2025-12-05 sec-litreleases pdf 89 KB 140 chars

SEC v. BEAR

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Scheme: unclassified
Court: Southern District of New York

Classified unclassified. No EDGAR filing fingerprint (criminal/DOJ-side scheme). detection rule →

Extracted insights

Entities 4

organization Defendants
person Defendants
agency Securities and Exchange Commission
organization Securities and Exchange Commission

Triples 6

Securities And Exchange Commission consents to relief sought by the motions
Defendants filed unopposed motion
Securities And Exchange Commission agrees final judgments should be modified
Securities And Exchange Commission notes provisions of the Judgment
Defendants seek modification of final judgments
Securities And Exchange Commission submitted proposed orders

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SEC v. BEAR · Source

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Extracted body text (140c)

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 

 
 
  
SECURITIES AND EXCHANGE COMMISSION,  
  

Plaintiff,  
 No. 1:03-cv-2937 

v.  
  
BEAR, STEARNS & CO. INC., 
 

         

  
Defendant.  

  
 
SECURITIES AND EXCHANGE COMMISSION, 
                                                     Plaintiff, 
 
                                        v. 
 
J.P. MORGAN SECURITIES INC., 
 
                                                     Defendant. 
 

 
 
 
 
 
No. 1:03-cv-2939 

 
SECURITIES AND EXCHANGE COMMISSION, 
                                                     Plaintiff, 
 
                                        v. 
 
LEHMAN BROTHERS, INC., 
 
                                                     Defendant. 
 

 
 
 
 
 
No. 1:03-cv-2940 

 

 

 

 

 

Case 1:04-cv-06909-WHP     Document 133     Filed 12/05/25     Page 1 of 5



 
SECURITIES AND EXCHANGE COMMISSION, 
                                                     Plaintiff, 
 
                                        v. 
 
MERRILL LYNCH, PIERCE, FENNER & SMITH 
INC., 
 
                                                     Defendant. 
 

 
 
 
 
 
No. 1:03-cv-2941 

 
SECURITIES AND EXCHANGE COMMISSION, 
                                                     Plaintiff, 
 
                                        v. 
 
UBS SECURITIES f/k/a UBS WARBERG LLC, 
 
                                                     Defendant. 
 

 
 
 
 
 
No. 1:03-cv-2943 

 
SECURITIES AND EXCHANGE COMMISSION, 
                                                     Plaintiff, 
 
                                        v. 
 
GOLDMAN, SACHS & CO., 
 
                                                     Defendant. 
 

 
 
 
 
 
No. 1:03-cv-2944 

 
SECURITIES AND EXCHANGE COMMISSION, 
                                                     Plaintiff, 
 
                                        v. 
 
CITIGROUP GLOBAL MARKETS INC., f/k/a 
SALOMON SMITH BARNEY,  
 
 
                                                     Defendant. 
 

 
 
 
 
 
No. 1:03-cv-2945 

 

Case 1:04-cv-06909-WHP     Document 133     Filed 12/05/25     Page 2 of 5



 
SECURITIES AND EXCHANGE COMMISSION, 
                                                     Plaintiff, 
 
                                        v. 
 
CREDIT SUISSE FIRST BOSTON LLC, f/k/a 
CREDIT SUISSE FIRST BOSTON 
CORPORATION, 
 
                                                     Defendant. 
 

 
 
 
 
 
No. 1:03-cv-2946 

 
SECURITIES AND EXCHANGE COMMISSION, 
                                                     Plaintiff, 
 
                                        v. 
 
MORGAN STANLEY& CO. INCORPORATED, 
 
                                                     Defendant. 
 

 
 
 
 
 
No. 1:03-cv-2948 

 
SECURITIES AND EXCHANGE COMMISSION, 
                                                     Plaintiff, 
 
                                        v. 
 
DEUTSCHE BANK SECURITIES INC.,  
 
 
                                                     Defendant. 
 

 
 
 
 
 
No. 1:04-cv-6909 

 

NOTICE REGARDING DEFENDANTS’ RULE 60(b) MOTION TO MODIFY 
ADDENDUM A OF GLOBAL RESEARCH SETTLEMENT 

On December 5, 2025, Defendants filed an unopposed motion pursuant to 

Rule 60(b) of the Federal Rules of Civil Procedure to modify final judgments in the 

above-captioned cases.   

Case 1:04-cv-06909-WHP     Document 133     Filed 12/05/25     Page 3 of 5



Without adopting or joining Defendants in their motions, the Securities and 

Exchange Commission (SEC) consents to the relief sought by the motions and 

agrees that the final judgments should be modified as reflected in the proposed 

orders submitted by each respective Defendant. In so doing, the SEC notes 

the  provisions of the Judgment that specifically contemplate future modification—

see Judgment, Addendum A, Section II.7 (with respect to any term of the injunctive 

relief undertakings not explicitly superseded by an SEC or self-regulatory 

organization rule, it was the expectation of the SEC that it would agree to an 

amendment or modification of Addendum A, “subject to Court approval, unless the 

SEC believes such amendment or modification would not be in the public 

interest.”)—and the passage of FINRA Rule 2241, which addresses the same issues 

and concerns as the Judgment. 

Based on these unique facts and circumstances, the SEC believes 

modification of the Judgment is in the public interest. 

 

Dated: December 5, 2025    Respectfully submitted, 

       /s/ Zachary A. Avallone 
Zachary A. Avallone  
           (pro hac vice pending) 
Securities and Exchange Commission 
100 F Street, NE 
Washington, DC 20549 
Tel: (202) 551-4479 
Email: [email protected] 

 
 

 

Case 1:04-cv-06909-WHP     Document 133     Filed 12/05/25     Page 4 of 5



CERTIFICATE OF SERVICE 

 I certify that on December 5, 2025, I caused a copy of the foregoing document 

to be filed through the Court’s ECF system, which will serve a copy on all counsel of 

record. 

       /s/ Zachary A. Avallone 
       Zachary A. Avallone 

Case 1:04-cv-06909-WHP     Document 133     Filed 12/05/25     Page 5 of 5