SEC v. IU Group, Inc.; Elijah Bang; and Daniel Lee, Central District of California (Apr. 25, 2011) — Complaint

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.
 
JOHN M. MCCOY III, Cal. 
Bar No. 166244 
Email: 
mccoyi(c4sec~gQv 
DAVID J.  VAWHAVERMAAT, Cal. BarNo. 175761 
Email· vanhavermaatd@sec 
gOY 
Attorneys for Plaintiff 
FILED
 
2011 JAN 19 AM II: 55
 
CLERK U.S. DISTRICT COURT
CENTRAL D1ST. OF CALIF.
 
LOS i\HGELES
 
Securities and Exchange Commission
Rosalind R. Tyson, Regional Director 
5670 Wilshire Boulevard, 
11 th Floor 
Los Angeles, California 90036
. Telephone: (323) 965-3998 
FacsImile: (323) 965-3908 
UNITED STATES DISTRICT COURT 
CENTRAL DISTRICT 
OF CALIFORNIA 
SECURITIES AND EXCHANGE 
COMMISSION, 
Plaintiff, 
vs. 
IU 
GROU~~ INC., ELIJAH BANG, a/k/a 
ELIJAH 
BtlANG, and DANIEL LEE, 
Defendants. 
'~aseCY 11 00556-t~1;
 
COMPLAINT FOR I 
VIOLATIONS OF THE 
FEDERAL SECURITIES LAWS 

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Plaintiff Securities and Exchange Commission ("Commission") alleges as 
follows: 
JURISDICTION AND VENUE 
1. This Court has jurisdiction over this action pursuant to Sections 20(b), 
20(d)(1) and 22(a) 
of the Securities Act of 1933 ("Securities Act"), 15 U.S.C. 
§§ 77t(b), 77t(d)(1), and 77v(a), and Sections 209(d), 209(e)(1), and 214 of the 
Investment Advisers Act 
of 1940 ("Advisers Act"), 15 U.S.C. §§ 80b-9(d), 80b­
9(e)(1), and 80b-14. Defendants have, directly or indirectly, made use 
of the 
means or instrumentalities 
of interstate commerce, of the mails, or of the facilities 
of a national securities exchange, in connection with the transactions, acts, 
practices, and courses 
ofbusiness alleged in this complaint. 
2. Venue is proper in this district pursuant to Section 22(a) 
of the 
Securities Act, 
15 U.S.C. § 77v(a), and Section 214 of the Advisers Act, 15 U.S.C. 
§ 80b-14, because certain of the transactions, acts, practices, and courses of 
conduct constituting violations of the federal securities laws occurred within this 
district, and at least two 
of the defendants reside and/or are located in this district. 
SUMMARY 
3. This matter involves an ongoing offering fraud and investment adviser 
fraud 
by IU Group, Inc. ("IU Group"), through its affiliate IU Wealth 
Management, LLC 
("IU Wealth"), which purports to operate as a hedge fund, 
Elijah Bang a/k/a Elijah Bhang ("Bang"), its principal, and Daniel Lee ("Lee"), its 
sales associate (IU Group, Bang, and Lee collectively, "Defendants"). In 2009, the 
California Department 
of Corporations ordered Bang and Lee to desist and refrain 
from conducting a prior offering fraud. Beginning in at least September 2010, 
Bang, Lee and 
IUGroup started their new offering fraud and purported wealth 
management business. 
4. The Defendants have solicited investors and clients on behalf ofIU 
Wealth with several false representations. These representations include 
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statements that the purported hedge fund has had a successful performance history 
since January 2007, generating substantial monthly returns 
ofup to 23%; that the 
majority 
of IV Wealth's clients are professional athletes, actors, producers, 
doctors, professors, politicians, and executives 
of private corporations; and that 
IV Wealth has over $800 million under management. Each 
ofthese 
representations made to investors was false. 
5. The Defendants made their misrepresentations to investors through IV 
Wealth's and an affiliate's websites and in emails sent by Lee to prospective 
investors and clients. Although the websites are no longer operational, Lee 
repeated many 
of the misrepresentations in communications with prospective 
investors as recently as November 23,2010. 
6. By engaging in the conduct described in this Complaint, the 
Defendants have violated, and unless enjoined will continue to violate, the 
antifraud and securities registration provisions 
of the federal securities laws. Bang 
also has violated, and unless enjoined will continue to violate, the investment 
adviser fraud and pooled investment vehicle fraud provisions 
of the federal 
securities laws. By this Complaint, the Commission seeks emergency relief 
against the Defendants, including a temporary restraining order, accountings, an 
order expediting discovery, and an order prohibiting the destruction 
of documents, 
as well as preliminary and permanent injunctions, disgorgement with prejudgment 
interest, and civil penalties against each 
ofthe Defendants. 
DEFENDANTS 
7. IV Group, Inc. is a California corporation with its principal place of 
business in Beverly Hills, California. The State of California has suspended IV 
Group's business license. IV Group is not registered with the Commission in any 
capacity. IV Wealth is one 
of several affiliated companies of IV Group. On May 
19,2009, the California Department 
of Corporations ordered IV Investments, LLC 
to desist and refrain from the unlawful offer or sale 
of securities and from the 
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fraudulent sale of securities. 
8. Elijah Bang, a/kIa Elijah Bhang, age 30, apparently resides in Los 
Angeles, California. Bang is IV Group's and IV Wealth's principal and is the 
registrant 
of the IV Wealth website. Bang is  not registered with the Commission in 
any capacity and does not hold any securities licenses. Bang was named as a 
respondent in and 
is subject to the provisions of the California Department of 
Corporations' May 19,2009 desist and refrain order involving IV Investments. 
9.' Daniel Lee, age and residence unknown. Lee is IV Wealth's sales 
associate. Lee does not appear to be registered with the Commission 
in any 
capacity or hold any securities licenses. Lee was named as a respondent in and is 
subject 
to the provisions of the California Department of Corporations' May 19, 
2009 desist and refrain order involving IV Investments. 
THEFRAUDULENTCONDVCT 
A. IV WEALTH'S HEDGE FuND AND ADVISORY BUSINESS 
10.'Although it is  not a licensed business entity, IV Wealth purports to 
have been operating as a hedge fund and advisory business since at least January 
2007. IV Wealth purports to be a hedge fund and claims that it specializes in 
handling the wealth 
of high-net worth individuals, with over $800 million in assets 
purportedly under management. 
11. IV Group and IV Wealth have offered preferred units, at $50,000 per 
uni,t, in IV Wealth's hedge fund, promising at least a 12% annual return. The 
Defendants solicited potential investors and advisory clients both through websites 
and through "cold-call" e-mail solicitations, including to university professors, 
often targeting those planning to retire or who have recently retired. The 
Defendants also apparently targeted the Christian community and claimed on IV 
Wealth's website that the purported hedge fund was founded by "devoted 
Christians who believe in God, Jesus Christ, and the Holy Spirit." In addition to its 
hedge fund, IV Wealth also purported to offer customized portfolios and other 
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wealth management services to potential advisory clients. 
12. Despite their aggressive solicitation campaign, the Defendants may 
have been unsuccessful in obtaining hedge fund investors or advisory clients. 
13. The offering 
of IV Wealth securities by the Defendants was not 
registered with the Commission, as required by federal securities laws and 
regulations. 
B. MATERIAL MISREPRESENTATIONS AND OMISSIONS 
14. Bang and Lee made numerous misrepresentations to potential 
investors and clients on IV Wealth's website and through email solicitations. As 
of November 2010, IV Wealth's website falsely represented: (1) that IV Wealth 
ran an operational hedge fund; (2) that the hedge fund had a successful 
performance history since January 2007, with an average monthly return of8.29%; 
and (3) that the majority 
of IV Wealth's clients were professional athletes, actors, 
and producers. None 
of these statements were true. 
15. IV Wealth's website was taken down in November 2010. IV Wealth 
also operated under the name 
of Icon Capital, which on its website made 
misrepresentations that were similar to those on IV Wealth's website, including 
misrepresentations regarding Icon Capital's purported track record and the nature 
of 
its purported clients. The Icon Capital website was taken down in November 2010. 
16. Lee made similar misrepresentations in emails that he sent to potential 
investors and clients. In unsolicited emails to potential investors and clients in 
September2010, Lee represented that IV Wealth had over $800 million under 
management and that 98% 
of IV Wealth's clients were professional athletes, 
actors, producers, doctors, professors, politicians, and executives 
ofprivate 
corporations. None 
of these statements made by Lee were true. 
17. The Defendants repeated some 
ofthe misrepresentations in a 
document titled "Client Presentation" that Lee emailed to at least one potential 
investor on November 16,2010. The Client Presentation document falsely stated 
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that IV Wealth's hedge fund had enjoyed gross returns of 1,051 % since 2007, with 
an average monthly gross return of23%. It repeated the misrepresentation that IV 
Wealth had over $800 million under management, including a purported $550 
million in stocks, $150 million in real estate/developments, and $100 million in a 
reserve. The Client Presentation document again falsely described IV Wealth's 
clients as consisting 
of professional athletes, entertainment moguls, public 
officials, including senators and congressmen, and other professionals. 
It also 
represented that IV Wealth's purported investment strategy involved minimal risk 
and would generate a guaranteed annual return 
of 12%. The representations in the 
Client Presentation document were virtually identical to the representations that 
had been posted on the IV Wealth and Icon Capital's websites, and contained in 
Lee's emails to prospective investors, which were false. 
18. On November 23,2010, Lee sent a follow-up email to the same 
prospective investor to whom he had previously sent the Client Presentation 
document. In his November 
23 email, Lee touted the "guaranteed" interest rate 
that IV Wealth would pay and represented that an investment in IV Wealth would 
be "as safe as you can get." Lee has continued to solicit this prospective investor 
as recently as January 11, 2011, and continues to try to set up meetings with him. 
FIRST CLAIM FOR RELIEF
 
UNREGISTERED OFFER AND SALE OF SECURITIES
 
Violations of Section 5(c) of the Securities Act
 
(Against All Defendants)
 
19. The Commission realleges and incorporates 
by reference paragraphs 1 
through 
18 above. 
20. Thedefendants,andeach 
ofthem,by'engagingintheconduct 
described above, directly or indirectly, made use 
of means or instruments of 
transportation or communication in interstate commerce or ofthe mails, to offer to 
sell securities. 
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21. No registration statement has been filed with the Commission with 
respect to the offering alleged herein. 
22. By engaging in the conduct described above, each 
of the defendants 
violated, and unless restrained and enjoined will continue to violate, Section 5(c) 
of the Securities Act, 15 U.S.C. § 77e(c). 
SECOND CLAIM FOR RELIEF
 
FRAUD IN THE OFFER OR SALE OF SECURITIES
 
Violations of Section 17(a) of the Securities Act
 
(Against All Defendants)
 
23. The Commission realleges and incorporates by reference paragraphs 1 
through 
18 above. 
24. The defendants, and each 
of them, by engaging in the conduct 
described above, directly or indirectly, in the offer or sale 
of securities by the use 
ofmeans orinstruments oftransportation orcommunication ininterstate 
commerce or by use 
of the mails: 
a.	 with scienter, employed devices, schemes, or artifices to 
defraud; 
b.	 obtained money or property by means of untrue statements of a 
material fact or by omitting to state a material fact necessary in 
order to make the statements made, in the light 
of the 
circumstances under whjch they were made, not misleading; or 
c.	 engaged in transactions, practices, or courses ofbusiness which 
operated or would operate as a fraud or deceit upon the 
purchaser. 
25. By engaging in the conduct described above, each 
of the defendants 
violated, and unless restrained and enjoined will continue to violate,  Section 17(a) 
of the Securities Act, 15 U.S.C. § 77q(a). 
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III 

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THIRD CLAIM FOR RELIEF
 
FRAUD By AN INVESTMENT ADVISER
 
Violations of Sections 206(1) and 206(2) of the Advisers Act
 
(Against Defendant Bang)
 
26. The Commission realleges and incorporates by reference paragraphs 1 
through 
18 above. 
27. Defendant Bang, by engaging in the conduct described above, while 
acting 
as an investment adviser, directly or indirectly, by use of the mails or means 
or instrumentalities 
of interstate commerce: 
,	 
a. with scienter, employed devices, schemes, or artifices to 
defraud clients or prospective clients; or 
b.	 engaged in transactions, practices, or courses of business which 
operated 
as a fraud or deceit upon clients or prospective clients. 
28. By engaging in the conduct described above, defendant Bang violated, 
and unless restrained and enjoined will continue 
to violate, Sections 206(1) and 
206(2) 
of the Advisers Act, 15 U.S.C. §§ 80b-6(l) and 80b-6(2). 
FOURTH CLAIM FOR RELIEF
 
FRAUD INVOLVING A POOLED INVESTMENT VEIDCLE
 
Violations of Section 206(4) of the Advisers Act and Rule 206(4)-8 Thereunder
 
(Against Defendant Bang)
 
29. The Commission realleges and incorporates by reference paragraphs 1 
through 
18 above. 
30. Defendant Bang, by engaging in the conduct described above, while 
acting 
as an investment adviser to a pooled investment vehicle, directly or 
indirectly, byuse 
ofthe mails ormeans orinstrumentalities ofinterstate commerce: 
a.	 made untrue statements of a material fact or omitted 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 
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misleading, to any investor or prospective investor in the 
pooled investment vehicle; or 
b.	 engaged in acts, practices, or courses of business that were 
fraudulent, deceptive, or manipulative with respect 
to any 
investor or prospective investor in the pooled investment 
vehicle. 
36. By engaging in the conduct described above, defendant Bang violated, 
and unless restrained and enjoined will continue to violate, Section 206(4) 
ofthe 
Advisers Act, 
15 U.S.C. § 80b-6(4), and Rule 206(4)-8 thereunder, 17 C.F.R. 
§ 275.206(4)-8. 
PRAYER FOR RELIEF 
WHEREFORE, the Commission respectfully requests that the Court: 
I. 
, 
Issue findings 
of fact and conclusions of law that the Defendants committed 
the alleged violations. 
II. 
Issue judgments, in forms consistent with Fed. R. Civ. P. 65(d), temporarily, 
preliminarily and permanently enjoining the Defendants and their officers, agents, 
servants, employees, and attorneys, and those persons in active concert or 
participationwith any 
ofthem, who receive actual notice ofthejudgmentby 
personal service or otherwise, and each 
ofthem, from violating Sections 5(c) and 
17(a) 
of the Securities Act, 15 U.S.C. §§ 77e(c) and 77q(a). 
III. 
Issue a judgment, in a form consistent with Fed. R. Civ. P. 65(d), 
temporarily, preliminarily and permanently enjoining Bang and his agents, 
servants, employees, and attorneys, and those persons in active concert or 
participation with any 
of them, who receive actual notice of the judgment by 
personal service or otherwise, and each 
of them, from violating Sections 206(1), 
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206(2), and 206(4) 
of the Advisers Act, 15 U.S.C. §§ 80b-6(1), 80b-6(2), and 
80b-6(4), and Rule 206(4)-8 thereunder, 
17 C.F.R. § 275.206(4)-8. 
I~ 
Issue, in a form consistent with Fed. R. Civ. P. 65,a temporary restraining 
order and a preliminary injunction prohibiting each 
of the Defendants from 
destroying documents, granting expedited discovery, and requiring accountings 
from each 
of the Defendants. 
~ 
Order each Defendant to disgorge all ill-gotten gains from their illegal 
conduct, together with prejudgment interest thereon. 
VI. 
Order each Defendant to pay civil penalties under Section 20(d) of the 
Securities Act, 
15 U.S.C. § 77t(d), and Section 209(e) ofthe Advisers Act, 
15 U.S.C. § 80b-9(e). 
VII. 
Retain jurisdiction of this action in accordance with the principles of equity 
and the Federal Rules 
of Civil Procedure in order to implement and carry out the 
terms 
of all orders and decrees that may be entered, or to entertain any suitable 
application or motion for additional relief within the jurisdiction 
of this Court. 
VIII. 
Grant such other and further relief as this Court may determine to be just and 
necessary. 
DATED: January 19,2011 
Attorney for Plaintiff
Securities and Exchange Commission 
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.
 

JOHN M. MCCOY III, Cal. Bar No. 166244 
Email: mccoyi(c4sec~gQv 
DAVID J. VAWHAVERMAAT, Cal. BarNo. 175761 
Email· vanhavermaatd@sec gOY 

Attorneys for Plaintiff 

FILED
 

2011 JAN 19 AM II: 55
 

CLERK U.S. DISTRICT COURT
CENTRAL D1ST. OF CALIF.
 

LOS i\HGELES
 

Securities and Exchange Commission
Rosalind R. Tyson, Regional Director 
5670 Wilshire Boulevard, 11 th Floor 
Los Angeles, California 90036

. Telephone: (323) 965-3998 
FacsImile: (323) 965-3908 

UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

SECURITIES AND EXCHANGE 
COMMISSION, 

Plaintiff, 

vs. 

IU GROU~~ INC., ELIJAH BANG, a/k/a 
ELIJAH BtlANG, and DANIEL LEE, 

Defendants. 

'~aseCY 11 00556-t~1;
 
COMPLAINT FOR I 
VIOLATIONS OF THE 
FEDERAL SECURITIES LAWS 



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Plaintiff Securities and Exchange Commission ("Commission") alleges as 

follows: 

JURISDICTION AND VENUE 

1. This Court has jurisdiction over this action pursuant to Sections 20(b), 

20(d)(1) and 22(a) of the Securities Act of 1933 ("Securities Act"), 15 U.S.C. 

§§ 77t(b), 77t(d)(1), and 77v(a), and Sections 209(d), 209(e)(1), and 214 of the 

Investment Advisers Act of 1940 ("Advisers Act"), 15 U.S.C. §§ 80b-9(d), 80b­

9(e)(1), and 80b-14. Defendants have, directly or indirectly, made use of the 

means or instrumentalities of interstate commerce, of the mails, or of the facilities 

of a national securities exchange, in connection with the transactions, acts, 

practices, and courses ofbusiness alleged in this complaint. 

2. Venue is proper in this district pursuant to Section 22(a) of the 

Securities Act, 15 U.S.C. § 77v(a), and Section 214 of the Advisers Act, 15 U.S.C. 

§ 80b-14, because certain of the transactions, acts, practices, and courses of 

conduct constituting violations of the federal securities laws occurred within this 

district, and at least two of the defendants reside and/or are located in this district. 

SUMMARY 

3. This matter involves an ongoing offering fraud and investment adviser 

fraud by IU Group, Inc. ("IU Group"), through its affiliate IU Wealth 

Management, LLC ("IU Wealth"), which purports to operate as a hedge fund, 

Elijah Bang a/k/a Elijah Bhang ("Bang"), its principal, and Daniel Lee ("Lee"), its 

sales associate (IU Group, Bang, and Lee collectively, "Defendants"). In 2009, the 

California Department of Corporations ordered Bang and Lee to desist and refrain 

from conducting a prior offering fraud. Beginning in at least September 2010, 

Bang, Lee and IUGroup started their new offering fraud and purported wealth 

management business. 

4. The Defendants have solicited investors and clients on behalf ofIU 

Wealth with several false representations. These representations include 

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statements that the purported hedge fund has had a successful performance history 

since January 2007, generating substantial monthly returns ofup to 23%; that the 

majority of IV Wealth's clients are professional athletes, actors, producers, 

doctors, professors, politicians, and executives of private corporations; and that 

IV Wealth has over $800 million under management. Each of these 

representations made to investors was false. 

5. The Defendants made their misrepresentations to investors through IV 

Wealth's and an affiliate's websites and in emails sent by Lee to prospective 

investors and clients. Although the websites are no longer operational, Lee 

repeated many of the misrepresentations in communications with prospective 

investors as recently as November 23,2010. 

6. By engaging in the conduct described in this Complaint, the 

Defendants have violated, and unless enjoined will continue to violate, the 

antifraud and securities registration provisions of the federal securities laws. Bang 

also has violated, and unless enjoined will continue to violate, the investment 

adviser fraud and pooled investment vehicle fraud provisions of the federal 

securities laws. By this Complaint, the Commission seeks emergency relief 

against the Defendants, including a temporary restraining order, accountings, an 

order expediting discovery, and an order prohibiting the destruction of documents, 

as well as preliminary and permanent injunctions, disgorgement with prejudgment 

interest, and civil penalties against each of the Defendants. 

DEFENDANTS 

7. IV Group, Inc. is a California corporation with its principal place of 

business in Beverly Hills, California. The State of California has suspended IV 

Group's business license. IV Group is not registered with the Commission in any 

capacity. IV Wealth is one of several affiliated companies of IV Group. On May 

19,2009, the California Department of Corporations ordered IV Investments, LLC 

to desist and refrain from the unlawful offer or sale of securities and from the 

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fraudulent sale of securities. 

8. Elijah Bang, a/kIa Elijah Bhang, age 30, apparently resides in Los 

Angeles, California. Bang is IV Group's and IV Wealth's principal and is the 

registrant of the IV Wealth website. Bang is not registered with the Commission in 

any capacity and does not hold any securities licenses. Bang was named as a 

respondent in and is subject to the provisions of the California Department of 

Corporations' May 19,2009 desist and refrain order involving IV Investments. 

9.' Daniel Lee, age and residence unknown. Lee is IV Wealth's sales 

associate. Lee does not appear to be registered with the Commission in any 

capacity or hold any securities licenses. Lee was named as a respondent in and is 

subject to the provisions of the California Department of Corporations' May 19, 

2009 desist and refrain order involving IV Investments. 

THEFRAUDULENTCONDVCT 

A. IV WEALTH'S HEDGE FuND AND ADVISORY BUSINESS 

10.'Although it is not a licensed business entity, IV Wealth purports to 

have been operating as a hedge fund and advisory business since at least January 

2007. IV Wealth purports to be a hedge fund and claims that it specializes in 

handling the wealth of high-net worth individuals, with over $800 million in assets 

purportedly under management. 

11. IV Group and IV Wealth have offered preferred units, at $50,000 per 

uni,t, in IV Wealth's hedge fund, promising at least a 12% annual return. The 

Defendants solicited potential investors and advisory clients both through websites 

and through "cold-call" e-mail solicitations, including to university professors, 

often targeting those planning to retire or who have recently retired. The 

Defendants also apparently targeted the Christian community and claimed on IV 

Wealth's website that the purported hedge fund was founded by "devoted 

Christians who believe in God, Jesus Christ, and the Holy Spirit." In addition to its 

hedge fund, IV Wealth also purported to offer customized portfolios and other 

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wealth management services to potential advisory clients. 

12. Despite their aggressive solicitation campaign, the Defendants may 

have been unsuccessful in obtaining hedge fund investors or advisory clients. 

13. The offering of IV Wealth securities by the Defendants was not 

registered with the Commission, as required by federal securities laws and 

regulations. 

B. MATERIAL MISREPRESENTATIONS AND OMISSIONS 

14. Bang and Lee made numerous misrepresentations to potential 

investors and clients on IV Wealth's website and through email solicitations. As 

of November 2010, IV Wealth's website falsely represented: (1) that IV Wealth 

ran an operational hedge fund; (2) that the hedge fund had a successful 

performance history since January 2007, with an average monthly return of8.29%; 

and (3) that the majority of IV Wealth's clients were professional athletes, actors, 

and producers. None of these statements were true. 

15. IV Wealth's website was taken down in November 2010. IV Wealth 

also operated under the name of Icon Capital, which on its website made 

misrepresentations that were similar to those on IV Wealth's website, including 

misrepresentations regarding Icon Capital's purported track record and the nature of 

its purported clients. The Icon Capital website was taken down in November 2010. 

16. Lee made similar misrepresentations in emails that he sent to potential 

investors and clients. In unsolicited emails to potential investors and clients in 

September2010, Lee represented that IV Wealth had over $800 million under 

management and that 98% of IV Wealth's clients were professional athletes, 

actors, producers, doctors, professors, politicians, and executives ofprivate 

corporations. None of these statements made by Lee were true. 

17. The Defendants repeated some of the misrepresentations in a 

document titled "Client Presentation" that Lee emailed to at least one potential 

investor on November 16,2010. The Client Presentation document falsely stated 

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that IV Wealth's hedge fund had enjoyed gross returns of 1,051 % since 2007, with 

an average monthly gross return of23%. It repeated the misrepresentation that IV 

Wealth had over $800 million under management, including a purported $550 

million in stocks, $150 million in real estate/developments, and $100 million in a 

reserve. The Client Presentation document again falsely described IV Wealth's 

clients as consisting of professional athletes, entertainment moguls, public 

officials, including senators and congressmen, and other professionals. It also 

represented that IV Wealth's purported investment strategy involved minimal risk 

and would generate a guaranteed annual return of 12%. The representations in the 

Client Presentation document were virtually identical to the representations that 

had been posted on the IV Wealth and Icon Capital's websites, and contained in 

Lee's emails to prospective investors, which were false. 

18. On November 23,2010, Lee sent a follow-up email to the same 

prospective investor to whom he had previously sent the Client Presentation 

document. In his November 23 email, Lee touted the "guaranteed" interest rate 

that IV Wealth would pay and represented that an investment in IV Wealth would 

be "as safe as you can get." Lee has continued to solicit this prospective investor 

as recently as January 11, 2011, and continues to try to set up meetings with him. 

FIRST CLAIM FOR RELIEF
 

UNREGISTERED OFFER AND SALE OF SECURITIES
 

Violations of Section 5(c) of the Securities Act
 

(Against All Defendants)
 

19. The Commission realleges and incorporates by reference paragraphs 1 

through 18 above. 

20. The defendants, and each of them, by'engaging in the conduct 

described above, directly or indirectly, made use of means or instruments of 

transportation or communication in interstate commerce or of the mails, to offer to 

sell securities. 

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21. No registration statement has been filed with the Commission with 

respect to the offering alleged herein. 

22. By engaging in the conduct described above, each of the defendants 

violated, and unless restrained and enjoined will continue to violate, Section 5(c) 

of the Securities Act, 15 U.S.C. § 77e(c). 

SECOND CLAIM FOR RELIEF
 

FRAUD IN THE OFFER OR SALE OF SECURITIES
 

Violations of Section 17(a) of the Securities Act
 

(Against All Defendants)
 

23. The Commission realleges and incorporates by reference paragraphs 1 

through 18 above. 

24. The defendants, and each of them, by engaging in the conduct 

described above, directly or indirectly, in the offer or sale of securities by the use 

of means or instruments of transportation or communication in interstate 

commerce or by use of the mails: 

a.	 with scienter, employed devices, schemes, or artifices to 

defraud; 

b.	 obtained money or property by means of untrue statements of a 

material fact or by omitting to state a material fact necessary in 

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

circumstances under whjch they were made, not misleading; or 

c.	 engaged in transactions, practices, or courses ofbusiness which 

operated or would operate as a fraud or deceit upon the 

purchaser. 

25. By engaging in the conduct described above, each of the defendants 

violated, and unless restrained and enjoined will continue to violate, Section 17(a) 

of the Securities Act, 15 U.S.C. § 77q(a). 

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THIRD CLAIM FOR RELIEF
 

FRAUD By AN INVESTMENT ADVISER
 

Violations of Sections 206(1) and 206(2) of the Advisers Act
 

(Against Defendant Bang)
 

26. The Commission realleges and incorporates by reference paragraphs 1 

through 18 above. 

27. Defendant Bang, by engaging in the conduct described above, while 

acting as an investment adviser, directly or indirectly, by use of the mails or means 

or instrumentalities of interstate commerce: 

,	 a. with scienter, employed devices, schemes, or artifices to 

defraud clients or prospective clients; or 

b.	 engaged in transactions, practices, or courses of business which 

operated as a fraud or deceit upon clients or prospective clients. 

28. By engaging in the conduct described above, defendant Bang violated, 

and unless restrained and enjoined will continue to violate, Sections 206(1) and 

206(2) of the Advisers Act, 15 U.S.C. §§ 80b-6(l) and 80b-6(2). 

FOURTH CLAIM FOR RELIEF
 

FRAUD INVOLVING A POOLED INVESTMENT VEIDCLE
 

Violations of Section 206(4) of the Advisers Act and Rule 206(4)-8 Thereunder
 

(Against Defendant Bang)
 

29. The Commission realleges and incorporates by reference paragraphs 1 

through 18 above. 

30. Defendant Bang, by engaging in the conduct described above, while 

acting as an investment adviser to a pooled investment vehicle, directly or 

indirectly, by use of the mails or means or instrumentalities of interstate commerce: 

a.	 made untrue statements of a material fact or omitted 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 

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misleading, to any investor or prospective investor in the 

pooled investment vehicle; or 

b.	 engaged in acts, practices, or courses of business that were 

fraudulent, deceptive, or manipulative with respect to any 

investor or prospective investor in the pooled investment 

vehicle. 

36. By engaging in the conduct described above, defendant Bang violated, 

and unless restrained and enjoined will continue to violate, Section 206(4) of the 

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

§ 275.206(4)-8. 

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that the Court: 

I. 

, Issue findings of fact and conclusions of law that the Defendants committed 

the alleged violations. 

II. 

Issue judgments, in forms consistent with Fed. R. Civ. P. 65(d), temporarily, 

preliminarily and permanently enjoining the Defendants and their officers, agents, 

servants, employees, and attorneys, and those persons in active concert or 

participation with any of them, who receive actual notice of the judgment by 

personal service or otherwise, and each of them, from violating Sections 5(c) and 

17(a) of the Securities Act, 15 U.S.C. §§ 77e(c) and 77q(a). 

III. 

Issue a judgment, in a form consistent with Fed. R. Civ. P. 65(d), 

temporarily, preliminarily and permanently enjoining Bang and his agents, 

servants, employees, and attorneys, and those persons in active concert or 

participation with any of them, who receive actual notice of the judgment by 

personal service or otherwise, and each of them, from violating Sections 206(1), 

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206(2), and 206(4) of the Advisers Act, 15 U.S.C. §§ 80b-6(1), 80b-6(2), and 

80b-6(4), and Rule 206(4)-8 thereunder, 17 C.F.R. § 275.206(4)-8. 

I~ 

Issue, in a form consistent with Fed. R. Civ. P. 65,a temporary restraining 

order and a preliminary injunction prohibiting each of the Defendants from 

destroying documents, granting expedited discovery, and requiring accountings 

from each of the Defendants. 

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Order each Defendant to disgorge all ill-gotten gains from their illegal 

conduct, together with prejudgment interest thereon. 

VI. 

Order each Defendant to pay civil penalties under 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). 

VII. 

Retain jurisdiction of this action in accordance with the principles of equity 

and the Federal Rules of Civil Procedure in order to implement and carry out the 

terms of all orders and decrees that may be entered, or to entertain any suitable 

application or motion for additional relief within the jurisdiction of this Court. 

VIII. 

Grant such other and further relief as this Court may determine to be just and 

necessary. 

DATED: January 19,2011 

Attorney for Plaintiff
Securities and Exchange Commission 

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