2011-09-09 SEC Press complaint 442 KB 1,069 chars

SEC v. Jody Dunn, No. 4:11-cv-00577, Eastern District of Texas (Sept. 9, 2011) — Complaint

raw: Securities and Exchange Commission v Jody Dunn

Securities and Exchange Commission v Jody Dunn, No. 4:11-cv-00577 (Sept. 9, 2011)

Caption
SEC v. Jody Dunn
Exhibit of SEC Charges Solicitor in Investment Scheme Targeting Deaf Community; 2011-181; September 9, 2011
Source PDF JSON
summary

Jody Dunn defrauded over 7,133 deaf investors by misrepresenting that their $7 million in funds—$4 million of which came from deaf individuals—would be invested through Imperia Invest IBC, when he instead misappropriated at least $3.45 million for personal expenses like his mortgage and car payments, leading the SEC to file a civil complaint for securities fraud and unregistered securities sales.

paragraph

Jody Dunn raised over $7 million from investors through Imperia Invest IBC, with approximately $4 million coming from 7,133 deaf investors whom he misled into believing their money would be invested. Instead, Dunn misappropriated at least $3.45 million of those funds to pay for personal expenses, including his mortgage, car payments, insurance, and other non-investment uses. The SEC filed a civil complaint charging him with securities fraud, material misrepresentations, and violations of federal securities registration requirements, seeking injunctive relief, disgorgement, and civil penalties.

narrative

Jody Dunn orchestrated a fraudulent scheme by raising over $7 million from investors through Imperia Invest IBC, with approximately $4 million of that amount coming from 7,133 deaf investors who were specifically targeted. He falsely represented that their funds would be invested in Imperia, but in reality, he diverted at least $3.45 million of investor money to cover personal expenses such as his mortgage, car payments, car insurance, and other non-business expenditures. Dunn failed to disclose this misappropriation and conducted the entire operation without registering the securities offering, violating federal securities laws. The Securities and Exchange Commission filed a civil complaint against him in the U.S. District Court for the Eastern District of Texas, alleging securities fraud, material misrepresentations, and unregistered securities sales. The complaint sought injunctive relief to halt further violations, disgorgement of all ill-gotten gains, and civil monetary penalties. No criminal charges or settlement outcomes are detailed in the provided document, as this was a civil enforcement action initiated by the SEC. The case highlights the exploitation of vulnerable communities and the misuse of investment vehicles to conceal personal financial misconduct.

Enriched metadata

Scheme
unregistered-securities (100%)
Court
Eastern District of Texas
Case No.
4:11-cv-00577
Victim loss
$3,450,000
Classified unregistered-securities(confidence 100%). EDGAR detection: forms Form D/S-1· recall 41% / precision 30%. detection rule →
Statutes
15 U.S.C. § 77q(a)
Parties
Securities and Exchange CommissionJody Dunn
Keywords
document pagepage pageidcv-documentpagepageiddunnjody dunninvestorsimperiasecurities exchangeexchange commissiondunn dunndeaf investorssecurities

Extracted insights

Dollar amounts 3
  • $7.00M $7 million $1M–$10M
  • $4.00M $4 million $1M–$10M
  • $3.45M $3.45 million $1M–$10M
Entities 5
  • person imperia invest ibc
  • company Imperia Invest IBC
  • person jody dunn
  • company securities
  • agency Securities and Exchange Commission
Triples 7
  • Jody Dunn raised $3.45 million from investors for Imperia Invest IBC
  • Imperia Invest IBC raised in excess of $7 million
  • Imperia Invest IBC collected $4 million primarily from deaf investors in the United States
  • Jody Dunn misappropriated investor funds for personal expenses including mortgage, car payments, and car insurance
  • Jody Dunn made material misrepresentations and fraudulent unregistered offer and sale of securities
  • Securities and Exchange Commission filed complaint against Jody Dunn
  • Approximately 7,133 deaf investors sent money to Jody Dunn
PDF
Securities and Exchange Commission v Jody Dunn · Source
Text layers
Extracted body text (1,069c) 
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

PLANO DIVISION

)
SECURITIES AND EXCHANGE COMMISSION,
)
)
COMPLAINT
PLAINTIFF,
)
)
v.
) Civil No. __________
JODY DUNN,
)
)
DEFENDANT.
)
)
Plaintiff, Securities and Exchange Commission (the “Commission”), for its Complaint
against the Defendant Jody Dunn alleges as follows:
INTRODUCTION
1. This matter involves material misrepresentations, misappropriation of investor
funds, and the fraudulent, unregistered offer and sale of securities by Jody Dunn (“Dunn”).
2. Dunn raised more than $3.45 million from investors for Imperia Invest IBC
(“Imperia”).
3. Imperia raised in excess of $7 million, $4 million of which was collected
primarily from deaf investors in the United States.
4. Approximately 7,133 deaf investors sent money to Dunn, who represented that he
would invest in Imperia on their behalf.  Dunn did not disclose to investors that he would
misappropriate a portion of their funds to pay his mortgage, make car payments, pay for car
insurance and a variety of other personal expenses.
OCR text (2,138c · tika · 95% conf) 
Case 4:11-cv-00577 Document 1 Filed 09/08/11 Page 1 of 13 PageID #: 1 

IN THE UNITED STATES DISTRICT COURT
 
FOR THE EASTERN DISTRICT OF TEXAS
 

PLANO DIVISION
 

) 
SECURITIES AND EXCHANGE COMMISSION, ) 

) COMPLAINT 
PLAINTIFF, ) 

) 
v. ) Civil No. __________ 

JODY DUNN, ) 
) 

DEFENDANT.	 ) 
) 

Plaintiff, Securities and Exchange Commission (the “Commission”), for its Complaint 

against the Defendant Jody Dunn alleges as follows: 

INTRODUCTION 

1. This matter involves material misrepresentations, misappropriation of investor 

funds, and the fraudulent, unregistered offer and sale of securities by Jody Dunn (“Dunn”).     

2. Dunn raised more than $3.45 million from investors for Imperia Invest IBC 

(“Imperia”). 

3. Imperia raised in excess of $7 million, $4 million of which was collected 

primarily from deaf investors in the United States.   

4. Approximately 7,133 deaf investors sent money to Dunn, who represented that he 

would invest in Imperia on their behalf.  Dunn did not disclose to investors that he would 

misappropriate a portion of their funds to pay his mortgage, make car payments, pay for car 

insurance and a variety of other personal expenses.   



    Case 4:11-cv-00577 Document 1 Filed 09/08/11 Page 2 of 13 PageID #: 2 



    Case 4:11-cv-00577 Document 1 Filed 09/08/11 Page 3 of 13 PageID #: 3 



    Case 4:11-cv-00577 Document 1 Filed 09/08/11 Page 4 of 13 PageID #: 4 



    Case 4:11-cv-00577 Document 1 Filed 09/08/11 Page 5 of 13 PageID #: 5 



    Case 4:11-cv-00577 Document 1 Filed 09/08/11 Page 6 of 13 PageID #: 6 



    Case 4:11-cv-00577 Document 1 Filed 09/08/11 Page 7 of 13 PageID #: 7 



    Case 4:11-cv-00577 Document 1 Filed 09/08/11 Page 8 of 13 PageID #: 8 



    Case 4:11-cv-00577 Document 1 Filed 09/08/11 Page 9 of 13 PageID #: 9 



    Case 4:11-cv-00577 Document 1 Filed 09/08/11 Page 10 of 13 PageID #: 10 



    Case 4:11-cv-00577 Document 1 Filed 09/08/11 Page 11 of 13 PageID #: 11 



    Case 4:11-cv-00577 Document 1 Filed 09/08/11 Page 12 of 13 PageID #: 12 



    Case 4:11-cv-00577 Document 1 Filed 09/08/11 Page 13 of 13 PageID #: 13