SEC v. TIGER ASIA MANAGEMENT, LLC; TIGER ASIA PARTNERS, LLC; SUNG KOOK (a/k/a BILL) HWANG; and RAYMOND Y.H. PARK, District of New Jersey (Jan. 1, 2012) — Complaint

Sanjay Wadhwa 
Attorney for Plaintiff 
SECURITIES AND EXCHANGE COMMISSION 
New York Regional Office 
3 
World Financial Center, Suite 400 
New 
York, NY 10281-1022 
(212) 336-0181 
UNITED STATES 
DISTRICT COURT 
DISTRICT OF NEW JERSEY 
SECURITIES AND EXCHANGE COMMISSION, 
Plaintiff, 
-against-
COMPLAINT 
TIGER ASIA MANAGEMENT, LLC, 
TIGER ASIA PARTNERS, LLC, 
SUNG KOOK (a/k/a BILL) HWANG, 
and 
RAYMOND Y.H. PARK 
ECFCASE 
Defendants. 
Plaintiff Securities and Exchange Commission ("Commission"), for its Complaint 
against defendants Tiger Asia Management, LLC ("Tiger Management"), Tiger Asia 
Partners, LLC ("Tiger Partners"), Sung Kook (a/k/a Bill) Hwang ("Hwang"), and 
Raymond Y.H. Park ("Park") (collectively, "Defendants"), alleges as follows: 
SUMMARY 
1. This case involves insider trading and attempted manipulative trading by 
Hwang, the sole principal and portfolio manager oftwo unregistered funds advised by 
Tiger Management and Tiger Partners, and Hwang's head trader, Park. In December 
2008 and January 2009, the Defendants entered into "wall-crossing" agreements for three 
private placements 
ofChinese bank stocks, subsequently violated the wall-crossing 

agreements by short selling the Chinese bank stocks, and then covered these short 
positions with private placement shares purchased at a discount. This illegal trading 
resulted in profits to the funds advised by Tiger Management and Tiger Partners 
of 
approximately $16.2 million. 
2. Also, starting in November 2008 and continuing through February 2009, 
Hwang, Tiger Management, and Tiger Partners, aided and abetted 
by Park, 
misappropriated fund assets 
by placing losing trades in Chinese bank stocks in which the 
funds had substantial short positions, in an attempt to manipulate the price 
ofthese stocks 
at month's end to inflate the calculation 
of management fees. The attempted 
manipulative trading scheme earned Tiger Management approximately $496,000 in 
fraudulent management fees. 
NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT 
3. The Commission brings this action pursuant to the authority conferred 
upon it by Section 20(b) 
ofthe Securities Act of 1933 ("Securities Act") [15 U.S.C. § 
77t(b)], Section 21(d) of the Securities Exchange Act of 1934 ("Exchange Act") [15 
U.S.C. § 78u(d)], and Section 209(d) 
ofthe Investment Advisers Act of 1940 ("Advisers 
Act") [15 U.S.C. § 80b-9(d)]. The Commission seeks permanent injunctions against each 
of the Defendants, enjoining them from engaging in the transactions, acts, practices, and 
courses 
of business alleged in this Complaint, and disgorgement ofill-gotten gains, 
including profits realized and losses avoided, from the unlawful activity set forth in this 
Complaint, together with prejudgment interest. The Commission also seeks civil 
penalties pursuant 
to Section 21A of the Exchange Act [15 U.S.C. § 78u-1] and Section 
209(e) 
of the Advisers Act [15 U.S.C. § 80b-9(e)]. Finally, the Commission seeks any 
2 


other relief that the Court may deem appropriate pursuant to Section 21 (d)(5) of the 
Exchange Act [15 U.S.C. § 78(u)(d)(5)]. 
JURISDICTION AND VENUE 
4. This Court has jurisdiction over this action pursuant to Sections 20(b ), 
20(d), and 22(a) 
ofthe Securities Act [15 U.S.C. §§ 77t(b), 77t(d), and 77v(a)]; Sections 
21(d), 21(e), and 
27 ofthe Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), and 78aa]; and 
Sections 209(d) and 214 
ofthe Advisers Act [15 U.S.C. §§ 80b-9 and 80b-14]. 
5. Venue lies in this Court pursuant to Sections 20(b) and 22(a) ofthe 
Securities Act [15 U.S.C. 
§§ 77t(b) and 77v(a)]; Sections 21(d), 21A, and 27 ofthe 
Exchange Act [15 U.S.C. §§ 78u(d), 78u-1, and 78aa]; and Section 214 ofthe Advisers 
Act [15 U.S.C. 
§ 80b-14]. Certain ofthe acts, practices, transactions, and courses of 
business alleged in this Complaint occurred within the District ofNew Jersey, and were 
effected, directly or indirectly, 
by making use ofthe means or instrumentalities of 
transportation or communication in interstate commerce, or of the mails. During the time 
of the conduct at issue, Hwang resided in New Jersey and placed and received telephone 
calls from his residence relating to certain 
of the acts, practices, transactions, and courses 
ofbusiness alleged in this Complaint. 
DEFENDANTS 
6. Hwang, age 48, resides in Tenafly, New Jersey. During the relevant 
period, he was the sole principal and portfolio manager 
of Tiger Asia Fund, L.P. and 
Tiger Asia Overseas Fund, Ltd. (collectively, the "Funds"). Hwang made all investment 
and disclosure decisions for the Funds, and was compensated for acting 
as the Funds' 
portfolio manager. Hwang has held Series 7, 24 and 
63 licenses. 
3 


7. Tiger Management is a Delaware limited liability company with its 
principal place 
ofbusiness in New York, New York. During the relevant period, Tiger 
Management served as the unregistered investment adviser and investment manager to 
Tiger Asia Overseas Fund, Ltd., and was responsible for administrative matters relating 
to the Tiger Asia Fund, L.P. Hwang owns and controls Tiger Management. 
8. Tiger Partners is a Delaware limited liability company with its principal 
place 
ofbusiness in New York, New York. During the relevant period, Tiger Partners 
served as the unregistered investment adviser and general partner 
ofTiger Asia Fund L.P. 
Hwang owns and controls Tiger Partners.
1 
9. Park, age 40, resides in Riverdale, New York. During the relevant period, 
Park was an employee 
ofTiger Management and was the head trader for the Funds. 
During the relevant period, Park served as the point 
of contact for investment banks 
soliciting the Funds to participate in private placements. Park reported to Hwang and 
executed 
Hwang's trading instructions; Park had no trading authority himself. Park has 
held Series 7, 55 and 
63 licenses. 
FACTS 

Chinese Bank Private Placements 

10. Between December 2008 and January 2009, Tiger Asia participated in 
three private placements for the securities 
oftwo Chinese b.anks: two for Bank of China 
("BOC") and one for China Construction Bank ("CCB") (collectively "the Chinese Bank 
Placements"). 
1 
Tiger Management, Tiger Partners, and the Funds will collectively be referred to as "Tiger Asia." 
4 


11. In each instance, an investment banking placement agent ("IBP A") 
approached Park and inquired about Tiger Asia's interest in participating in the private 
placement. Prior to providing Park with the details 
ofthe transaction, the IBP A required 
that Park, on behalf 
ofTiger Asia, be "wall-crossed"-meaning that Tiger Asia agreed to 
keep the disclosed information confidential and to refrain from trading in the relevant 
securities until the transaction took place or was canceled. 
12. In each instance Park, from his office in New York, New York, agreed on 
behalf 
ofTiger Asia to be wall-crossed in telephone conversations with the IBP A. It is 
well understood in the investment 
industry-an industry in which Hwang and Park have 
obtained licenses and have spent their careers -  that the information provided about the 
Chinese Bank Placements was material nonpublic information that Tiger Asia would 
receive only upon agreeing to not share or trade while in possession 
of the information. 
13. Following the wall-crossing conversations with the IBP As, Park told 
Hwang about each 
ofthe Chinese Bank Placement offers while Hwang was in his office 
in New York, New York or in his home in Tenafly, New Jersey. 
14. After receiving this information from Park, Hwang ordered Park to short 
sell the relevant stock on the Hong Kong Stock Exchange ("HKSE") in the days prior to 
each Chinese Bank Placement. During the relevant period, Hong Kong was thirteen 
hours ahead 
ofEastern Time ("ET"), and the HKSE had a morning session from 9:00pm 
to 11:30 pm ET, an afternoon session from 1:30am to 3:00am ET, and a ten minute 
auction period after the close 
ofthe afternoon session. During the auction session, short 
sales could only be ordered at the afternoon session closing price. 
5 


15. Hwang also ordered Park to purchase a large amount of stock in each 
Chinese Bank Placement at the discounted placement price, some 
of which was used to 
cover the Funds' newly-acquired short positions. 
16. Park did not disclose to any ofthe IBP As that Tiger Asia had breached its 
agreement 
to keep the information confidential and to refrain from trading in the relevant 
stock. In each Chinese Bank Placement, Tiger Asia was allocated all or most 
ofthe stock 
that it had agreed to purchase. Through this conduct, Tiger Asia made total illegal profits 
of approximately $16.2 million for the Funds. 
Insider Trading Concerning the December 2008 Private Placement of BOC Stock 
17. On December 18, 2008, the IBP A for a large investment bank called Park 
to determine Tiger Asia's interest in participating in a private placement 
of that 
investment bank's shares 
of BOC. The IBP A told Park that he had confidential 
information that could only be shared with Park 
if Park agreed to be "wall-crossed." 
Park, speaking from Tiger Asia's New York offices, agreed to be wall-crossed on behalf 
ofTiger Asia, after which the IBPA told him that the investment bank intended to sell its 
entire stake in BOC, the transaction date would be December 31, 2008, and the price 
would 
be set at an 8-10% discount from the stock's closing price on December 31, 2008. 
18. The IBPA then asked for an indication ofhow much stock Tiger Asia was 
interested in purchasing, which Park declined to answer until after he had spoken with 
Hwang. Later on December 
18, 2008, the IBPA memorialized his wall-crossing ofTiger 
Asia in an internal email. 
19. On December 21,2008, Hwang directed Park and Tiger Asia's assistant 
trader to short sell 
$5 million ofBOC stock, which they did. On December 22, 2008, the 
6 


IBPA sent an email to Park with the subject"[ o ]ver the wall notice," stating in part: "My 
compliance department has asked meto [sic] send the email below 
to everyone i [sic] 
have taken over the wall 
.... you have agreed on behalf ofTiger Asia to ... not engage in 
any trading activities regarding any security 
ofBank of China .... "  Park responded: "Got 
it. Thx." Four hours later, Hwang directed Park and the assistant trader to short sell an 
additional 
$5 million of BOC stock, which they did. 
20. On that same day, Hwang also told Park 
to communicate to the IBP A that 
Tiger Asia would "likely [buy] around $50 mil between 10-15 percent discount." On 
December 24, 2008, Hwang confirmed his intention to purchase the BOC stock in an 
email to Park and another Tiger Asia employee: "We plan 
to buy around $50mil. to 
cover our short if discount is good enough." At Hwang's direction, Park and the assistant 
trader continued 
to short $5 million ofBOC stock daily on December 23,  28, and 29, 
2008. 
21. On December 28, 2008, Park confirmed 
to the IBP A, on the same email 
chain as the "over the wall notice," that Tiger Asia was "still good for $50mm between 
the 10-15% discount." 
22. On December 30, 2008, Park emailed Hwang: "The deal will come at a 
12% discount. We are assured $50mm allocation 
if we choose to take it." Hwang 
responded "Pls take $50 mil." Park relayed this order 
to the IBP A by email from the 
United States. On December 31, 2008, Tiger Asia was allocated 199 million shares 
of 
BOC in the private placement, which it used to fully cover the short position it had 
established over the prior ten days. 
7 


23. Based on the private placement price and the sale prices of BOC shares 
Tiger Asia shorted after being brought over the wall, Tiger Asia reaped illicit profits 
of 
approximately $3.2 million. 
Insider Trading Concerning the January 2009 Private Placement of CCB Stock 
24. On January 5, 2009 around 7:45 pm ET, another IBPA at the same 
investment bank as that involved in the December 2008 private placement 
ofBOC 
shares, called Park to inquire about Tiger Asia's interest in participating in a private 
placement 
ofshares ofCCB owned by a large domestic financial institution. 
25. The IBPA told Park that he had confidential information that could only 
be shared with Park ifhe agreed to be wall-crossed. Park, speaking from Tiger Asia's 
New York offices, agreed 
to be wall-crossed on behalf ofTiger Asia, after which the 
IBP A told him that the financial institution intended to sell a large amount 
ofits CCB 
stock through a private placement and that the price would be set at a discount 
of 
approximately 15% from the closing price the day before the transaction closed. The 
IBPA then asked for an indication 
ofhow much stock Tiger Asia was interested in 
purchasing, to which Park replied that he would need 
to follow up with colleagues at 
Tiger Asia. In a call later that day, the IBP A informed Park that the transaction would 
take place within the next 
forty~eight hours. Park then told Hwang about the planned 
private placement 
of CCB stock. 
26. On January 5, 2009 between 8:45p.m. ET and 11:46 ET, Hwang sent 
several emails to Park instructing him 
to short sell millions of shares of CCB stock. At 
the end 
of the Hong Kong trading day on January 5, 2009, Tiger Asia had executed short 
8 


sales of93 million CCB shares. On the same day, Tiger Asia also purchased during the 
trading day and sold during the closing auction 1 7 million CCB shares for a profit. 
27. Tiger Asia accounted for 35.86% 
ofthe auction volume in CCB on 
January 
5, 2009. On January 5, CCB closed down 3% from the morning session's close, 
and down 4.3% from the previous day's close. 
28. On January 
6, 2009 Hwang emailed Park, the assistant trader and another 
colleague cautioning: "Pls do NOT discuss about the potential deal with ANYBODY 
including our analysts without getting 
my consent." (emphasis in original.) 
29. On January 6, 2009 around 10:40 am ET, the IBPA informed Park that the 
private placement would take place before the HKSE's open that day, the pricing would 
be at a  12% discount 
to the previous close, and Tiger Asia would be allocated $1 billion 
of CCB stock if they wanted it. 
30. Hwang told Park by email to accept the 
$1 billion allocation, which Park, 
on behalf 
ofTiger Asia, and from New York, relayed to the IBPA by telephone. On 
January 
6, 2009, Tiger Asia was allocated 1.977 billion shares of CCB stock in the 
private placement, which it used 
to cover its entire short position in the stock. 
31. Based on the private placement price and the sale prices 
of CCB shares 
Tiger Asia shorted after being brought over the wall, Tiger Asia reaped illicit profits 
of 
approximately $7.3 million. 
Insider Trading Concerning the January 2009 Private Placement 
ofBOC Stock 
32. On January 11,2009 around 10:58 pm ET, two IBPAs at a large 
investment bank called Park to determine Tiger Asia's interest in participating in a 
private placement 
of shares ofBOC owned by an international financial institution. 
9 


33. During this conversation, which was recorded by the investment bank, the 
IBPAs wall-crossed Park on behalf 
ofTiger Asia. After Park agreed to be wall-crossed, 
the IBP As stated that the financial institution intended 
to sell its BOC stock through a 
private placement in the next twenty-four to forty-eight hours, and that the price would be 
set at a 7-11% discount to that day's closing price. The IBP As made it clear that this was 
a private placement being offered to a small number 
of sophisticated investors and asked 
for an indication 
of how much stock Tiger Asia was interested in purchasing. Park, 
speaking from Tiger Asia's New York offices, replied that Tiger Asia was interested in 
purchasing between $100 million and $150 million 
ofBOC stock depending on the price 
but that he would have 
to discuss it with the "fund manager" and would get back to them. 
34. A few minutes later, at 11:19 pm ET, Park emailed Hwang the 
confidential information about the private placement that the IBP As had provided. A 
little over an hour later, at 12:27 am ET on January 12, 2009, Hwang instructed Park 
to 
communicate to the IBP As that Tiger Asia would purchase $150 million ofBOC stock if 
the price was HKD 1.60, and $100 million of BOC stock ifthe price was HKD 1.70. 
(HKD denotes Hong Kong dollar.) Approximately a 
halfhour later, Park called the 
IBPAs and communicated Hwang's commitments. 
35. On January 11, 2009, prior to Park being wall-crossed on behalf 
ofTiger 
Asia, Hwang directed Park and the assistant trader to short sell $30 million 
ofBOC stock. 
After Park was wall-crossed, Hwang increased his sell order to $50 million 
ofBOC 
stock. Tiger Asia ultimately short sold approximately $42 million of BOC stock on 
January 11, 2009. 
10 


36. On January 12, 2009, around 1:00pm ET, Park had a call with the IBP A, 
in which he learned that the transaction would most likely take place at the HKSE close 
that night and that the discount would 
be 9-1 0% from the closing price on the HKSE. 
Park repeated this information 
to Hwang and noted that the "stock [would] trade one 
more day" on the HKSE. 
37. After Park reported this information 
to him, Hwang directed Park and the 
assistant trader to short sell up 
to $50 million ofBOC stock. However, because they 
were not able to locate sufficient shares 
ofBOC stock, Tiger Asia only short sold $42 
million 
ofBOC stock on January 12, 2009. 
38. On January 12, 2009, at 
9:18pm ET, Hwang instructed Park to order $125 
million 
ofBOC stock in the private placement regardless ofhow many shares Tiger Asia 
could short sell that night. After further discussions between Park and the IBP 
A, Tiger 
Asia's allocation was increased 
to $373 million ofBOC shares in the private placement, 
at  a 7.6% discount from the HKSE closing price, which it used to cover a large portion 
of 
its short position. 
39. Based on the private placement price and the sale prices 
ofBOC shares 
Tiger Asia shorted on and after January 
11, 2009, the day Tiger Asia was brought over 
the wall, Tiger Asia reaped illicit profits 
of approximately $5.7 million. 
Attempted Manipulative Trading 
40. Pursuant to the Funds' offering documents, Tiger Management was 
entitled 
to receive a fixed annual management fee equal to 1.5% of the value ofthe net 
assets 
ofthe Funds calculated as ofthe end of each month. On at least four occasions, 
Tiger Asia attempted to manipulate the month-end closing prices 
of stocks listed on the 
11 


HKSE. The stocks that Tiger Asia attempted to manipulate were among the largest short 
position holdings in the Funds' portfolios. Tiger Asia placed trades designed to depress 
the price 
ofthe stocks in which it held large short positions, which would increase the 
value 
ofthe short positions, in an attempt to inflate the Funds' assets under management. 
The more assets Tiger Asia had under management, the greater the management fee Tiger 
Management was entitled to collect. 
41. On November 28, 2008, at Hwang's direction, Tiger Asia short sold shares 
of Industrial and Commercial Bank of China ("ICBC"), CCB, and China Life Insurance 
Company Limited ("China Life") during the last hour 
ofthe afternoon trading session 
and sold the same stocks during the auction session. 
In order to conceal Tiger Asia's 
trading, Park directed Tiger Asia's assistant trader to not use the same brokers for the 
sales during the auction session 
as he had for the short sales during the regular session. 
ICBC, CCB and China Life were among Tiger Asia's largest short positions. The auction 
session sales were intended to depress the closing prices 
ofiCBC, CCB, and China Life 
stock. 
42. On December 31, 2008, at Hwang's direction, Park and the assistant trader 
sold large quantities 
ofiCBC, CCB and China Life stock during the auction session in an 
attempt to depress the stocks' closing prices. 
43. On January 29, 2009, Hwang instructed Park and the assistant trader in an 
email to "[l]ong [b]uy 
$7 mill ICBC during first 3 hours oftrading today and sell what 
we bought ($7 mil) at the auction. This is 
to prevent any pushing up at the end." Park 
and the assistant trader executed the trades 
as directed by Hwang. 
12 


44. On February 27, 2009, Tiger Asia did not own any long shares ofits 
largest short positions. So, Park and the assistant trader purchased large quantities 
of 
CCB, ICBC, Bank of Communications, China Mobile and China Life stock during the 
morning and afternoon regular trading sessions, and then sold those newly purchased 
shares during the auction session. Park and the assistant trader also short sold these 
stocks throughout the trading day. This trading was intended to depress the closing 
prices 
of CCB, ICBC, Bank of Communications, China Mobile and China Life stock. 
45. Tiger Management earned over $496,000 
in management fees attributable 
to the change in value 
of Tiger Asia's short positions described in Paragraphs 41 through 
44 during the months in which the attempted manipulative trading occurred. 
FIRST CLAIM FOR RELIEF 
Violations 
of Section 1 O(b) of the Exchange Act and Rule 1 Ob-5 Thereunder 
(Against all Defendants) 
46. The Commission realleges and incorporates 
by reference herein each and 
every allegation contained in paragraphs 1 through 45 
of this Complaint. 
4
7. The information provided by the IBP As to Park who communicated it to 
Hwang was, in each case, material and nonpublic. Before providing this material 
nonpublic information to Park, in each case, the IBP A required that Park, on behalf 
of 
Tiger Asia, agree to be brought over the wall, and to refrain from trading the relevant 
securities. In each case, Park agreed, on behalf ofTiger Asia, to be brought over the 
wall. 
48. In each case, after receiving the material nonpublic information from the 
IBPA, Hwang directed Park to short sell the relevant securities in Tiger Asia's accounts 
in advance 
ofthe private placement. 
13 


49. Defendants Hwang, Tiger Management, Tiger Partners and Park 
knowingly or recklessly breached a duty 
of trust and confidence owed to the IBP As by 
short selling the relevant securities while in possession ofmaterial nonpublic information 
about the forthcoming private placements provided by the IBP As. 
50. By engaging in the conduct described above, defendants Hwang, Tiger 
Management, Tiger Partners and Park, and each 
ofthem, in connection with the purchase 
or sale 
of securities, by use of the means or instrumentalities ofinterstate commerce, or 
of the mails, or a facility ofa national securities exchange, directly or indirectly: 
(a) employed devices, schemes or artifices to defraud; (b) made untrue statements 
of 
material fact, or omitted to state material facts necessary in order to make statements 
made, in light 
ofthe circumstances under which they were made, not misleading; or 
(c) engaged in acts, practices or courses 
ofbusiness which operated or would have 
operated as a fraud or deceit upon persons. 
51. 
By virtue of the foregoing, defendants Hwang, Tiger Management, Tiger 
Partners and Park, and each 
of them, directly or indirectly, violated, and, unless enjoined, 
will again violate, Section lO(b) 
ofthe Exchange Act, [15 U.S.C. § 78j(b)] and Rule lOb­
5 thereunder [17 C.F.R. 
§ 240.10b-5]. 
SECOND CLAIM FOR RELIEF 
Violations of Section 17(a) of the Securities Act 
(Against all Defendants) 
52. The Commission realleges and incorporates by reference herein each and 
every allegation contained in paragraphs 
1 through 51 ofthis Complaint. 
53. By virtue 
ofthe foregoing, in the offer or sale of securities, by the use of 
any means or instruments of transportation or communication in interstate commerce, or 
14 


by use ofthe mails, directly or indirectly, defendants Hwang, Tiger Management, Tiger 
Partners and Park, and each 
ofthem: (a) employed devices, schemes or artifices to 
defraud; (b) obtained money or property by means 
of an untrue statement ofa 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; or (c) engaged in 
transactions practices or courses ofbusiness which operate or would operate 
as a fraud or 
deceit upon a purchaser. 
54. By reason 
ofthe conduct described above, defendants Hwang, Tiger 
Management, Tiger Partners and Park, and each 
of them, directly or indirectly, violated, 
and unless enjoined, will again violate, Section 17(a) 
of the Securities Act [15 U.S.C. § 
77q(a)]. 
THIRD CLAIM FOR RELIEF 
Violations of Sections 206(1) and 206(2) of the Advisers Act 

(Against Defendants Hwang, Tiger Management and Tiger Partners) 

55. The Commission realleges and incorporates by reference herein each and 
every allegation contained in paragraphs 1 through 54 
ofthis Complaint. 
56. At all relevant times, Hwang, Tiger Management and Tiger Partners were 
investment advisers within the meaning 
of Section 202(a)(11) of the Advisers Act [15 
U.S.C. § 80b-2(a)(11)]. 
57. Despite owing a duty to the Funds to act in the best interests 
of the Funds, 
Hwang, Tiger Management and Tiger Partners knowingly or recklessly attempted to 
manipulate the month-end closing prices 
of stocks in which the Funds had large short 
positions. Tiger Asia placed these trades in an attempt 
to inflate the Funds' assets under 
15 


management. The more assets Tiger Asia had under management, the greater the 
management fee Tiger Management was entitled 
to collect. 
58. By engaging in the conduct described above, defendants Hwang, Tiger 
Management and Tiger Partners, and each 
ofthem, directly or indirectly, knowingly or 
recklessly, 
by use ofthe mails or any means or instrumentalities ofinterstate commerce: 
(a) employed devices, schemes or artifices to defraud clients or prospective clients, or (b) 
engaged in transactions, practices or courses 
ofbusiness which operated as a fraud or 
deceit upon clients or prospective clients. 
59. By reason 
of the foregoing, defendants Hwang, Tiger Management and 
Tiger Partners, and each ofthem, directly or indirectly, violated, and unless enjoined, will 
again violate, Sections 206(1) and 206(2) 
ofthe Advisers Act [15 U.S.C. §§ 80b-6(1) and 
80b-6(2)]. 
FOURTH CLAIM FOR RELIEF 
Violations of Sections 206(4) of the Advisers Act and Rule 206(4)-8 Thereunder 
(Against Defendants Hwang, Tiger Management and Tiger Partners) 
60. The Commission realleges and incorporates by reference herein each and 
every allegation contained in paragraphs 1 through 
59 of this Complaint. 
61. The Funds were pooled investment vehicles, 
as defined in Rule 206(4)-8 
under the Advisers Act, and engaged primarily in the business 
ofinvesting, directly or 
indirectly, in securities. 
62. By engaging in the conduct alleged above, defendants Hwang, Tiger 
Management and Tiger Partners, and each 
of them, directly or indirectly, knowingly or 
recklessly, by use 
ofthe mails or any means or instrumentalities ofinterstate commerce: 
(a) made untrue statements 
ofmaterial fact or omitted to state material facts necessary to 
16 


make the statements made, in light ofthe circumstances under which they were made, not 
misleading, to an investor or prospective investor in the Funds; or (b) otherwise engaged 
in acts, practices, or courses ofbusiness that were fraudulent, deceptive or manipulative 
with respect to investors or prospective investor in the Funds. 
63. . By reason 
of the foregoing, Defendants Hwang, Tiger Management and 
Tiger Partners, and each 
of them, directly or indirectly, violated, and unless enjoined, will 
again violate, Section 206(4) 
ofthe Advisers Act [15 U.S.C. § 80b-6(4)] and Rule 
206(4)-8 thereunder [17 C.F.R. 
§ 275.206(4)-8]. 
FIFTH CLAIM FOR RELIEF 
Aiding and Abetting Violations of Sections 206(1) and 206(2) of the Advisers Act 
(Against Defendant Park) 
64. The Commission realleges and incorporates by reference herein each and 
every allegation contained in paragraphs 1 through 
63 of this Complaint. 
65. At all relevant times, Park was an associated person 
ofTiger Management, 
an investment adviser. 
66. Park provided substantial assistance to Hwang, Tiger Management and 
Tiger Partners in their attempts 
to manipulate the month-end closing prices ofstocks in 
which the Funds had large short positions. At Hwang's direction, Park and Tiger Asia's 
assistant trader knowingly sold large quantities 
of stocks in which the Funds had large 
short positions on the last trading day 
of the months ofNovember 2008, December 2008, 
January 2009, and February 2009, in an attempt to depress the stocks' closing prices. 
67. By engaging in the conduct described above, Park knowingly provided 
substantial assistance to Hwang, Tiger Management and Tiger Partners, and thus aided 
17 


and abetted Hwang's, Tiger Management's and Tiger Partners' violations ofSections 
206(1) and 206(2) 
ofthe Advisers Act [15 U.S.C. §§ 80b-6(1) and 80b-6(2)]. 
SIXTH CLAIM FOR RELIEF 

Aiding and Abetting Violations 
of Section 206(4) of the Advisers Act and Rule 

206(4)-8 Thereunder 

(Against Defendant Park) 

68. The Commission realleges and incorporates by reference herein each and 
every allegation contained in paragraphs 
1 through 67 ofthis Complaint. 
69. At all relevant times, Park was an associated person 
ofTiger Management, 
an investment adviser. 
70. 
By engaging in the conduct described above, Park knowingly provided 
substantial assistance to Hwang, Tiger Management and Tiger Partners, and thus aided 
and abetted Hwang's, Tiger Management's and Tiger Partners' violations 
of Section 
206(4) 
ofthe Advisers Act [15 U.S.C. § 80b-6(4)], and Rule 206(4)-8 thereunder [17 
C.F.R. 
§ 275.206(4)-8]. 
RELIEF SOUGHT 
WHEREFORE, the Commission respectfully requests that this Court enter a 
Final Judgment: 
I. 
Permanently restraining and enjoining defendants Hwang, Tiger Management, 
Tiger Partners and Park, and each 
ofthem, from violating Section 17(a) ofthe Securities 
Act [15 U.S.C. § 77q(a)], Section 10(b) 
ofthe Exchange Act [15 U.S.C. § 78j(b)] and 
Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5], and Sections 206(1), 206(2), and 206(4) 
18 


ofthe Advisers Act [15 U.S.C. §§ 80b-6(1), (2), and (4)] and Rule 206(4)-8 thereunder 
[17 C.F.R. § 275.206(4)-8]; 
II. 
Ordering defendants Hwang, Tiger Management, Tiger Partners and Park to 
disgorge, with prejudgment interest, all ill-gotten gains received as a result 
ofthe conduct 
alleged in this Complaint. 
III. 
Ordering defendants Hwang, Tiger Management, Tiger Partners and Park to pay 
civil monetary penalties pursuant to Section 21A 
ofthe Exchange Act [15 U.S.C. § 78u­
1] or Section 209(e) ofthe Advisers Act [15 U.S.C. § 80b-9(e)]; and 
IV. 
Granting such other and further relief as this Court 
may deem just and proper. 
Dated: 	December 12, 2012 
New York, New York 
Associate Regional Director 
Attorney for Plaintiff 
SECURITIES AND EXCHANGE 
COMMISSION 
New York Regional Office 
3 World Financial Center, Suite 400 
New York, New York 10281-1022 
(212) 336-0181 
[email protected] 
Of Counsel: 

Amelia 
A. Cottrell ([email protected])* 

Thomas 
P. Smith, Jr. ([email protected])* 

Sandeep Satwalekar ([email protected])* 

*not admitted in New Jersey 

19 

Sanjay Wadhwa 
Attorney for Plaintiff 
SECURITIES AND EXCHANGE COMMISSION 
New York Regional Office 
3 World Financial Center, Suite 400 
New York, NY 10281-1022 
(212) 336-0181 

UNITED STATES DISTRICT COURT 
DISTRICT OF NEW JERSEY 

SECURITIES AND EXCHANGE COMMISSION, 

Plaintiff, 

-against- COMPLAINT 

TIGER ASIA MANAGEMENT, LLC, 
TIGER ASIA PARTNERS, LLC, 
SUNG KOOK (a/k/a BILL) HWANG, 

and 
RAYMOND Y.H. PARK 

ECFCASE 

Defendants. 

Plaintiff Securities and Exchange Commission ("Commission"), for its Complaint 

against defendants Tiger Asia Management, LLC ("Tiger Management"), Tiger Asia 

Partners, LLC ("Tiger Partners"), Sung Kook (a/k/a Bill) Hwang ("Hwang"), and 

Raymond Y.H. Park ("Park") (collectively, "Defendants"), alleges as follows: 

SUMMARY 

1. This case involves insider trading and attempted manipulative trading by 

Hwang, the sole principal and portfolio manager of two unregistered funds advised by 

Tiger Management and Tiger Partners, and Hwang's head trader, Park. In December 

2008 and January 2009, the Defendants entered into "wall-crossing" agreements for three 

private placements of Chinese bank stocks, subsequently violated the wall-crossing 



agreements by short selling the Chinese bank stocks, and then covered these short 

positions with private placement shares purchased at a discount. This illegal trading 

resulted in profits to the funds advised by Tiger Management and Tiger Partners of 

approximately $16.2 million. 

2. Also, starting in November 2008 and continuing through February 2009, 

Hwang, Tiger Management, and Tiger Partners, aided and abetted by Park, 

misappropriated fund assets by placing losing trades in Chinese bank stocks in which the 

funds had substantial short positions, in an attempt to manipulate the price of these stocks 

at month's end to inflate the calculation of management fees. The attempted 

manipulative trading scheme earned Tiger Management approximately $496,000 in 

fraudulent management fees. 

NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT 

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

upon it by Section 20(b) of the Securities Act of 1933 ("Securities Act") [15 U.S.C. § 

77t(b)], Section 21(d) of the Securities Exchange Act of 1934 ("Exchange Act") [15 

U.S.C. § 78u(d)], and Section 209(d) ofthe Investment Advisers Act of 1940 ("Advisers 

Act") [15 U.S.C. § 80b-9(d)]. The Commission seeks permanent injunctions against each 

of the Defendants, enjoining them from engaging in the transactions, acts, practices, and 

courses of business alleged in this Complaint, and disgorgement of ill-gotten gains, 

including profits realized and losses avoided, from the unlawful activity set forth in this 

Complaint, together with prejudgment interest. The Commission also seeks civil 

penalties pursuant to Section 21A of the Exchange Act [15 U.S.C. § 78u-1] and Section 

209(e) of the Advisers Act [15 U.S.C. § 80b-9(e)]. Finally, the Commission seeks any 

2 




other relief that the Court may deem appropriate pursuant to Section 21 (d)(5) of the 

Exchange Act [15 U.S.C. § 78(u)(d)(5)]. 

JURISDICTION AND VENUE 

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

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

21(d), 21(e), and 27 ofthe Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), and 78aa]; and 

Sections 209(d) and 214 ofthe Advisers Act [15 U.S.C. §§ 80b-9 and 80b-14]. 

5. Venue lies in this Court pursuant to Sections 20(b) and 22(a) of the 

Securities Act [15 U.S.C. §§ 77t(b) and 77v(a)]; Sections 21(d), 21A, and 27 ofthe 

Exchange Act [15 U.S.C. §§ 78u(d), 78u-1, and 78aa]; and Section 214 ofthe Advisers 

Act [15 U.S.C. § 80b-14]. Certain ofthe acts, practices, transactions, and courses of 

business alleged in this Complaint occurred within the District ofNew Jersey, and were 

effected, directly or indirectly, by making use of the means or instrumentalities of 

transportation or communication in interstate commerce, or of the mails. During the time 

of the conduct at issue, Hwang resided in New Jersey and placed and received telephone 

calls from his residence relating to certain of the acts, practices, transactions, and courses 

ofbusiness alleged in this Complaint. 

DEFENDANTS 

6. Hwang, age 48, resides in Tenafly, New Jersey. During the relevant 

period, he was the sole principal and portfolio manager of Tiger Asia Fund, L.P. and 

Tiger Asia Overseas Fund, Ltd. (collectively, the "Funds"). Hwang made all investment 

and disclosure decisions for the Funds, and was compensated for acting as the Funds' 

portfolio manager. Hwang has held Series 7, 24 and 63 licenses. 

3 




7. Tiger Management is a Delaware limited liability company with its 

principal place of business in New York, New York. During the relevant period, Tiger 

Management served as the unregistered investment adviser and investment manager to 

Tiger Asia Overseas Fund, Ltd., and was responsible for administrative matters relating 

to the Tiger Asia Fund, L.P. Hwang owns and controls Tiger Management. 

8. Tiger Partners is a Delaware limited liability company with its principal 

place ofbusiness in New York, New York. During the relevant period, Tiger Partners 

served as the unregistered investment adviser and general partner of Tiger Asia Fund L.P. 

Hwang owns and controls Tiger Partners. 1 

9. Park, age 40, resides in Riverdale, New York. During the relevant period, 

Park was an employee of Tiger Management and was the head trader for the Funds. 

During the relevant period, Park served as the point of contact for investment banks 

soliciting the Funds to participate in private placements. Park reported to Hwang and 

executed Hwang's trading instructions; Park had no trading authority himself. Park has 

held Series 7, 55 and 63 licenses. 

FACTS 


Chinese Bank Private Placements 


10. Between December 2008 and January 2009, Tiger Asia participated in 

three private placements for the securities of two Chinese b.anks: two for Bank of China 

("BOC") and one for China Construction Bank ("CCB") (collectively "the Chinese Bank 

Placements"). 

1 
Tiger Management, Tiger Partners, and the Funds will collectively be referred to as "Tiger Asia." 

4 




11. In each instance, an investment banking placement agent ("IBP A") 

approached Park and inquired about Tiger Asia's interest in participating in the private 

placement. Prior to providing Park with the details of the transaction, the IBP A required 

that Park, on behalf of Tiger Asia, be "wall-crossed"- meaning that Tiger Asia agreed to 

keep the disclosed information confidential and to refrain from trading in the relevant 

securities until the transaction took place or was canceled. 

12. In each instance Park, from his office in New York, New York, agreed on 

behalf of Tiger Asia to be wall-crossed in telephone conversations with the IBP A. It is 

well understood in the investment industry- an industry in which Hwang and Park have 

obtained licenses and have spent their careers - that the information provided about the 

Chinese Bank Placements was material nonpublic information that Tiger Asia would 

receive only upon agreeing to not share or trade while in possession of the information. 

13. Following the wall-crossing conversations with the IBP As, Park told 

Hwang about each of the Chinese Bank Placement offers while Hwang was in his office 

in New York, New York or in his home in Tenafly, New Jersey. 

14. After receiving this information from Park, Hwang ordered Park to short 

sell the relevant stock on the Hong Kong Stock Exchange ("HKSE") in the days prior to 

each Chinese Bank Placement. During the relevant period, Hong Kong was thirteen 

hours ahead of Eastern Time ("ET"), and the HKSE had a morning session from 9:00pm 

to 11:30 pm ET, an afternoon session from 1:30am to 3:00am ET, and a ten minute 

auction period after the close of the afternoon session. During the auction session, short 

sales could only be ordered at the afternoon session closing price. 

5 




15. Hwang also ordered Park to purchase a large amount of stock in each 

Chinese Bank Placement at the discounted placement price, some of which was used to 

cover the Funds' newly-acquired short positions. 

16. Park did not disclose to any of the IBP As that Tiger Asia had breached its 

agreement to keep the information confidential and to refrain from trading in the relevant 

stock. In each Chinese Bank Placement, Tiger Asia was allocated all or most of the stock 

that it had agreed to purchase. Through this conduct, Tiger Asia made total illegal profits 

of approximately $16.2 million for the Funds. 

Insider Trading Concerning the December 2008 Private Placement of BOC Stock 

17. On December 18, 2008, the IBP A for a large investment bank called Park 

to determine Tiger Asia's interest in participating in a private placement of that 

investment bank's shares of BOC. The IBP A told Park that he had confidential 

information that could only be shared with Park if Park agreed to be "wall-crossed." 

Park, speaking from Tiger Asia's New York offices, agreed to be wall-crossed on behalf 

ofTiger Asia, after which the IBPA told him that the investment bank intended to sell its 

entire stake in BOC, the transaction date would be December 31, 2008, and the price 

would be set at an 8-10% discount from the stock's closing price on December 31, 2008. 

18. The IBPA then asked for an indication ofhow much stock Tiger Asia was 

interested in purchasing, which Park declined to answer until after he had spoken with 

Hwang. Later on December 18, 2008, the IBPA memorialized his wall-crossing ofTiger 

Asia in an internal email. 

19. On December 21,2008, Hwang directed Park and Tiger Asia's assistant 

trader to short sell $5 million ofBOC stock, which they did. On December 22, 2008, the 

6 




IBPA sent an email to Park with the subject"[ o ]ver the wall notice," stating in part: "My 

compliance department has asked meto [sic] send the email below to everyone i [sic] 

have taken over the wall .... you have agreed on behalf ofTiger Asia to ... not engage in 

any trading activities regarding any security ofBank of China .... " Park responded: "Got 

it. Thx." Four hours later, Hwang directed Park and the assistant trader to short sell an 

additional $5 million of BOC stock, which they did. 

20. On that same day, Hwang also told Park to communicate to the IBP A that 

Tiger Asia would "likely [buy] around $50 mil between 10-15 percent discount." On 

December 24, 2008, Hwang confirmed his intention to purchase the BOC stock in an 

email to Park and another Tiger Asia employee: "We plan to buy around $50mil. to 

cover our short if discount is good enough." At Hwang's direction, Park and the assistant 

trader continued to short $5 million ofBOC stock daily on December 23, 28, and 29, 

2008. 

21. On December 28, 2008, Park confirmed to the IBP A, on the same email 

chain as the "over the wall notice," that Tiger Asia was "still good for $50mm between 

the 10-15% discount." 

22. On December 30, 2008, Park emailed Hwang: "The deal will come at a 

12% discount. We are assured $50mm allocation if we choose to take it." Hwang 

responded "Pls take $50 mil." Park relayed this order to the IBP A by email from the 

United States. On December 31, 2008, Tiger Asia was allocated 199 million shares of 

BOC in the private placement, which it used to fully cover the short position it had 

established over the prior ten days. 

7 




23. Based on the private placement price and the sale prices of BOC shares 

Tiger Asia shorted after being brought over the wall, Tiger Asia reaped illicit profits of 

approximately $3.2 million. 

Insider Trading Concerning the January 2009 Private Placement of CCB Stock 

24. On January 5, 2009 around 7:45 pm ET, another IBPA at the same 

investment bank as that involved in the December 2008 private placement ofBOC 

shares, called Park to inquire about Tiger Asia's interest in participating in a private 

placement of shares of CCB owned by a large domestic financial institution. 

25. The IBPA told Park that he had confidential information that could only 

be shared with Park ifhe agreed to be wall-crossed. Park, speaking from Tiger Asia's 

New York offices, agreed to be wall-crossed on behalf of Tiger Asia, after which the 

IBP A told him that the financial institution intended to sell a large amount of its CCB 

stock through a private placement and that the price would be set at a discount of 

approximately 15% from the closing price the day before the transaction closed. The 

IBPA then asked for an indication ofhow much stock Tiger Asia was interested in 

purchasing, to which Park replied that he would need to follow up with colleagues at 

Tiger Asia. In a call later that day, the IBP A informed Park that the transaction would 

take place within the next forty~eight hours. Park then told Hwang about the planned 

private placement of CCB stock. 

26. On January 5, 2009 between 8:45p.m. ET and 11:46 ET, Hwang sent 

several emails to Park instructing him to short sell millions of shares of CCB stock. At 

the end of the Hong Kong trading day on January 5, 2009, Tiger Asia had executed short 

8 




sales of 93 million CCB shares. On the same day, Tiger Asia also purchased during the 

trading day and sold during the closing auction 1 7 million CCB shares for a profit. 

27. Tiger Asia accounted for 35.86% of the auction volume in CCB on 

January 5, 2009. On January 5, CCB closed down 3% from the morning session's close, 

and down 4.3% from the previous day's close. 

28. On January 6, 2009 Hwang emailed Park, the assistant trader and another 

colleague cautioning: "Pls do NOT discuss about the potential deal with ANYBODY 

including our analysts without getting my consent." (emphasis in original.) 

29. On January 6, 2009 around 10:40 am ET, the IBPA informed Park that the 

private placement would take place before the HKSE's open that day, the pricing would 

be at a 12% discount to the previous close, and Tiger Asia would be allocated $1 billion 

of CCB stock if they wanted it. 

30. Hwang told Park by email to accept the $1 billion allocation, which Park, 

on behalf ofTiger Asia, and from New York, relayed to the IBPA by telephone. On 

January 6, 2009, Tiger Asia was allocated 1.977 billion shares of CCB stock in the 

private placement, which it used to cover its entire short position in the stock. 

31. Based on the private placement price and the sale prices of CCB shares 

Tiger Asia shorted after being brought over the wall, Tiger Asia reaped illicit profits of 

approximately $7.3 million. 

Insider Trading Concerning the January 2009 Private Placement ofBOC Stock 

32. On January 11,2009 around 10:58 pm ET, two IBPAs at a large 

investment bank called Park to determine Tiger Asia's interest in participating in a 

private placement of shares ofBOC owned by an international financial institution. 

9 




33. During this conversation, which was recorded by the investment bank, the 

IBPAs wall-crossed Park on behalf ofTiger Asia. After Park agreed to be wall-crossed, 

the IBP As stated that the financial institution intended to sell its BOC stock through a 

private placement in the next twenty-four to forty-eight hours, and that the price would be 

set at a 7-11% discount to that day's closing price. The IBP As made it clear that this was 

a private placement being offered to a small number of sophisticated investors and asked 

for an indication of how much stock Tiger Asia was interested in purchasing. Park, 

speaking from Tiger Asia's New York offices, replied that Tiger Asia was interested in 

purchasing between $100 million and $150 million ofBOC stock depending on the price 

but that he would have to discuss it with the "fund manager" and would get back to them. 

34. A few minutes later, at 11:19 pm ET, Park emailed Hwang the 

confidential information about the private placement that the IBP As had provided. A 

little over an hour later, at 12:27 am ET on January 12, 2009, Hwang instructed Park to 

communicate to the IBP As that Tiger Asia would purchase $150 million ofBOC stock if 

the price was HKD 1.60, and $100 million of BOC stock if the price was HKD 1.70. 

(HKD denotes Hong Kong dollar.) Approximately a halfhour later, Park called the 

IBPAs and communicated Hwang's commitments. 

35. On January 11, 2009, prior to Park being wall-crossed on behalf ofTiger 

Asia, Hwang directed Park and the assistant trader to short sell $30 million ofBOC stock. 

After Park was wall-crossed, Hwang increased his sell order to $50 million ofBOC 

stock. Tiger Asia ultimately short sold approximately $42 million of BOC stock on 

January 11, 2009. 

10 




36. On January 12, 2009, around 1:00pm ET, Park had a call with the IBP A, 

in which he learned that the transaction would most likely take place at the HKSE close 

that night and that the discount would be 9-1 0% from the closing price on the HKSE. 

Park repeated this information to Hwang and noted that the "stock [would] trade one 

more day" on the HKSE. 

37. After Park reported this information to him, Hwang directed Park and the 

assistant trader to short sell up to $50 million ofBOC stock. However, because they 

were not able to locate sufficient shares ofBOC stock, Tiger Asia only short sold $42 

million ofBOC stock on January 12, 2009. 

38. On January 12, 2009, at 9:18pm ET, Hwang instructed Park to order $125 

million ofBOC stock in the private placement regardless ofhow many shares Tiger Asia 

could short sell that night. After further discussions between Park and the IBP A, Tiger 

Asia's allocation was increased to $373 million ofBOC shares in the private placement, 

at a 7.6% discount from the HKSE closing price, which it used to cover a large portion of 

its short position. 

39. Based on the private placement price and the sale prices ofBOC shares 

Tiger Asia shorted on and after January 11, 2009, the day Tiger Asia was brought over 

the wall, Tiger Asia reaped illicit profits of approximately $5.7 million. 

Attempted Manipulative Trading 

40. Pursuant to the Funds' offering documents, Tiger Management was 

entitled to receive a fixed annual management fee equal to 1.5% of the value of the net 

assets of the Funds calculated as of the end of each month. On at least four occasions, 

Tiger Asia attempted to manipulate the month-end closing prices of stocks listed on the 

11 




HKSE. The stocks that Tiger Asia attempted to manipulate were among the largest short 

position holdings in the Funds' portfolios. Tiger Asia placed trades designed to depress 

the price of the stocks in which it held large short positions, which would increase the 

value of the short positions, in an attempt to inflate the Funds' assets under management. 

The more assets Tiger Asia had under management, the greater the management fee Tiger 

Management was entitled to collect. 

41. On November 28, 2008, at Hwang's direction, Tiger Asia short sold shares 

of Industrial and Commercial Bank of China ("ICBC"), CCB, and China Life Insurance 

Company Limited ("China Life") during the last hour of the afternoon trading session 

and sold the same stocks during the auction session. In order to conceal Tiger Asia's 

trading, Park directed Tiger Asia's assistant trader to not use the same brokers for the 

sales during the auction session as he had for the short sales during the regular session. 

ICBC, CCB and China Life were among Tiger Asia's largest short positions. The auction 

session sales were intended to depress the closing prices ofiCBC, CCB, and China Life 

stock. 

42. On December 31, 2008, at Hwang's direction, Park and the assistant trader 

sold large quantities ofiCBC, CCB and China Life stock during the auction session in an 

attempt to depress the stocks' closing prices. 

43. On January 29, 2009, Hwang instructed Park and the assistant trader in an 

email to "[l]ong [b]uy $7 mill ICBC during first 3 hours oftrading today and sell what 

we bought ($7 mil) at the auction. This is to prevent any pushing up at the end." Park 

and the assistant trader executed the trades as directed by Hwang. 

12 




44. On February 27, 2009, Tiger Asia did not own any long shares of its 

largest short positions. So, Park and the assistant trader purchased large quantities of 

CCB, ICBC, Bank of Communications, China Mobile and China Life stock during the 

morning and afternoon regular trading sessions, and then sold those newly purchased 

shares during the auction session. Park and the assistant trader also short sold these 

stocks throughout the trading day. This trading was intended to depress the closing 

prices of CCB, ICBC, Bank of Communications, China Mobile and China Life stock. 

45. Tiger Management earned over $496,000 in management fees attributable 

to the change in value of Tiger Asia's short positions described in Paragraphs 41 through 

44 during the months in which the attempted manipulative trading occurred. 

FIRST CLAIM FOR RELIEF 

Violations of Section 1 O(b) of the Exchange Act and Rule 1 Ob-5 Thereunder 
(Against all Defendants) 

46. The Commission realleges and incorporates by reference herein each and 

every allegation contained in paragraphs 1 through 45 of this Complaint. 

47. The information provided by the IBP As to Park who communicated it to 

Hwang was, in each case, material and nonpublic. Before providing this material 

nonpublic information to Park, in each case, the IBP A required that Park, on behalf of 

Tiger Asia, agree to be brought over the wall, and to refrain from trading the relevant 

securities. In each case, Park agreed, on behalf ofTiger Asia, to be brought over the 

wall. 

48. In each case, after receiving the material nonpublic information from the 

IBPA, Hwang directed Park to short sell the relevant securities in Tiger Asia's accounts 

in advance of the private placement. 

13 




49. Defendants Hwang, Tiger Management, Tiger Partners and Park 

knowingly or recklessly breached a duty of trust and confidence owed to the IBP As by 

short selling the relevant securities while in possession ofmaterial nonpublic information 

about the forthcoming private placements provided by the IBP As. 

50. By engaging in the conduct described above, defendants Hwang, Tiger 

Management, Tiger Partners and Park, and each of them, in connection with the purchase 

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

of the mails, or a facility of a national securities exchange, directly or indirectly: 

(a) employed devices, schemes or artifices to defraud; (b) made untrue statements of 

material fact, or omitted to state material facts necessary in order to make statements 

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

(c) engaged in acts, practices or courses of business which operated or would have 

operated as a fraud or deceit upon persons. 

51. By virtue of the foregoing, defendants Hwang, Tiger Management, Tiger 

Partners and Park, and each of them, directly or indirectly, violated, and, unless enjoined, 

will again violate, Section lO(b) ofthe Exchange Act, [15 U.S.C. § 78j(b)] and Rule lOb­

5 thereunder [17 C.F.R. § 240.10b-5]. 

SECOND CLAIM FOR RELIEF 

Violations of Section 17(a) of the Securities Act 
(Against all Defendants) 

52. The Commission realleges and incorporates by reference herein each and 

every allegation contained in paragraphs 1 through 51 of this Complaint. 

53. By virtue of the foregoing, in the offer or sale of securities, by the use of 

any means or instruments of transportation or communication in interstate commerce, or 

14 




by use of the mails, directly or indirectly, defendants Hwang, Tiger Management, Tiger 

Partners and Park, and each of them: (a) employed devices, schemes or artifices to 

defraud; (b) obtained money or property by means of 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; or (c) engaged in 

transactions practices or courses ofbusiness which operate or would operate as a fraud or 

deceit upon a purchaser. 

54. By reason of the conduct described above, defendants Hwang, Tiger 

Management, Tiger Partners and Park, and each of them, directly or indirectly, violated, 

and unless enjoined, will again violate, Section 17(a) of the Securities Act [15 U.S.C. § 

77q(a)]. 

THIRD CLAIM FOR RELIEF 

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

(Against Defendants Hwang, Tiger Management and Tiger Partners) 


55. The Commission realleges and incorporates by reference herein each and 

every allegation contained in paragraphs 1 through 54 of this Complaint. 

56. At all relevant times, Hwang, Tiger Management and Tiger Partners were 

investment advisers within the meaning of Section 202(a)(11) of the Advisers Act [15 

U.S.C. § 80b-2(a)(11)]. 

57. Despite owing a duty to the Funds to act in the best interests of the Funds, 

Hwang, Tiger Management and Tiger Partners knowingly or recklessly attempted to 

manipulate the month-end closing prices of stocks in which the Funds had large short 

positions. Tiger Asia placed these trades in an attempt to inflate the Funds' assets under 

15 




management. The more assets Tiger Asia had under management, the greater the 

management fee Tiger Management was entitled to collect. 

58. By engaging in the conduct described above, defendants Hwang, Tiger 

Management and Tiger Partners, and each of them, directly or indirectly, knowingly or 

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

(a) employed devices, schemes or artifices to defraud clients or prospective clients, or (b) 

engaged in transactions, practices or courses of business which operated as a fraud or 

deceit upon clients or prospective clients. 

59. By reason of the foregoing, defendants Hwang, Tiger Management and 

Tiger Partners, and each ofthem, directly or indirectly, violated, and unless enjoined, will 

again violate, Sections 206(1) and 206(2) ofthe Advisers Act [15 U.S.C. §§ 80b-6(1) and 

80b-6(2)]. 

FOURTH CLAIM FOR RELIEF 

Violations of Sections 206(4) of the Advisers Act and Rule 206(4)-8 Thereunder 
(Against Defendants Hwang, Tiger Management and Tiger Partners) 

60. The Commission realleges and incorporates by reference herein each and 

every allegation contained in paragraphs 1 through 59 of this Complaint. 

61. The Funds were pooled investment vehicles, as defined in Rule 206(4)-8 

under the Advisers Act, and engaged primarily in the business of investing, directly or 

indirectly, in securities. 

62. By engaging in the conduct alleged above, defendants Hwang, Tiger 

Management and Tiger Partners, and each of them, directly or indirectly, knowingly or 

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

(a) made untrue statements ofmaterial fact or omitted to state material facts necessary to 

16 




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

misleading, to an investor or prospective investor in the Funds; or (b) otherwise engaged 

in acts, practices, or courses ofbusiness that were fraudulent, deceptive or manipulative 

with respect to investors or prospective investor in the Funds. 

63. . By reason of the foregoing, Defendants Hwang, Tiger Management and 

Tiger Partners, and each of them, directly or indirectly, violated, and unless enjoined, will 

again violate, Section 206(4) ofthe Advisers Act [15 U.S.C. § 80b-6(4)] and Rule 

206(4)-8 thereunder [17 C.F.R. § 275.206(4)-8]. 

FIFTH CLAIM FOR RELIEF 

Aiding and Abetting Violations of Sections 206(1) and 206(2) of the Advisers Act 
(Against Defendant Park) 

64. The Commission realleges and incorporates by reference herein each and 

every allegation contained in paragraphs 1 through 63 of this Complaint. 

65. At all relevant times, Park was an associated person ofTiger Management, 

an investment adviser. 

66. Park provided substantial assistance to Hwang, Tiger Management and 

Tiger Partners in their attempts to manipulate the month-end closing prices of stocks in 

which the Funds had large short positions. At Hwang's direction, Park and Tiger Asia's 

assistant trader knowingly sold large quantities of stocks in which the Funds had large 

short positions on the last trading day of the months ofNovember 2008, December 2008, 

January 2009, and February 2009, in an attempt to depress the stocks' closing prices. 

67. By engaging in the conduct described above, Park knowingly provided 

substantial assistance to Hwang, Tiger Management and Tiger Partners, and thus aided 

17 




and abetted Hwang's, Tiger Management's and Tiger Partners' violations of Sections 

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

SIXTH CLAIM FOR RELIEF 


Aiding and Abetting Violations of Section 206(4) of the Advisers Act and Rule 

206(4)-8 Thereunder 


(Against Defendant Park) 


68. The Commission realleges and incorporates by reference herein each and 

every allegation contained in paragraphs 1 through 67 of this Complaint. 

69. At all relevant times, Park was an associated person ofTiger Management, 

an investment adviser. 

70. By engaging in the conduct described above, Park knowingly provided 

substantial assistance to Hwang, Tiger Management and Tiger Partners, and thus aided 

and abetted Hwang's, Tiger Management's and Tiger Partners' violations of Section 

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

C.F.R. § 275.206(4)-8]. 

RELIEF SOUGHT 

WHEREFORE, the Commission respectfully requests that this Court enter a 

Final Judgment: 

I. 

Permanently restraining and enjoining defendants Hwang, Tiger Management, 

Tiger Partners and Park, and each ofthem, from violating Section 17(a) of the Securities 

Act [15 U.S.C. § 77q(a)], Section 10(b) ofthe Exchange Act [15 U.S.C. § 78j(b)] and 

Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5], and Sections 206(1), 206(2), and 206(4) 

18 




ofthe Advisers Act [15 U.S.C. §§ 80b-6(1), (2), and (4)] and Rule 206(4)-8 thereunder 

[17 C.F.R. § 275.206(4)-8]; 

II. 

Ordering defendants Hwang, Tiger Management, Tiger Partners and Park to 

disgorge, with prejudgment interest, all ill-gotten gains received as a result of the conduct 

alleged in this Complaint. 

III. 

Ordering defendants Hwang, Tiger Management, Tiger Partners and Park to pay 

civil monetary penalties pursuant to Section 21A of the Exchange Act [15 U.S.C. § 78u­

1] or Section 209(e) ofthe Advisers Act [15 U.S.C. § 80b-9(e)]; and 

IV. 

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

Dated: 	 December 12, 2012 
New York, New York 

Associate Regional Director 
Attorney for Plaintiff 
SECURITIES AND EXCHANGE 
COMMISSION 
New York Regional Office 
3 World Financial Center, Suite 400 
New York, New York 10281-1022 
(212) 336-0181 
[email protected] 

Of Counsel: 

Amelia A. Cottrell ([email protected])* 

Thomas P. Smith, Jr. ([email protected])* 

Sandeep Satwalekar ([email protected])* 


*not admitted in New Jersey 


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mailto:[email protected]
mailto:[email protected]