SEC v. Christopher P. Vallos, No. 1:22-cv-11613, District of Massachusetts (Sept. 23, 2022) — Complaint

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

SECURITIES AND EXCHANGE COMMISSION,

                                    Plaintiff,

            v.

CHRISTOPHER P. VALLOS,

                                    Defendant.

Civil Action No. 22-CV-____ (___)

JURY TRIAL DEMANDED

COMPLAINT

Plaintiff, the United States Securities and Exchange Commission (the “Commission” or
“SEC”), for its complaint against Defendant, Christopher P. Vallos, alleges as follows:
SUMMARY
1. From at least July 2016 through at least May 2017 (the “Relevant Period”),
Christopher P. Vallos engaged in a scheme to sell company stock to retail investors in the public
United States securities markets, while concealing the fact that he also controlled the company.
By engaging in this deceptive conduct, Vallos deprived investors of the full and fair disclosure
mandated by the federal securities laws.
2. As a result of the conduct alleged herein, the Defendant violated, and unless
restrained and enjoined will continue to violate, Sections 17(a) of the Securities Act of 1933
(“Securities Act”) and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”)
and Rule 10b-5 thereunder.
NATURE OF THE PROCEEDING AND RELIEF SOUGHT
3. The Commission brings this action pursuant to the authority conferred upon it by

2
Section 20(b) of the Securities Act [15 U.S.C. § 77t(b)] and Section 21(d) of the Exchange Act
[15 U.S.C. §§ 78u(d)(1) and 78u(d)(5)].
4. The Commission seeks a final judgment: permanently enjoining the Defendant
from engaging in the transactions, acts, practices, and courses of business alleged in this
Complaint; disgorgement of all ill-gotten gains from the unlawful conduct set forth in this
Complaint, together with prejudgment interest pursuant to Section 21(d) of the Exchange Act; an
order permanently prohibiting the Defendant from participating in any offering of a penny stock,
pursuant to Section 20(g) of the Securities Act [15 U.S.C. § 77t(g)] and/or Section 21(d) of the
Exchange Act [15 U.S.C. § 78u(d)]; an order prohibiting the Defendant from serving as an
officer or director of any company that has a class of securities registered under Section 12 of the
Exchange Act [15 U.S.C. § 781] or that is required to file reports under Section 15(d) of the
Exchange Act [15 U.S.C. § 78o(d)], pursuant to Section 20(e) [15 U.S.C. § 77t(e)] of the
Securities Act and Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)]; and such other
relief as the Court may deem appropriate.
JURISDICTION AND VENUE
5. This Court has jurisdiction over this action pursuant to Section 22(a) of the
Securities Act [15 U.S.C. § 77v(a)] and Sections 21(d), 21(e), and 27 of the Exchange Act [15
U.S.C. §§ 78u(d), 78u(e), and 78aa].
6. Defendant, directly and indirectly, has made use of the means and
instrumentalities of interstate commerce, of the mails and wires, and/or of the facilities of a
national securities exchange in connection with transactions, acts, practices, and courses of
business alleged herein.
7. Venue lies in this Court pursuant to Section 22(a) of the Securities Act [15 U.S.C.

3
§ 77v(a)] and Section 27 of the Exchange Act [15 U.S.C. § 78aa].  Certain of the acts, practices,
and transactions and courses of business alleged in this Complaint occurred within the District of
Massachusetts.  For example, during the Relevant Period, certain individuals who reside in the
District of Massachusetts purchased the stock of Gold Lakes Corporation.
DEFENDANT
8. Christopher P. Vallos, age 48, was a resident of Painesville, Ohio during the
relevant period.  Vallos was the President and Chief Executive Officer of Gold Lakes
Corporation from November 2014 to September 2018.
RELEVANT ENTITY
9. Gold Lakes Corporation (“Gold Lakes”) was a publicly-traded Nevada
corporation with its principal place of business in Beachwood, Ohio.  It was incorporated under
the name Siga Resources, Inc.  The company also previously operated under the name TNX
Maverick Corp.  Gold Lakes was a microcap or penny stock, the shares of which were traded
under the ticker symbol “GLLK” on OTC Link LLC (an Alternative Trading System that
displays quotes from broker-dealers for many over-the-counter securities operated by OTC
Markets Group Inc.).  Gold Lakes purported to be an exploration stage company that specialized
in the acquisition and development of mining assets.
BACKGROUND
10. An “affiliate” of a company whose stock is publicly-traded (often referred to as an
“issuer”) is a person or entity that, directly or indirectly through one or more intermediaries,
controls, is controlled by, or is under common control with, such issuer (i.e., a control person).
“Control” means the power to direct management and policies of the company in question.
Typically, affiliates include officers, directors and controlling shareholders but any person who is

4
under “common control” with or has common control of an issuer is also an affiliate.
11. The federal securities laws require that, before selling stock, an affiliate of a
company comply with certain registration requirements, sale restrictions, and disclosure
obligations.  These laws are critical safeguards designed to inform investors about the nature of
the stock they are holding or considering buying, and from whom they would be buying that
stock.
FACTS
12. In or around November 2014, Vallos became the President and Chief Executive
Officer (CEO) of Gold Lakes.  As a result, Vallos had the ability to direct the management and
policies of Gold Lakes, and was therefore an affiliate of Gold Lakes.
13. In or around July 2016, a company (referred to hereafter as “Company A”) loaned
Gold Lakes $50,000, and Gold Lakes executed a promissory note with Fund A in which it agreed
to repay the funds to Company A.  Company A was controlled by a business associate of Vallos.
14. In or around April 2017, Vallos created, and caused to be created, documentation
which transferred and assigned $1,500 of Company A’s promissory note to an individual
(referred to hereafter as “Individual 1”).  In other words, Gold Lakes’s obligation to pay $1,500
of its outstanding debt to Company A was transferred from Company A to Individual 1; Gold
Lakes then owed Individual 1 $1,500.  The transfer agreement also contained a right for
Individual 1 to convert the $1,500 debt obligation to 150,000,000 shares of Gold Lakes stock.
15. At this time, Individual 1, by virtue of their close relationship with Vallos, was an
affiliate of Gold Lakes.  However, when the documentation reflecting the transfer and
assignment of the debt obligation was submitted to a registered brokerage firm, Vallos included a
document that falsely stated that Individual 1 was not an affiliated party to Gold Lakes.  Vallos

5
signed the transfer agreement and the non-affiliate letter dated April 18, 2017 in his capacity as
President of Gold Lakes.
16. In or around April 2017, Vallos opened a brokerage account at a brokerage firm
in Individual 1’s name, using their name and other personal identifying information to open the
account.  Vallos also provided the brokerage firm with an attorney letter dated April 10, 2017,
which falsely stated that Individual 1 was not an affiliated person as to Gold Lakes.
17. Shortly after opening the brokerage account in Individual 1’s name, in or around
April 2017, Vallos exercised Individual 1’s right to convert the debt obligation to 150,000,000
shares of Gold Lakes stock.  Vallos deposited those shares into the brokerage account he had just
opened.
18. From approximately May 11 to May 19, 2017, Vallos sold all of the Gold Lakes
stock in Individual 1’s account and received proceeds of approximately $13,348.26.
19. In sum, Vallos created the transfer and assignment agreement in April 2017,
converted the debt to stock, and sold the stock out of Individual 1’s account, all as a means to
obtain Gold Lake stock that he could sell for a profit while disguising the fact that he controlled
the company.  In the course of the scheme, he repeatedly falsely claimed that Individual 1 was
not an affiliated party, and concealed the fact that he was acting in Individual 1’s name.  As a
result, the retail investors that purchased the Gold Lakes stock during that period were not aware
that the stock was being sold by a company affiliate, and thus were denied the benefit of the
disclosures required by federal securities laws.

6

FIRST CLAIM FOR RELIEF
FRAUD IN THE OFFER OR SALE OF SECURITIES
(Violations of Section 17(a) of the Securities Act)
20. The Commission re-alleges and incorporates by reference the allegations
contained in paragraphs 1 through 19.
21. By reason of the conduct described above, Defendant, in connection with the offer
or sale of securities, by the use of the means or instrumentalities of interstate commerce or of the
mails, directly or indirectly, acting knowingly, recklessly, or, as to (ii) and (iii), negligently
(i) employed devices, schemes, or artifices to defraud; (ii) obtained money or property by means
of untrue statements of material facts and omissions to state material facts necessary in order to
make the statements made, in light of the circumstances under which they were made, not
misleading; and (iii) engaged in acts, practices, or courses of business which operated or would
operate as a fraud or deceit upon any persons, including purchasers or sellers of the securities.
22. By reason of the conduct described above, Defendant violated Securities Act
Section 17(a) [15 U.S.C. § 77q(a)].

7

SECOND CLAIM FOR RELIEF
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES
 (Violations of Section 10(b) of the Exchange Act and Rule 10b-5 Thereunder)
23. The Commission re-alleges and incorporates by reference the allegations
contained in paragraphs 1 through 19.
24. By reason of the conduct described above, Defendant, directly or indirectly, in
connection with the purchase or sale of securities, by the use of the means or instrumentalities of
interstate commerce or of the mails, or of any facility of any national securities exchange,
knowingly or recklessly, (i) employed devices, schemes, or artifices to defraud; (ii) made untrue
statements of a material fact or omitted to state a material fact necessary in order to make the
statements made, in the light of the circumstances under which they were made, not misleading;
and (iii) engaged in acts, practices, or courses of business which operated or would operate as a
fraud or deceit upon any persons, including purchasers or sellers of the securities.
25. By reason of the conduct described above, Defendant violated Exchange Act
Section 10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5 [17 C.F.R. § 240.10b-5] thereunder.
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that this Court enter a Final
Judgment:
A. Permanently restraining and enjoining the Defendant from violating Section 17(a)
of the Securities Act [15 U.S.C. § 77q(a)] and 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];
B. Ordering disgorgement of all ill-gotten gains from the unlawful conduct set forth
in this Complaint, together with prejudgment interest pursuant to Section 21(d) of the Exchange

8
Act;
C. Permanently Prohibiting the Defendant from participating in any offering of a
penny stock, pursuant to Section 20(g) of the Securities Act [15 U.S.C. §77t(g)] and/or 21(d) of
the Exchange Act [15 U.S.C. §78u(d)];
D. Prohibiting the Defendant from serving as an officer or director of any company
that has a class of securities registered under Section 12 of the Exchange Act [15 U.S.C. § 781]
or that is required to file reports under Section 15(d) of the Exchange Act [15 U.S.C. § 78o(d)],
pursuant to Section 20(e) [15 U.S.C. § 77t(e)] of the Securities Act and Section 21(d)(2) of the
Exchange Act [15 U.S.C. § 78u(d)(2)]; and
 E. Granting such other and further relief as this Court may deem just and proper.
JURY DEMAND
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, the Commission demands a
jury in this matter.

9

DATED:  9/23/2022

                                                                        Respectfully            submitted,
UNITED STATES SECURITIES AND
EXCHANGE COMMISSION

      By its attorneys,

/s/ Amy Harman Burkart   __
Amy Harman Burkart (Mass BBO No. 651828)
J. Lauchlan Wash (Mass BBO No. 629092)
Martin F. Healey (Mass. BBO No. 227550)
Boston Regional Office
33 Arch Street, 24th Floor
Boston, Massachusetts  02110
(617) 573-8900 (Main)
(617) 573-4590 (Facsimile)
(617) 573-5905 (Burkart)
burkarta@ sec.gov (Burkart)

UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 

 
 
SECURITIES AND EXCHANGE COMMISSION, 
 
 Plaintiff, 
 
 v. 
 
CHRISTOPHER P. VALLOS, 
 
 Defendant. 
 
 

 
 
 
 
Civil Action No. 22-CV-____ (___) 
 
JURY TRIAL DEMANDED 

 
 

 
COMPLAINT  

 
Plaintiff, the United States Securities and Exchange Commission (the “Commission” or 

“SEC”), for its complaint against Defendant, Christopher P. Vallos, alleges as follows: 

SUMMARY   

1. From at least July 2016 through at least May 2017 (the “Relevant Period”), 

Christopher P. Vallos engaged in a scheme to sell company stock to retail investors in the public 

United States securities markets, while concealing the fact that he also controlled the company.  

By engaging in this deceptive conduct, Vallos deprived investors of the full and fair disclosure 

mandated by the federal securities laws.   

2. As a result of the conduct alleged herein, the Defendant violated, and unless 

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

(“Securities Act”) and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) 

and Rule 10b-5 thereunder.   

NATURE OF THE PROCEEDING AND RELIEF SOUGHT 

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

Case 1:22-cv-11613   Document 1   Filed 09/23/22   Page 1 of 9



2 

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

[15 U.S.C. §§ 78u(d)(1) and 78u(d)(5)]. 

4. The Commission seeks a final judgment: permanently enjoining the Defendant 

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

Complaint; disgorgement of all ill-gotten gains from the unlawful conduct set forth in this 

Complaint, together with prejudgment interest pursuant to Section 21(d) of the Exchange Act; an 

order permanently prohibiting the Defendant from participating in any offering of a penny stock, 

pursuant to Section 20(g) of the Securities Act [15 U.S.C. § 77t(g)] and/or Section 21(d) of the 

Exchange Act [15 U.S.C. § 78u(d)]; an order prohibiting the Defendant from serving as an 

officer or director of any company that has a class of securities registered under Section 12 of the 

Exchange Act [15 U.S.C. § 781] or that is required to file reports under Section 15(d) of the 

Exchange Act [15 U.S.C. § 78o(d)], pursuant to Section 20(e) [15 U.S.C. § 77t(e)] of the 

Securities Act and Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)]; and such other 

relief as the Court may deem appropriate. 

JURISDICTION AND VENUE 

5. This Court has jurisdiction over this action pursuant to Section 22(a) of the 

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

U.S.C. §§ 78u(d), 78u(e), and 78aa]. 

6. Defendant, directly and indirectly, has made use of the means and 

instrumentalities of interstate commerce, of the mails and wires, and/or of the facilities of a 

national securities exchange in connection with transactions, acts, practices, and courses of 

business alleged herein.  

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

Case 1:22-cv-11613   Document 1   Filed 09/23/22   Page 2 of 9



3 

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

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

Massachusetts.  For example, during the Relevant Period, certain individuals who reside in the 

District of Massachusetts purchased the stock of Gold Lakes Corporation.   

DEFENDANT 

8. Christopher P. Vallos, age 48, was a resident of Painesville, Ohio during the 

relevant period.  Vallos was the President and Chief Executive Officer of Gold Lakes 

Corporation from November 2014 to September 2018.       

RELEVANT ENTITY 

9. Gold Lakes Corporation (“Gold Lakes”) was a publicly-traded Nevada 

corporation with its principal place of business in Beachwood, Ohio.  It was incorporated under 

the name Siga Resources, Inc.  The company also previously operated under the name TNX 

Maverick Corp.  Gold Lakes was a microcap or penny stock, the shares of which were traded 

under the ticker symbol “GLLK” on OTC Link LLC (an Alternative Trading System that 

displays quotes from broker-dealers for many over-the-counter securities operated by OTC 

Markets Group Inc.).  Gold Lakes purported to be an exploration stage company that specialized 

in the acquisition and development of mining assets. 

BACKGROUND  

10. An “affiliate” of a company whose stock is publicly-traded (often referred to as an 

“issuer”) is a person or entity that, directly or indirectly through one or more intermediaries, 

controls, is controlled by, or is under common control with, such issuer (i.e., a control person).  

“Control” means the power to direct management and policies of the company in question.  

Typically, affiliates include officers, directors and controlling shareholders but any person who is 

Case 1:22-cv-11613   Document 1   Filed 09/23/22   Page 3 of 9



4 

under “common control” with or has common control of an issuer is also an affiliate. 

11. The federal securities laws require that, before selling stock, an affiliate of a 

company comply with certain registration requirements, sale restrictions, and disclosure 

obligations.  These laws are critical safeguards designed to inform investors about the nature of 

the stock they are holding or considering buying, and from whom they would be buying that 

stock.   

FACTS 

12. In or around November 2014, Vallos became the President and Chief Executive 

Officer (CEO) of Gold Lakes.  As a result, Vallos had the ability to direct the management and 

policies of Gold Lakes, and was therefore an affiliate of Gold Lakes.   

13. In or around July 2016, a company (referred to hereafter as “Company A”) loaned 

Gold Lakes $50,000, and Gold Lakes executed a promissory note with Fund A in which it agreed 

to repay the funds to Company A.  Company A was controlled by a business associate of Vallos.         

14. In or around April 2017, Vallos created, and caused to be created, documentation 

which transferred and assigned $1,500 of Company A’s promissory note to an individual 

(referred to hereafter as “Individual 1”).  In other words, Gold Lakes’s obligation to pay $1,500 

of its outstanding debt to Company A was transferred from Company A to Individual 1; Gold 

Lakes then owed Individual 1 $1,500.  The transfer agreement also contained a right for 

Individual 1 to convert the $1,500 debt obligation to 150,000,000 shares of Gold Lakes stock.     

15. At this time, Individual 1, by virtue of their close relationship with Vallos, was an 

affiliate of Gold Lakes.  However, when the documentation reflecting the transfer and 

assignment of the debt obligation was submitted to a registered brokerage firm, Vallos included a 

document that falsely stated that Individual 1 was not an affiliated party to Gold Lakes.  Vallos 

Case 1:22-cv-11613   Document 1   Filed 09/23/22   Page 4 of 9



5 

signed the transfer agreement and the non-affiliate letter dated April 18, 2017 in his capacity as 

President of Gold Lakes. 

16. In or around April 2017, Vallos opened a brokerage account at a brokerage firm 

in Individual 1’s name, using their name and other personal identifying information to open the 

account.  Vallos also provided the brokerage firm with an attorney letter dated April 10, 2017, 

which falsely stated that Individual 1 was not an affiliated person as to Gold Lakes. 

17. Shortly after opening the brokerage account in Individual 1’s name, in or around 

April 2017, Vallos exercised Individual 1’s right to convert the debt obligation to 150,000,000 

shares of Gold Lakes stock.  Vallos deposited those shares into the brokerage account he had just 

opened. 

18. From approximately May 11 to May 19, 2017, Vallos sold all of the Gold Lakes 

stock in Individual 1’s account and received proceeds of approximately $13,348.26.   

19. In sum, Vallos created the transfer and assignment agreement in April 2017, 

converted the debt to stock, and sold the stock out of Individual 1’s account, all as a means to 

obtain Gold Lake stock that he could sell for a profit while disguising the fact that he controlled 

the company.  In the course of the scheme, he repeatedly falsely claimed that Individual 1 was 

not an affiliated party, and concealed the fact that he was acting in Individual 1’s name.  As a 

result, the retail investors that purchased the Gold Lakes stock during that period were not aware 

that the stock was being sold by a company affiliate, and thus were denied the benefit of the 

disclosures required by federal securities laws.   

  

Case 1:22-cv-11613   Document 1   Filed 09/23/22   Page 5 of 9



6 

 

FIRST CLAIM FOR RELIEF 

FRAUD IN THE OFFER OR SALE OF SECURITIES  

(Violations of Section 17(a) of the Securities Act) 

20. The Commission re-alleges and incorporates by reference the allegations 

contained in paragraphs 1 through 19. 

21. By reason of the conduct described above, Defendant, in connection with the offer 

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

mails, directly or indirectly, acting knowingly, recklessly, or, as to (ii) and (iii), negligently 

(i) employed devices, schemes, or artifices to defraud; (ii) obtained money or property by means 

of untrue statements of material facts and omissions to state material facts necessary in order to 

make the statements made, in light of the circumstances under which they were made, not 

misleading; and (iii) engaged in acts, practices, or courses of business which operated or would 

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

22. By reason of the conduct described above, Defendant violated Securities Act 

Section 17(a) [15 U.S.C. § 77q(a)]. 

  

Case 1:22-cv-11613   Document 1   Filed 09/23/22   Page 6 of 9



7 

 

SECOND CLAIM FOR RELIEF 

FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES  

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

23. The Commission re-alleges and incorporates by reference the allegations 

contained in paragraphs 1 through 19. 

24. By reason of the conduct described above, Defendant, directly or indirectly, in 

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

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

knowingly or recklessly, (i) employed devices, schemes, or artifices to defraud; (ii) made untrue 

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

statements made, in the light of the circumstances under which they were made, not misleading; 

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

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

25. By reason of the conduct described above, Defendant violated Exchange Act 

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

PRAYER FOR RELIEF 

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

Judgment: 

A. Permanently restraining and enjoining the Defendant from violating Section 17(a) 

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

B. Ordering disgorgement of all ill-gotten gains from the unlawful conduct set forth 

in this Complaint, together with prejudgment interest pursuant to Section 21(d) of the Exchange 

Case 1:22-cv-11613   Document 1   Filed 09/23/22   Page 7 of 9



8 

Act;  

C. Permanently Prohibiting the Defendant from participating in any offering of a 

penny stock, pursuant to Section 20(g) of the Securities Act [15 U.S.C. §77t(g)] and/or 21(d) of 

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

D. Prohibiting the Defendant from serving as an officer or director of any company 

that has a class of securities registered under Section 12 of the Exchange Act [15 U.S.C. § 781] 

or that is required to file reports under Section 15(d) of the Exchange Act [15 U.S.C. § 78o(d)], 

pursuant to Section 20(e) [15 U.S.C. § 77t(e)] of the Securities Act and Section 21(d)(2) of the 

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

 E. Granting such other and further relief as this Court may deem just and proper. 

JURY DEMAND 

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

jury in this matter.  

  

Case 1:22-cv-11613   Document 1   Filed 09/23/22   Page 8 of 9



9 

 

DATED:  9/23/2022 
 
      Respectfully submitted, 

UNITED STATES SECURITIES AND 
EXCHANGE COMMISSION 

 
      By its attorneys, 
 
 

/s/ Amy Harman Burkart   __ 
Amy Harman Burkart (Mass BBO No. 651828) 
J. Lauchlan Wash (Mass BBO No. 629092) 
Martin F. Healey (Mass. BBO No. 227550) 
Boston Regional Office 
33 Arch Street, 24th Floor 
Boston, Massachusetts  02110 
(617) 573-8900 (Main) 
(617) 573-4590 (Facsimile) 
(617) 573-5905 (Burkart) 
burkarta@ sec.gov (Burkart) 
 
 

Case 1:22-cv-11613   Document 1   Filed 09/23/22   Page 9 of 9