SEC v. Alfred V. Tobia, Jr.; and Elizabeth Lee, No. 1:25-cv-00280, Southern District of New York (Jan. 13, 2025) — Complaint

ANTONIA M. APPS
REGIONAL DIRECTOR
Tejal D. Shah
George N. Stepaniuk
Oren Gleich
Mariel Bronen
Kiran Patel
Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
New York Regional Office
100 Pearl Street
Suite 20-100
New York, NY 10004-2616
212-336-0190 (Gleich)
[email protected]

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

SECURITIES AND EXCHANGE
COMMISSION,

                                             Plaintiff,

                        -against-

ALFRED V. TOBIA, JR. and ELIZABETH
LEE,

                                             Defendants.

COMPLAINT

25 Civ. 280

JURY TRIAL DEMANDED

Plaintiff Securities and Exchange Commission (“Commission”), for its Complaint against
Defendants Alfred V. Tobia, Jr. (“Tobia”) and Elizabeth Lee (“Lee”) (collectively, “Defendants”),
alleges as follows:
SUMMARY
1. This case concerns insider trading violations by Tobia and his wife’s sister Lee.
From June 2021 through August 2021 (the “Relevant Period”), Tobia, in his role as an insider of
two publicly traded companies, obtained material nonpublic information about potential corporate
transactions involving three other publicly traded companies.  With that information, Tobia tipped

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Lee, who then purchased shares of these three companies in her brokerage account and in an
account held by her elderly parents (Tobia’s parents-in-law).  Tobia and Lee’s insider trading scheme
yielded more than $400,000 in unlawful profits.
2. During the Relevant Period, Tobia was the President and Chief Investment Officer
of Company A, a publicly traded company, and also sat on its Board of Directors and that of
Company B, also a publicly traded company.  Lee is, and was at the time, a self-employed jewelry
maker.
3. On June 24, 2021, Tobia had a phone call in his capacity as a Director of Company B
with a director (“Director A”) of PFSWeb, Inc. (“PFSWeb”), another publicly traded company.
During a confidential discussion about a potential transaction between Company B and PFSWeb
relating to one of PFSWeb’s two business units, Tobia learned from Director A that PFSWeb was in
the process of completing a sale of its other business unit, known as LiveArea.
4. Less than an hour after getting off the phone with Director A, Tobia called Lee.
Fourteen minutes later, Lee started buying shares of PFSWeb in her elderly parents’ account.  Two
minutes later, Lee started buying PFSWeb shares in her own account.  In all, Lee purchased over
60,000 shares of PFSWeb in both accounts at a total cost of over $455,000 between Thursday, June
24, and Friday, July 2, 2021.
5. On the morning of the next trading day, Tuesday, July 6, 2021, PFSWeb publicly
announced its sale of LiveArea.  The price of PFSWeb stock increased by approximately 43% that
day.  Approximately 90 minutes after the announcement, Lee sold all the PFSWeb shares in her
account and her parents’ account for a total of over $621,000 and reaped a total profit of
over $165,000.
6. By mid-July 2021, Company A had engaged in confidential negotiations with
Sequans Communications S.A. (“Sequans”), another publicly traded company, about its potential

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acquisition by Company A.  As President and Chief Investment Officer of Company A, Tobia
played a significant role in Company A’s efforts to acquire Sequans.
7. On the morning of July 27, 2021, three weeks after Lee completed her PFSWeb
trades, Tobia called Lee.  About seven minutes after the call ended, Lee began purchasing shares of
Sequans in her parents’ account.  Lee then made several more purchases of Sequans in her own
account that morning.  In total that morning, Lee purchased 80,000 shares of Sequans in both
accounts at a total cost of approximately $400,000.
8. Company A and Sequans did not end up reaching an agreement for Company A to
acquire Sequans, and there was no public announcement about their discussions.  As a result, Lee
did not profit from her shares of Sequans based on the material nonpublic information Tobia had
given her.
9. In August 2021, Tobia was involved in discussions at Company A about its making
an offer to acquire Spok Holdings Inc. (“Spok”), yet another publicly traded company.  On August
11, 2021, Tobia received a draft letter from Company A to Spok’s Board of Directors proposing the
acquisition.
10. The next morning, on August 12, 2021, Tobia called Lee.  A few minutes after their
call ended, Lee began buying Spok shares, first in her parents’ account and then in her own account.
Between August 12 and August 16, 2021, Lee purchased 25,000 shares of Spok in her own account
for over $187,000 and over 102,000 shares in her parents’ account for over $765,000, roughly half
the total value of her parents’ account at the time.
11. On August 30, 2021, Company A issued a press release and publicly disclosed that
Company A had acquired 6.5% of Spok’s outstanding shares and that Company A proposed to
acquire the rest of the outstanding shares of Spok’s common stock.  Spok’s stock price increased by
approximately 26% on the news.

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12. Lee sold all the Spok shares in her account on August 31, 2021, and all the Spok
shares in her parents’ account on September 1, 2021, and reaped a total profit of over $262,000.
13. Lee’s unlawful profits from trading on the tips she received from Tobia about
PFSWeb and Spok totaled approximately $428,595—$302,628 in her parents’ account and $125,967
in her own account.
VIOLATIONS
14. By virtue of the foregoing conduct and as alleged further herein, Tobia and Lee
violated Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. § 78j(b)]
and Rule 10b-5 [17 C.F.R. § 240.10b-5] thereunder.
NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT
15. The Commission brings this action pursuant to the authority conferred upon it by
Exchange Act Sections 21(d) and 21A [15 U.S.C. §§ 78u(d) and 78u-1].
16. The Commission seeks a final judgment: (a) permanently enjoining Defendants from
violating the federal securities laws and rules this Complaint alleges they have violated; (b) ordering
Defendants to pay civil money penalties pursuant to Exchange Act Section 21A [15 U.S.C. § 78u-1];
(c) prohibiting Tobia from serving as an officer or director of any company that has a class of
securities registered under Exchange Act Section 12 [15 U.S.C. § 78l] or that is required to file
reports under Exchange Act Section 15(d) [15 U.S.C. § 78o(d)], pursuant to Exchange Act Section
21(d)(2) [15 U.S.C. § 78u(d)(2)]; and (d) ordering any other and further relief the Court may deem
just and proper.
JURISDICTION AND VENUE
17. This Court has jurisdiction over this action pursuant to Exchange Act Section 27 [15
U.S.C. § 78aa].
18. Defendants, directly and indirectly, have made use of the means or instrumentalities

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of interstate commerce or of the mails, or of the facilities of a national securities exchange, in
connection with the transactions, acts, practices, and courses of business alleged herein.
19. Venue lies in this District under Exchange Act Section 27 [15 U.S.C. § 78aa].
Defendants transacted business in the Southern District of  New York, and certain of  the acts,
practices, transactions, and courses of  business alleged in this Complaint occurred within this
District.  For example, Tobia worked out of Company A’s offices in New York, New York, where
Tobia obtained the relevant material nonpublic information about at least Spok and Sequans.
DEFENDANTS
20. Tobia, age 60, resides (and did reside during the Relevant Period) in New York,
New York and is married to Lee’s sister.  He was the President and Chief Investment Officer of
Company A from September 2019 to September 2021, and a member of Company A’s Board of
Directors from May 2018 to September 2021.  Tobia also served on the Board of Company B from
July 2017 to September 2021.  Before joining Company A, Tobia was a partner with a Commission-
registered investment adviser (“Investment Adviser A”), a firm that he co-founded.  Tobia left his
position at Investment Adviser A upon joining Company A in 2019, but he kept an ownership stake
and remained a passive member of the firm.  Before forming Investment Adviser A in 2000, Tobia
worked at several registered broker-dealer firms and held Series 7, 63, and 24 licenses.
21. Lee, age 57, resides in Dumont, New Jersey and is Tobia’s sister-in-law.  She has
been self-employed as a jewelry maker since 2020.  Prior to starting her jewelry business, Lee worked
in fashion design for various brands from 2000 through 2020, including at a publicly traded
company.
RELEVANT ENTITIES
22.  Company A is a Delaware corporation headquartered in New York, New York.
Company A describes itself as a “value-oriented acquirer of businesses across public and private

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markets.”  Company A’s common stock is registered with the Commission pursuant to Section
12(b) of the Exchange Act and trades on the NASDAQ.
23. Company B is a Delaware corporation headquartered in Chelmsford,
Massachusetts.  Company B describes itself as a “customer and brand experience company operating
in six service categories - data, marketing, sales, customer care, fulfillment and logistics.”  Company
B’s common stock is registered with the Commission pursuant to Section 12(b) of the Exchange Act
and trades on the NASDAQ exchange.
24. PFSWeb is a Delaware corporation headquartered in Irving, Texas.  During the
Relevant Period, PFSWeb had two primary business units: LiveArea, which provided e-commerce
web services, and another called PFS, which provided logistics and order fulfillment services.
Before being acquired by GXO Logistics, Inc. in October 2023, PFSWeb’s common stock was
registered with the Commission pursuant to Section 12(b) of the Exchange Act and traded on the
NASDAQ under the ticker symbol PFSW.
25. Sequans is incorporated in France and headquartered in Colombes, France.
Sequans designs, develops, and supplies semiconductor chips for use in internet connected devices.
Sequans’ American Depositary Shares are registered with the Commission pursuant to Section 12(b)
of the Exchange Act and trade on the New York Stock Exchange under the ticker symbol SQNS.
26. Spok is a Delaware corporation headquartered in Alexandria, Virginia.  Spok
provides communication services used by hospitals and health systems.  Spok’s common stock is
registered with the Commission pursuant to Section 12(b) of the Exchange Act and trades on the
NASDAQ under the ticker symbol SPOK.

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FACTS
I. BACKGROUND
A. Tobia And Lee’s Relationship
27. Tobia and his wife have been married for over thirty years.
28. Tobia and Lee, his wife’s sister, have known each other for over thirty years and
have a close family relationship.
29. Over the years, Tobia and his wife have provided financial and other support to Lee,
a third sister, and Lee’s elderly parents, who are 88 and 84 years old respectively.
30. Since approximately 2013, Lee’s primary means of support has been the income
from the stocks she owns and the proceeds of stock sales.
31. Most of Lee’s stock investments have been based on recommendations or other
information she obtained from Tobia, including, as alleged in Section II below, material nonpublic
information concerning PFSWeb, Sequans and Spok.
32. During the Relevant Period, Lee knew that Tobia was a high-ranking officer and
director at Company A and a director at Company B, and she knew that both were public
companies.
33. During the Relevant Period, Lee also understood that Tobia’s educational
background was in finance, that he had worked at a number of firms in the securities industry, that
his work involved analyzing companies and stocks, and that he had cofounded an investment firm.
B. Tobia’s Duties of Confidentiality
34. As an officer and director of Company A, Tobia owed a fiduciary duty to Company
A, which included a duty to maintain the confidentiality of material nonpublic information that he
obtained through his employment at Company A.
35. In addition, Company A’s insider trading policy and Tobia’s employment agreement

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with Company A contained prohibitions on disclosure of confidential information.
36. The prohibition on disclosing material nonpublic information under Company A’s
insider trading policy encompassed disclosures to “any outside person (including family
members . . .).”  The policy also set forth examples of information that is generally considered
material, including “news of a pending or proposed joint venture, merger, acquisition, tender offer,
divestiture, recapitalization, strategic alliance, licensing arrangement or purchase or sales of
substantial assets.”
37. Tobia’s employment agreement with Company A similarly provided that Tobia
agreed not to “reveal, disclose or make known any Confidential Information” including “acquisition
plans” and other “strategies.”
38. Tobia reviewed and signed the Company A insider trading policy and employment
agreement and was aware of the prohibitions they contained.
39. Company A’s policies were consistent with Tobia’s independent understanding of
prohibitions on disclosing material nonpublic information based on his work experience over several
years in roles that involved being entrusted with such information.
40. As a director of Company B, Tobia also owed a fiduciary duty to Company B.
41. In at least one instance in his role as a director of Company B, as alleged below,
Tobia also owed a duty of confidentiality to PFSWeb with respect to material nonpublic information
that Tobia obtained from PFSWeb’s Director A.
II. LEE’S UNLAWFUL TRADING BASED ON TOBIA’S TIPS
 A. PFSWeb
42. In June 2021, Tobia, in his capacity as a director of Company B, contacted
PFSWeb’s Director A through an introduction by a mutual friend.
43. Both PFSWeb and Company B had operations in the logistics and order

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fulfillment industry.
44. Tobia told Director A that he wanted to discuss a potential transaction between
PFSWeb and Company B.
45. Tobia and Director A spoke for over an hour on June 24, 2021, starting at 10:00 a.m.
46. Director A spoke to Tobia in Director A’s capacity as a PFSWeb board member
speaking to the director of another company interested in exploring a possible transaction between
their respective companies.
47. At the time of his call with Tobia, Director A knew that PFSWeb was in the process
of consummating, and was planning to soon announce, the sale of its LiveArea business unit to a
company called Merkle.
48. At the time of his call with Tobia, Director A also knew that, once the sale of the
LiveArea business unit was complete, PFSWeb intended to pursue a process to find a potential
buyer for PFS, PFSWeb’s remaining logistics and order fulfillment business unit.
49. During their call, Director A and Tobia agreed to have PFSWeb and Company B
sign a written nondisclosure agreement in connection with discussions between the two companies
about a potential transaction.
50. During their call, Director A told Tobia that PFSWeb’s advisors would be sending
him the written nondisclosure agreement.
51. Director A understood and expected that the nonpublic information about PFSWeb
and Company B discussed on his call with Tobia was to remain confidential pending execution of
the written nondisclosure agreement.
52. Director A also understood that Tobia shared the same understanding and
expectation regarding the confidentiality of their conversation.
53. Tobia owed a duty of trust and confidence to PFSWeb with respect to the nonpublic

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information that Director A disclosed to Tobia on their June 24, 2021 call.
54. With that understanding, on their June 24 call, Director A conveyed to Tobia
information from which Tobia learned that (i) PFSWeb’s LiveArea business unit would soon be
sold; (ii) PFSWeb would soon be announcing the sale of Live Area; and (iii) PFSWeb and Company
B could then resume discussions about a potential transaction involving PFSWeb’s remaining
business unit, PFS.
55. At 11:43 a.m. on June 24, 2021, less than an hour after concluding his call with
Director A, Tobia called Lee.
56. Less than fifteen minutes after her call with Tobia ended, at 11:57 a.m. the same day,
Lee began buying PFSWeb stock in her parents’ brokerage account.
57. Two minutes later, at 11:59 a.m. that day, Lee started buying PFSWeb stock in her
own account.
58. Lee continued to buy PFSWeb stock in both her and her parents’ accounts over the
next several days.
59. In almost every instance, a call with Tobia preceded her PFSWeb stock purchases,
often by just minutes before she placed a trade.
60. For example, (i) on June 28, 2021, Lee received a call from Tobia at 1:44 p.m. that
lasted almost four minutes, and she then purchased additional shares of PFSWeb in her parents’
account, at 1:50 p.m. and 1:54 p.m., and purchased additional PFSWeb shares in her own account at
2:51 p.m.; (ii) on July 1, 2021, Tobia called Lee at 9:03 a.m. and 9:28 a.m., and Lee bought more
PFSWeb shares in her account at 10:28 a.m.; and (iii) on July 1, 2021, at 12:27 p.m., Tobia called Lee
again, and she bought more PFSWeb shares in her parents’ account at 12:28 p.m. and in her own
account at 12:51 p.m.
61. In total, Lee purchased over 60,000 shares of PFSWeb in both accounts between

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Thursday, June 24, and Friday, July 2, 2021 (approximately 20,000 in Lee’s account and 40,000 in her
parents’ account), at an average price of $7.49 per share and at a total cost of over $455,000
(approximately $156,000 in Lee’s account and $299,000 in her parents’ account).
62. Before the market opened on the next trading day, Tuesday, July 6, 2021, PFSWeb
publicly announced its sale of LiveArea, and the price of PFSWeb stock increased by 43% that day,
closing at $10.80 per share, a $3.23 increase from the July 2 closing price of $7.57 per share.
63. Approximately 90 minutes after the announcement, Lee sold all the PFSWeb shares
in her account and her parents’ account for a total of over $621,000, and reaped a total profit of
over $165,000—over $61,000 in her account and over $104,000 in her parents’ account.
64. Lee’s trades in PFSWeb yielded gains of over 36% on shares that were held for less
than two weeks and in some instances for just one business day.
 B. Sequans

65. From May 2021 through July 2021, Company A was engaged in discussions with
Sequans about Company A’s potential acquisition of Sequans.
66. On May 17, 2021, Company A and Sequans executed a written nondisclosure
agreement in connection with the discussions.
67. As President and Chief Investment Officer of Company A, Tobia played an integral
role in Company A’s efforts to acquire Sequans.
68. On July 26, 2021, at 4:25 p.m., Company A sent an email to Sequans’ Chairman and
Chief Executive Officer attaching a letter to Sequans’ Board of Directors.  The letter explained:
“We are providing this brief summary of our discussions to outline our interest in pursuing a
transaction with Sequans and explain why we believe [Company A] is a unique partner for the next
chapter of its growth.”  The letter went on to discuss why Company A considered Sequans an
attractive target, and why Company A’s capital and other resources would support Sequans’ business

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strategy.
69. Tobia received emails attaching drafts of the letter in the days leading up to its
transmission, and Tobia received the final version of the letter by email on July 26, 2021, the same
day it was sent to Sequans.
70. On July 27, 2021, at 10:08 a.m., the morning after Company A sent its letter to
Sequans, Tobia called Lee and they spoke for approximately two-and-a-half minutes.
71. At 10:17 that morning, approximately seven minutes after Lee had concluded her call
with Tobia, she began purchasing shares of Sequans in her parents’ account.
72. Over approximately the next hour, Lee made several purchases of Sequans shares in
her own account.
73. In total that morning, Lee purchased 80,000 shares of Sequans in both accounts
(30,000 in her account and 50,000 in her parents’ account), at an average price of $5.00 per share
and at a total cost of approximately $400,000 (approximately $152,000 in her account and $248,000
in her parents’ account).
74. Company A did not ultimately reach an agreement to acquire Sequans, and there was
no public announcement about the companies’ discussions regarding a potential acquisition.  As a
result, Lee did not profit from owning or selling shares of Sequans based on the information she had
obtained from Tobia.
 C. Spok
75. By August 2021, Company A had already acquired a substantial position in Spok and
was taking steps to prepare for a bid to purchase the entire company.
76. That month, Tobia was involved in discussions at Company A about making an
offer to acquire Spok.
77. On August 11, 2021, Tobia (and others at Company A) received a draft of a

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confidential letter to be sent by Company A to Spok’s Board of Directors communicating Company
A’s offer to acquire all the outstanding shares of Spok at a premium to the market price.
78. The next morning, on August 12, 2021, at 8:42 a.m., Lee texted Tobia, “Can u advise
a stock that pays a nice dividend?”
79. Tobia responded by texting “No,” and a few minutes later texted, “I have another
name” and “Will call.”
80. At 11:05 a.m. that morning, Tobia called Lee, and their call lasted 96 seconds.
81. Almost immediately after the call concluded, at 11:09 a.m., Lee began purchasing
shares of Spok stock in her parents’ account and began purchasing Spok shares in her own account
a few minutes later at 11:11 a.m.
82. That afternoon, at 1:28 p.m., Tobia called Lee, and Lee then called Tobia back three
minutes later at 1:31 p.m.
83. Between 1:31 p.m. and 1:47 p.m. that afternoon, Lee made additional purchases of
Spok shares in her parents’ account.
84. A few days later, on August 16, 2021, as Tobia continued to participate in planning
for Company A’s offer to acquire Spok, Tobia again communicated with Lee by phone and text, and
she made additional purchases of Spok shares that day after they communicated.
85. At 10:47 a.m. that day, Tobia texted Lee, “Are you there[  ].”
86. At 10:49 a.m., Lee responded, “I’m in city today,” and Tobia wrote back, “Ok I will
call you later.”
87. At 11:21 a.m. that morning, Tobia called Lee, and their call lasted 69 seconds.
88. About three minutes later, at 11:25 a.m., Lee purchased additional shares of Spok in
her parents’ account and then purchased Spok shares in her own account at 11:32 a.m.
89. In total, Lee purchased 25,000 shares of Spok in her own account and over 102,000

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shares in her parents’ account between August 12 and August 16, 2021, at an average price per share
of $7.51.
90. The total cost for the purchases of Spok in Lee’s account was over $187,000, and the
total cost for the purchases of Spok in her parents’ account was over $765,000, an amount that
represented approximately half the total value of her parents’ account.
91. On August 30, 2021, after the market closed, Company A issued a press release and
publicly filed a Form 13D with the Commission disclosing that Company A had acquired 6.5% of
Spok’s outstanding shares and that it proposed to acquire the remaining outstanding shares of
Spok’s common stock at a price of $10.75 per share.
92. Spok’s stock price increased by 26% following Company A’s announcement, from a
closing price of $7.85 per share on August 30 to a closing price of $9.91 per share on August 31.
93. Lee sold all the Spok shares in her account on August 31, 2021, and all the Spok
shares in her parents’ account on September 1, 2021, at an average price of $9.57 per share.
94. Lee’s sales of Spok shares in her account generated proceeds of over $252,000, for a
profit of over $64,000, and her sales of Spok shares in her parents’ account generated proceeds of
over $963,000, for a profit of over $198,000.
95. Across the two accounts, Lee realized trading profits of over $262,000 on her Spok
purchases, a 27% return on an investment of approximately $953,000 in about three weeks.
FIRST CLAIM FOR RELIEF

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

96. The Commission realleges and incorporates by reference here the allegations in
paragraphs 1 through 95.
97. Defendants, directly or indirectly, singly or in concert, in connection with the
purchase or sale of securities and by the use of means or instrumentalities of interstate commerce, or

15
the mails, or the facilities of a national securities exchange, knowingly or recklessly have (i) employed
one or more devices, schemes, or artifices to defraud, (ii) made one or more untrue statements of a
material fact or omitted to state one or more material facts necessary in order to make the
statements made, in light of the circumstances under which they were made, not misleading, and/or
(iii) engaged in one or more acts, practices, or courses of business which operated or would operate
as a fraud or deceit upon other persons.
98. By reason of the foregoing, Defendants, directly or indirectly, singly or in concert,
have violated and, unless enjoined, will again violate 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].
PRAYER FOR RELIEF
 WHEREFORE, the Commission respectfully requests that the Court enter a Final
Judgment:
I.
Permanently enjoining Defendants and their agents, servants, employees and attorneys and
all persons in active concert or participation with any of them from violating, directly or indirectly,
Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5];
II.
Ordering Defendants to pay civil monetary penalties pursuant to Exchange Act Section 21A
[15 U.S.C. § 78u-1];
III.
 Prohibiting Tobia from serving as an officer or director of any company that has a class of
securities registered under Exchange Act Section 12 [15 U.S.C. § 78l] or that is required to file
reports under Exchange Act Section 15(d) [15 U.S.C. § 78o(d)], pursuant to Exchange Act Section
21(d)(2) [15 U.S.C. § 78u(d)(2)]; and

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IV.
Granting any other and further relief this Court may deem just and proper.

Dated: New York, New York
January 13, 2025

 /s/ Antonia M. Apps
____________________________________
ANTONIA M. APPS
REGIONAL DIRECTOR
Tejal D. Shah
George N. Stepaniuk
Oren Gleich
Mariel Bronen
Kiran Patel
Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
New York Regional Office
100 Pearl Street
Suite 20-100
New York, NY 10004-2616
212-336-0190 (Gleich)
[email protected]

ANTONIA M. APPS 
REGIONAL DIRECTOR 
Tejal D. Shah 
George N. Stepaniuk 
Oren Gleich 
Mariel Bronen 
Kiran Patel 
Attorneys for Plaintiff 
SECURITIES AND EXCHANGE COMMISSION 
New York Regional Office 
100 Pearl Street  
Suite 20-100 
New York, NY 10004-2616 
212-336-0190 (Gleich) 
[email protected]  
 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 

 
SECURITIES AND EXCHANGE 
COMMISSION, 
 
                                             Plaintiff, 
 
                        -against- 
 
ALFRED V. TOBIA, JR. and ELIZABETH 
LEE,    
  
                                             Defendants.  
 

 
 
COMPLAINT 

   
25 Civ. 280 

 
   

JURY TRIAL DEMANDED 
  

           
          

 
Plaintiff Securities and Exchange Commission (“Commission”), for its Complaint against 

Defendants Alfred V. Tobia, Jr. (“Tobia”) and Elizabeth Lee (“Lee”) (collectively, “Defendants”), 

alleges as follows: 

SUMMARY 

1. This case concerns insider trading violations by Tobia and his wife’s sister Lee.  

From June 2021 through August 2021 (the “Relevant Period”), Tobia, in his role as an insider of 

two publicly traded companies, obtained material nonpublic information about potential corporate 

transactions involving three other publicly traded companies.  With that information, Tobia tipped 

Case 1:25-cv-00280     Document 1     Filed 01/13/25     Page 1 of 16



  

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Lee, who then purchased shares of these three companies in her brokerage account and in an 

account held by her elderly parents (Tobia’s parents-in-law).  Tobia and Lee’s insider trading scheme 

yielded more than $400,000 in unlawful profits.  

2. During the Relevant Period, Tobia was the President and Chief Investment Officer 

of Company A, a publicly traded company, and also sat on its Board of Directors and that of 

Company B, also a publicly traded company.  Lee is, and was at the time, a self-employed jewelry 

maker.  

3. On June 24, 2021, Tobia had a phone call in his capacity as a Director of Company B 

with a director (“Director A”) of PFSWeb, Inc. (“PFSWeb”), another publicly traded company.  

During a confidential discussion about a potential transaction between Company B and PFSWeb 

relating to one of PFSWeb’s two business units, Tobia learned from Director A that PFSWeb was in 

the process of completing a sale of its other business unit, known as LiveArea. 

4. Less than an hour after getting off the phone with Director A, Tobia called Lee.  

Fourteen minutes later, Lee started buying shares of PFSWeb in her elderly parents’ account.  Two 

minutes later, Lee started buying PFSWeb shares in her own account.  In all, Lee purchased over 

60,000 shares of PFSWeb in both accounts at a total cost of over $455,000 between Thursday, June 

24, and Friday, July 2, 2021.   

5. On the morning of the next trading day, Tuesday, July 6, 2021, PFSWeb publicly 

announced its sale of LiveArea.  The price of PFSWeb stock increased by approximately 43% that 

day.  Approximately 90 minutes after the announcement, Lee sold all the PFSWeb shares in her 

account and her parents’ account for a total of over $621,000 and reaped a total profit of 

over $165,000. 

6. By mid-July 2021, Company A had engaged in confidential negotiations with 

Sequans Communications S.A. (“Sequans”), another publicly traded company, about its potential 

Case 1:25-cv-00280     Document 1     Filed 01/13/25     Page 2 of 16



  

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acquisition by Company A.  As President and Chief Investment Officer of Company A, Tobia 

played a significant role in Company A’s efforts to acquire Sequans. 

7. On the morning of July 27, 2021, three weeks after Lee completed her PFSWeb 

trades, Tobia called Lee.  About seven minutes after the call ended, Lee began purchasing shares of 

Sequans in her parents’ account.  Lee then made several more purchases of Sequans in her own 

account that morning.  In total that morning, Lee purchased 80,000 shares of Sequans in both 

accounts at a total cost of approximately $400,000. 

8. Company A and Sequans did not end up reaching an agreement for Company A to 

acquire Sequans, and there was no public announcement about their discussions.  As a result, Lee 

did not profit from her shares of Sequans based on the material nonpublic information Tobia had 

given her. 

9. In August 2021, Tobia was involved in discussions at Company A about its making 

an offer to acquire Spok Holdings Inc. (“Spok”), yet another publicly traded company.  On August 

11, 2021, Tobia received a draft letter from Company A to Spok’s Board of Directors proposing the 

acquisition.   

10. The next morning, on August 12, 2021, Tobia called Lee.  A few minutes after their 

call ended, Lee began buying Spok shares, first in her parents’ account and then in her own account.  

Between August 12 and August 16, 2021, Lee purchased 25,000 shares of Spok in her own account 

for over $187,000 and over 102,000 shares in her parents’ account for over $765,000, roughly half 

the total value of her parents’ account at the time. 

11. On August 30, 2021, Company A issued a press release and publicly disclosed that 

Company A had acquired 6.5% of Spok’s outstanding shares and that Company A proposed to 

acquire the rest of the outstanding shares of Spok’s common stock.  Spok’s stock price increased by 

approximately 26% on the news.   

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12. Lee sold all the Spok shares in her account on August 31, 2021, and all the Spok 

shares in her parents’ account on September 1, 2021, and reaped a total profit of over $262,000.    

13. Lee’s unlawful profits from trading on the tips she received from Tobia about 

PFSWeb and Spok totaled approximately $428,595—$302,628 in her parents’ account and $125,967 

in her own account. 

VIOLATIONS 

14. By virtue of the foregoing conduct and as alleged further herein, Tobia and Lee 

violated Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. § 78j(b)] 

and Rule 10b-5 [17 C.F.R. § 240.10b-5] thereunder. 

NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT 

15. The Commission brings this action pursuant to the authority conferred upon it by 

Exchange Act Sections 21(d) and 21A [15 U.S.C. §§ 78u(d) and 78u-1].  

16. The Commission seeks a final judgment: (a) permanently enjoining Defendants from 

violating the federal securities laws and rules this Complaint alleges they have violated; (b) ordering 

Defendants to pay civil money penalties pursuant to Exchange Act Section 21A [15 U.S.C. § 78u-1]; 

(c) prohibiting Tobia from serving as an officer or director of any company that has a class of 

securities registered under Exchange Act Section 12 [15 U.S.C. § 78l] or that is required to file 

reports under Exchange Act Section 15(d) [15 U.S.C. § 78o(d)], pursuant to Exchange Act Section 

21(d)(2) [15 U.S.C. § 78u(d)(2)]; and (d) ordering any other and further relief the Court may deem 

just and proper.  

JURISDICTION AND VENUE 

17. This Court has jurisdiction over this action pursuant to Exchange Act Section 27 [15 

U.S.C. § 78aa].  

18. Defendants, directly and indirectly, have made use of the means or instrumentalities 

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of interstate commerce or of the mails, or of the facilities of a national securities exchange, in 

connection with the transactions, acts, practices, and courses of business alleged herein. 

19. Venue lies in this District under Exchange Act Section 27 [15 U.S.C. § 78aa].  

Defendants transacted business in the Southern District of  New York, and certain of  the acts, 

practices, transactions, and courses of  business alleged in this Complaint occurred within this 

District.  For example, Tobia worked out of  Company A’s offices in New York, New York, where 

Tobia obtained the relevant material nonpublic information about at least Spok and Sequans.  

DEFENDANTS 

20. Tobia, age 60, resides (and did reside during the Relevant Period) in New York, 

New York and is married to Lee’s sister.  He was the President and Chief Investment Officer of 

Company A from September 2019 to September 2021, and a member of Company A’s Board of 

Directors from May 2018 to September 2021.  Tobia also served on the Board of Company B from 

July 2017 to September 2021.  Before joining Company A, Tobia was a partner with a Commission-

registered investment adviser (“Investment Adviser A”), a firm that he co-founded.  Tobia left his 

position at Investment Adviser A upon joining Company A in 2019, but he kept an ownership stake 

and remained a passive member of the firm.  Before forming Investment Adviser A in 2000, Tobia 

worked at several registered broker-dealer firms and held Series 7, 63, and 24 licenses.  

21. Lee, age 57, resides in Dumont, New Jersey and is Tobia’s sister-in-law.  She has 

been self-employed as a jewelry maker since 2020.  Prior to starting her jewelry business, Lee worked 

in fashion design for various brands from 2000 through 2020, including at a publicly traded 

company. 

RELEVANT ENTITIES 

22.  Company A is a Delaware corporation headquartered in New York, New York.  

Company A describes itself as a “value-oriented acquirer of businesses across public and private 

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markets.”  Company A’s common stock is registered with the Commission pursuant to Section 

12(b) of the Exchange Act and trades on the NASDAQ.   

23. Company B is a Delaware corporation headquartered in Chelmsford, 

Massachusetts.  Company B describes itself as a “customer and brand experience company operating 

in six service categories - data, marketing, sales, customer care, fulfillment and logistics.”  Company 

B’s common stock is registered with the Commission pursuant to Section 12(b) of the Exchange Act 

and trades on the NASDAQ exchange.   

24. PFSWeb is a Delaware corporation headquartered in Irving, Texas.  During the 

Relevant Period, PFSWeb had two primary business units: LiveArea, which provided e-commerce 

web services, and another called PFS, which provided logistics and order fulfillment services.  

Before being acquired by GXO Logistics, Inc. in October 2023, PFSWeb’s common stock was 

registered with the Commission pursuant to Section 12(b) of the Exchange Act and traded on the 

NASDAQ under the ticker symbol PFSW.   

25. Sequans is incorporated in France and headquartered in Colombes, France.  

Sequans designs, develops, and supplies semiconductor chips for use in internet connected devices.  

Sequans’ American Depositary Shares are registered with the Commission pursuant to Section 12(b) 

of the Exchange Act and trade on the New York Stock Exchange under the ticker symbol SQNS.   

26. Spok is a Delaware corporation headquartered in Alexandria, Virginia.  Spok 

provides communication services used by hospitals and health systems.  Spok’s common stock is 

registered with the Commission pursuant to Section 12(b) of the Exchange Act and trades on the 

NASDAQ under the ticker symbol SPOK.   

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FACTS 

I. BACKGROUND 

A. Tobia And Lee’s Relationship 

27. Tobia and his wife have been married for over thirty years.  

28. Tobia and Lee, his wife’s sister, have known each other for over thirty years and 

have a close family relationship. 

29. Over the years, Tobia and his wife have provided financial and other support to Lee, 

a third sister, and Lee’s elderly parents, who are 88 and 84 years old respectively.   

30. Since approximately 2013, Lee’s primary means of support has been the income 

from the stocks she owns and the proceeds of stock sales.   

31. Most of Lee’s stock investments have been based on recommendations or other 

information she obtained from Tobia, including, as alleged in Section II below, material nonpublic 

information concerning PFSWeb, Sequans and Spok. 

32. During the Relevant Period, Lee knew that Tobia was a high-ranking officer and 

director at Company A and a director at Company B, and she knew that both were public 

companies.   

33. During the Relevant Period, Lee also understood that Tobia’s educational 

background was in finance, that he had worked at a number of firms in the securities industry, that 

his work involved analyzing companies and stocks, and that he had cofounded an investment firm.   

B. Tobia’s Duties of Confidentiality 

34. As an officer and director of Company A, Tobia owed a fiduciary duty to Company 

A, which included a duty to maintain the confidentiality of material nonpublic information that he 

obtained through his employment at Company A.   

35. In addition, Company A’s insider trading policy and Tobia’s employment agreement 

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with Company A contained prohibitions on disclosure of confidential information.   

36. The prohibition on disclosing material nonpublic information under Company A’s 

insider trading policy encompassed disclosures to “any outside person (including family 

members . . .).”  The policy also set forth examples of information that is generally considered 

material, including “news of a pending or proposed joint venture, merger, acquisition, tender offer, 

divestiture, recapitalization, strategic alliance, licensing arrangement or purchase or sales of 

substantial assets.”   

37. Tobia’s employment agreement with Company A similarly provided that Tobia 

agreed not to “reveal, disclose or make known any Confidential Information” including “acquisition 

plans” and other “strategies.”   

38. Tobia reviewed and signed the Company A insider trading policy and employment 

agreement and was aware of the prohibitions they contained. 

39. Company A’s policies were consistent with Tobia’s independent understanding of 

prohibitions on disclosing material nonpublic information based on his work experience over several 

years in roles that involved being entrusted with such information. 

40. As a director of Company B, Tobia also owed a fiduciary duty to Company B.   

41. In at least one instance in his role as a director of Company B, as alleged below, 

Tobia also owed a duty of confidentiality to PFSWeb with respect to material nonpublic information 

that Tobia obtained from PFSWeb’s Director A. 

II. LEE’S UNLAWFUL TRADING BASED ON TOBIA’S TIPS  

 A. PFSWeb    

42. In June 2021, Tobia, in his capacity as a director of Company B, contacted 

PFSWeb’s Director A through an introduction by a mutual friend. 

43. Both PFSWeb and Company B had operations in the logistics and order 

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fulfillment industry.   

44. Tobia told Director A that he wanted to discuss a potential transaction between 

PFSWeb and Company B.      

45. Tobia and Director A spoke for over an hour on June 24, 2021, starting at 10:00 a.m.   

46. Director A spoke to Tobia in Director A’s capacity as a PFSWeb board member 

speaking to the director of another company interested in exploring a possible transaction between 

their respective companies. 

47. At the time of his call with Tobia, Director A knew that PFSWeb was in the process 

of consummating, and was planning to soon announce, the sale of its LiveArea business unit to a 

company called Merkle.   

48. At the time of his call with Tobia, Director A also knew that, once the sale of the 

LiveArea business unit was complete, PFSWeb intended to pursue a process to find a potential 

buyer for PFS, PFSWeb’s remaining logistics and order fulfillment business unit. 

49. During their call, Director A and Tobia agreed to have PFSWeb and Company B 

sign a written nondisclosure agreement in connection with discussions between the two companies 

about a potential transaction.   

50. During their call, Director A told Tobia that PFSWeb’s advisors would be sending 

him the written nondisclosure agreement. 

51. Director A understood and expected that the nonpublic information about PFSWeb 

and Company B discussed on his call with Tobia was to remain confidential pending execution of 

the written nondisclosure agreement.   

52. Director A also understood that Tobia shared the same understanding and 

expectation regarding the confidentiality of their conversation. 

53. Tobia owed a duty of trust and confidence to PFSWeb with respect to the nonpublic 

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information that Director A disclosed to Tobia on their June 24, 2021 call.       

54. With that understanding, on their June 24 call, Director A conveyed to Tobia 

information from which Tobia learned that (i) PFSWeb’s LiveArea business unit would soon be 

sold; (ii) PFSWeb would soon be announcing the sale of Live Area; and (iii) PFSWeb and Company 

B could then resume discussions about a potential transaction involving PFSWeb’s remaining 

business unit, PFS.   

55. At 11:43 a.m. on June 24, 2021, less than an hour after concluding his call with 

Director A, Tobia called Lee. 

56. Less than fifteen minutes after her call with Tobia ended, at 11:57 a.m. the same day, 

Lee began buying PFSWeb stock in her parents’ brokerage account. 

57. Two minutes later, at 11:59 a.m. that day, Lee started buying PFSWeb stock in her 

own account. 

58. Lee continued to buy PFSWeb stock in both her and her parents’ accounts over the 

next several days.   

59. In almost every instance, a call with Tobia preceded her PFSWeb stock purchases, 

often by just minutes before she placed a trade. 

60. For example, (i) on June 28, 2021, Lee received a call from Tobia at 1:44 p.m. that 

lasted almost four minutes, and she then purchased additional shares of PFSWeb in her parents’ 

account, at 1:50 p.m. and 1:54 p.m., and purchased additional PFSWeb shares in her own account at 

2:51 p.m.; (ii) on July 1, 2021, Tobia called Lee at 9:03 a.m. and 9:28 a.m., and Lee bought more 

PFSWeb shares in her account at 10:28 a.m.; and (iii) on July 1, 2021, at 12:27 p.m., Tobia called Lee 

again, and she bought more PFSWeb shares in her parents’ account at 12:28 p.m. and in her own 

account at 12:51 p.m. 

61. In total, Lee purchased over 60,000 shares of PFSWeb in both accounts between 

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Thursday, June 24, and Friday, July 2, 2021 (approximately 20,000 in Lee’s account and 40,000 in her 

parents’ account), at an average price of $7.49 per share and at a total cost of over $455,000 

(approximately $156,000 in Lee’s account and $299,000 in her parents’ account).   

62. Before the market opened on the next trading day, Tuesday, July 6, 2021, PFSWeb 

publicly announced its sale of LiveArea, and the price of PFSWeb stock increased by 43% that day, 

closing at $10.80 per share, a $3.23 increase from the July 2 closing price of $7.57 per share. 

63. Approximately 90 minutes after the announcement, Lee sold all the PFSWeb shares 

in her account and her parents’ account for a total of over $621,000, and reaped a total profit of 

over $165,000—over $61,000 in her account and over $104,000 in her parents’ account. 

64. Lee’s trades in PFSWeb yielded gains of over 36% on shares that were held for less 

than two weeks and in some instances for just one business day. 

 B. Sequans 
 

65. From May 2021 through July 2021, Company A was engaged in discussions with 

Sequans about Company A’s potential acquisition of Sequans. 

66. On May 17, 2021, Company A and Sequans executed a written nondisclosure 

agreement in connection with the discussions. 

67. As President and Chief Investment Officer of Company A, Tobia played an integral 

role in Company A’s efforts to acquire Sequans.   

68. On July 26, 2021, at 4:25 p.m., Company A sent an email to Sequans’ Chairman and 

Chief Executive Officer attaching a letter to Sequans’ Board of Directors.  The letter explained:  

“We are providing this brief summary of our discussions to outline our interest in pursuing a 

transaction with Sequans and explain why we believe [Company A] is a unique partner for the next 

chapter of its growth.”  The letter went on to discuss why Company A considered Sequans an 

attractive target, and why Company A’s capital and other resources would support Sequans’ business 

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strategy. 

69. Tobia received emails attaching drafts of the letter in the days leading up to its 

transmission, and Tobia received the final version of the letter by email on July 26, 2021, the same 

day it was sent to Sequans.  

70. On July 27, 2021, at 10:08 a.m., the morning after Company A sent its letter to 

Sequans, Tobia called Lee and they spoke for approximately two-and-a-half minutes.   

71. At 10:17 that morning, approximately seven minutes after Lee had concluded her call 

with Tobia, she began purchasing shares of Sequans in her parents’ account.   

72. Over approximately the next hour, Lee made several purchases of Sequans shares in 

her own account.   

73. In total that morning, Lee purchased 80,000 shares of Sequans in both accounts 

(30,000 in her account and 50,000 in her parents’ account), at an average price of $5.00 per share 

and at a total cost of approximately $400,000 (approximately $152,000 in her account and $248,000 

in her parents’ account). 

74. Company A did not ultimately reach an agreement to acquire Sequans, and there was 

no public announcement about the companies’ discussions regarding a potential acquisition.  As a 

result, Lee did not profit from owning or selling shares of Sequans based on the information she had 

obtained from Tobia. 

 C. Spok 

75. By August 2021, Company A had already acquired a substantial position in Spok and 

was taking steps to prepare for a bid to purchase the entire company.  

76. That month, Tobia was involved in discussions at Company A about making an 

offer to acquire Spok.   

77. On August 11, 2021, Tobia (and others at Company A) received a draft of a 

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confidential letter to be sent by Company A to Spok’s Board of Directors communicating Company 

A’s offer to acquire all the outstanding shares of Spok at a premium to the market price. 

78. The next morning, on August 12, 2021, at 8:42 a.m., Lee texted Tobia, “Can u advise 

a stock that pays a nice dividend?”   

79. Tobia responded by texting “No,” and a few minutes later texted, “I have another 

name” and “Will call.”   

80. At 11:05 a.m. that morning, Tobia called Lee, and their call lasted 96 seconds.   

81. Almost immediately after the call concluded, at 11:09 a.m., Lee began purchasing 

shares of Spok stock in her parents’ account and began purchasing Spok shares in her own account 

a few minutes later at 11:11 a.m.   

82. That afternoon, at 1:28 p.m., Tobia called Lee, and Lee then called Tobia back three 

minutes later at 1:31 p.m. 

83. Between 1:31 p.m. and 1:47 p.m. that afternoon, Lee made additional purchases of 

Spok shares in her parents’ account. 

84. A few days later, on August 16, 2021, as Tobia continued to participate in planning 

for Company A’s offer to acquire Spok, Tobia again communicated with Lee by phone and text, and 

she made additional purchases of Spok shares that day after they communicated.   

85. At 10:47 a.m. that day, Tobia texted Lee, “Are you there[  ].”   

86. At 10:49 a.m., Lee responded, “I’m in city today,” and Tobia wrote back, “Ok I will 

call you later.”   

87. At 11:21 a.m. that morning, Tobia called Lee, and their call lasted 69 seconds.   

88. About three minutes later, at 11:25 a.m., Lee purchased additional shares of Spok in 

her parents’ account and then purchased Spok shares in her own account at 11:32 a.m. 

89. In total, Lee purchased 25,000 shares of Spok in her own account and over 102,000 

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shares in her parents’ account between August 12 and August 16, 2021, at an average price per share 

of $7.51.   

90. The total cost for the purchases of Spok in Lee’s account was over $187,000, and the 

total cost for the purchases of Spok in her parents’ account was over $765,000, an amount that 

represented approximately half the total value of her parents’ account. 

91. On August 30, 2021, after the market closed, Company A issued a press release and 

publicly filed a Form 13D with the Commission disclosing that Company A had acquired 6.5% of 

Spok’s outstanding shares and that it proposed to acquire the remaining outstanding shares of 

Spok’s common stock at a price of $10.75 per share.   

92. Spok’s stock price increased by 26% following Company A’s announcement, from a 

closing price of $7.85 per share on August 30 to a closing price of $9.91 per share on August 31.   

93. Lee sold all the Spok shares in her account on August 31, 2021, and all the Spok 

shares in her parents’ account on September 1, 2021, at an average price of $9.57 per share.   

94. Lee’s sales of Spok shares in her account generated proceeds of over $252,000, for a 

profit of over $64,000, and her sales of Spok shares in her parents’ account generated proceeds of 

over $963,000, for a profit of over $198,000.   

95. Across the two accounts, Lee realized trading profits of over $262,000 on her Spok 

purchases, a 27% return on an investment of approximately $953,000 in about three weeks. 

FIRST CLAIM FOR RELIEF 
 

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

 
96. The Commission realleges and incorporates by reference here the allegations in 

paragraphs 1 through 95. 

97. Defendants, directly or indirectly, singly or in concert, in connection with the 

purchase or sale of securities and by the use of means or instrumentalities of interstate commerce, or 

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the mails, or the facilities of a national securities exchange, knowingly or recklessly have (i) employed 

one or more devices, schemes, or artifices to defraud, (ii) made one or more untrue statements of a 

material fact or omitted to state one or more material facts necessary in order to make the 

statements made, in light of the circumstances under which they were made, not misleading, and/or 

(iii) engaged in one or more acts, practices, or courses of business which operated or would operate 

as a fraud or deceit upon other persons. 

98. By reason of the foregoing, Defendants, directly or indirectly, singly or in concert, 

have violated and, unless enjoined, will again violate 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]. 

PRAYER FOR RELIEF 

 WHEREFORE, the Commission respectfully requests that the Court enter a Final 

Judgment: 

I. 

Permanently enjoining Defendants and their agents, servants, employees and attorneys and 

all persons in active concert or participation with any of them from violating, directly or indirectly, 

Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]; 

II. 

Ordering Defendants to pay civil monetary penalties pursuant to Exchange Act Section 21A 

[15 U.S.C. § 78u-1]; 

III. 

 Prohibiting Tobia from serving as an officer or director of any company that has a class of 

securities registered under Exchange Act Section 12 [15 U.S.C. § 78l] or that is required to file 

reports under Exchange Act Section 15(d) [15 U.S.C. § 78o(d)], pursuant to Exchange Act Section 

21(d)(2) [15 U.S.C. § 78u(d)(2)]; and  

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IV. 

Granting any other and further relief this Court may deem just and proper.  

  

Dated: New York, New York 
January 13, 2025  
 
 /s/ Antonia M. Apps 

____________________________________   
ANTONIA M. APPS  
REGIONAL DIRECTOR  
Tejal D. Shah 
George N. Stepaniuk 
Oren Gleich 
Mariel Bronen 
Kiran Patel 
Attorneys for Plaintiff 
SECURITIES AND EXCHANGE COMMISSION 
New York Regional Office 
100 Pearl Street  
Suite 20-100 
New York, NY 10004-2616 
212-336-0190 (Gleich) 
[email protected] 

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