SEC v. Mikhail Kokorich, No. 1:21-CV-1869, District of Columbia (July 13, 2021) — Complaint

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UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 
SECURITIES AND EXCHANGE COMMISSION, 
100 F Street, N.E. 
Washington, DC 20549 
 
 
Plaintiff,        
v. 
 
 
Case No. 1:21-CV-1869 
 
JURY TRIAL DEMANDED 
 
MIKHAIL KOKORICH,   
c/o Dorsey & Whitney 
1401 New York Avenue N.W., Suite 900  
Washington DC, 20005 
 
 
  
Defendant.        
 
COMPLAINT 
Plaintiff Securities and Exchange Commission (“SEC”) alleges as follows: 
SUMMARY OF THE ACTION 
1. This case concerns a fraud perpetrated by Defendant Mikhail Kokorich to secure 
and  promote  a  merger  agreement  between  Momentus  Inc.  (“Momentus”)  and  Stable  Road  
Acquisition Corp. (“Stable Road”), which, if successful, would effectively take Momentus public 
and  infuse  it  with  nearly  $350  million  in  investor  funds.    Momentus  is  a  privately  held  space  
technology  company  that  hopes  to  provide  satellite-positioning  services.    Kokorich  is  one  of  
Momentus’s founders and was its Chief Executive Officer (“CEO”) at all relevant times.  Stable 
Road is a publicly traded special-purpose acquisition company (“SPAC”). 
2. A Russian citizen who since 2018 has faced repeated adverse determinations from 
U.S. government agencies for national security reasons, Kokorich engaged in fraudulent conduct 
to secure and promote the merger agreement with Stable Road.  Specifically, Kokorich knowingly 

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or  recklessly  made  misrepresentations  of  material  facts  and  misleading  omissions  and  deceived  
both Stable Road and investors regarding: (1) Momentus’s key technology which, when tested in 
space  in  2019,  failed  Momentus’s  internal  criteria  for  success;  and  (2)  multiple  adverse  
determinations  against  Kokorich  for  national  security  reasons,  which  materially  impaired  
Momentus’s ability to participate in U.S.-based rocket launches so long as he was involved with 
the company. 
3.     Momentus  attempted  in  2019  to  test  in  space  its  key  technology,  a  microwave  
electro-thermal (“MET”) water plasma thruster.  However, the MET thruster used during that test 
was not designed for commercial use, and the thruster failed Momentus’s own pre-launch criteria 
for a successful test.  As a result, Momentus’s technology remains unproven. 
4. Moreover, no later than 2018, Kokorich faced multiple adverse determinations by 
U.S.  government  agencies  because  of  concerns  that  he  posed  a  risk  to  U.S.  national  security.    
Therefore, with Kokorich as CEO, Momentus was unlikely to be allowed to participate in U.S.-
based  rocket  launches  because  U.S.  government  agencies,  including  the  U.S.  Department  of  
Defense,  had  the  authority  to  block  Momentus’s  involvement  in  those  launches  for  national  
security reasons. 
5. In the summer and fall of 2020, Kokorich and Stable Road’s CEO negotiated the 
details of a merger agreement between Momentus and Stable Road.  During those negotiations, 
Kokorich did not disclose the failures associated with the tests of the MET thruster in space, or 
that the U.S. government considered him a risk to national security.  To the contrary, Kokorich 
claimed that the 2019 space test of the MET thruster had been a success and that he was confident 
that the U.S. government would grant his asylum application, which would allow him to remain 
and work in the United States. 

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6. While he was helping negotiate the terms of the merger, Kokorich also participated 
in a number of presentations to potential Private Investment in Public Equity (“PIPE”) investors, 
investors  who  purchase  shares  of  stock  in  a  public  company  directly  from  the  issuer.    Those  
presentations  outlined  the  purported  benefits  of  the  proposed  business  combination  between  
Momentus  and  Stable  Road  and  included  the  material  misrepresentations  and  misleading  
omissions that Kokorich had previously made. 
7. On October 7, 2020, Momentus and Stable Road announced the signing of a merger 
agreement that would, if ultimately approved by shareholders, essentially take Momentus public 
and generate millions of dollars for Kokorich, Momentus and others.  They also announced that 
Stable Road had entered into subscription agreements with PIPE investors, pursuant to which the 
PIPE  investors  agreed  to  purchase  an  aggregate  of  17,500,000  shares  of  common  stock  of  the  
merged company for $10.00 per share. 
8. Momentus’s  business  plans  and  revenue  projections,  as  communicated  to  PIPE  
investors  and  described  in  registration  statements  filed  with  the  SEC  in  connection  with  the  
anticipated merger, were premised on Momentus already having proven technology that it could 
deploy on U.S.-based launches starting in December 2020.  But the technology was unproven, and 
there was profound risk that Momentus would be unable to participate in U.S.-based launches with 
Kokorich  in  place  as  CEO.    Because  of  Kokorich’s  knowing  or  reckless  conduct  and  his  
misrepresentations  and  misleading  omissions  of  material  fact,  PIPE  and  retail  investors  in  the  
SPAC  were  given  materially  misleading  information  upon  which  to  make  their  investment  
decisions. 
9. By engaging in the misconduct described herein, Kokorich violated the antifraud 
provisions of the Securities and Exchange Act of 1934 (“Exchange Act”) and the Securities Act 

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of 1933 (“Securities Act”) and aided and abetted violations by Momentus.  Kokorich will continue 
to violate the federal securities laws unless restrained or enjoined by this Court. 
10. The   SEC   seeks   injunctive   relief,   disgorgement,   civil   penalties,   and   other   
appropriate and necessary equitable relief. 
JURISDICTION AND VENUE 
11. The SEC brings this action, and this Court has jurisdiction, pursuant to Securities 
Act  Sections  20(b),  20(d),  and  22(a)  [15  U.S.C.  §§  77t(b),  (d),  and  77v(a)],  and  Exchange  Act  
Sections 21(d)(1) and 27 [15 U.S.C. §§ 78u(d)(1) and 78aa]. 
12. Defendant Kokorich, directly or indirectly, singly or in concert with others, made 
use of the means or instruments of transportation and communication in interstate commerce, or 
of  the  mails,  or  of  the  facilities  of  a  national  securities  exchange  in  connection  with  the  acts,  
transactions, and practices alleged in this Complaint.   
13. Kokorich is subject to personal jurisdiction because, among other things, he lived 
in the United States during the relevant period, purposefully directed his business activities at the 
United States, and knowingly provided statements for use in materials used to promote securities 
transactions in the United States and to be used in SEC filings.  In addition, the merger agreement 
at issue in this case, which Defendant Kokorich signed in his capacity as the CEO of Momentus, 
contains a forum selection clause providing that “to the fullest extent permitted by law, the federal 
district courts of the United States of America shall be the exclusive forum for the resolution of 
any complaint asserting a cause of action arising under the Securities Act of 1933, as amended,” 
and that “[a]ny person or entity holding, owning or otherwise acquiring any interest in any security 
of the Corporation shall be deemed to have notice of and to have consented” the forum selection 
clause. 

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14. Venue is proper in this district pursuant to Securities Act Section 22(a) [15 U.S.C. 
§ 77v(a)] and Exchange Act Section 27 [15 U.S.C. § 78aa] because Defendant transacts business 
in this district and violations of the securities laws alleged in this Complaint occurred within this 
district, including the filing of false and misleading documents with the SEC. 
DEFENDANT 
15. Mikhail  Kokorich,  age  45,  is  a  Russian  citizen  who  is  currently  residing  in  
Switzerland.  He served as Momentus’s CEO from the time he helped to start the company in 2017 
until his resignation on January 25, 2021.  Kokorich resided in California from at least 2016 until 
on or about January 27, 2021, when he left the United States.   
OTHER RELEVANT ENTITIES 
16. Momentus is a privately held company incorporated in Delaware and headquartered 
in  Santa  Clara,  California.    Founded  in  late  2017,  Momentus  describes  itself  as  a  space  
infrastructure company, which hopes to provide, among other things, satellite-positioning services. 
17. Stable Road Acquisition Corp. is a Delaware corporation with its principal place of 
business in Venice, California.  As a SPAC, Stable Road has no operations of its own and exists 
for  the  purpose  of  merging  with  a  privately  held  company  and  effectively  taking  that  company  
public.  On November 13, 2019, SRAC completed its initial public offering of 17,250,000 units at 
a price of $10.00 per unit, generating gross proceeds of $172.5 million.  Momentus will receive 
the  proceeds  of  the  IPO  upon  completion  of  the  proposed  merger  with  Stable  Road.    SRAC’s  
securities are traded on Nasdaq under the ticker symbols “SRAC,” “SRACU,” and “SRACW.” 
I. Background 
a. Momentus Is a Startup with Unproven Technology 
18. Large  commercial  satellite  launch  providers offer  launch  services  to  satellite  
owners but only leave these “rideshare” satellites in a limited range of orbits.  Momentus hopes to 

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offer “last mile” satellite placement services to place these rideshare satellites into custom orbits 
of  the  customers’  choosing.    According  to  Momentus’s  plans,  Momentus  will  integrate  its  
customer’s payload into Momentus’s vehicle, which will then be loaded onto a larger rocket.  The 
rocket will then leave Momentus’s vehicle in orbit, at which point Momentus will move its vehicle 
and  the  customer’s  integrated  payload  into  a  custom  orbit  using  what  it  touted  in  investor  
presentations  as  its  “cornerstone”  technology,  a  propulsion  system  using  MET  water  plasma  
thrusters. 
19. Momentus’s business model is premised on the rapid development and testing of 
its  MET  water  propulsion  thruster  technology.    As  Momentus  explained  in  the  registration  
statements at issue in this case: “The success of our in-space infrastructure services business will 
depend  on  our  ability  to  successfully  and  regularly  deploy  customer  satellites  into  their  custom  
orbits.”  
20. In  order  to  do  so,  Momentus  must  operate  its  MET  water  propulsion  thruster  
reliably in space and provide the necessary thrust and length of operation needed to move customer 
satellites into specified orbits.  An MET water propulsion thruster has never been commercially 
used in space.   
b. Momentus Needed a Test to Market its Technology and Services 
21. In late 2018 and early 2019, Momentus, as a small startup, lacked in-space flight 
experience with its thruster to show that it could deploy customer satellites into custom orbits.  As 
Kokorich recognized, it was important for Momentus to demonstrate that it could build, launch 
and operate an MET thruster system in space.  Kokorich expected that a test in space would help 
to market Momentus and attract investors. 
22. Momentus therefore planned a mission to test its MET thruster in space.  In July 
2019, Momentus launched an MET thruster on the “MX-1” satellite for the purpose of testing its 

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thruster  in  space  and  performing  maneuvers.    Prior  to  the  satellite  launch,  in  an  internal  slide  
presentation, Momentus partly defined “mission success” as “100 individual burns of 1 minute of 
more.”  A “burn” refers to operating the thruster producing thrust for a period of time. 
23. Before the launch of its test mission, Momentus conditioned the public to believe 
that the mission would demonstrate the thruster’s commercial viability.  For example, in a January 
2019  blog  post  on  its  website,  Momentus  stated  that  the  mission,  which  it  named  “El  Camino  
Real,” would give investors “absolute confidence” that Momentus’s service would be “on time, 
safe and reliable.”  Momentus went on to say that it would “be able to run the thruster long enough 
to fully characterize its performance in space with dozens of stop start cycles and [to] then safely 
de-orbit the vehicle.” 
24. Momentus, through its launch partner, stated in a publicly filed FCC application on 
September  12,  2018,  that  El  Camino  Real  was  “a  commercial  demonstration”  of  Momentus’s  
propulsion   system   that   would   show   its   “reliability,   longevity,   performance,   and   utility.”      
Momentus explained in the FCC application that the mission’s objective was to demonstrate that 
its thrusters provide “cost-effective high delta V [change in velocity from thrust] capability” and 
thereby show that “this particular system is mature enough to be used by the small satellite market, 
and can be quickly and easily integrated with CubeSats as well as larger, more capable spacecraft.”  
Kokorich reviewed this application at the time it was submitted to the FCC. 
25. Contrary  to  the  claims  in  Momentus’s  blog  post  or  in  the  FCC  application,  the  
Momentus MET water propulsion thruster, as integrated into the MX-1 satellite, was not powerful 
enough or appropriate to provide commercial satellite-placement services.  Moreover, the thruster 
was not powerful enough to provide any measurable or detectible changes in the MX-1 satellite’s 
orbital velocity.  As one former Momentus officer stated, the thruster tested in the El Camino Real 

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mission did not have “commercial potential” because it was “too small, too inefficient, too low in 
[specific impulse], too low in total impulse.”  
c. Momentus’s Test Failed 
26. The El Camino Real mission was a failure. After experiencing significant problems 
with supporting sub-systems and its propulsion system, Momentus attempted only 23 firings, and 
data suggests that only three hot firings produced plasma.  None of those firings lasted a full minute 
or  generated  measurable  thrust.    Momentus  lost  contact  with  the  satellite  approximately  three  
months into the planned six-month mission and was never able to attempt the remaining 77 firings 
it had planned, much less achieve any of the “100 individual burns of 1 minute or more.”  Thus, 
Momentus  failed  to  meet  its  own  criteria  for  mission  success,  as  set  forth  in  its  internal  slide  
presentation. 
27. Momentus did not perform “dozens of start and stop cycles” or “safely deorbit” the 
vehicle, as represented in its January 2019 blog post. 
28. The MX-1 satellite is still in space, but it is not functional. 
29. The El Camino Real mission did not demonstrate the commercial viability of the 
thruster tested.  One former Momentus officer stated that the mission yielded “no data to suggest 
that that thruster would deliver an impulse of any commercial significance,” and that Momentus 
was not able to characterize the performance of the thrusters.  Additionally, a Momentus engineer 
admitted  that  the  mission  did  not  yield  sufficient  data  to  demonstrate  the  propulsion  system’s  
reliability or longevity. 
30. Kokorich was kept informed of the relevant aspects of the El Camino Real results.  
By his own admission, he understood even before the launch that the mission was not designed to 
show  that  the  thruster  could  provide  measurable  delta-v  (change  in  velocity  from  thrust),  to  
measure  specific  impulse  (the  efficiency  of  the  propulsion  system),  or  to  show  the  thruster’s  

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reliability.    Kokorich  was  also  copied  on  emails  in  November  2019  between  Momentus’s  Chief  
Technology Officer and its Chief Engineer discussing creation of a “failure review board” to study the 
El Camino Real mission, due to the inability to obtain useful data from the mission because of its failure. 
In addition, one Momentus’s engineer internally acknowledged in February 2020, in a document 
sent to Kokorich, that Momentus did not obtain “any useful mission results” from the launch. 
d. Kokorich Publicly Mischaracterized the Results from Momentus’s Test 
31. In  a  September  25,  2019,  article  in  the  industry  periodical  Space  News  titled,  
“Momentus reports success in testing water plasma propulsion,” Kokorich was quoted as stating, 
“Water  plasma  propulsion  is  now  technologically  mature  enough  to  be  baselined  for  
operational  in-space  transportation  missions,”  meaning  it  could  be  used  commercially.    He  
also repeated the claim from Momentus’s January 2019 blog post that “the purpose of the El 
Camino Real mission was to flight demonstrate our core propulsion technology so customers, 
investors  and  stakeholders  can  have  absolute  confidence  that  Momentus  will  deliver  their  
payloads to a given orbit.” 
32. As Kokorich knew or was reckless in not knowing, his claims in the Space News 
article  were  false  and  misleading  because  the  El  Camino  Real  mission  was  never  intended  to  
demonstrate  the  thruster’s  commercial  viability  or  to  give  investors  and  customers  “absolute  
confidence” that Momentus could maneuver customer payloads to a custom orbit.  Moreover, the 
mission was a failure because the thruster produced plasma, which is necessary but not sufficient 
to generate thrust, only three times out of 23 attempts, and for less than a full minute each time, 
which did not meet Momentus’s own criteria and explains why they did not obtain “any useful 
mission  results.”    Even  if  the  mission  had  achieved  Momentus’s  internal  criteria  for  success—
which  it  did  not,  as  Kokorich  knew—it  would  not  have  demonstrated  that  the  thruster  was  
“technologically mature enough to be baselined for operational in-space transportation missions.” 

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e. Adverse Determinations Against Kokorich for National Security Reasons  
33. Since  2018,  multiple  U.S.  government  agencies  have  taken  actions  adverse  to  
Kokorich for national security reasons – a fact known to Kokorich.  
34. The Bureau of Industry and Security (“BIS”), a bureau of the U.S. Department of 
Commerce,  oversees  the  issuance  of  export  control  licenses,  which  authorize  the  provision  of  
certain technologies to foreign individuals or entities.  The stated mission of the BIS is to “advance 
U.S. national security, foreign policy, and economic objectives.”  
35. Because  Kokorich  is  a  Russian  citizen,  he  could  not  access  Momentus’s  export-
controlled technology without an export control license.  In 2017, Momentus (then operating under 
the name “Space Apprentices Enterprise”) applied for an export control license for Kokorich.  In 
March 2018, the BIS denied the application. In its rejection notice to Momentus, BIS explained 
that, after consulting with the Departments of Defense and State, it had concluded that Kokorich 
was not an “acceptable recipient” of the technology “for national security reasons.” 
36. In  April  2018,  in  connection  with  Kokorich’s  investment  in  a  different  space  
technology company he founded before Momentus, the Committee on Foreign Investment in the 
United  States  (“CFIUS”),  an  intergovernmental  agency  that  includes  the  U.S.  Departments  of  
Commerce, Defense, and State sent a letter to Kokorich.  In that letter, CFIUS informed Kokorich 
that  it  “believe[d]”  his  investment  and  the  investments  of  certain  others  “pose[d]  a  risk  to  the  
national security of the United States.”  CFIUS explained that its analysis included an assessment 
of  whether  “a  foreign  person  has  the  capability  or  intention  to  exploit  or  cause  harm”  (which  
CFIUS defines as the “threat”), and “whether the nature of the U.S. business creates susceptibility 
to  impairment  of  U.S.  national  security  (the  “vulnerability”).”    CFIUS  further  explained  that  a  
national security risk is a “function of the interaction between threat and vulnerability.”  

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37. On or about June 22, 2018, CFIUS representatives participated in a teleconference 
with  Kokorich’s  attorneys.    On  that  call,  CFIUS  representatives  informed  Kokorich’s  attorneys  
that  CFIUS  had  determined  that  a  full  divestiture  of  Kokorich’s  participation  in  the  space  
technology company was necessary to mitigate the national security concerns.  
38. After  the  teleconference,  in  a  letter  response  dated  June  24,  2018,  on  which  
Kokorich was copied, Kokorich’s attorneys stated that they understood that CFIUS had deemed 
Kokorich  a  national  security  risk  and  tried  to  persuade  CFIUS  to  reconsider  this  determination.    
Kokorich’s attorneys argued that he was actually a national security asset and a vocal critic of the 
Russian government.   
39. Kokorich’s  argument  did  not  work.    In  a  letter  dated  June  25,  2018,  CFIUS  told  
Kokorich  that  it  would  require  him  to  divest  his  ownership  and  control  interest  in  the  space  
technology company.  CFIUS explained that its concerns related, in part, to the sophistication of 
the company’s technology and concerns involving Kokorich and other foreign investors. 
f. Kokorich’s Attempts to Legally Remain in the United States Were 
Repeatedly Rebuffed 
40. In or about June 2018, U.S. Customs and Immigration Services (“USCIS”) revoked 
Kokorich’s  work  visa  and  denied  his  application  for  permanent  resident  status.    In  response,  
Kokorich applied for political asylum and withholding of removal proceedings in September 2018, 
claiming again that he was a prominent critic of the Russian government. 
41. A year later, on or about August 28, 2019, USCIS issued a referral notice informing 
Kokorich  that  it  had  not  granted  his  asylum  application,  and  that  it  had  referred  his  case  to  an  
immigration judge for adjudication in removal proceedings.  USCIS stated that its determination 
was  based  on  “inconsistencies”  in  Kokorich’s  application  and  testimony  “with  regard  to  [his]  
political affiliations and activities in Russia.”  

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42. On or about that same date, multiple government agencies, including the FBI, the 
U.S.  Department  of  Homeland  Security,  and  the  BIS’s  Office  of  Export  Enforcement,  arrived  
unannounced  at  Momentus’s  headquarters.    Agents  questioned  multiple  Momentus  employees  
about possible export control violations by Kokorich as well as improper technology transfers. 
43. Before  they  left,  the  federal  agents  detained  Kokorich  and  transported  him  to  an  
immigration detention center.  Kokorich was subsequently released on bond. 
g. Kokorich Sought a SPAC Merger with Momentus 
44. By late 2019, Momentus was in constant fundraising mode.  The company had no 
revenues and needed additional capital to fund its growth.  Beginning in early 2020, Kokorich had 
discussions  with  an  investment  bank  in  an  attempt  to  secure  additional  capital  for  Momentus’s  
operations.  In mid-2020, Momentus formally engaged the bank and sought its assistance to find a 
suitable SPAC candidate for a merger.  
 
45. In addition to his discussions with Stable Road, Kokorich had discussions with two 
other SPACs.  The two other SPACs chose not to move forward with a merger with Momentus 
because Momentus was still at a relatively early stage and immature as a company. 
46. On or about June 29, 2020, Kokorich and Stable Road’s CEO met in person for the 
first time at Stable Road’s offices in California to discuss the possibility of a merger between the 
two companies.  After the initial discussion, merger negotiations began in earnest in July 2020.  
Kokorich  remained  heavily  involved  in  merger  negotiations,  including  on  the  subject  of  
Momentus’s  valuation  and  business  model.    He  also  helped  develop  a  list  of  PIPE  investors  to  
contact and reviewed draft presentations to PIPE investors. 
47. Pursuant to the merger agreement ultimately signed by Momentus and Stable Road, 
if approved by the shareholders, Kokorich would become the CEO of the new merged company. 

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Kokorich was also entitled to exchange his shares of Momentus stock for approximately 19 million 
shares of stock in the new publicly traded company, which would be between 13.5% and 14.3% 
of the total shares outstanding. 
II. Kokorich and Momentus Made Misrepresentations of Material Fact and 
Misleading Omissions about Momentus’s Technology  
48. From his very first meeting with Stable Road’s CEO on June 29, 2020, Kokorich 
made misrepresentations and misleading omissions of material fact.  For example, Kokorich told 
Stable Road’s CEO that the El Camino Real mission had been a success and that it was a great 
achievement for Momentus to have fired the thruster and tested its propulsion technology in space.  
Specifically, Kokorich said that Momentus had performed a number of tests, with recorded data, 
and that the vehicle was still in space although they could no longer conduct additional tests. 
49. Notably,  in  that  discussion,  Kokorich  omitted  material  facts  that  made  his  
statements  about  the  El  Camino  Real  mission  misleading.    Kokorich  did  not  tell  Stable  Road’s  
CEO of any of the failures, problems, shortcomings, or issues with the El Camino Real mission 
described above.  Moreover, Kokorich did not explain to Stable Road’s CEO that the El Camino 
Real mission was not designed to show any demonstrable impulse or delta-v from the thruster, or 
to demonstrate the thruster’s reliability. 
50. At the time he made these misstatements and misleading omissions of material fact, 
Kokorich knew, was reckless in not knowing, or should have known that Stable Road and its CEO 
would rely on his statements in determining to proceed with the merger and PIPE fund-raising, 
and that his false and misleading statements would be repeated to investors while promoting the 
merger. 
51. Before signing the merger agreement, Momentus and Stable Road made multiple 
presentations  to  potential  PIPE  investors  via  Zoom.    Kokorich  personally  participated  in  these  

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presentations, and he mentioned the alleged “success” of the El Camino Real mission, but failed 
to  disclose  the  significant  failures,  problems,  shortcomings,  and  issues  described  above.    The  
presentations were conducted by video conference and included slides that were shown to the PIPE 
investors during the presentations.  Each of those presentations contained a slide titled, “Momentus 
at  a  Glance,”  which  misleadingly  claimed  that  Momentus  “successfully  tested  water  based  
propulsion technology on a demo flight launched mid-2019 – is still operational today.”  In total, 
PIPE investors agreed to purchase 17,500,000 shares of common stock of the merged company for 
$10.00 per share. 
52. Momentus and Stable Road announced their merger on October 7, 2020.  That day, 
Kokorich  and  Stable  Road’s  CEO  made  a  presentation  on  a  conference  call  to  analysts  and  
institutional investors using slides virtually identical to the ones shown to PIPE investors.  This 
presentation  similarly  contained  the  claim  that  Momentus  “successfully  tested  water  based  
propulsion  technology  on  a  demo  flight  launched  mid-2019  –  is  still  operational today.”  In his 
scripted  comments,  Kokorich  falsely  reiterated  that  Momentus  had  “successfully  tested  our  
groundbreaking  thruster  in  space.”    Again,  Kokorich  failed  to  disclose  the  significant  failures,  
problems,  shortcomings,  or  issues  described  above.    Stable  Road  publicly  filed  a  copy  of  these  
slides and the presenters’ script on a Form 8-K later that day. 
53. During  Kokorich’s  tenure  as  Momentus’s  CEO,  Stable  Road  filed  an  initial  S-4  
registration  statement  related  to  the  merger  on  November  2,  2020,  and  a  subsequent  amended  
registration statement on December 14, 2020.  A registration statement is a filing with the SEC 
making  required  disclosures  in  connection  with  the  registration  of  a  security,  a  securities  
offering, or an investment company under federal securities laws.   

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54. Kokorich participated in the preparation of the November and December 2020 S-4 
registration  statements,  and  specifically  the  subsections  of  the  S-4  statements  that  described  or  
contained  information  about  Momentus.    In  addition  to  the  overall  review  and  approval  of  
Momentus’s portion of the registration statements as Momentus’s CEO, Kokorich helped to draft 
what he described as the technology and business or market strategy sections of the S-4 statements. 
55. Each  registration  statement  contained  a  subsection  titled,  “Information  about  
Momentus” that is written in Momentus’s voice, and that Momentus drafted.  In this subsection of 
each registration statement, Momentus falsely states that it “successfully tested our water plasma 
propulsion technology in space,” referring to the El Camino Real mission. 
56. Each subsection also contained a graphic captioned: “Our water plasma propulsion 
technology.”  In the body of the slide there is a diagram of a thruster surrounded by various claims 
about  the  thruster’s  functionality,  including:  “High  ISP  –  Tunable  up  to  2  to  5  times  common  
chemical  propulsion  systems”;  and  “High  thrust  –  Tunable  up  to  3  to  10  times  most  common  
electrical propulsion systems.”  
57. Momentus’s  characterizations  of  the  El  Camino  Real  mission  in  the  registration  
statements  were  false  and  misleading.    Momentus  boasted  in  its  graphic  that  its  “water  plasma  
propulsion technology” offered high thrust and high ISP (specific impulse), and elsewhere claimed 
that its “water plasma propulsion technology” was successfully tested in space.  However, the El 
Camino  Real  mission  did  not  demonstrate  high  thrust  or  high  specific  impulse.    It  did  not  
demonstrate that the thruster it tested was “tunable up to 2 to 5 times common chemical propulsion 
systems” or “up to 3 to 30 times most common electrical propulsion systems.”  The registration 
statements  failed  to  disclose  any  of  the  significant  failures,  problems,  shortcomings,  or  issues  

16 
 
described above.  The claims in the registration statements that Momentus “successfully tested” 
its technology were therefore materially false and misleading. 
58. Moreover, the only publicly available criteria for what constituted success for the 
mission  were  contained  in  Momentus’s  pre-launch  blog  post  and  the  FCC  application  filed  by  
Momentus’s  launch  partner.    By  characterizing  the  mission  as  a  success  without  explaining  the  
many failures and problems experienced during the mission, or that the mission failed Momentus’s 
pre-launch evaluation criteria, Kokorich and Momentus made materially false statements and/or 
omitted facts necessary to make their statements not misleading. 
59. Investors had no way of knowing, based on the bare claim that the El Camino Real 
mission  “successfully  tested”  Momentus’s  thrusters,  that  the  mission  did  not  demonstrate  that  
Momentus’s services would be “on time, safe and reliable,” as promised in the blog.  Similarly, 
they had no way to know that the mission did not demonstrate the thrusters’ “reliability, longevity, 
performance, and utility,” as described in the FCC application. 
60. On  June  29,  2021,  Stable  Road  and  Momentus  filed  with  the  SEC  an  amended  
registration statement that corrected these false statements and misleading omissions by describing 
the actual results of the El Camino Real mission.  The registration statement explained that “[t]he 
mission’s  objective  was  to  demonstrate  the  MET’s  ability  to  produce  water  plasma  in  space  by  
performing  100  one  minute  firings.”    After  discussing the failure of the MX-1 satellite, and the 
associated problems with the attempted firings of the thruster which were stopped “after only 23 
of  the  planned  100  firings  had  been  performed,”  the  statement  clarified  that  “a  pump  issue  
significantly restricted flow of water into the thruster during nine of the 12 hot firings, preventing 
plasma generation” and that “the three hot firings that did have water present were found to have 
produced plasma.” 

17 
 
61. Kokorich  and  Momentus’s  false  statements  and  misleading  omissions  were  
material  to  investors.    Because  Momentus  can  only  generate  revenue  under  its  current  business  
plan if its thruster can generate commercially significant thrust, reasonable investors would find it 
important  to  know  whether  Momentus  had  actually  proven  that  its  technology  is  commercially  
viable.    They  would  find  it  important  to  know  whether  Momentus  had  shown  that  its  services  
would be “on time, safe and reliable” or whether Momentus could “deliver [customer] payloads 
to  a  given  orbit.”    They  would  also  find  it  important  to  know  whether  the  mission  succeeded  
according  to  Momentus’s  pre-launch  definition  of  success.    By  misleading  investors  about  the  
results  of  the  in-space  testing,  Kokorich  and  Momentus  gave  investors  false  comfort  that  
Momentus was further on the road to the commercial deployment of its technology than it actually 
was.  
62. Kokorich and Momentus knowingly or recklessly made the misrepresentations and 
omissions of material fact regarding the El Camino Real mission, as described in paragraphs 48 
through  61  above.    They  understood  that  the  launch  was  never  designed  to  test  the  commercial  
viability  of  Momentus’s  thrusters.    They  also  knew  that  the  launch  did  not  yield  “any  useful  
mission  results,”  as  one  of  Momentus’s  engineers  wrote  in  an  internal  document  shared  with  
Kokorich.    Yet  they  claimed  that  the  test  would  give  investors  “absolute  confidence”  that  
Momentus could deliver customer payloads to a given orbit and repeatedly represented that the 
mission was a success without any qualification. 
III. Kokorich   and   Momentus   Made   Misrepresentations   of   Material   Fact   and   
Misleading Omissions about Kokorich’s National Security Issues 
a. U.S.  Government  Agencies’  National  Security  Determinations  Regarding  
Kokorich Threatened Momentus’s Viability 
63. Before it is able to launch any vehicle on a U.S. mission, Momentus or its launch 
partners  must  obtain  licenses  from  various  U.S.  government  agencies,  including  the  Federal  

18 
 
Aviation Administration (“FAA”).  Those agencies have the authority to deny a license for national 
security reasons and work in consultation with the U.S. Department of Defense to determine if the 
payload of a mission presents a national security risk.  
64. If  Momentus  or  its  launch  partner  is  unable  to  obtain  the  necessary  licenses,  
Momentus cannot execute on its business plan.  It may be unable to conduct additional missions 
to test its technology.  It may also never be able to offer commercial satellite placement services.  
65. The  U.S.  government’s  national  security-related  determinations  about  Kokorich  
therefore posed a significant threat to Momentus’s ability to participate in launches and generate 
meaningful revenue and were material.  
b.   Kokorich  and  Momentus  Repeatedly  Mischaracterized  Kokorich’s  National  
Security Issues 
66. Just as he had misled Stable Road’s CEO about the purported “success” of the El 
Camino Real mission, from the beginning of the merger discussions, Kokorich told Stable Road’s 
CEO that he was confident that his asylum application would be approved.  Specifically, Kokorich 
told Stable Road’s CEO prior to signing the merger agreement that he had a strong case for political 
asylum,  and  that  he  also  had  a  second  path  to  U.S.  citizenship  if  for  any  reason  the  asylum  
application was not granted.  Kokorich’s immigration status was of interest to Stable Road because 
Kokorich  was  supposed  to  lead  the  new  company  and  because  Momentus  described  him  as  
important to the company’s success.  As Momentus stated in the relevant registration statements 
filed on November 2, 2020 and December 14, 2020, “Momentus is highly dependent on Mikhail 
Kokorich,  its  co-founder  and  chief  executive  officer.  Mr.  Kokorich  invented  the  majority  of  
Momentus’s inventions and remains deeply involved in Momentus’s business.” 
67. Notably, Kokorich did not tell Stable Road’s CEO that the USCIS had previously 
issued a referral notice saying that it had not granted his asylum application, and that it had referred 

19 
 
his case to an immigration judge for adjudication in removal proceedings.  Kokorich also assured 
Stable  Road’s  CEO  that  the  CFIUS  divestiture  order  regarding  his  other  space  technology  
company was closed, and that it was a different situation from his Momentus ownership.  In that 
vein,  Kokorich  asserted  that  the  issues  CFIUS  raised  in  the  prior  matter  had  to  do  with  other  
investors, not specifically him, even though he knew or was reckless in not knowing the opposite 
was true based on CFIUS’s communications with his counsel. 
68. Kokorich  and  Momentus  also  failed  to  share  with  Stable  Road  the  extent  of  
Kokorich’s national security issues with the U.S. government.  Specifically, they did not tell Stable 
Road that U.S. government agencies had previously, and repeatedly, made adverse determinations 
against Kokorich for national security reasons.  
69. Despite Kokorich’s assurances that his asylum application would be granted, U.S. 
government  agencies’  adverse  determinations  against  Kokorich  for  national  security  reasons  
continued  to  create  problems  for  him  and  Momentus  in  the  months  leading  up  to  the  merger  
announcement.  In February 2020, Momentus filed a new application for an export control license 
for  Kokorich.    On  April  15,  2020,  Momentus  learned  that  the  application’s  status  was  “hold  
without action,” meaning the application had been placed on hold by the BIS reviewer.  On October 
7,  2020,  the  day  the  merger  was  announced,  a  BIS  representative  emailed  Momentus’s  Deputy  
General Counsel and Chief Ethics and Compliance Officer to convey, in part, that the Departments 
of Defense and State had indicated that they would recommend denying the application.  Two days 
later, the same representative further disclosed that the Departments of Defense, State and Energy 
had all recommended denying the application.  On October 23, 2020, the representative emailed 
to  disclose  that  BIS’s  Operating  Committee  had  determined  to  deny  the  license,  although  the  
representative indicated the possibility that he might seek to appeal that decision internally.  

20 
 
70. On  November  9,  2020,  after  the  filing  with  the  SEC  of  the  first  registration  
statement for the merger, but before the filing of the second registration statement, Momentus and 
Kokorich learned that there would be no internal appeal and that U.S. Department of Commerce 
would  deny  Momentus’s  pending  application  for  an  export  control  license  for  Kokorich.    
Momentus  received  the  formal  notification  of  the  intent  to  deny  the  application.    That  letter  
notification  stated  that  Momentus’s  technology  would  make  a  “significant  contribution  to  the  
military potential to any other country or combination of countries which would prove detrimental 
to the national security of the United States” and that Kokorich was not an acceptable recipient of 
Momentus’s technology. 
c.   Kokorich’s   National   Security   Issues   Negatively   Affected   Momentus’s   
Operations  
71. The growing issues that Momentus faced by having Kokorich as a CEO came to a 
head  in  December  2020,  just  two  months  after  the  merger  announcement.    Momentus  was  
scheduled to participate in a launch with a large commercial launch provider in January 2021.  That 
launch represented a key milestone for Momentus because it was supposed to be the company’s 
first commercial flight.  
72. On  December  22,  2020,  the  FAA  notified  the  launch  provider  that  it  would  not  
approve the upcoming rocket launch with Momentus’s payload on board.  As a result, the launch 
provider removed Momentus’s payload from its rocket and proceeded with the launch. On January 
4, 2021, Momentus issued a press release stating that it was “remanifesting its January 2021 mission 
to a subsequent launch opportunity in 2021,” which would “allow for the additional time necessary 
to secure FAA approval of Momentus’s payloads.”  On January 7, 2021, the FAA sent a letter to 
the  launch  provider  explaining  that  the  Department  of  Defense  had  identified  potential  national  
security concerns with Momentus’s payloads and that it could not approve the provider’s launch if 

21 
 
it  included  Momentus’s  payload  because  the  Department  of  Defense’s  review  would  not  be  
complete before the launch date. 
73. Shortly after this setback, on January 21, 2021, Momentus learned of a letter from 
the Department of Defense stating that Momentus posed a risk to national security as a result of 
Kokorich’s ownership and control of the company.  On January 25, 2021, Kokorich stepped down 
as CEO of Momentus and placed his shares of Momentus stock in a voting trust.  
74. Even that did not solve Momentus’s problems, however.  In May 2021, the FAA 
once  again  did  not  approve  Momentus’s  participation  in  a  June  2021  launch  with  the  launch  
provider.  On  May  10,  2021,  Momentus  received  a  letter  from  the  U.S.  Federal  Aviation  
Administration (“FAA”) denying Momentus’s application for a payload review.  
75. The  FAA  explicitly  based  its  denial  on  a  finding  that  the  launch  of  Momentus’s  
payload would jeopardize national security due to Momentus’s then-current corporate structure. 
76. Later in May 2021, the launch provider informed Momentus that it would not allow 
any  Momentus  payload  on  any  launch  through  the  end  of  the  year  while  Momentus  “works  to  
secure  approvals  from  the  U.S.  government.”    Momentus’s  best-case  scenario,  therefore,  is  an  
inaugural commercial launch in January 2022, a full year after Momentus hoped to begin offering 
commercial services.   
77. On  June  9,  2021,  Kokorich  and  Momentus  entered  into  a  National  Security  
Agreement with CFIUS, pursuant to which Kokorich agreed to fully divest from the company and 
Momentus agreed, among other things, to implement increased security measures and appoint a 
CFIUS-approved director to its board of directors. 

22 
 
d.    Material  Misrepresentations  and  Misleading  Omissions  in  the  Registration  
Statements 
78. As  a  result  of  Kokorich  and  Momentus’s  deception,  both  the  initial  registration  
statement,  filed  in  November  2020,  and  the  amended  registration  statement,  filed  in  December  
2020 (after Momentus learned that Kokorich’s most recent application for an export license would 
be  denied  for  national  security  reasons),  contain  material  false  statements  and  misleading  
omissions regarding Kokorich’s national security status.  As described in Paragraph 54, Kokorich 
participated in the preparation of the November and December 2020 S-4 registration statements.  
In  his  role  as  CEO,  Kokorich  generally  reviewed  and  approved  Momentus’s  portion  of  the  
registration statements. 
79. As  described  above,  each  registration  statement  contained  a  subsection  titled,  
“Information about Momentus,” that Momentus drafted.  Kokorich reviewed and approved these 
subsections before they were provided to Stable Road for inclusion in the registration statement. 
In  that  subsection,  Momentus  stated  that  it  believed  Kokorich’s  asylum  application  would  be  
granted.    Because  the  U.S.  government  would  be  unlikely  to  grant  asylum  to  an  individual  it  
viewed as a national security threat, that statement falsely implied that Kokorich was not a national 
security risk.  Kokorich knew that multiple U.S. government agencies had raised national security 
concerns  about  him  and  had  provided  specific  grounds  for  doing  so.    To  state  that  Momentus  
believed Kokorich’s asylum application would be granted without disclosing the actions taken by 
these agencies or their stated grounds for doing so was materially misleading. 
80. Additionally, in the “Risk Factors” subsection, which Momentus also drafted and 
provided to Stable Road for inclusion in the registration statement, and which Kokorich reviewed 
and did not correct, Momentus disclosed that Kokorich had not “yet” obtained an export control 
license.  Momentus did not explain, however, that the BIS had denied Momentus’s first application 

23 
 
in  2018  because  of  national  security  issues.    It  also  did  not  explain  that,  at  the  time  of  the  first  
registration  statement,  Momentus’s  pending  application  had  been  placed  on  hold  or  that,  at  the  
time of the second registration statement, BIS had formally communicated its intent to deny the 
application  for  national  security  reasons.    Those  omissions  were  materially  misleading  because  
they left investors with the impression that Momentus anticipated that Kokorich would ultimately 
receive an export control license, when in fact the company had no basis for that expectation given 
Kokorich’s national security problems. 
81. Both the initial and first amended S-4 registration statements included aggressive 
revenue projections for Momentus, forecasting that the company would grow from zero revenues 
in  2019  to  revenues  of  over  $4  billion  in  2027.    Those  projections  were  materially  misleading,  
however, because they failed to disclose that Kokorich’s ownership and leadership of the company 
jeopardized  Momentus’s  ability  to  earn  any  revenue  from  U.S.-based  launches,  and  Momentus  
only had U.S.-based launches planned at the time. 
82. Kokorich   knew   all   of   the   relevant   facts   related   to   the   various   adverse   
determinations against him for national security reasons.  Specifically, Kokorich knew that in 2018 
he had to divest his interest in his prior space technology company because CFIUS determined he 
posed a threat to national security.  He also knew that Momentus’s 2020 application for an export 
control license for him would be denied for national security reasons.  Similarly, he knew that his 
asylum application was based on a claim that he was a prominent critic of the Russian government, 
an argument that had failed to persuade CFIUS in 2018 that he was not a national security risk.  
And  he  knew  or  was  reckless  in  not  knowing  how  his  status  as  a  national  security  risk  could  
threaten  Momentus’s  ability  to  join  U.S.-based  launches  as  discussed  in  Momentus’s  business  
plans. 

24 
 
83. Kokorich  also  knew  or  was  reckless  in  not  knowing  that  he  failed  to  share  this  
information with Stable Road.  He also knew or was reckless in not knowing that the omission of 
the fact that the denial of the export control licenses for Kokorich because he had been deemed a 
national security risk would mislead investors.  And he knew or was reckless in not knowing that 
his claim that his asylum application would likely be granted, which ignored the U.S. government’s 
repeated conclusions that he was a national security risk, was false. 
CLAIMS 
FIRST CLAIM FOR RELIEF 
 
(Against Kokorich for Violations of Section 10(b) of the Exchange Act and Rule 
10b-5 Thereunder) 
 
84. Paragraphs 1 through 83 are realleged and incorporated by reference as if fully set 
forth herein. 
85. By  reason  of  the  conduct  described  above,  Kokorich,  in  connection  with  the  
purchase or sale of a security, by the use of means or instrumentalities of interstate commerce, of 
the mails, or of the facilities of a national securities exchange, directly or indirectly: (a) used or 
employed devices, schemes, or artifices to defraud; (b) made an untrue statement of a material fact 
or omitted to state a material fact necessary in order to make the statements made, in light of the 
circumstances under which they were made, not misleading; and (c) engaged in acts, practices, or 
courses of business which operated or would operate as a fraud or deceit upon other persons. As 
alleged  above,  Kokorich’s  fraudulent  violations  included:  misleading  Stable  Road  and  its  
representatives   regarding   Momentus’s   technology   and   his   own   national   security   issues;   
participating  in  the  creation,  editing,  or  approval  of  investor  presentations  that  contained  
misrepresentations  or  misleading  omissions  of  material  fact;  making  false  and  misleading  
statements  and  omissions  of  material  fact  directly  to  PIPE  investors;  and  participating  in  the  

25 
 
creation,  review  and  approval  of  portions  of  the  relevant  registration  statements  that  contain  
misrepresentations or misleading omissions of material fact.  
86. While  engaging  in  the  conduct  described  above,  Kokorich  acted  knowingly  or  
recklessly.  
87. By  engaging  in  the  conduct  described  above,  Kokorich  violated,  and  unless  
restrained and 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]. 
SECOND CLAIM FOR RELIEF 
 
(Against Kokorich for Violations of Section 17(a) of the Securities Act) 
  
88. Paragraphs 1 through 83 are realleged and incorporated by reference as if fully set 
forth herein.  
89. By  reason  of  the  conduct  described  above,  Kokorich,  in  the  offer  or  sale  of  
securities, by the use of the means or instruments of transportation or communication in interstate 
commerce or by use of the mails, directly or indirectly: (i) employed devices, schemes, or artifices 
to defraud; (ii) obtained money or property by means of any untrue statement of a material fact or 
any omission to state a material fact 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  
transactions, practices, or courses of business which operated or would operate as a fraud or deceit 
upon  the  purchaser.    As  alleged  above,  Kokorich’s  fraudulent  violations  included:  misleading  
Stable  Road  and  its  representatives  regarding  Momentus’s  technology  and  his  own  national  
security  issues;  participating  in  the  creation,  editing,  or  approval  of  investor  presentations  that  
contained  misrepresentations  or  misleading  omissions  of  material  fact;  making  false  and  
misleading statements and omissions of material fact directly to PIPE investors; and participating 

26 
 
in the creation, review and approval of portions of the relevant registration statements that contain 
misrepresentations or misleading omissions of material fact. 
90. While  engaging  in  the  conduct  described  above,  Kokorich  acted  knowingly,  
recklessly, or negligently.  
91. By  engaging  in  the  conduct  described  above,  Kokorich  violated,  and  unless  
restrained and enjoined will again violate, Sections 17(a) of the Securities Act [15 U.S.C. § 77q(a)]. 
THIRD CLAIM FOR RELIEF 
 
(Against Kokorich for Aiding and Abetting Momentus’s Violations of Section 
10(b) of the Exchange Act) 
 
92. Paragraphs 1 through 83 are realleged and incorporated by reference as if fully set 
forth herein.  
93. Momentus violated 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] by reason of Kokorich’s conduct described above and 
by making false statements and misleading omissions of material fact in the relevant registration 
statements.  
94. Kokorich  knowingly  or  recklessly  provided  substantial  assistance  that  aided  and  
abetted Momentus’s violations. 
95. Accordingly, pursuant to Section 20(e) of the Exchange Act [15 U.S.C. § 78t(e)], 
Kokorich is liable for Momentus’s violations. 
FOURTH CLAIM FOR RELIEF 
 
(Against Kokorich for Aiding and Abetting Violations of Section 17(a) of the 
Securities Act) 
 
96. Paragraphs 1 through 83 are realleged and incorporated by reference as if fully set 
forth herein.  

27 
 
97. Momentus violated Section 17(a) of the Securities Act [15 U.S.C. §§ 77q] by reason 
of Kokorich’s conduct described above and by making false statements and misleading omissions 
of material fact in the relevant registration statements.  
98. Kokorich  knowingly  or  recklessly  provided  substantial  assistance  that  aided  and  
abetted Momentus’s violations. 
99. Accordingly, pursuant to Section 15(b) of the Securities Act [15 U.S.C. § 77o(b)], 
Kokorich is liable for those violations. 
PRAYER FOR RELIEF 
WHEREFORE, the SEC respectfully requests that the Court enter a Final Judgment: 
I. 
Issue  findings  of  fact  and  conclusions  of  law  that  Defendant  Kokorich  committed  the  
alleged violations. 
II. 
Issue  judgments,  in  forms  consistent  with  Rule  65(d)  of  the  Federal  Rules  of  Civil  
Procedure, permanently enjoining Defendant Kokorich 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,  from  violating  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 Section 
17(a) of the Securities Act [15 U.S.C. § 77q(a)]. 
III. 
Order  Defendant  to  disgorge  all  funds  received  from  his  illegal  conduct,  together  with  
prejudgment interest thereon, under Section 21(d)(5) and Section 21(d)(7) of the Exchange Act. 

28 
 
IV. 
Order Defendant to pay civil penalties under 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)]. 
V. 
Enter an order against Kokorich pursuant to Sections 20(e) of the Securities Act [15 U.S.C. 
§ 77t(e)], and Sections 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)], prohibiting him from 
acting  as  an  officer  or  director  of  any  issuer  that  has  a  class  of  securities  registered  pursuant  to  
Section 12 of the Exchange Act [15 U.S.C. § 781] or that is required to file reports pursuant to 
Section 15(d) of the Exchange Act [15 U.S.C. § 78o(d)]. 
VI. 
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. 
VII. 
Grant such other and further relief as this Court may determine to be just and necessary. 
JURY TRIAL DEMAND 
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, the Commission demands 
a jury trial on all the issues so triable. 
Dated:  July 13, 2021 Respectfully submitted, 
               
 
/s/ Fernando Campoamor-Sánchez 
Melissa Armstrong 
Tel: 202.551.4724 
Email: [email protected]  
Fernando Campoamor-Sánchez (DC Bar No. 451210) 

29 
 
Tel: 202.551.8523 
Email: [email protected] 
 
Securities and Exchange Commission 
100 F Street, N.E. 
Washington, D.C. 20549 
 
 

1 
 

UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 

SECURITIES AND EXCHANGE COMMISSION, 
100 F Street, N.E. 
Washington, DC 20549 
 

 

Plaintiff,  

v. 
 

 
Case No. 1:21-CV-1869 
 
JURY TRIAL DEMANDED 
 

MIKHAIL KOKORICH,   
c/o Dorsey & Whitney 
1401 New York Avenue N.W., Suite 900  
Washington DC, 20005 

 
 

  
Defendant.  

 

COMPLAINT 

Plaintiff Securities and Exchange Commission (“SEC”) alleges as follows: 

SUMMARY OF THE ACTION 

1. This case concerns a fraud perpetrated by Defendant Mikhail Kokorich to secure 

and promote a merger agreement between Momentus Inc. (“Momentus”) and Stable Road 

Acquisition Corp. (“Stable Road”), which, if successful, would effectively take Momentus public 

and infuse it with nearly $350 million in investor funds.  Momentus is a privately held space 

technology company that hopes to provide satellite-positioning services.  Kokorich is one of 

Momentus’s founders and was its Chief Executive Officer (“CEO”) at all relevant times.  Stable 

Road is a publicly traded special-purpose acquisition company (“SPAC”). 

2. A Russian citizen who since 2018 has faced repeated adverse determinations from 

U.S. government agencies for national security reasons, Kokorich engaged in fraudulent conduct 

to secure and promote the merger agreement with Stable Road.  Specifically, Kokorich knowingly 



2 
 

or recklessly made misrepresentations of material facts and misleading omissions and deceived 

both Stable Road and investors regarding: (1) Momentus’s key technology which, when tested in 

space in 2019, failed Momentus’s internal criteria for success; and (2) multiple adverse 

determinations against Kokorich for national security reasons, which materially impaired 

Momentus’s ability to participate in U.S.-based rocket launches so long as he was involved with 

the company. 

3.   Momentus attempted in 2019 to test in space its key technology, a microwave 

electro-thermal (“MET”) water plasma thruster.  However, the MET thruster used during that test 

was not designed for commercial use, and the thruster failed Momentus’s own pre-launch criteria 

for a successful test.  As a result, Momentus’s technology remains unproven. 

4. Moreover, no later than 2018, Kokorich faced multiple adverse determinations by 

U.S. government agencies because of concerns that he posed a risk to U.S. national security.  

Therefore, with Kokorich as CEO, Momentus was unlikely to be allowed to participate in U.S.-

based rocket launches because U.S. government agencies, including the U.S. Department of 

Defense, had the authority to block Momentus’s involvement in those launches for national 

security reasons. 

5. In the summer and fall of 2020, Kokorich and Stable Road’s CEO negotiated the 

details of a merger agreement between Momentus and Stable Road.  During those negotiations, 

Kokorich did not disclose the failures associated with the tests of the MET thruster in space, or 

that the U.S. government considered him a risk to national security.  To the contrary, Kokorich 

claimed that the 2019 space test of the MET thruster had been a success and that he was confident 

that the U.S. government would grant his asylum application, which would allow him to remain 

and work in the United States. 



3 
 

6. While he was helping negotiate the terms of the merger, Kokorich also participated 

in a number of presentations to potential Private Investment in Public Equity (“PIPE”) investors, 

investors who purchase shares of stock in a public company directly from the issuer.  Those 

presentations outlined the purported benefits of the proposed business combination between 

Momentus and Stable Road and included the material misrepresentations and misleading 

omissions that Kokorich had previously made. 

7. On October 7, 2020, Momentus and Stable Road announced the signing of a merger 

agreement that would, if ultimately approved by shareholders, essentially take Momentus public 

and generate millions of dollars for Kokorich, Momentus and others.  They also announced that 

Stable Road had entered into subscription agreements with PIPE investors, pursuant to which the 

PIPE investors agreed to purchase an aggregate of 17,500,000 shares of common stock of the 

merged company for $10.00 per share. 

8. Momentus’s business plans and revenue projections, as communicated to PIPE 

investors and described in registration statements filed with the SEC in connection with the 

anticipated merger, were premised on Momentus already having proven technology that it could 

deploy on U.S.-based launches starting in December 2020.  But the technology was unproven, and 

there was profound risk that Momentus would be unable to participate in U.S.-based launches with 

Kokorich in place as CEO.  Because of Kokorich’s knowing or reckless conduct and his 

misrepresentations and misleading omissions of material fact, PIPE and retail investors in the 

SPAC were given materially misleading information upon which to make their investment 

decisions. 

9. By engaging in the misconduct described herein, Kokorich violated the antifraud 

provisions of the Securities and Exchange Act of 1934 (“Exchange Act”) and the Securities Act 



4 
 

of 1933 (“Securities Act”) and aided and abetted violations by Momentus.  Kokorich will continue 

to violate the federal securities laws unless restrained or enjoined by this Court. 

10. The SEC seeks injunctive relief, disgorgement, civil penalties, and other 

appropriate and necessary equitable relief. 

JURISDICTION AND VENUE 

11. The SEC brings this action, and this Court has jurisdiction, pursuant to Securities 

Act Sections 20(b), 20(d), and 22(a) [15 U.S.C. §§ 77t(b), (d), and 77v(a)], and Exchange Act 

Sections 21(d)(1) and 27 [15 U.S.C. §§ 78u(d)(1) and 78aa]. 

12. Defendant Kokorich, directly or indirectly, singly or in concert with others, made 

use of the means or instruments of transportation and communication in interstate commerce, or 

of the mails, or of the facilities of a national securities exchange in connection with the acts, 

transactions, and practices alleged in this Complaint.   

13. Kokorich is subject to personal jurisdiction because, among other things, he lived 

in the United States during the relevant period, purposefully directed his business activities at the 

United States, and knowingly provided statements for use in materials used to promote securities 

transactions in the United States and to be used in SEC filings.  In addition, the merger agreement 

at issue in this case, which Defendant Kokorich signed in his capacity as the CEO of Momentus, 

contains a forum selection clause providing that “to the fullest extent permitted by law, the federal 

district courts of the United States of America shall be the exclusive forum for the resolution of 

any complaint asserting a cause of action arising under the Securities Act of 1933, as amended,” 

and that “[a]ny person or entity holding, owning or otherwise acquiring any interest in any security 

of the Corporation shall be deemed to have notice of and to have consented” the forum selection 

clause. 



5 
 

14. Venue is proper in this district pursuant to Securities Act Section 22(a) [15 U.S.C. 

§ 77v(a)] and Exchange Act Section 27 [15 U.S.C. § 78aa] because Defendant transacts business 

in this district and violations of the securities laws alleged in this Complaint occurred within this 

district, including the filing of false and misleading documents with the SEC. 

DEFENDANT 

15. Mikhail Kokorich, age 45, is a Russian citizen who is currently residing in 

Switzerland.  He served as Momentus’s CEO from the time he helped to start the company in 2017 

until his resignation on January 25, 2021.  Kokorich resided in California from at least 2016 until 

on or about January 27, 2021, when he left the United States.   

OTHER RELEVANT ENTITIES 

16. Momentus is a privately held company incorporated in Delaware and headquartered 

in Santa Clara, California.  Founded in late 2017, Momentus describes itself as a space 

infrastructure company, which hopes to provide, among other things, satellite-positioning services. 

17. Stable Road Acquisition Corp. is a Delaware corporation with its principal place of 

business in Venice, California.  As a SPAC, Stable Road has no operations of its own and exists 

for the purpose of merging with a privately held company and effectively taking that company 

public.  On November 13, 2019, SRAC completed its initial public offering of 17,250,000 units at 

a price of $10.00 per unit, generating gross proceeds of $172.5 million.  Momentus will receive 

the proceeds of the IPO upon completion of the proposed merger with Stable Road.  SRAC’s 

securities are traded on Nasdaq under the ticker symbols “SRAC,” “SRACU,” and “SRACW.” 

I. Background 

a. Momentus Is a Startup with Unproven Technology 

18. Large commercial satellite launch providers  offer launch services to satellite 

owners but only leave these “rideshare” satellites in a limited range of orbits.  Momentus hopes to 



6 
 

offer “last mile” satellite placement services to place these rideshare satellites into custom orbits 

of the customers’ choosing.  According to Momentus’s plans, Momentus will integrate its 

customer’s payload into Momentus’s vehicle, which will then be loaded onto a larger rocket.  The 

rocket will then leave Momentus’s vehicle in orbit, at which point Momentus will move its vehicle 

and the customer’s integrated payload into a custom orbit using what it touted in investor 

presentations as its “cornerstone” technology, a propulsion system using MET water plasma 

thrusters. 

19. Momentus’s business model is premised on the rapid development and testing of 

its MET water propulsion thruster technology.  As Momentus explained in the registration 

statements at issue in this case: “The success of our in-space infrastructure services business will 

depend on our ability to successfully and regularly deploy customer satellites into their custom 

orbits.”  

20. In order to do so, Momentus must operate its MET water propulsion thruster 

reliably in space and provide the necessary thrust and length of operation needed to move customer 

satellites into specified orbits.  An MET water propulsion thruster has never been commercially 

used in space.   

b. Momentus Needed a Test to Market its Technology and Services 

21. In late 2018 and early 2019, Momentus, as a small startup, lacked in-space flight 

experience with its thruster to show that it could deploy customer satellites into custom orbits.  As 

Kokorich recognized, it was important for Momentus to demonstrate that it could build, launch 

and operate an MET thruster system in space.  Kokorich expected that a test in space would help 

to market Momentus and attract investors. 

22. Momentus therefore planned a mission to test its MET thruster in space.  In July 

2019, Momentus launched an MET thruster on the “MX-1” satellite for the purpose of testing its 



7 
 

thruster in space and performing maneuvers.  Prior to the satellite launch, in an internal slide 

presentation, Momentus partly defined “mission success” as “100 individual burns of 1 minute of 

more.”  A “burn” refers to operating the thruster producing thrust for a period of time. 

23. Before the launch of its test mission, Momentus conditioned the public to believe 

that the mission would demonstrate the thruster’s commercial viability.  For example, in a January 

2019 blog post on its website, Momentus stated that the mission, which it named “El Camino 

Real,” would give investors “absolute confidence” that Momentus’s service would be “on time, 

safe and reliable.”  Momentus went on to say that it would “be able to run the thruster long enough 

to fully characterize its performance in space with dozens of stop start cycles and [to] then safely 

de-orbit the vehicle.” 

24. Momentus, through its launch partner, stated in a publicly filed FCC application on 

September 12, 2018, that El Camino Real was “a commercial demonstration” of Momentus’s 

propulsion system that would show its “reliability, longevity, performance, and utility.”  

Momentus explained in the FCC application that the mission’s objective was to demonstrate that 

its thrusters provide “cost-effective high delta V [change in velocity from thrust] capability” and 

thereby show that “this particular system is mature enough to be used by the small satellite market, 

and can be quickly and easily integrated with CubeSats as well as larger, more capable spacecraft.”  

Kokorich reviewed this application at the time it was submitted to the FCC. 

25. Contrary to the claims in Momentus’s blog post or in the FCC application, the 

Momentus MET water propulsion thruster, as integrated into the MX-1 satellite, was not powerful 

enough or appropriate to provide commercial satellite-placement services.  Moreover, the thruster 

was not powerful enough to provide any measurable or detectible changes in the MX-1 satellite’s 

orbital velocity.  As one former Momentus officer stated, the thruster tested in the El Camino Real 



8 
 

mission did not have “commercial potential” because it was “too small, too inefficient, too low in 

[specific impulse], too low in total impulse.”  

c. Momentus’s Test Failed 

26. The El Camino Real mission was a failure. After experiencing significant problems 

with supporting sub-systems and its propulsion system, Momentus attempted only 23 firings, and 

data suggests that only three hot firings produced plasma.  None of those firings lasted a full minute 

or generated measurable thrust.  Momentus lost contact with the satellite approximately three 

months into the planned six-month mission and was never able to attempt the remaining 77 firings 

it had planned, much less achieve any of the “100 individual burns of 1 minute or more.”  Thus, 

Momentus failed to meet its own criteria for mission success, as set forth in its internal slide 

presentation. 

27. Momentus did not perform “dozens of start and stop cycles” or “safely deorbit” the 

vehicle, as represented in its January 2019 blog post. 

28. The MX-1 satellite is still in space, but it is not functional. 

29. The El Camino Real mission did not demonstrate the commercial viability of the 

thruster tested.  One former Momentus officer stated that the mission yielded “no data to suggest 

that that thruster would deliver an impulse of any commercial significance,” and that Momentus 

was not able to characterize the performance of the thrusters.  Additionally, a Momentus engineer 

admitted that the mission did not yield sufficient data to demonstrate the propulsion system’s 

reliability or longevity. 

30. Kokorich was kept informed of the relevant aspects of the El Camino Real results.  

By his own admission, he understood even before the launch that the mission was not designed to 

show that the thruster could provide measurable delta-v (change in velocity from thrust), to 

measure specific impulse (the efficiency of the propulsion system), or to show the thruster’s 



9 
 

reliability.  Kokorich was also copied on emails in November 2019 between Momentus’s Chief 

Technology Officer and its Chief Engineer discussing creation of a “failure review board” to study the 

El Camino Real mission, due to the inability to obtain useful data from the mission because of its failure. 

In addition, one Momentus’s engineer internally acknowledged in February 2020, in a document 

sent to Kokorich, that Momentus did not obtain “any useful mission results” from the launch. 

d. Kokorich Publicly Mischaracterized the Results from Momentus’s Test 

31. In a September 25, 2019, article in the industry periodical Space News titled, 

“Momentus reports success in testing water plasma propulsion,” Kokorich was quoted as stating, 

“Water plasma propulsion is now technologically mature enough to be baselined for 

operational in-space transportation missions,” meaning it could be used commercially.  He 

also repeated the claim from Momentus’s January 2019 blog post that “the purpose of the El 

Camino Real mission was to flight demonstrate our core propulsion technology so customers, 

investors and stakeholders can have absolute confidence that Momentus will deliver their 

payloads to a given orbit.” 

32. As Kokorich knew or was reckless in not knowing, his claims in the Space News 

article were false and misleading because the El Camino Real mission was never intended to 

demonstrate the thruster’s commercial viability or to give investors and customers “absolute 

confidence” that Momentus could maneuver customer payloads to a custom orbit.  Moreover, the 

mission was a failure because the thruster produced plasma, which is necessary but not sufficient 

to generate thrust, only three times out of 23 attempts, and for less than a full minute each time, 

which did not meet Momentus’s own criteria and explains why they did not obtain “any useful 

mission results.”  Even if the mission had achieved Momentus’s internal criteria for success—

which it did not, as Kokorich knew—it would not have demonstrated that the thruster was 

“technologically mature enough to be baselined for operational in-space transportation missions.” 



10 
 

e. Adverse Determinations Against Kokorich for National Security Reasons  

33. Since 2018, multiple U.S. government agencies have taken actions adverse to 

Kokorich for national security reasons – a fact known to Kokorich.  

34. The Bureau of Industry and Security (“BIS”), a bureau of the U.S. Department of 

Commerce, oversees the issuance of export control licenses, which authorize the provision of 

certain technologies to foreign individuals or entities.  The stated mission of the BIS is to “advance 

U.S. national security, foreign policy, and economic objectives.”  

35. Because Kokorich is a Russian citizen, he could not access Momentus’s export-

controlled technology without an export control license.  In 2017, Momentus (then operating under 

the name “Space Apprentices Enterprise”) applied for an export control license for Kokorich.  In 

March 2018, the BIS denied the application. In its rejection notice to Momentus, BIS explained 

that, after consulting with the Departments of Defense and State, it had concluded that Kokorich 

was not an “acceptable recipient” of the technology “for national security reasons.” 

36. In April 2018, in connection with Kokorich’s investment in a different space 

technology company he founded before Momentus, the Committee on Foreign Investment in the 

United States (“CFIUS”), an intergovernmental agency that includes the U.S. Departments of 

Commerce, Defense, and State sent a letter to Kokorich.  In that letter, CFIUS informed Kokorich 

that it “believe[d]” his investment and the investments of certain others “pose[d] a risk to the 

national security of the United States.”  CFIUS explained that its analysis included an assessment 

of whether “a foreign person has the capability or intention to exploit or cause harm” (which 

CFIUS defines as the “threat”), and “whether the nature of the U.S. business creates susceptibility 

to impairment of U.S. national security (the “vulnerability”).”  CFIUS further explained that a 

national security risk is a “function of the interaction between threat and vulnerability.”  



11 
 

37. On or about June 22, 2018, CFIUS representatives participated in a teleconference 

with Kokorich’s attorneys.  On that call, CFIUS representatives informed Kokorich’s attorneys 

that CFIUS had determined that a full divestiture of Kokorich’s participation in the space 

technology company was necessary to mitigate the national security concerns.  

38. After the teleconference, in a letter response dated June 24, 2018, on which 

Kokorich was copied, Kokorich’s attorneys stated that they understood that CFIUS had deemed 

Kokorich a national security risk and tried to persuade CFIUS to reconsider this determination.  

Kokorich’s attorneys argued that he was actually a national security asset and a vocal critic of the 

Russian government.   

39. Kokorich’s argument did not work.  In a letter dated June 25, 2018, CFIUS told 

Kokorich that it would require him to divest his ownership and control interest in the space 

technology company.  CFIUS explained that its concerns related, in part, to the sophistication of 

the company’s technology and concerns involving Kokorich and other foreign investors. 

f. Kokorich’s Attempts to Legally Remain in the United States Were 
Repeatedly Rebuffed 

40. In or about June 2018, U.S. Customs and Immigration Services (“USCIS”) revoked 

Kokorich’s work visa and denied his application for permanent resident status.  In response, 

Kokorich applied for political asylum and withholding of removal proceedings in September 2018, 

claiming again that he was a prominent critic of the Russian government. 

41. A year later, on or about August 28, 2019, USCIS issued a referral notice informing 

Kokorich that it had not granted his asylum application, and that it had referred his case to an 

immigration judge for adjudication in removal proceedings.  USCIS stated that its determination 

was based on “inconsistencies” in Kokorich’s application and testimony “with regard to [his] 

political affiliations and activities in Russia.”  



12 
 

42. On or about that same date, multiple government agencies, including the FBI, the 

U.S. Department of Homeland Security, and the BIS’s Office of Export Enforcement, arrived 

unannounced at Momentus’s headquarters.  Agents questioned multiple Momentus employees 

about possible export control violations by Kokorich as well as improper technology transfers. 

43. Before they left, the federal agents detained Kokorich and transported him to an 

immigration detention center.  Kokorich was subsequently released on bond. 

g. Kokorich Sought a SPAC Merger with Momentus 

44. By late 2019, Momentus was in constant fundraising mode.  The company had no 

revenues and needed additional capital to fund its growth.  Beginning in early 2020, Kokorich had 

discussions with an investment bank in an attempt to secure additional capital for Momentus’s 

operations.  In mid-2020, Momentus formally engaged the bank and sought its assistance to find a 

suitable SPAC candidate for a merger.   

45. In addition to his discussions with Stable Road, Kokorich had discussions with two 

other SPACs.  The two other SPACs chose not to move forward with a merger with Momentus 

because Momentus was still at a relatively early stage and immature as a company. 

46. On or about June 29, 2020, Kokorich and Stable Road’s CEO met in person for the 

first time at Stable Road’s offices in California to discuss the possibility of a merger between the 

two companies.  After the initial discussion, merger negotiations began in earnest in July 2020.  

Kokorich remained heavily involved in merger negotiations, including on the subject of 

Momentus’s valuation and business model.  He also helped develop a list of PIPE investors to 

contact and reviewed draft presentations to PIPE investors. 

47. Pursuant to the merger agreement ultimately signed by Momentus and Stable Road, 

if approved by the shareholders, Kokorich would become the CEO of the new merged company. 



13 
 

Kokorich was also entitled to exchange his shares of Momentus stock for approximately 19 million 

shares of stock in the new publicly traded company, which would be between 13.5% and 14.3% 

of the total shares outstanding. 

II. Kokorich and Momentus Made Misrepresentations of Material Fact and 
Misleading Omissions about Momentus’s Technology  

48. From his very first meeting with Stable Road’s CEO on June 29, 2020, Kokorich 

made misrepresentations and misleading omissions of material fact.  For example, Kokorich told 

Stable Road’s CEO that the El Camino Real mission had been a success and that it was a great 

achievement for Momentus to have fired the thruster and tested its propulsion technology in space.  

Specifically, Kokorich said that Momentus had performed a number of tests, with recorded data, 

and that the vehicle was still in space although they could no longer conduct additional tests. 

49. Notably, in that discussion, Kokorich omitted material facts that made his 

statements about the El Camino Real mission misleading.  Kokorich did not tell Stable Road’s 

CEO of any of the failures, problems, shortcomings, or issues with the El Camino Real mission 

described above.  Moreover, Kokorich did not explain to Stable Road’s CEO that the El Camino 

Real mission was not designed to show any demonstrable impulse or delta-v from the thruster, or 

to demonstrate the thruster’s reliability. 

50. At the time he made these misstatements and misleading omissions of material fact, 

Kokorich knew, was reckless in not knowing, or should have known that Stable Road and its CEO 

would rely on his statements in determining to proceed with the merger and PIPE fund-raising, 

and that his false and misleading statements would be repeated to investors while promoting the 

merger. 

51. Before signing the merger agreement, Momentus and Stable Road made multiple 

presentations to potential PIPE investors via Zoom.  Kokorich personally participated in these 



14 
 

presentations, and he mentioned the alleged “success” of the El Camino Real mission, but failed 

to disclose the significant failures, problems, shortcomings, and issues described above.  The 

presentations were conducted by video conference and included slides that were shown to the PIPE 

investors during the presentations.  Each of those presentations contained a slide titled, “Momentus 

at a Glance,” which misleadingly claimed that Momentus “successfully tested water based 

propulsion technology on a demo flight launched mid-2019 – is still operational today.”  In total, 

PIPE investors agreed to purchase 17,500,000 shares of common stock of the merged company for 

$10.00 per share. 

52. Momentus and Stable Road announced their merger on October 7, 2020.  That day, 

Kokorich and Stable Road’s CEO made a presentation on a conference call to analysts and 

institutional investors using slides virtually identical to the ones shown to PIPE investors.  This 

presentation similarly contained the claim that Momentus “successfully tested water based 

propulsion technology on a demo flight launched mid-2019 – is still operational today.”  In his 

scripted comments, Kokorich falsely reiterated that Momentus had “successfully tested our 

groundbreaking thruster in space.”  Again, Kokorich failed to disclose the significant failures, 

problems, shortcomings, or issues described above.  Stable Road publicly filed a copy of these 

slides and the presenters’ script on a Form 8-K later that day. 

53. During Kokorich’s tenure as Momentus’s CEO, Stable Road filed an initial S-4 

registration statement related to the merger on November 2, 2020, and a subsequent amended 

registration statement on December 14, 2020.  A registration statement is a filing with the SEC 

making required disclosures in connection with the registration of a security, a securities 

offering, or an investment company under federal securities laws.   



15 
 

54. Kokorich participated in the preparation of the November and December 2020 S-4 

registration statements, and specifically the subsections of the S-4 statements that described or 

contained information about Momentus.  In addition to the overall review and approval of 

Momentus’s portion of the registration statements as Momentus’s CEO, Kokorich helped to draft 

what he described as the technology and business or market strategy sections of the S-4 statements. 

55. Each registration statement contained a subsection titled, “Information about 

Momentus” that is written in Momentus’s voice, and that Momentus drafted.  In this subsection of 

each registration statement, Momentus falsely states that it “successfully tested our water plasma 

propulsion technology in space,” referring to the El Camino Real mission. 

56. Each subsection also contained a graphic captioned: “Our water plasma propulsion 

technology.”  In the body of the slide there is a diagram of a thruster surrounded by various claims 

about the thruster’s functionality, including: “High ISP – Tunable up to 2 to 5 times common 

chemical propulsion systems”; and “High thrust – Tunable up to 3 to 10 times most common 

electrical propulsion systems.”  

57. Momentus’s characterizations of the El Camino Real mission in the registration 

statements were false and misleading.  Momentus boasted in its graphic that its “water plasma 

propulsion technology” offered high thrust and high ISP (specific impulse), and elsewhere claimed 

that its “water plasma propulsion technology” was successfully tested in space.  However, the El 

Camino Real mission did not demonstrate high thrust or high specific impulse.  It did not 

demonstrate that the thruster it tested was “tunable up to 2 to 5 times common chemical propulsion 

systems” or “up to 3 to 30 times most common electrical propulsion systems.”  The registration 

statements failed to disclose any of the significant failures, problems, shortcomings, or issues 



16 
 

described above.  The claims in the registration statements that Momentus “successfully tested” 

its technology were therefore materially false and misleading. 

58. Moreover, the only publicly available criteria for what constituted success for the 

mission were contained in Momentus’s pre-launch blog post and the FCC application filed by 

Momentus’s launch partner.  By characterizing the mission as a success without explaining the 

many failures and problems experienced during the mission, or that the mission failed Momentus’s 

pre-launch evaluation criteria, Kokorich and Momentus made materially false statements and/or 

omitted facts necessary to make their statements not misleading. 

59. Investors had no way of knowing, based on the bare claim that the El Camino Real 

mission “successfully tested” Momentus’s thrusters, that the mission did not demonstrate that 

Momentus’s services would be “on time, safe and reliable,” as promised in the blog.  Similarly, 

they had no way to know that the mission did not demonstrate the thrusters’ “reliability, longevity, 

performance, and utility,” as described in the FCC application. 

60. On June 29, 2021, Stable Road and Momentus filed with the SEC an amended 

registration statement that corrected these false statements and misleading omissions by describing 

the actual results of the El Camino Real mission.  The registration statement explained that “[t]he 

mission’s objective was to demonstrate the MET’s ability to produce water plasma in space by 

performing 100 one minute firings.”  After discussing the failure of the MX-1 satellite, and the 

associated problems with the attempted firings of the thruster which were stopped “after only 23 

of the planned 100 firings had been performed,” the statement clarified that “a pump issue 

significantly restricted flow of water into the thruster during nine of the 12 hot firings, preventing 

plasma generation” and that “the three hot firings that did have water present were found to have 

produced plasma.” 



17 
 

61. Kokorich and Momentus’s false statements and misleading omissions were 

material to investors.  Because Momentus can only generate revenue under its current business 

plan if its thruster can generate commercially significant thrust, reasonable investors would find it 

important to know whether Momentus had actually proven that its technology is commercially 

viable.  They would find it important to know whether Momentus had shown that its services 

would be “on time, safe and reliable” or whether Momentus could “deliver [customer] payloads 

to a given orbit.”  They would also find it important to know whether the mission succeeded 

according to Momentus’s pre-launch definition of success.  By misleading investors about the 

results of the in-space testing, Kokorich and Momentus gave investors false comfort that 

Momentus was further on the road to the commercial deployment of its technology than it actually 

was.  

62. Kokorich and Momentus knowingly or recklessly made the misrepresentations and 

omissions of material fact regarding the El Camino Real mission, as described in paragraphs 48 

through 61 above.  They understood that the launch was never designed to test the commercial 

viability of Momentus’s thrusters.  They also knew that the launch did not yield “any useful 

mission results,” as one of Momentus’s engineers wrote in an internal document shared with 

Kokorich.  Yet they claimed that the test would give investors “absolute confidence” that 

Momentus could deliver customer payloads to a given orbit and repeatedly represented that the 

mission was a success without any qualification. 

III. Kokorich and Momentus Made Misrepresentations of Material Fact and 
Misleading Omissions about Kokorich’s National Security Issues 

a. U.S. Government Agencies’ National Security Determinations Regarding 
Kokorich Threatened Momentus’s Viability 

63. Before it is able to launch any vehicle on a U.S. mission, Momentus or its launch 

partners must obtain licenses from various U.S. government agencies, including the Federal 



18 
 

Aviation Administration (“FAA”).  Those agencies have the authority to deny a license for national 

security reasons and work in consultation with the U.S. Department of Defense to determine if the 

payload of a mission presents a national security risk.  

64. If Momentus or its launch partner is unable to obtain the necessary licenses, 

Momentus cannot execute on its business plan.  It may be unable to conduct additional missions 

to test its technology.  It may also never be able to offer commercial satellite placement services.  

65. The U.S. government’s national security-related determinations about Kokorich 

therefore posed a significant threat to Momentus’s ability to participate in launches and generate 

meaningful revenue and were material.  

b. Kokorich and Momentus Repeatedly Mischaracterized Kokorich’s National 
Security Issues 

66. Just as he had misled Stable Road’s CEO about the purported “success” of the El 

Camino Real mission, from the beginning of the merger discussions, Kokorich told Stable Road’s 

CEO that he was confident that his asylum application would be approved.  Specifically, Kokorich 

told Stable Road’s CEO prior to signing the merger agreement that he had a strong case for political 

asylum, and that he also had a second path to U.S. citizenship if for any reason the asylum 

application was not granted.  Kokorich’s immigration status was of interest to Stable Road because 

Kokorich was supposed to lead the new company and because Momentus described him as 

important to the company’s success.  As Momentus stated in the relevant registration statements 

filed on November 2, 2020 and December 14, 2020, “Momentus is highly dependent on Mikhail 

Kokorich, its co-founder and chief executive officer. Mr. Kokorich invented the majority of 

Momentus’s inventions and remains deeply involved in Momentus’s business.” 

67. Notably, Kokorich did not tell Stable Road’s CEO that the USCIS had previously 

issued a referral notice saying that it had not granted his asylum application, and that it had referred 



19 
 

his case to an immigration judge for adjudication in removal proceedings.  Kokorich also assured 

Stable Road’s CEO that the CFIUS divestiture order regarding his other space technology 

company was closed, and that it was a different situation from his Momentus ownership.  In that 

vein, Kokorich asserted that the issues CFIUS raised in the prior matter had to do with other 

investors, not specifically him, even though he knew or was reckless in not knowing the opposite 

was true based on CFIUS’s communications with his counsel. 

68. Kokorich and Momentus also failed to share with Stable Road the extent of 

Kokorich’s national security issues with the U.S. government.  Specifically, they did not tell Stable 

Road that U.S. government agencies had previously, and repeatedly, made adverse determinations 

against Kokorich for national security reasons.  

69. Despite Kokorich’s assurances that his asylum application would be granted, U.S. 

government agencies’ adverse determinations against Kokorich for national security reasons 

continued to create problems for him and Momentus in the months leading up to the merger 

announcement.  In February 2020, Momentus filed a new application for an export control license 

for Kokorich.  On April 15, 2020, Momentus learned that the application’s status was “hold 

without action,” meaning the application had been placed on hold by the BIS reviewer.  On October 

7, 2020, the day the merger was announced, a BIS representative emailed Momentus’s Deputy 

General Counsel and Chief Ethics and Compliance Officer to convey, in part, that the Departments 

of Defense and State had indicated that they would recommend denying the application.  Two days 

later, the same representative further disclosed that the Departments of Defense, State and Energy 

had all recommended denying the application.  On October 23, 2020, the representative emailed 

to disclose that BIS’s Operating Committee had determined to deny the license, although the 

representative indicated the possibility that he might seek to appeal that decision internally.  



20 
 

70. On November 9, 2020, after the filing with the SEC of the first registration 

statement for the merger, but before the filing of the second registration statement, Momentus and 

Kokorich learned that there would be no internal appeal and that U.S. Department of Commerce 

would deny Momentus’s pending application for an export control license for Kokorich.  

Momentus received the formal notification of the intent to deny the application.  That letter 

notification stated that Momentus’s technology would make a “significant contribution to the 

military potential to any other country or combination of countries which would prove detrimental 

to the national security of the United States” and that Kokorich was not an acceptable recipient of 

Momentus’s technology. 

c. Kokorich’s National Security Issues Negatively Affected Momentus’s 
Operations  

71. The growing issues that Momentus faced by having Kokorich as a CEO came to a 

head in December 2020, just two months after the merger announcement.  Momentus was 

scheduled to participate in a launch with a large commercial launch provider in January 2021.  That 

launch represented a key milestone for Momentus because it was supposed to be the company’s 

first commercial flight.  

72. On December 22, 2020, the FAA notified the launch provider that it would not 

approve the upcoming rocket launch with Momentus’s payload on board.  As a result, the launch 

provider removed Momentus’s payload from its rocket and proceeded with the launch. On January 

4, 2021, Momentus issued a press release stating that it was “remanifesting its January 2021 mission 

to a subsequent launch opportunity in 2021,” which would “allow for the additional time necessary 

to secure FAA approval of Momentus’s payloads.”  On January 7, 2021, the FAA sent a letter to 

the launch provider explaining that the Department of Defense had identified potential national 

security concerns with Momentus’s payloads and that it could not approve the provider’s launch if21 
 

it included Momentus’s payload because the Department of Defense’s review would not be 

complete before the launch date. 

73. Shortly after this setback, on January 21, 2021, Momentus learned of a letter from 

the Department of Defense stating that Momentus posed a risk to national security as a result of 

Kokorich’s ownership and control of the company.  On January 25, 2021, Kokorich stepped down 

as CEO of Momentus and placed his shares of Momentus stock in a voting trust.  

74. Even that did not solve Momentus’s problems, however.  In May 2021, the FAA 

once again did not approve Momentus’s participation in a June 2021 launch with the launch 

provider. On May 10, 2021, Momentus received a letter from the U.S. Federal Aviation 

Administration (“FAA”) denying Momentus’s application for a payload review.  

75. The FAA explicitly based its denial on a finding that the launch of Momentus’s 

payload would jeopardize national security due to Momentus’s then-current corporate structure. 

76. Later in May 2021, the launch provider informed Momentus that it would not allow 

any Momentus payload on any launch through the end of the year while Momentus “works to 

secure approvals from the U.S. government.”  Momentus’s best-case scenario, therefore, is an 

inaugural commercial launch in January 2022, a full year after Momentus hoped to begin offering 

commercial services.   

77. On June 9, 2021, Kokorich and Momentus entered into a National Security 

Agreement with CFIUS, pursuant to which Kokorich agreed to fully divest from the company and 

Momentus agreed, among other things, to implement increased security measures and appoint a 

CFIUS-approved director to its board of directors. 



22 
 

d.  Material Misrepresentations and Misleading Omissions in the Registration 
Statements 

78. As a result of Kokorich and Momentus’s deception, both the initial registration 

statement, filed in November 2020, and the amended registration statement, filed in December 

2020 (after Momentus learned that Kokorich’s most recent application for an export license would 

be denied for national security reasons), contain material false statements and misleading 

omissions regarding Kokorich’s national security status.  As described in Paragraph 54, Kokorich 

participated in the preparation of the November and December 2020 S-4 registration statements.  

In his role as CEO, Kokorich generally reviewed and approved Momentus’s portion of the 

registration statements. 

79. As described above, each registration statement contained a subsection titled, 

“Information about Momentus,” that Momentus drafted.  Kokorich reviewed and approved these 

subsections before they were provided to Stable Road for inclusion in the registration statement. 

In that subsection, Momentus stated that it believed Kokorich’s asylum application would be 

granted.  Because the U.S. government would be unlikely to grant asylum to an individual it 

viewed as a national security threat, that statement falsely implied that Kokorich was not a national 

security risk.  Kokorich knew that multiple U.S. government agencies had raised national security 

concerns about him and had provided specific grounds for doing so.  To state that Momentus 

believed Kokorich’s asylum application would be granted without disclosing the actions taken by 

these agencies or their stated grounds for doing so was materially misleading. 

80. Additionally, in the “Risk Factors” subsection, which Momentus also drafted and 

provided to Stable Road for inclusion in the registration statement, and which Kokorich reviewed 

and did not correct, Momentus disclosed that Kokorich had not “yet” obtained an export control 

license.  Momentus did not explain, however, that the BIS had denied Momentus’s first application 



23 
 

in 2018 because of national security issues.  It also did not explain that, at the time of the first 

registration statement, Momentus’s pending application had been placed on hold or that, at the 

time of the second registration statement, BIS had formally communicated its intent to deny the 

application for national security reasons.  Those omissions were materially misleading because 

they left investors with the impression that Momentus anticipated that Kokorich would ultimately 

receive an export control license, when in fact the company had no basis for that expectation given 

Kokorich’s national security problems. 

81. Both the initial and first amended S-4 registration statements included aggressive 

revenue projections for Momentus, forecasting that the company would grow from zero revenues 

in 2019 to revenues of over $4 billion in 2027.  Those projections were materially misleading, 

however, because they failed to disclose that Kokorich’s ownership and leadership of the company 

jeopardized Momentus’s ability to earn any revenue from U.S.-based launches, and Momentus 

only had U.S.-based launches planned at the time. 

82. Kokorich knew all of the relevant facts related to the various adverse 

determinations against him for national security reasons.  Specifically, Kokorich knew that in 2018 

he had to divest his interest in his prior space technology company because CFIUS determined he 

posed a threat to national security.  He also knew that Momentus’s 2020 application for an export 

control license for him would be denied for national security reasons.  Similarly, he knew that his 

asylum application was based on a claim that he was a prominent critic of the Russian government, 

an argument that had failed to persuade CFIUS in 2018 that he was not a national security risk.  

And he knew or was reckless in not knowing how his status as a national security risk could 

threaten Momentus’s ability to join U.S.-based launches as discussed in Momentus’s business 

plans. 



24 
 

83. Kokorich also knew or was reckless in not knowing that he failed to share this 

information with Stable Road.  He also knew or was reckless in not knowing that the omission of 

the fact that the denial of the export control licenses for Kokorich because he had been deemed a 

national security risk would mislead investors.  And he knew or was reckless in not knowing that 

his claim that his asylum application would likely be granted, which ignored the U.S. government’s 

repeated conclusions that he was a national security risk, was false. 

CLAIMS 

FIRST CLAIM FOR RELIEF 
 

(Against Kokorich for Violations of Section 10(b) of the Exchange Act and Rule 
10b-5 Thereunder) 

 
84. Paragraphs 1 through 83 are realleged and incorporated by reference as if fully set 

forth herein. 

85. By reason of the conduct described above, Kokorich, in connection with the 

purchase or sale of a security, by the use of means or instrumentalities of interstate commerce, of 

the mails, or of the facilities of a national securities exchange, directly or indirectly: (a) used or 

employed devices, schemes, or artifices to defraud; (b) made an untrue statement of a material fact 

or omitted to state a material fact necessary in order to make the statements made, in light of the 

circumstances under which they were made, not misleading; and (c) engaged in acts, practices, or 

courses of business which operated or would operate as a fraud or deceit upon other persons. As 

alleged above, Kokorich’s fraudulent violations included: misleading Stable Road and its 

representatives regarding Momentus’s technology and his own national security issues; 

participating in the creation, editing, or approval of investor presentations that contained 

misrepresentations or misleading omissions of material fact; making false and misleading 

statements and omissions of material fact directly to PIPE investors; and participating in the 



25 
 

creation, review and approval of portions of the relevant registration statements that contain 

misrepresentations or misleading omissions of material fact.  

86. While engaging in the conduct described above, Kokorich acted knowingly or 

recklessly.  

87. By engaging in the conduct described above, Kokorich violated, and unless 

restrained and 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]. 

SECOND CLAIM FOR RELIEF 
 

(Against Kokorich for Violations of Section 17(a) of the Securities Act) 
  

88. Paragraphs 1 through 83 are realleged and incorporated by reference as if fully set 

forth herein.  

89. By reason of the conduct described above, Kokorich, in the offer or sale of 

securities, by the use of the means or instruments of transportation or communication in interstate 

commerce or by use of the mails, directly or indirectly: (i) employed devices, schemes, or artifices 

to defraud; (ii) obtained money or property by means of any untrue statement of a material fact or 

any omission to state a material fact 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 

transactions, practices, or courses of business which operated or would operate as a fraud or deceit 

upon the purchaser.  As alleged above, Kokorich’s fraudulent violations included: misleading 

Stable Road and its representatives regarding Momentus’s technology and his own national 

security issues; participating in the creation, editing, or approval of investor presentations that 

contained misrepresentations or misleading omissions of material fact; making false and 

misleading statements and omissions of material fact directly to PIPE investors; and participating 



26 
 

in the creation, review and approval of portions of the relevant registration statements that contain 

misrepresentations or misleading omissions of material fact. 

90. While engaging in the conduct described above, Kokorich acted knowingly, 

recklessly, or negligently.  

91. By engaging in the conduct described above, Kokorich violated, and unless 

restrained and enjoined will again violate, Sections 17(a) of the Securities Act [15 U.S.C. § 77q(a)]. 

THIRD CLAIM FOR RELIEF 
 

(Against Kokorich for Aiding and Abetting Momentus’s Violations of Section 
10(b) of the Exchange Act) 

 
92. Paragraphs 1 through 83 are realleged and incorporated by reference as if fully set 

forth herein.  

93. Momentus violated 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] by reason of Kokorich’s conduct described above and 

by making false statements and misleading omissions of material fact in the relevant registration 

statements.  

94. Kokorich knowingly or recklessly provided substantial assistance that aided and 

abetted Momentus’s violations. 

95. Accordingly, pursuant to Section 20(e) of the Exchange Act [15 U.S.C. § 78t(e)], 

Kokorich is liable for Momentus’s violations. 

FOURTH CLAIM FOR RELIEF 
 

(Against Kokorich for Aiding and Abetting Violations of Section 17(a) of the 
Securities Act) 

 
96. Paragraphs 1 through 83 are realleged and incorporated by reference as if fully set 

forth herein.  



27 
 

97. Momentus violated Section 17(a) of the Securities Act [15 U.S.C. §§ 77q] by reason 

of Kokorich’s conduct described above and by making false statements and misleading omissions 

of material fact in the relevant registration statements.  

98. Kokorich knowingly or recklessly provided substantial assistance that aided and 

abetted Momentus’s violations. 

99. Accordingly, pursuant to Section 15(b) of the Securities Act [15 U.S.C. § 77o(b)], 

Kokorich is liable for those violations. 

PRAYER FOR RELIEF 

WHEREFORE, the SEC respectfully requests that the Court enter a Final Judgment: 

I. 

Issue findings of fact and conclusions of law that Defendant Kokorich committed the 

alleged violations. 

II. 

Issue judgments, in forms consistent with Rule 65(d) of the Federal Rules of Civil 

Procedure, permanently enjoining Defendant Kokorich 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, from violating 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 Section 

17(a) of the Securities Act [15 U.S.C. § 77q(a)]. 

III. 

Order Defendant to disgorge all funds received from his illegal conduct, together with 

prejudgment interest thereon, under Section 21(d)(5) and Section 21(d)(7) of the Exchange Act. 



28 
 

IV. 

Order Defendant to pay civil penalties under 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)]. 

V. 

Enter an order against Kokorich pursuant to Sections 20(e) of the Securities Act [15 U.S.C. 

§ 77t(e)], and Sections 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)], prohibiting him from 

acting as an officer or director of any issuer that has a class of securities registered pursuant to 

Section 12 of the Exchange Act [15 U.S.C. § 781] or that is required to file reports pursuant to 

Section 15(d) of the Exchange Act [15 U.S.C. § 78o(d)]. 

VI. 

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. 

VII. 

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

JURY TRIAL DEMAND 

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, the Commission demands 

a jury trial on all the issues so triable. 

Dated:  July 13, 2021 Respectfully submitted, 
               

 
/s/ Fernando Campoamor-Sánchez 
Melissa Armstrong 

Tel: 202.551.4724 
Email: [email protected]  

Fernando Campoamor-Sánchez (DC Bar No. 451210) 



29 
 

Tel: 202.551.8523 
Email: [email protected] 
 

Securities and Exchange Commission 
100 F Street, N.E. 
Washington, D.C. 20549