SEC v. Mario Gogliormella; Steven Lacaj; and Karim Ibrahim a/k/a Chris Hayes, No. LR-26021, Southern District of New York (June 12, 2024) — Press Release

U.S. SECURITIES AND EXCHANGE COMMISSION Litigation Release No. 26021 / June 12, 2024 Securities and Exchange Commission v. Mario Gogliormella, Steven Lacaj, and Karim Ibrahim a/k/a/ Chris Hayes, No. 24-cv-4348 (S.D.N.Y. filed June 7, 2024) SEC Charges Former StraightPath and Legend Boiler Room Operators with Defrauding Retail Investors Washington D.C., June 12, 2024 - On June 7, 2024, the Securities and Exchange Commission announced charges against New York residents Mario Gogliormella, Steven Lacaj, and Karim Ibrahim with fraud for selling unregistered membership interests in LLCs that purported to invest in shares of pre-IPO companies, first on behalf of StraightPath Venture Partners LLC, the subject of the Commission's emergency action in May 2022, and, later, on behalf of Legend Venture Partners LLC, the subject of the Commission's emergency action in June 2023. Both StraightPath and Legend are now under court-ordered receiverships. In this new action, the SEC's complaint alleges that between 2019 to 2022, Gogliormella, Lacaj, and Karim Ibrahim directed an unregistered sales force of more than 50 callers in boiler rooms to pressure investors into making investments without telling them that the shares had been substantially marked up-between approximately 19 and 105 percent on average above the prices that StraightPath or Legend had paid for the underlying shares. As a result of these tactics, the defendants and their sales force allegedly pocketed more than $45 million in fees from unsuspecting investors. The SEC's complaint, filed in federal court for the Southern District of New York, charges Gogliormella, Lacaj, and Karim Ibrahim with violating Sections 5(a), 5(c), and 17(a)(1) and (3) of the Securities Act of 1933 ("Securities Act"); Sections 15(a) and 10(b) of the Securities Exchange Act of 1934 ("Exchange Act") and Rule 10b-5(a) and (c) thereunder; and Sections 206(1), 206(2), 206(3), and 206(4) of the Investment Advisers Act of 1940 ("Advisers Act") and Rule 206(4)-8 thereunder; Lacaj and Karim Ibrahim with violating Section 17(a)(2) of the Securities Act and Section 10(b) of the Exchange Act and Rule 10b-5(b) thereunder; Gogliormella with control person liability under Exchange Act Section 20(a) for L&G Capital Corp.'s and Legend's violations of Section 10(b) of the Exchange Act and Rule 10b-5(b); and all defendants with aiding-and-abetting StraightPath's and Legend's violations of Sections 5(a), 5(c), and 17(a) of the Securities Act and of Sections 15(a) and 10(b) of the Exchange Act and Rule 10b-5 thereunder, and Legend's violations of Sections 206(1), 206(2), 206(3), and 206(4) of the Advisers Act and Rule 206(4)-8 thereunder, and seeks permanent injunctive relief, return of allegedly ill-gotten gains, and civil penalties. The SEC also charged Adam Ibrahim, Karim Ibrahim's brother, as a relief defendant. In a parallel action, the U.S. Attorney's Office for the Southern District of New York today unsealed an indictment charging Gogliormella, Lacaj, and Karim Ibrahim with securities fraud, among other offenses, in connection with their work for StraightPath and Legend. The SEC's ongoing investigation is being conducted by Joshua D. Tannen and Lee A. Greenwood of the Asset Management Unit and Sushila P. Rao, Suzanne M. Bettis, Megan Genet, Tiantong Wen, Douglas Smith, Kerri L. Palen, Patricia Schrage, Daniel Loss, Alistaire Bambach, and Steven G. Rawlings of the New York Regional Office. It is being supervised by Mr. Pollock. The litigation will be led by Ms. Rao, Mr. Tannen, and Ms. Bettis and supervised by Mr. Loss and Mr. Pollock. The SEC appreciates the assistance of the U.S. Attorney's Office for the Southern District of New York and the U.S. Postal Inspection Service. Investors can learn more about the risks of investing in pre-IPO offerings in this Investor Alert. SEC Complaint

U.S. SECURITIES AND EXCHANGE COMMISSION Litigation Release No. 26021 / June 12, 2024 Securities and Exchange Commission v. Mario Gogliormella, Steven Lacaj, and Karim Ibrahim a/k/a/ Chris Hayes, No. 24-cv-4348 (S.D.N.Y. filed June 7, 2024) SEC Charges Former StraightPath and Legend Boiler Room Operators with Defrauding Retail Investors Washington D.C., June 12, 2024 - On June 7, 2024, the Securities and Exchange Commission announced charges against New York residents Mario Gogliormella, Steven Lacaj, and Karim Ibrahim with fraud for selling unregistered membership interests in LLCs that purported to invest in shares of pre-IPO companies, first on behalf of StraightPath Venture Partners LLC, the subject of the Commission's emergency action in May 2022, and, later, on behalf of Legend Venture Partners LLC, the subject of the Commission's emergency action in June 2023. Both StraightPath and Legend are now under court-ordered receiverships. In this new action, the SEC's complaint alleges that between 2019 to 2022, Gogliormella, Lacaj, and Karim Ibrahim directed an unregistered sales force of more than 50 callers in boiler rooms to pressure investors into making investments without telling them that the shares had been substantially marked up-between approximately 19 and 105 percent on average above the prices that StraightPath or Legend had paid for the underlying shares. As a result of these tactics, the defendants and their sales force allegedly pocketed more than $45 million in fees from unsuspecting investors. The SEC's complaint, filed in federal court for the Southern District of New York, charges Gogliormella, Lacaj, and Karim Ibrahim with violating Sections 5(a), 5(c), and 17(a)(1) and (3) of the Securities Act of 1933 ("Securities Act"); Sections 15(a) and 10(b) of the Securities Exchange Act of 1934 ("Exchange Act") and Rule 10b-5(a) and (c) thereunder; and Sections 206(1), 206(2), 206(3), and 206(4) of the Investment Advisers Act of 1940 ("Advisers Act") and Rule 206(4)-8 thereunder; Lacaj and Karim Ibrahim with violating Section 17(a)(2) of the Securities Act and Section 10(b) of the Exchange Act and Rule 10b-5(b) thereunder; Gogliormella with control person liability under Exchange Act Section 20(a) for L&G Capital Corp.'s and Legend's violations of Section 10(b) of the Exchange Act and Rule 10b-5(b); and all defendants with aiding-and-abetting StraightPath's and Legend's violations of Sections 5(a), 5(c), and 17(a) of the Securities Act and of Sections 15(a) and 10(b) of the Exchange Act and Rule 10b-5 thereunder, and Legend's violations of Sections 206(1), 206(2), 206(3), and 206(4) of the Advisers Act and Rule 206(4)-8 thereunder, and seeks permanent injunctive relief, return of allegedly ill-gotten gains, and civil penalties. The SEC also charged Adam Ibrahim, Karim Ibrahim's brother, as a relief defendant. In a parallel action, the U.S. Attorney's Office for the Southern District of New York today unsealed an indictment charging Gogliormella, Lacaj, and Karim Ibrahim with securities fraud, among other offenses, in connection with their work for StraightPath and Legend. The SEC's ongoing investigation is being conducted by Joshua D. Tannen and Lee A. Greenwood of the Asset Management Unit and Sushila P. Rao, Suzanne M. Bettis, Megan Genet, Tiantong Wen, Douglas Smith, Kerri L. Palen, Patricia Schrage, Daniel Loss, Alistaire Bambach, and Steven G. Rawlings of the New York Regional Office. It is being supervised by Mr. Pollock. The litigation will be led by Ms. Rao, Mr. Tannen, and Ms. Bettis and supervised by Mr. Loss and Mr. Pollock. The SEC appreciates the assistance of the U.S. Attorney's Office for the Southern District of New York and the U.S. Postal Inspection Service. Investors can learn more about the risks of investing in pre-IPO offerings in this Investor Alert. SEC Complaint