Securities and Exchange Commission (the “Commission”) having filed a Complaint and Defendant Christopher Slaga a/k/a Keith Renko (“Slaga” or “Defendant”) having entered a general appearance; consented to the Court’s jurisdiction over Defendant and subject matter jurisdiction; consented to entry of this Judgment; waived findings of fact and conclusions of law; and waived any right to appeal from this Judgment: It is hereby ORDERED, ADJUDGED, and DECREED as follows: 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; 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. 2. As provided in Rule 65(d)(2) of the Federal Rules of Civil Procedure, the foregoing Paragraph also binds the following who receive actual notice of this 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 Paragraph 2(a). #:142 1 2 3 4 5 6 7 8 9 1 0 11 1 2 1 3 1 4 1 5 1 6 1 7 1 8 1 9 2 0 21 2 2 2 3 2 4 2 5 2 6 2 7 2 8 3. Defendant 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 c. to engage in any transaction, practice, or course of business which operates or would operate as a fraud or deceit upon the purchaser. 4. As provided in Rule 65(d)(2) of the Federal Rules of Civil Procedure, the foregoing Paragraph also binds the following who receive actual notice of this 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 Paragraph 4(a). 5. Defendant is permanently RESTRAINED and ENJOINED from violating Sections 5(a) and (c) of the Securities Act [15 U.S.C. §§ 77e(a), (c)] by, directly or indirectly, in the absence of any applicable exemption: a. Unless a registration statement is in effect as to a security, making use of any means or instruments of transportation or communication in interstate commerce or of the mails to sell such security through the use or medium of any prospectus or otherwise; b. Unless a registration statement is in effect as to a security, carrying or causing to be carried through the mails or in interstate #:143 1 2 3 4 5 6 7 8 9 1 0 11 1 2 1 3 1 4 1 5 1 6 1 7 1 8 1 9 2 0 21 2 2 2 3 2 4 2 5 2 6 2 7 2 8 commerce, by any means or instruments of transportation, any such security for the purpose of sale or for delivery after sale; or c. Making use of any means or instruments of transportation or communication in interstate commerce or of the mails to offer to sell or offer to buy through the use or medium of any prospectus or otherwise any security, unless a registration statement has been filed with the Commission as to such security, or while the registration statement is the subject of a refusal order or stop order or (prior to the effective date of the registration statement) any public proceeding or examination under Section 8 of the Securities Act [15 U.S.C. § 77h]. 6. As provided in Rule 65(d)(2) of the Federal Rules of Civil Procedure, the foregoing Paragraph also binds the following who receive actual notice of this 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 Paragraph 6(a). 7. Pursuant to Sections 21(d)(1) and 21(d)(5) of the Exchange Act [15 U.S.C. §§ 78u(d)(1) and 78u(d)(5)] and Section 20(b) of the Securities Act [15 U.S.C. § 77t(b)], Defendant is permanently RESTRAINED and ENJOINED from directly or indirectly, including, but not limited to, through any entity owned or controlled by him, participating in the issuance, purchase, offer, or sale of any security; provided, however, that such injunction shall not prevent him from purchasing or selling securities for his own personal account. 8. As provided in Rule 65(d)(2) of the Federal Rules of Civil Procedure, the foregoing Paragraph also binds the following who receive actual notice of this Judgment by personal service or otherwise: #:144 1 2 3 4 5 6 7 8 9 1 0 11 1 2 1 3 1 4 1 5 1 6 1 7 1 8 1 9 2 0 21 2 2 2 3 2 4 2 5 2 6 2 7 2 8 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 Paragraph 8(a). 9. Pursuant to Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)] and Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)], 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 that is required to file reports pursuant to Section 15(d) of the Exchange Act [15 U.S.C. § 78o(d)]. 10. Defendant is liable for disgorgement of $2,808,934.32, jointly and severally with Defendants Q4 Capital Group LLC and J4 Capital Advisors LLC, representing net profits gained as a result of the conduct alleged in the Complaint, together with prejudgment interest thereon in the amount of $262,495.31, and a civil penalty in the amount of $2,808,934.32 pursuant to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d) of the Exchange Act [15 U.S.C. § 78u(d)]. Defendant shall satisfy this obligation by paying $5,880,363.95 to the Securities and Exchange Commission within 30 days after entry of this Judgment. 11. 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: #:145 1 2 3 4 5 6 7 8 9 1 0 11 1 2 1 3 1 4 1 5 1 6 1 7 1 8 1 9 2 0 21 2 2 2 3 2 4 2 5 2 6 2 7 2 8 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; Christopher Slaga as a defendant in this action; and specifying that payment is made pursuant to this Judgment. 12. Defendant shall simultaneously transmit photocopies of evidence of payment and case identifying information to the Commission’s counsel in this action. By making this 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. 13. 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 Judgment. 14. 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 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. 15. 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 #:146 1 2 3 4 5 6 7 8 9 1 0 11 1 2 1 3 1 4 1 5 1 6 1 7 1 8 1 9 2 0 21 2 2 2 3 2 4 2 5 2 6 2 7 2 8 administration of any distribution of the Fund and the Fund may only be disbursed pursuant to an Order of the Court. 16. 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 penalty, Defendant shall not, after offset or reduction of any award of compensatory damages in any Related Investor Action based on Defendant’s 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 Defendant’s payment of a civil penalty in this action (“Penalty Offset”). If the court in any Related Investor Action grants such a Penalty Offset, Defendant 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 penalty imposed in this Judgment. For purposes of this Paragraph, a “Related Investor Action” means a private damages action brought against Defendant by or on behalf of one or more investors based on substantially the same facts as alleged in the Complaint in this action. 17. 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. 18. 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 #:147 #:148
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA SECURITIES AND EXCHANGE COMMISSION, Plaintiff, v. CHRISTOPHER SLAGA a/k/a KEITH RENKO, Q4 CAPITAL GROUP, LLC, J4 CAPITAL ADVISORS LLC, and HAYDEN GREENE, Defendants. Case No. 8:23-cv-01425-JWH-DFMx JUDGMENT AS TO DEFENDANT CHRISTOPHER SLAGA A/K/A KEITH RENKO Case 8:23-cv-01425-JWH-DFM Document 35 Filed 12/23/24 Page 1 of 8 Page ID #:141 -2- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 The Securities and Exchange Commission (the “Commission”) having filed a Complaint and Defendant Christopher Slaga a/k/a Keith Renko (“Slaga” or “Defendant”) having entered a general appearance; consented to the Court’s jurisdiction over Defendant and subject matter jurisdiction; consented to entry of this Judgment; waived findings of fact and conclusions of law; and waived any right to appeal from this Judgment: It is hereby ORDERED, ADJUDGED, and DECREED as follows: 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; 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. 2. As provided in Rule 65(d)(2) of the Federal Rules of Civil Procedure, the foregoing Paragraph also binds the following who receive actual notice of this 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 Paragraph 2(a). Case 8:23-cv-01425-JWH-DFM Document 35 Filed 12/23/24 Page 2 of 8 Page ID #:142 -3- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3. Defendant 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 c. to engage in any transaction, practice, or course of business which operates or would operate as a fraud or deceit upon the purchaser. 4. As provided in Rule 65(d)(2) of the Federal Rules of Civil Procedure, the foregoing Paragraph also binds the following who receive actual notice of this 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 Paragraph 4(a). 5. Defendant is permanently RESTRAINED and ENJOINED from violating Sections 5(a) and (c) of the Securities Act [15 U.S.C. §§ 77e(a), (c)] by, directly or indirectly, in the absence of any applicable exemption: a. Unless a registration statement is in effect as to a security, making use of any means or instruments of transportation or communication in interstate commerce or of the mails to sell such security through the use or medium of any prospectus or otherwise; b. Unless a registration statement is in effect as to a security, carrying or causing to be carried through the mails or in interstate Case 8:23-cv-01425-JWH-DFM Document 35 Filed 12/23/24 Page 3 of 8 Page ID #:143 -4- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 commerce, by any means or instruments of transportation, any such security for the purpose of sale or for delivery after sale; or c. Making use of any means or instruments of transportation or communication in interstate commerce or of the mails to offer to sell or offer to buy through the use or medium of any prospectus or otherwise any security, unless a registration statement has been filed with the Commission as to such security, or while the registration statement is the subject of a refusal order or stop order or (prior to the effective date of the registration statement) any public proceeding or examination under Section 8 of the Securities Act [15 U.S.C. § 77h]. 6. As provided in Rule 65(d)(2) of the Federal Rules of Civil Procedure, the foregoing Paragraph also binds the following who receive actual notice of this 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 Paragraph 6(a). 7. Pursuant to Sections 21(d)(1) and 21(d)(5) of the Exchange Act [15 U.S.C. §§ 78u(d)(1) and 78u(d)(5)] and Section 20(b) of the Securities Act [15 U.S.C. § 77t(b)], Defendant is permanently RESTRAINED and ENJOINED from directly or indirectly, including, but not limited to, through any entity owned or controlled by him, participating in the issuance, purchase, offer, or sale of any security; provided, however, that such injunction shall not prevent him from purchasing or selling securities for his own personal account. 8. As provided in Rule 65(d)(2) of the Federal Rules of Civil Procedure, the foregoing Paragraph also binds the following who receive actual notice of this Judgment by personal service or otherwise: Case 8:23-cv-01425-JWH-DFM Document 35 Filed 12/23/24 Page 4 of 8 Page ID #:144 -5- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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 Paragraph 8(a). 9. Pursuant to Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)] and Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)], 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 that is required to file reports pursuant to Section 15(d) of the Exchange Act [15 U.S.C. § 78o(d)]. 10. Defendant is liable for disgorgement of $2,808,934.32, jointly and severally with Defendants Q4 Capital Group LLC and J4 Capital Advisors LLC, representing net profits gained as a result of the conduct alleged in the Complaint, together with prejudgment interest thereon in the amount of $262,495.31, and a civil penalty in the amount of $2,808,934.32 pursuant to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d) of the Exchange Act [15 U.S.C. § 78u(d)]. Defendant shall satisfy this obligation by paying $5,880,363.95 to the Securities and Exchange Commission within 30 days after entry of this Judgment. 11. 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: Case 8:23-cv-01425-JWH-DFM Document 35 Filed 12/23/24 Page 5 of 8 Page ID #:145 -6- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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; Christopher Slaga as a defendant in this action; and specifying that payment is made pursuant to this Judgment. 12. Defendant shall simultaneously transmit photocopies of evidence of payment and case identifying information to the Commission’s counsel in this action. By making this 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. 13. 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 Judgment. 14. 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 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. 15. 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 Case 8:23-cv-01425-JWH-DFM Document 35 Filed 12/23/24 Page 6 of 8 Page ID #:146 -7- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 administration of any distribution of the Fund and the Fund may only be disbursed pursuant to an Order of the Court. 16. 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 penalty, Defendant shall not, after offset or reduction of any award of compensatory damages in any Related Investor Action based on Defendant’s 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 Defendant’s payment of a civil penalty in this action (“Penalty Offset”). If the court in any Related Investor Action grants such a Penalty Offset, Defendant 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 penalty imposed in this Judgment. For purposes of this Paragraph, a “Related Investor Action” means a private damages action brought against Defendant by or on behalf of one or more investors based on substantially the same facts as alleged in the Complaint in this action. 17. 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. 18. 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 Case 8:23-cv-01425-JWH-DFM Document 35 Filed 12/23/24 Page 7 of 8 Page ID #:147 Case 8:23-cv-01425-JWH-DFM Document 35 Filed 12/23/24 Page 8 of 8 Page ID #:148