SEC v. ERIC T. LANDIS; and RIDGEVIEW CAPITAL PARTNERS LLC, No. 1:18-cv-12453, District of Columbia (Dec. 6, 2022) — Complaint

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

SECURITIES AND EXCHANGE
COMMISSION,

                         Plaintiff,
 v.
ERIC T. LANDIS and
RIDGEVIEW CAPITAL PARTNERS LLC,
                         Defendants.
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Civil Action No.

JURY TRIAL DEMANDED

COMPLAINT
Plaintiff Securities and Exchange Commission (the “Commission”) alleges the following
against Defendants Eric Landis (“Landis”) and Ridgeview Capital Partners LLC (“Ridgeview”).
SUMMARY
1. This is a securities fraud enforcement action against Landis and an entity that he
controlled, Ridgeview. Beginning in at least January 2015 and continuing through at least
January 2018 (the “Relevant Period”), Landis, operating through Ridgeview, engaged in a
scheme to manipulate the stock of at least 97 publicly traded companies. Landis sought to induce
others to trade in the securities of companies whose stock he manipulated by creating the mirage
that those companies’ securities were in high demand.
2. Landis purported to be a stock promoter who was paid by others to generate
interest in the stock of various small companies, whose securities are commonly referred to as
microcap securities or microcap stock. Landis represented to the parties who paid him for stock
promotion activities that he would send emails to prospective investors through email lists
purportedly comprised of tens of thousands subscribers. In reality, Landis did not send

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promotional emails to nearly the number of subscribers he claimed, and in some instances he did
not send any emails at all.
3. Instead, Landis arranged to place thousands of manipulative trades in the stock of
the companies he was paid to promote. In furtherance of the scheme, Landis used multiple
brokerage accounts, some in the name of Ridgeview and others in the names of another person
and entity who had given him access to their accounts. Landis intended to create the false
appearance of active trading in the securities, and he infused the securities markets with false
information concerning the actual supply and demand of these publicly traded microcap
securities.
4. As a result of the conduct alleged herein, the Defendants violated, and unless
restrained and enjoined will continue to violate, Section 17(a) of the Securities Act of 1933
(“Securities Act”), and Sections 9(a) and 10(b) of the Securities Exchange Act of 1934
(“Exchange Act”) and Rule 10b-5 thereunder.
5. The Commission seeks a permanent injunction enjoining the Defendants from
engaging in the transactions, acts, practices, and courses of business alleged in this Complaint,
disgorgement of all ill-gotten gains from the unlawful conduct together with prejudgment
interest, civil penalties, an order prohibiting Defendants from participating in any offering of a
penny stock, and such other relief as the Court may deem appropriate.
JURISDICTION AND VENUE
6. This Court has jurisdiction over this action pursuant to Section 22(a) of the
Securities Act [15 U.S.C. § 77v(a)] and Sections 21(d), 21(e), and 27 of the Exchange Act
[15 U.S.C. §§ 78u(d), 78u(e), and 78aa].
7. Venue lies in this Court pursuant to Section 22(a) of the Securities Act [15 U.S.C.
§ 77v(a)] and Section 27 of the Exchange Act [15 U.S.C. § 78aa]. Certain of the acts, practices,

3
transactions and courses of business alleged in this Complaint occurred within the District of
Massachusetts, and were effected, directly or indirectly, by making use of means or
instrumentalities of transportation or communication in interstate commerce, or the mails.
Among other things, various of the stocks affected by Landis’s manipulative trading were
offered and sold to investors located in Massachusetts.
DEFENDANTS
8. Eric T. Landis, age 53, is a resident of Charlottesville, Virginia. In 2004, Landis
settled a prior enforcement action brought by the Commission for his role in a market
manipulation scheme, and he pleaded guilty in a related criminal case to a felony count for
obstructing justice. SEC v. 2DoTrade Inc., No. 3:03cv02246 (N.D. Tx. Jan. 23, 2004); United
States v. Landis, No. 1:04cr00098 (D.D.C. Oct. 3, 2006).
9. Ridgeview Capital Partners LLC was incorporated in Virginia by Landis in 2003.
During the Relevant Period, Landis was the sole owner of Ridgeview.
FACTS
A. General Description of Landis’s Fraudulent Scheme
10. Individuals or entities sometimes hire and pay stock promoters to generate interest
in particular publicly traded companies’ securities, including securities of small, often relatively
infrequently traded, companies (i.e., “microcap” companies). During the Relevant Period, Landis
was self-employed as a stock promoter and claimed to be in the business of disseminating
information about public companies through email distributions to lists of subscribers.
11. To facilitate his image as a stock promoter, Landis established, paid for, and
controlled email distribution lists designed to tout the stock of publicly traded companies,
including The Street Alert, The Penny Reporter, and The Stock Beacon.

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12. Landis’s lists were a sham. Instead of promoting stocks through mass emails,
Landis arranged to buy and sell the stock of a number of companies he had agreed to promote.
He created the false appearance of increased supply and demand, which in turn induced
additional trading activity by other investors.
13. Landis used multiple brokerage accounts to conduct his manipulative trading.
These included: a brokerage account held in his name (the “Landis Accounts”), accounts in
Ridgeview’s name at three different brokerage firms (the “Ridgeview Accounts”), accounts in
the name of one of Landis’s relatives at two other brokerage firms (the “Relative Accounts”),
and accounts in the name of an entity controlled by a business associate (the “Business Associate
Accounts”). Landis had electronic access to each of these accounts and could place orders to buy
and sell securities in those accounts through the internet.
14. During the Relevant Period, Landis used the Landis, Ridgeview, Relative, and
Business Associate Accounts to place manipulative trades in the publicly traded stock of at least
97 companies, engineering thousands of coordinated trades between the accounts to create the
false impression that market participants were engaging in arms-lengths transactions. Landis
frequently entered orders using various combinations of the accounts to both buy and sell the
same security, with opposite orders submitted at substantially the same time, size, and price. This
resulted in approximately 1,300 instances in which an account Landis controlled was on both the
buy and sell side of a trade in a particular security. Landis coordinated these matched orders for
no legitimate economic reason. Instead, he intended to mislead investors about the extent of the
trading activity in the market for a given stock.
15. Landis received about $3.3 million during the Relevant Period to promote various
microcap companies, which he created the appearance of doing by placing thousands of
manipulative trades. This Complaint details three examples of Landis’s fraudulent scheme.

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B. Examples of Landis’s Fraudulent Scheme
1. 2015: Interactive Multi-Media Auction Corp.
16. Between approximately March 1, 2015, and April 23, 2015, Landis contracted to
promote the stock of a microcap company called Interactive Multi-Media Auction Corp.
(“Interactive”). Landis received $10,000 per day from a third party to disseminate marketing
emails about Interactive on April 27 and 28, 2015, and May 4, 2015 on The Street Alert. He
received an additional $5,000 to disseminate marketing emails about Interactive on April 29,
2015 on The Penny Reporter.
17. Landis falsely represented to his client that he sent about 37,000 and 27,000
emails on April 28 and 29, respectively. In fact, The Street Alert never had more than 3,000
subscribers, and The Penny Reporter may have had less than 100. On each of the days that
Landis had told his client he would disseminate promotional emails, Landis engaged in
manipulative trading of Interactive’s stock. This trading was designed to create the false
appearance of active market interest in Interactive.
18. For example, on April 28 and 29, 2015, Landis used the Ridgeview and Relative
Accounts to coordinate sham trading. On each of these days, Landis accessed multiple
Ridgeview and Relative Accounts within minutes of each other, each time using the same
Internet Protocol (or “IP”) address, 71.62.20.199, which is associated with his home in
Charlottesville, Virginia.
1
 Landis then entered the following orders, among others, to both buy
and sell the securities of Interactive:

1
     An IP address is a numerical label assigned, frequently by an Internet Service Provider, to
each device or location that is connected to the internet.

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LANDIS INTERACTIVE MATCH TRADES - APRIL 28, 2015
Executed Trades Buy-Side Order Sell-Side Order
Time Qty Price Broker Account Time Qty Broker Account Time Qty
9:39:36 1,600 $1.55 Broker1 Relative 9:39:24 3,000 Broker4 Ridgeview 9:39:27 1,600
9:46:54 1,400 $1.55 Broker1 Relative 9:39:24 3,000 Broker2 Ridgeview 9:46:41 3,050
9:48:29 1,150 $1.55 Broker1 Relative 9:46:38 2,600 Broker2 Ridgeview 9:46:41 3,050
10:29:05 450 $1.59 Broker1 Relative 9:46:38 2,600 Broker4 Ridgeview 10:28:58 1,100
11:24:40 1,000 $1.55 Broker2 Ridgeview 11:24:36 1,000 Broker1 Relative 11:15:36 2,000

LANDIS INTERACTIVE MATCH TRADES - APRIL 29, 2015
Executed Trades Buy-Side Order Sell-Side Order
Time Qty Price Broker Account Time Qty Broker Account Time Qty
9:30:37 600 $1.61 Broker1 Relative 9:19:48 600 Broker2 Ridgeview 9:20:22 2,500
9:30:58 900 $1.58 Broker1 Relative 9:18:10 2,000 Broker2 Ridgeview 9:20:22 2,500
9:30:58 900 $1.58 Broker1 Relative 9:18:41 900 Broker2 Ridgeview 9:20:22 2,500
Landis coordinated the above trades, as well as other trades on these and other days in April and
May 2015, for the purpose of creating the false or misleading appearance of increased volume in
the trading of the securities of Interactive.
19. Landis’s overall trading comprised a significant percentage of the total trading
volume in the securities of Interactive on April 28 and 29, 2015:
Date Landis Market Percent
04-28-2015 26,650 53,875 49%
04-29-2015 13,210 31,720 42%
20. Prior to April 2015, none of the Landis, Ridgeview, or Relative Accounts had
bought or sold Interactive in at least 2015 and possibly longer.
2. 2016: Agora Holdings Inc.
21.   On a number of occasions in 2016, Landis contracted to promote the securities
of Agora Holdings Inc. (“Agora”) and, through Ridgeview, received over $200,000 to do so. In
exchange, Landis agreed to disseminate emails touting Agora to thousands of subscribers on his
email distribution lists. Again, Landis created the appearance of increased market interest in
Agora by trading in its securities himself.

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22. For example, on September 15, 26, and 28, 2016, Landis was paid by a third party
to send emails promoting Agora on two of his email lists, each of which, Landis claimed, had
approximately 72,000 subscribers. On those days, Landis engaged in manipulative trading
designed to create the false appearance of supply and demand in the securities of Agora, and for
the purpose of inducing others to invest.
23. On each of September 15, 26, and 28, Landis accessed Ridgeview and Relative
Accounts within minutes of each other through the same IP address, 73.251.124.231, which is
associated with Landis’s home in Charlottesville, Virginia. Landis then entered the following
orders, among others, to both buy and sell the securities of Agora:
LANDIS AGORA MATCHED TRADES - SEPTEMBER 15, 2016
Executed Trades Buy-Side Order Sell-Side Order
Time Qty Price Broker Account Time Qty Broker Account Time Qty
9:30:31 5,000 $0.19 Broker3 Relative 9:30:31 5,000 Broker1 Relative 9:28:52 70,000
9:30:31 5,000 $0.19 Broker3 Relative 9:30:31 5,000 Broker1 Relative 9:28:52 70,000
9:30:31 5,000 $0.19 Broker3 Relative 9:30:31 5,000 Broker1 Relative 9:28:52 70,000
9:30:31 5,000 $0.19 Broker3 Relative 9:30:31 5,000 Broker1 Relative 9:28:52 70,000
9:31:26 3,900 $0.18 Broker3 Relative 9:31:26 3,900 Broker1 Relative 9:28:52 70,000
9:44:21 5,000 $0.17 Broker2 Ridgeview 9:38:48 5,000 Broker3 Relative 9:44:11 29,550
9:44:21 5,750 $0.17 Broker2 Ridgeview 9:44:00 20,000 Broker3 Relative 9:44:11 29,550
9:44:46 14,250 $0.17 Broker2 Ridgeview 9:44:00 20,000 Broker3 Relative 9:44:46 19,250
12:53:16 5,000 $0.18 Broker2 Ridgeview 12:51:51 5,000 Broker3 Relative 12:53:16 36,000
12:53:27 5,000 $0.18 Broker2 Ridgeview 12:52:42 20,000 Broker3 Relative 12:53:16 36,000
LANDIS AGORA MATCHED TRADES - SEPTEMBER 26, 2016
Executed Trades Buy-Side Order Sell-Side Order
Time Qty Price Broker Account Time Qty Broker Account Time Qty
9:53:24 6,500 $0.17 Broker3 Relative 9:53:24 6,500 Broker2 Ridgeview 9:53:08 25,350
9:55:34 100 $0.17 Broker3 Relative 9:54:42 5,000 Broker2 Ridgeview 9:55:15 20,000
9:55:49 5,000 $0.17 Broker3 Relative 9:55:49 5,000 Broker2 Ridgeview 9:55:15 20,000
9:59:41 5,000 $0.17 Broker2 Ridgeview 9:59:15 11,000 Broker3 Relative 9:59:41 5,000
9:59:41 5,000 $0.17 Broker2 Ridgeview 9:59:15 11,000 Broker3 Relative 9:59:41 5,000
10:03:21 5,000 $0.17 Broker2 Ridgeview 10:02:56 12,500 Broker3 Relative 10:03:21 5,000
10:03:22 5,000 $0.17 Broker2 Ridgeview 10:02:56 12,500 Broker3 Relative 10:03:22 5,000
10:18:45 5,000 $0.17 Broker2 Ridgeview 10:18:19 9,500 Broker3 Relative 10:18:45 5,000
LANDIS AGORA MATCHED TRADES - SEPTEMBER 28, 2016
Executed Trades Buy-Side Order Sell-Side Order
Time Qty Price Broker Account Time Qty Broker Account Time Qty
9:37:48 10,000 $0.18 Broker2 Ridgeview 9:37:45 10,000 Broker3 Relative 9:37:18 44,400
9:38:18 5,600 $0.18 Broker2 Ridgeview 9:33:55 5,600 Broker3 Relative 9:37:18 44,400
9:38:20 5,000 $0.18 Broker2 Ridgeview 9:38:19 5,000 Broker3 Relative 9:37:18 44,400
9:39:31 13,800 $0.18 Broker2 Ridgeview 9:39:26 20,000 Broker3 Relative 9:37:18 44,400
9:50:42 5,000 $0.18 Broker2 Ridgeview 9:39:26 20,000 Broker3 Relative 9:50:31 10,000
9:56:13 5,000 $0.18 Broker1 Relative 9:53:10 5,000 Broker3 Relative 9:56:13 25,000
10:15:33 10,000 $0.17 Broker3 Relative 10:15:33 10,000 Broker1 Relative 10:15:29 65,900
11:22:28 5,000 $0.17 Broker1 Relative 11:18:26 5,000 Broker3 Relative 11:22:07 75,000
11:22:49 18,000 $0.17 Broker2 Ridgeview 11:21:53 18,000 Broker3 Relative 11:22:07 75,000

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Landis coordinated these and other trades for the purpose of creating the false or misleading
appearance of increased volume in the trading of the securities of Agora.
24. Landis’s trading comprised a significant percentage of the total trading volume in
the securities of Agora on September 15, 26, and 28, 2016:
Date Landis Market Percent
09-15-2016      556,700    2,159,395  26%
09-26-2016      612,600    1,482,216  41%
09-28-2016   1,063,200    1,994,020  53%
3. 2017: Environmental Packaging Technologies Holdings Inc.
25. Landis continued to engage in manipulative trading in 2017. For example, in June
2017, Landis agreed to promote the securities of Environmental Packaging Technologies
Holdings Inc. (“Environmental Packaging”), and, through Ridgeview, received $20,000 to
disseminate emails on June 12 and June 13, 2017, touting the stock of Environmental Packaging.
26. Landis falsely represented to his client at this time that The Street Alert and The
Stock Beacon had approximately 72,000 subscribers each. In fact, The Street Alert never had
more than 3,000 subscribers, and The Stock Beacon never had more than 600 subscribers. To
create the appearance of increased investor interest in Environmental Packaging, Landis instead
traded in Packaging himself.
27. For example, on June 13, Landis accessed Ridgeview and Relative Accounts
within minutes of each other through the same home IP address he used when trading in Agora.
28.  After accessing the accounts from the same location each day, Landis entered the
following orders, among others, to both buy and sell the securities of Environmental Packaging:

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LANDIS ENVIRONMENTAL PACKAGING MATCHED TRADES - JUNE 13, 2017
Executed Trades Buy-Side Order Sell-Side Order
Time Qty Price Broker Account Time Qty Broker Account Time Qty
9:40:42 100 $1.27 Broker3 Relative 9:40:40 5,000 Broker2 Ridgeview 9:40:41 10,000
9:43:33 1,000 $1.27 Broker3 Relative 9:43:33 1,000 Broker2 Ridgeview 9:40:41 10,000
10:03:18 900 $1.27 Broker3 Relative 10:01:32 1,000 Broker2 Ridgeview 10:03:17 1,891
10:07:58 391 $1.27 Broker3 Relative 10:07:58 600 Broker2 Ridgeview 10:03:17 1,891
10:15:10 209 $1.27 Broker3 Relative 10:07:58 600 Broker2 Ridgeview 10:14:50 2,000
10:58:01 1,000 $1.20 Broker3 Relative 10:58:01 1,000 Broker2 Ridgeview 10:46:14 14,791
10:58:04 1,000 $1.20 Broker3 Relative 10:58:04 1,000 Broker2 Ridgeview 10:46:14 14,791
Landis coordinated these and other trades for the purpose of creating the false or misleading
appearance of increased volume in the trading of the securities of Environmental Packaging.
29. Landis’s trading comprised a significant percentage of the total trading volume in
the securities of Environmental Packaging on June 12 and 13, 2017:
Date Landis Market Percent
06-12-2017        93,600       424,956  22%
06-13-2017        87,600       226,263  39%
30. Other than June 12 and June 13, 2017, the specific days Landis was paid to
promote the stock, neither Landis, nor any of the Ridgeview, Relative, or Business Associate
Accounts, ever traded in Environmental Packaging stock.
* * *
31. As a result of the conduct described herein, Landis engaged in a scheme to
defraud investors in at least 97 publicly traded companies through fraudulent trading and market
manipulation. Landis’s conduct created apparent trading activity in the stock of those companies
for the purpose of inducing the purchase and sale of the stock of those companies by others.
32. Landis, through Ridgeview, obtained more than $3.3 million during the Relevant
Period for his purported stock promotion services.

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FIRST CLAIM FOR RELIEF
FRAUD IN THE OFFER OR SALE OF SECURITIES
(Violations of Section 17(a)(1) and (3) of the Securities Act)

33. The Commission repeats and incorporates by reference the allegations in
paragraphs 1-32 above.
34. By reason of the conduct described above, the Defendants, in the offer or sale of
securities, by the use of the means or instrumentalities of interstate commerce or of the mails,
directly or indirectly, acting with the requisite degree of knowledge or state of mind (i) employed
devices, schemes, or artifices to defraud; and (ii) engaged in transactions, practices, or courses of
business which operated or would operate as a fraud or deceit upon any persons, including
purchasers or sellers of the securities.
35. By reason of the conduct described above, the Defendants each violated Securities
Act Section 17(a)(1) and (3) [15 U.S.C. § 77q(a)(1) and (3)].
SECOND CLAIM FOR RELIEF
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES
(Violations of Section 10(b) of the Exchange Act and Rules 10b-5(a) and (c) thereunder)

36. The Commission repeats and incorporates by reference the allegations in
paragraphs 1-32 above.
37. By reason of the conduct described above, the Defendants, directly or indirectly,
in connection with the purchase or sale of securities, by the use of the means or instrumentalities
of interstate commerce or of the mails, or of any facility of any national securities exchange,
intentionally, knowingly or recklessly, (i) employed devices, schemes, or artifices to defraud;
and (ii) engaged in acts, practices, or courses of business which operated or would operate as a
fraud or deceit upon any persons, including purchasers or sellers of the securities.

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38. By reason of the conduct described above, the Defendants violated Exchange Act
Section 10(b) [15 U.S.C. § 78j(b)] and Rules 10b-5(a) and (c) [17 C.F.R. § 240.10b-5(a) and (c)]
thereunder.
THIRD CLAIM FOR RELIEF
MARKET MANIPULATION
(Violations of Section 9(a)(1)-(2) of the Exchange Act)

39. The Commission repeats and incorporates by reference the allegations in
paragraphs 1-32 above.
40. Sections 9(a)(1) and (2) of the Exchange Act [15 U.S.C. §78i(a)(1)-(2)] make it
unlawful for any person, directly or indirectly, by the use of the mails or any means or
instrumentality of interstate commerce, or of any facility of any national securities exchange,
(1) to effect any transaction in a security which involves no change in the beneficial ownership
of the security and to enter substantially similar orders for the purchase and sale of any security
for the purpose of creating a false or misleading appearance of active trading in the security; or
(2) to effect a series of transactions in a security creating actual or apparent active trading in such
security, or raising or depressing the price of such security, for the purpose of inducing the
purchase or sale of such security by others.
41. By engaging in the conduct described above, the Defendants violated Section
9(a)(1) and (2) of the Exchange Act [15 U.S.C. § 78i(a)(1) and (2)].
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that this Court:
A. Enter a permanent injunction restraining the Defendants and each of their officers,
agents, servants, employees, attorneys, and those persons in active concert or participation with
them who receive actual notice of the injunction by personal service or otherwise, including

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email, fax, or overnight delivery service, from directly or indirectly engaging in the conduct
described above, or in conduct of similar purport and effect, in violation of:
1. Section 9(a) of the Exchange Act [15 U.S.C. 78i(a)];
2. 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]; and
3. Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)].
B. Order the Defendants to disgorge their ill-gotten gains, plus prejudgment interest;
C.        Order        the        Defendants        to        pay        appropriate civil monetary penalties in accordance
with Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the
Exchange Act [15 U.S.C. § 78u(d)(3)];
D. Order the Defendants be unconditionally and permanently prohibited from
participating in any offering of a penny stock, as authorized by Section 20(g) of the Securities
Act [15 U.S.C. § 77t(g)] and Section 21d(6)(B) of the Exchange Act [15 U.S.C. § 78u(d)(6)(B)];
E. Retain jurisdiction over this action to implement and carry out the terms of all
orders and decrees that may be entered; and
F. Grant such other and further relief as this Court may deem just and proper.

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JURY DEMAND
The Commission demands a jury in this matter for all claims so triable.
Respectfully submitted,

SECURITIES AND EXCHANGE COMMISSION

By its attorneys,

/s/ Eric A. Forni
Eric A. Forni (Mass. Bar No. 669685)
Kathleen B. Shields (Mass Bar No. 637438)
Jonathan Allen (Mass Bar No. 680729)
J. Lauchlan Wash (Mass Bar No. 629092)
Rebecca Israel
David M. Scheffler (Mass Bar No.670324)
Amy Gwiazda (Mass Bar No.663494)
Boston Regional Office
33 Arch Street, 24th Floor
Boston, MA  02110
Phone:   (617) 573-4563 (Allen direct)
Fax:  (617) 573-4590
Dated:  November 28, 2018 [email protected]

UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 

 
 
SECURITIES AND EXCHANGE 
COMMISSION, 

   Plaintiff, 

 v. 

ERIC T. LANDIS and  
RIDGEVIEW CAPITAL PARTNERS LLC, 

   Defendants. 

) 
) 
) 
) 
) 
) 
) 
) 
) 
) 
) 

 
 

 
 
 
Civil Action No.  
 
JURY TRIAL DEMANDED 

 
 
 

 

COMPLAINT 
Plaintiff Securities and Exchange Commission (the “Commission”) alleges the following 

against Defendants Eric Landis (“Landis”) and Ridgeview Capital Partners LLC (“Ridgeview”). 

SUMMARY 
1. This is a securities fraud enforcement action against Landis and an entity that he 

controlled, Ridgeview. Beginning in at least January 2015 and continuing through at least 

January 2018 (the “Relevant Period”), Landis, operating through Ridgeview, engaged in a 

scheme to manipulate the stock of at least 97 publicly traded companies. Landis sought to induce 

others to trade in the securities of companies whose stock he manipulated by creating the mirage 

that those companies’ securities were in high demand.  

2. Landis purported to be a stock promoter who was paid by others to generate 

interest in the stock of various small companies, whose securities are commonly referred to as 

microcap securities or microcap stock. Landis represented to the parties who paid him for stock 

promotion activities that he would send emails to prospective investors through email lists 

purportedly comprised of tens of thousands subscribers. In reality, Landis did not send 

Case 1:18-cv-12453-IT   Document 1   Filed 11/28/18   Page 1 of 13



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promotional emails to nearly the number of subscribers he claimed, and in some instances he did 

not send any emails at all.  

3. Instead, Landis arranged to place thousands of manipulative trades in the stock of 

the companies he was paid to promote. In furtherance of the scheme, Landis used multiple 

brokerage accounts, some in the name of Ridgeview and others in the names of another person 

and entity who had given him access to their accounts. Landis intended to create the false 

appearance of active trading in the securities, and he infused the securities markets with false 

information concerning the actual supply and demand of these publicly traded microcap 

securities.  

4. As a result of the conduct alleged herein, the Defendants violated, and unless 

restrained and enjoined will continue to violate, Section 17(a) of the Securities Act of 1933 

(“Securities Act”), and Sections 9(a) and 10(b) of the Securities Exchange Act of 1934 

(“Exchange Act”) and Rule 10b-5 thereunder.  

5. The Commission seeks a permanent injunction enjoining the Defendants from 

engaging in the transactions, acts, practices, and courses of business alleged in this Complaint, 

disgorgement of all ill-gotten gains from the unlawful conduct together with prejudgment 

interest, civil penalties, an order prohibiting Defendants from participating in any offering of a 

penny stock, and such other relief as the Court may deem appropriate. 

JURISDICTION AND VENUE 
6. This Court has jurisdiction over this action pursuant to Section 22(a) of the 

Securities Act [15 U.S.C. § 77v(a)] and Sections 21(d), 21(e), and 27 of the Exchange Act 

[15 U.S.C. §§ 78u(d), 78u(e), and 78aa]. 

7. Venue lies in this Court pursuant to Section 22(a) of the Securities Act [15 U.S.C. 

§ 77v(a)] and Section 27 of the Exchange Act [15 U.S.C. § 78aa]. Certain of the acts, practices, 

Case 1:18-cv-12453-IT   Document 1   Filed 11/28/18   Page 2 of 13



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transactions and courses of business alleged in this Complaint occurred within the District of 

Massachusetts, and were effected, directly or indirectly, by making use of means or 

instrumentalities of transportation or communication in interstate commerce, or the mails. 

Among other things, various of the stocks affected by Landis’s manipulative trading were 

offered and sold to investors located in Massachusetts.  

DEFENDANTS 
8. Eric T. Landis, age 53, is a resident of Charlottesville, Virginia. In 2004, Landis 

settled a prior enforcement action brought by the Commission for his role in a market 

manipulation scheme, and he pleaded guilty in a related criminal case to a felony count for 

obstructing justice. SEC v. 2DoTrade Inc., No. 3:03cv02246 (N.D. Tx. Jan. 23, 2004); United 

States v. Landis, No. 1:04cr00098 (D.D.C. Oct. 3, 2006). 

9. Ridgeview Capital Partners LLC was incorporated in Virginia by Landis in 2003. 

During the Relevant Period, Landis was the sole owner of Ridgeview. 

FACTS 

A. General Description of Landis’s Fraudulent Scheme 

10. Individuals or entities sometimes hire and pay stock promoters to generate interest 

in particular publicly traded companies’ securities, including securities of small, often relatively 

infrequently traded, companies (i.e., “microcap” companies). During the Relevant Period, Landis 

was self-employed as a stock promoter and claimed to be in the business of disseminating 

information about public companies through email distributions to lists of subscribers.  

11. To facilitate his image as a stock promoter, Landis established, paid for, and 

controlled email distribution lists designed to tout the stock of publicly traded companies, 

including The Street Alert, The Penny Reporter, and The Stock Beacon.  

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12. Landis’s lists were a sham. Instead of promoting stocks through mass emails, 

Landis arranged to buy and sell the stock of a number of companies he had agreed to promote. 

He created the false appearance of increased supply and demand, which in turn induced 

additional trading activity by other investors.  

13. Landis used multiple brokerage accounts to conduct his manipulative trading. 

These included: a brokerage account held in his name (the “Landis Accounts”), accounts in 

Ridgeview’s name at three different brokerage firms (the “Ridgeview Accounts”), accounts in 

the name of one of Landis’s relatives at two other brokerage firms (the “Relative Accounts”), 

and accounts in the name of an entity controlled by a business associate (the “Business Associate 

Accounts”). Landis had electronic access to each of these accounts and could place orders to buy 

and sell securities in those accounts through the internet. 

14. During the Relevant Period, Landis used the Landis, Ridgeview, Relative, and 

Business Associate Accounts to place manipulative trades in the publicly traded stock of at least 

97 companies, engineering thousands of coordinated trades between the accounts to create the 

false impression that market participants were engaging in arms-lengths transactions. Landis 

frequently entered orders using various combinations of the accounts to both buy and sell the 

same security, with opposite orders submitted at substantially the same time, size, and price. This 

resulted in approximately 1,300 instances in which an account Landis controlled was on both the 

buy and sell side of a trade in a particular security. Landis coordinated these matched orders for 

no legitimate economic reason. Instead, he intended to mislead investors about the extent of the 

trading activity in the market for a given stock. 

15. Landis received about $3.3 million during the Relevant Period to promote various 

microcap companies, which he created the appearance of doing by placing thousands of 

manipulative trades. This Complaint details three examples of Landis’s fraudulent scheme. 

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B. Examples of Landis’s Fraudulent Scheme 

1. 2015: Interactive Multi-Media Auction Corp. 

16. Between approximately March 1, 2015, and April 23, 2015, Landis contracted to 

promote the stock of a microcap company called Interactive Multi-Media Auction Corp. 

(“Interactive”). Landis received $10,000 per day from a third party to disseminate marketing 

emails about Interactive on April 27 and 28, 2015, and May 4, 2015 on The Street Alert. He 

received an additional $5,000 to disseminate marketing emails about Interactive on April 29, 

2015 on The Penny Reporter.  

17. Landis falsely represented to his client that he sent about 37,000 and 27,000 

emails on April 28 and 29, respectively. In fact, The Street Alert never had more than 3,000 

subscribers, and The Penny Reporter may have had less than 100. On each of the days that 

Landis had told his client he would disseminate promotional emails, Landis engaged in 

manipulative trading of Interactive’s stock. This trading was designed to create the false 

appearance of active market interest in Interactive.  

18. For example, on April 28 and 29, 2015, Landis used the Ridgeview and Relative 

Accounts to coordinate sham trading. On each of these days, Landis accessed multiple 

Ridgeview and Relative Accounts within minutes of each other, each time using the same 

Internet Protocol (or “IP”) address, 71.62.20.199, which is associated with his home in 

Charlottesville, Virginia.1 Landis then entered the following orders, among others, to both buy 

and sell the securities of Interactive:  

 

 

                                                 
1  An IP address is a numerical label assigned, frequently by an Internet Service Provider, to 

each device or location that is connected to the internet.  

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LANDIS INTERACTIVE MATCH TRADES - APRIL 28, 2015 
Executed Trades Buy-Side Order Sell-Side Order 

Time Qty Price Broker Account Time Qty Broker Account Time Qty 
9:39:36 1,600 $1.55 Broker1 Relative 9:39:24 3,000 Broker4 Ridgeview 9:39:27 1,600 
9:46:54 1,400 $1.55 Broker1 Relative 9:39:24 3,000 Broker2 Ridgeview 9:46:41 3,050 
9:48:29 1,150 $1.55 Broker1 Relative 9:46:38 2,600 Broker2 Ridgeview 9:46:41 3,050 

10:29:05 450 $1.59 Broker1 Relative 9:46:38 2,600 Broker4 Ridgeview 10:28:58 1,100 
11:24:40 1,000 $1.55 Broker2 Ridgeview 11:24:36 1,000 Broker1 Relative 11:15:36 2,000 

 
LANDIS INTERACTIVE MATCH TRADES - APRIL 29, 2015 

Executed Trades Buy-Side Order Sell-Side Order 
Time Qty Price Broker Account Time Qty Broker Account Time Qty 

9:30:37 600 $1.61 Broker1 Relative 9:19:48 600 Broker2 Ridgeview 9:20:22 2,500 
9:30:58 900 $1.58 Broker1 Relative 9:18:10 2,000 Broker2 Ridgeview 9:20:22 2,500 
9:30:58 900 $1.58 Broker1 Relative 9:18:41 900 Broker2 Ridgeview 9:20:22 2,500 

Landis coordinated the above trades, as well as other trades on these and other days in April and 

May 2015, for the purpose of creating the false or misleading appearance of increased volume in 

the trading of the securities of Interactive. 

19. Landis’s overall trading comprised a significant percentage of the total trading 

volume in the securities of Interactive on April 28 and 29, 2015:  

Date Landis Market Percent 
04-28-2015 26,650 53,875 49% 
04-29-2015 13,210 31,720 42% 

20. Prior to April 2015, none of the Landis, Ridgeview, or Relative Accounts had 

bought or sold Interactive in at least 2015 and possibly longer.  

2. 2016: Agora Holdings Inc. 

21.   On a number of occasions in 2016, Landis contracted to promote the securities 

of Agora Holdings Inc. (“Agora”) and, through Ridgeview, received over $200,000 to do so. In 

exchange, Landis agreed to disseminate emails touting Agora to thousands of subscribers on his 

email distribution lists. Again, Landis created the appearance of increased market interest in 

Agora by trading in its securities himself. 

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22. For example, on September 15, 26, and 28, 2016, Landis was paid by a third party 

to send emails promoting Agora on two of his email lists, each of which, Landis claimed, had 

approximately 72,000 subscribers. On those days, Landis engaged in manipulative trading 

designed to create the false appearance of supply and demand in the securities of Agora, and for 

the purpose of inducing others to invest. 

23. On each of September 15, 26, and 28, Landis accessed Ridgeview and Relative 

Accounts within minutes of each other through the same IP address, 73.251.124.231, which is 

associated with Landis’s home in Charlottesville, Virginia. Landis then entered the following 

orders, among others, to both buy and sell the securities of Agora: 

LANDIS AGORA MATCHED TRADES - SEPTEMBER 15, 2016 
Executed Trades Buy-Side Order Sell-Side Order 

Time Qty Price Broker Account Time Qty Broker Account Time Qty 
9:30:31 5,000 $0.19 Broker3 Relative 9:30:31 5,000 Broker1 Relative 9:28:52 70,000 
9:30:31 5,000 $0.19 Broker3 Relative 9:30:31 5,000 Broker1 Relative 9:28:52 70,000 
9:30:31 5,000 $0.19 Broker3 Relative 9:30:31 5,000 Broker1 Relative 9:28:52 70,000 
9:30:31 5,000 $0.19 Broker3 Relative 9:30:31 5,000 Broker1 Relative 9:28:52 70,000 
9:31:26 3,900 $0.18 Broker3 Relative 9:31:26 3,900 Broker1 Relative 9:28:52 70,000 
9:44:21 5,000 $0.17 Broker2 Ridgeview 9:38:48 5,000 Broker3 Relative 9:44:11 29,550 
9:44:21 5,750 $0.17 Broker2 Ridgeview 9:44:00 20,000 Broker3 Relative 9:44:11 29,550 
9:44:46 14,250 $0.17 Broker2 Ridgeview 9:44:00 20,000 Broker3 Relative 9:44:46 19,250 

12:53:16 5,000 $0.18 Broker2 Ridgeview 12:51:51 5,000 Broker3 Relative 12:53:16 36,000 
12:53:27 5,000 $0.18 Broker2 Ridgeview 12:52:42 20,000 Broker3 Relative 12:53:16 36,000 

LANDIS AGORA MATCHED TRADES - SEPTEMBER 26, 2016 
Executed Trades Buy-Side Order Sell-Side Order 

Time Qty Price Broker Account Time Qty Broker Account Time Qty 
9:53:24 6,500 $0.17 Broker3 Relative 9:53:24 6,500 Broker2 Ridgeview 9:53:08 25,350 
9:55:34 100 $0.17 Broker3 Relative 9:54:42 5,000 Broker2 Ridgeview 9:55:15 20,000 
9:55:49 5,000 $0.17 Broker3 Relative 9:55:49 5,000 Broker2 Ridgeview 9:55:15 20,000 
9:59:41 5,000 $0.17 Broker2 Ridgeview 9:59:15 11,000 Broker3 Relative 9:59:41 5,000 
9:59:41 5,000 $0.17 Broker2 Ridgeview 9:59:15 11,000 Broker3 Relative 9:59:41 5,000 

10:03:21 5,000 $0.17 Broker2 Ridgeview 10:02:56 12,500 Broker3 Relative 10:03:21 5,000 
10:03:22 5,000 $0.17 Broker2 Ridgeview 10:02:56 12,500 Broker3 Relative 10:03:22 5,000 
10:18:45 5,000 $0.17 Broker2 Ridgeview 10:18:19 9,500 Broker3 Relative 10:18:45 5,000 

LANDIS AGORA MATCHED TRADES - SEPTEMBER 28, 2016 
Executed Trades Buy-Side Order Sell-Side Order 

Time Qty Price Broker Account Time Qty Broker Account Time Qty 
9:37:48 10,000 $0.18 Broker2 Ridgeview 9:37:45 10,000 Broker3 Relative 9:37:18 44,400 
9:38:18 5,600 $0.18 Broker2 Ridgeview 9:33:55 5,600 Broker3 Relative 9:37:18 44,400 
9:38:20 5,000 $0.18 Broker2 Ridgeview 9:38:19 5,000 Broker3 Relative 9:37:18 44,400 
9:39:31 13,800 $0.18 Broker2 Ridgeview 9:39:26 20,000 Broker3 Relative 9:37:18 44,400 
9:50:42 5,000 $0.18 Broker2 Ridgeview 9:39:26 20,000 Broker3 Relative 9:50:31 10,000 
9:56:13 5,000 $0.18 Broker1 Relative 9:53:10 5,000 Broker3 Relative 9:56:13 25,000 

10:15:33 10,000 $0.17 Broker3 Relative 10:15:33 10,000 Broker1 Relative 10:15:29 65,900 
11:22:28 5,000 $0.17 Broker1 Relative 11:18:26 5,000 Broker3 Relative 11:22:07 75,000 
11:22:49 18,000 $0.17 Broker2 Ridgeview 11:21:53 18,000 Broker3 Relative 11:22:07 75,000 

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Landis coordinated these and other trades for the purpose of creating the false or misleading 

appearance of increased volume in the trading of the securities of Agora. 

24. Landis’s trading comprised a significant percentage of the total trading volume in 

the securities of Agora on September 15, 26, and 28, 2016: 

Date Landis Market Percent 
09-15-2016      556,700    2,159,395  26% 
09-26-2016      612,600    1,482,216  41% 
09-28-2016   1,063,200    1,994,020  53% 

3. 2017: Environmental Packaging Technologies Holdings Inc. 

25. Landis continued to engage in manipulative trading in 2017. For example, in June 

2017, Landis agreed to promote the securities of Environmental Packaging Technologies 

Holdings Inc. (“Environmental Packaging”), and, through Ridgeview, received $20,000 to 

disseminate emails on June 12 and June 13, 2017, touting the stock of Environmental Packaging.  

26. Landis falsely represented to his client at this time that The Street Alert and The 

Stock Beacon had approximately 72,000 subscribers each. In fact, The Street Alert never had 

more than 3,000 subscribers, and The Stock Beacon never had more than 600 subscribers. To 

create the appearance of increased investor interest in Environmental Packaging, Landis instead 

traded in Packaging himself. 

27. For example, on June 13, Landis accessed Ridgeview and Relative Accounts 

within minutes of each other through the same home IP address he used when trading in Agora. 

28.  After accessing the accounts from the same location each day, Landis entered the 

following orders, among others, to both buy and sell the securities of Environmental Packaging: 

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LANDIS ENVIRONMENTAL PACKAGING MATCHED TRADES - JUNE 13, 2017 
Executed Trades Buy-Side Order Sell-Side Order 

Time Qty Price Broker Account Time Qty Broker Account Time Qty 
9:40:42 100 $1.27 Broker3 Relative 9:40:40 5,000 Broker2 Ridgeview 9:40:41 10,000 
9:43:33 1,000 $1.27 Broker3 Relative 9:43:33 1,000 Broker2 Ridgeview 9:40:41 10,000 

10:03:18 900 $1.27 Broker3 Relative 10:01:32 1,000 Broker2 Ridgeview 10:03:17 1,891 
10:07:58 391 $1.27 Broker3 Relative 10:07:58 600 Broker2 Ridgeview 10:03:17 1,891 
10:15:10 209 $1.27 Broker3 Relative 10:07:58 600 Broker2 Ridgeview 10:14:50 2,000 
10:58:01 1,000 $1.20 Broker3 Relative 10:58:01 1,000 Broker2 Ridgeview 10:46:14 14,791 
10:58:04 1,000 $1.20 Broker3 Relative 10:58:04 1,000 Broker2 Ridgeview 10:46:14 14,791 

Landis coordinated these and other trades for the purpose of creating the false or misleading 

appearance of increased volume in the trading of the securities of Environmental Packaging. 

29. Landis’s trading comprised a significant percentage of the total trading volume in 

the securities of Environmental Packaging on June 12 and 13, 2017: 

Date Landis Market Percent 
06-12-2017        93,600       424,956  22% 
06-13-2017        87,600       226,263  39% 

30. Other than June 12 and June 13, 2017, the specific days Landis was paid to 

promote the stock, neither Landis, nor any of the Ridgeview, Relative, or Business Associate 

Accounts, ever traded in Environmental Packaging stock.  

* * * 

31. As a result of the conduct described herein, Landis engaged in a scheme to 

defraud investors in at least 97 publicly traded companies through fraudulent trading and market 

manipulation. Landis’s conduct created apparent trading activity in the stock of those companies 

for the purpose of inducing the purchase and sale of the stock of those companies by others.  

32. Landis, through Ridgeview, obtained more than $3.3 million during the Relevant 

Period for his purported stock promotion services.  

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FIRST CLAIM FOR RELIEF 

FRAUD IN THE OFFER OR SALE OF SECURITIES 
(Violations of Section 17(a)(1) and (3) of the Securities Act) 

 
33. The Commission repeats and incorporates by reference the allegations in 

paragraphs 1-32 above. 

34. By reason of the conduct described above, the Defendants, in the offer or sale of 

securities, by the use of the means or instrumentalities of interstate commerce or of the mails, 

directly or indirectly, acting with the requisite degree of knowledge or state of mind (i) employed 

devices, schemes, or artifices to defraud; and (ii) engaged in transactions, practices, or courses of 

business which operated or would operate as a fraud or deceit upon any persons, including 

purchasers or sellers of the securities.  

35. By reason of the conduct described above, the Defendants each violated Securities 

Act Section 17(a)(1) and (3) [15 U.S.C. § 77q(a)(1) and (3)]. 

SECOND CLAIM FOR RELIEF 

FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES 
(Violations of Section 10(b) of the Exchange Act and Rules 10b-5(a) and (c) thereunder) 

 
36. The Commission repeats and incorporates by reference the allegations in 

paragraphs 1-32 above. 

37. By reason of the conduct described above, the Defendants, directly or indirectly, 

in connection with the purchase or sale of securities, by the use of the means or instrumentalities 

of interstate commerce or of the mails, or of any facility of any national securities exchange, 

intentionally, knowingly or recklessly, (i) employed devices, schemes, or artifices to defraud; 

and (ii) engaged in acts, practices, or courses of business which operated or would operate as a 

fraud or deceit upon any persons, including purchasers or sellers of the securities. 

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38. By reason of the conduct described above, the Defendants violated Exchange Act 

Section 10(b) [15 U.S.C. § 78j(b)] and Rules 10b-5(a) and (c) [17 C.F.R. § 240.10b-5(a) and (c)] 

thereunder. 

THIRD CLAIM FOR RELIEF 

MARKET MANIPULATION 
(Violations of Section 9(a)(1)-(2) of the Exchange Act) 

 
39. The Commission repeats and incorporates by reference the allegations in 

paragraphs 1-32 above. 

40. Sections 9(a)(1) and (2) of the Exchange Act [15 U.S.C. §78i(a)(1)-(2)] make it 

unlawful for any person, directly or indirectly, by the use of the mails or any means or 

instrumentality of interstate commerce, or of any facility of any national securities exchange, 

(1) to effect any transaction in a security which involves no change in the beneficial ownership 

of the security and to enter substantially similar orders for the purchase and sale of any security 

for the purpose of creating a false or misleading appearance of active trading in the security; or 

(2) to effect a series of transactions in a security creating actual or apparent active trading in such 

security, or raising or depressing the price of such security, for the purpose of inducing the 

purchase or sale of such security by others. 

41. By engaging in the conduct described above, the Defendants violated Section 

9(a)(1) and (2) of the Exchange Act [15 U.S.C. § 78i(a)(1) and (2)]. 

PRAYER FOR RELIEF 
WHEREFORE, the Commission respectfully requests that this Court: 

A. Enter a permanent injunction restraining the Defendants and each of their officers, 

agents, servants, employees, attorneys, and those persons in active concert or participation with 

them who receive actual notice of the injunction by personal service or otherwise, including 

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email, fax, or overnight delivery service, from directly or indirectly engaging in the conduct 

described above, or in conduct of similar purport and effect, in violation of:  

1. Section 9(a) of the Exchange Act [15 U.S.C. 78i(a)];  
2. 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]; and 
3. Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]. 

B. Order the Defendants to disgorge their ill-gotten gains, plus prejudgment interest; 

C. Order the Defendants to pay appropriate civil monetary penalties in accordance 

with Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the 

Exchange Act [15 U.S.C. § 78u(d)(3)];  

D. Order the Defendants be unconditionally and permanently prohibited from 

participating in any offering of a penny stock, as authorized by Section 20(g) of the Securities 

Act [15 U.S.C. § 77t(g)] and Section 21d(6)(B) of the Exchange Act [15 U.S.C. § 78u(d)(6)(B)]; 

E. Retain jurisdiction over this action to implement and carry out the terms of all 

orders and decrees that may be entered; and 

F. Grant such other and further relief as this Court may deem just and proper. 

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JURY DEMAND 
The Commission demands a jury in this matter for all claims so triable.  

Respectfully submitted, 
 
SECURITIES AND EXCHANGE COMMISSION 
 
By its attorneys, 
 
/s/ Eric A. Forni     
Eric A. Forni (Mass. Bar No. 669685) 
Kathleen B. Shields (Mass Bar No. 637438) 
Jonathan Allen (Mass Bar No. 680729) 
J. Lauchlan Wash (Mass Bar No. 629092) 
Rebecca Israel  
David M. Scheffler (Mass Bar No.670324) 
Amy Gwiazda (Mass Bar No.663494) 
Boston Regional Office 
33 Arch Street, 24th Floor 
Boston, MA  02110 
Phone:  (617) 573-4563 (Allen direct) 
Fax:  (617) 573-4590 

Dated:  November 28, 2018 [email protected] 

Case 1:18-cv-12453-IT   Document 1   Filed 11/28/18   Page 13 of 13