SEC v. AI Financial Education Foundation Ltd., No. 1:25-cv-03649, District of Colorado (Nov. 17, 2025) — Complaint

 
 
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UNITED STATES DISTRICT COURT 
DISTRICT OF COLORADO 
 
Case No.  
 
SECURITIES AND EXCHANGE COMMISSION, 
 
Plaintiff, 
 
v. 
 
AI FINANCIAL EDUCATION FOUNDATION LTD. 
 
Defendant. 
 
 
COMPLAINT AND JURY TRIAL DEMAND 
 
 
Plaintiff Securities and Exchange Commission (the “SEC”),  for its Complaint against AI 
Financial Education Foundation Ltd. (“AI Financial”), a  lleges as follows: 
SUMMARY OF ALLEGATIONS 
 
1. This case concerns material misrepresentations and statements that could not be 
substantiated made by AI Financial, a purported investment adviser, in a form filed with the 
Commission and made available to the public on July 3, 2024, about AI Financial’s organization, 
office location, assets under management, and clients. 
2. Specifically, AI Financial represented in its Form ADV (a form used by investment 
advisers to register with both the Commission and state securities regulators) that it operates out of 
office space at 9888 W. Belleview Avenue, Suite 2234, Denver, Colorado 80123 (“9888 W. 
Belleview”); that Sky Zeng serves as its Chief Executive Officer (“CEO”); that it manages $10 
million in assets in the United States; that it advises a private fund (with the same name as the 
defendant: AI Financial Education Foundation Ltd.); and that a separate registered investment 
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adviser (“RIA”) reports information about this private fund to the Commission on its own Form 
ADV. 
3. There is no 9888 W. Belleview Avenue with the zip code 80123 in Denver, but there 
is such an address with that zip code in Littleton, Colorado, which is part of the Denver 
metropolitan area. 
4. Contrary to AI Financial’s representations, the current business occupant of 9888 W. 
Belleview has no knowledge of AI Financial or its purported CEO, and the separate RIA has not 
reported information about the purported private fund. Moreover, the Commission has not found 
any reporting of information about the private fund on other filings made with the Commission. 
5. In addition, AI Financial failed to respond to a request by Commission attorneys to 
provide records to substantiate the information on the Form ADV, including the amount of private 
fund assets under management in the United States. 
6. By engaging in the conduct described in this Complaint, AI Financial violated, and 
unless enjoined will continue to violate, Sections 204(a) and 207 of the Investment Advisers Act of 
1940 (the “Advisers Act”) [15 U.S.C. §§ 80b-4(a), 80b-7]. 
NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT 
 
7. The Commission brings this action under enforcement authority conferred by 
Sections 209(d) and 209(e) of the Advisers Act [15 U.S.C. §§ 80b-9(d) and 80b-9(e)]. 
8. The Commission seeks a final judgment: (a) permanently enjoining AI Financial 
from violating the federal securities laws this Complaint alleges it has violated; (b) permanently 
enjoining AI Financial, its owners, and its executive officers, from filing a Form ADV as an exempt 
reporting adviser; (c) ordering AI Financial to pay a civil money penalty under Section 209(e) of 
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the Advisers Act [15 U.S.C. § 80b-209(e)]; and (d) ordering any other and further relief the Court 
may deem just and proper. 
JURISDICTION AND VENUE 
 
9. This Court has jurisdiction over this action under Section 214 of the Advisers Act 
[15 U.S.C. § 80b-14]. 
10. Defendant, directly or indirectly, made use of the means or instrumentalities of 
interstate commerce or of the mails in connection with the transactions, acts, practices, and course 
of business alleged. 
11. Venue is proper in the District of Colorado under Section 214 of the Advisers Act 
[15 U.S.C. § 80b-14]. Certain of the acts, practices, transactions, and courses of business alleged in 
this Complaint occurred within this District. Specifically, AI Financial represented on corporate 
filings with both the Commission and the Colorado Secretary of State that its primary business 
address is 9888 W. Belleview, which is located in the District. 
DEFENDANT 
12. AI Financial Education Foundation Ltd. claims that it is a Colorado corporation. 
On June 23, 2024, AI Financial filed a certificate of incorporation with the Colorado Secretary of 
State, in which it used the name “Denggao Peng” as the filer and incorporator. On the certificate of 
incorporation, AI Financial listed 1312 17th Street, Suite 600, Denver CO 80202 as both its 
principal office address and Peng’s address. On June 30, 2024, AI Financial filed a Statement of 
Change with the Colorado Secretary of State, changing its principal office address to 9888 W. 
Belleview. 
  
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FACTS 
 
I. Investment Adviser Registration and Commission Form ADV 
13. The Commission regulates investment advisers, primarily under the Advisers Act 
and the rules adopted under that statute. One of the central elements of the regulatory program is 
the requirement that an “investment adviser” under the Advisers Act register with the Commission, 
unless exempt or prohibited from registration. Generally, only larger advisers that have $100 
million or more of regulatory assets under management, or that provide advice to investment 
company clients, are permitted to register with the Commission. Smaller advisers register under 
state law with state securities authorities. 
14. Exempt reporting advisers (“ERAs”) are a category of investment advisers who 
would otherwise be required to register with the Commission under the Advisers Act but for the 
specific exemptions outlined in Section 203 of the Advisers Act. ERAs include an adviser to private 
funds with less than $150 million in assets under management in the United States. The registration 
exemption for such private fund advisers is Section 203(m) of the Advisers Act and Rule 203(m)-1 
thereunder. 
15. While ERAs are exempt from the registration requirements, any books or records 
they do maintain are subject to examination by the Commission under Section 204(a) of the 
Advisers Act. 
16. Form ADV is the form used by investment advisers to register with the Commission 
and with state securities authorities. It consists of two parts, both of which are required to be filed 
with the Commission, and both of which are publicly available once filed: Form ADV Part 1 and 
Form ADV Part 2. 
17. ERAs, while exempt from registration, are still required to file certain items in Form 
ADV Part 1. ERAs do not complete Part 2. 
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18. Part 1 asks for information about, among other things, an adviser’s business, amount 
of assets under management, ownership, and clients. 
19. Form ADV is filed electronically with the Commission through the Investment 
Adviser Registration Depository (“IARD”), a secure Internet based filing system that collects and 
maintains the registration, reporting, and disclosure information for investment advisers. The 
Financial Industry Regulatory Authority (“FINRA”), under contract with the Commission, is the 
developer and operator of the IARD system. Once filed, the Form ADV is available to the public 
through the Commission’s Investment Adviser Public Disclosure database, located at 
https://adviserinfo.sec.gov. 
II. AI Financial Made Material Misstatements and Statements in its Form ADV Filed 
with the Commission That Could Not Be Substantiated. 
 
20. On July 3, 2024, AI Financial filed its Form ADV with the Commission as an ERA. 
In that filing, AI Financial claims that it qualifies for a registration exemption because it acts solely 
as an adviser to private funds and has assets under management in the United States of less than 
$150 million. 
21. In the Form ADV, AI Financial lists 9888 W. Belleview as its principal office and 
place of business, and states that Sky Zeng serves as its CEO. AI Financial also provides a 
telephone number with a (202) area code as the main number for its Colorado office, even though 
(202) is the area code for Washington, D.C. 
22. In the Form ADV, AI Financial provides two Central Index Key (“CIK”) numbers, 
which are numbers that the Commission assigns to a public reporting company and that can be 
searched on the Commission’s computer systems to identify corporations and individuals required 
to file certain disclosure information. 
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23. The Form ADV represents that the amount of AI Financial’s private fund assets 
under management in the United States is $10 million. 
24. In addition, the Form ADV represents that AI Financial advises a private fund, also 
named “AI Financial Education Foundation Ltd.,” and lists a private fund identification number. 
The private fund identification number is a unique identification number assigned to a private fund. 
25. AI Financial further states in its Form ADV that a separate RIA “provides 
information” about AI Financial’s private fund on its own Form ADV filing.  
26. Contrary to AI Financial’s representations in the Form ADV: 
a. the individual who has owned the business located at 9888 W. Belleview 
since 2022 stated that he has no knowledge of, nor any affiliation with, AI Financial or Sky Zeng; 
b. the third-party RIA has not reported the AI Financial private fund on its Form 
ADV filings. Further, the Commission has not found reporting of the private fund or the associated 
identification number on other filings; and 
c. a search for either AI Financial or its purported CIK numbers on the 
Commission’s public reporting company database yields no information. 
III. AI Financial Failed to Produce Records for Examination. 
27. Section 204(a) of the Advisers Act provides that all records of investment advisers 
are “subject at any time, or from time to time, to such reasonable periodic, special, or other 
examinations by representatives of the Commission as the Commission deems necessary or 
appropriate in the public interest or for the protection of investors.” 15 U.S.C. § 80b-4(a). 
28. Although ERAs are exempt from the registration requirements, any books and 
records they do maintain are subject to examination under Section 204(a). 
29. Since November 19, 2024, Commission attorneys have attempted to obtain books 
and records from AI Financial that it is required to produce under the Advisers Act.  
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30. On November 19 and November 21, 2024, a Commission attorney emailed AI 
Financial a letter requesting production of books and records regarding the information on the Form 
ADV, including its organizational information and the private fund assets under management in the 
United States. Although the Form ADV itself does not contain an email address for AI Financial, 
the Commission attorney used email addresses that AI Financial provided to (i) FINRA in 
connection with the Form ADV filing process and (ii) the Colorado Department of State in 
connection with filing its incorporation documents. 
31. On November 21, 2024, Commission attorneys called telephone numbers that AI 
Financial provided on the Form ADV and to FINRA in connection with the Form ADV filing 
process. One number went to a busy tone; the other number reached a voicemail recording and the 
Commission attorney left a message that was never returned. 
32. On April 15, 2025, a Commission attorney again emailed AI Financial at the same 
addresses that AI Financial provided to FINRA and the Colorado Department of State. To date, AI 
Financial has not responded to any emails or returned the voicemail message. 
33. In sum, the Form ADV materially misrepresented information about AI Financial’s 
primary business location and reporting of private fund clients; and it provided information about 
its CEO and the amount of private fund assets under management in the United States that (1) could 
not be substantiated, (2) AI Financial failed to provide information about when requested, and (3) is 
likely false. Further, AI Financial failed to respond to Commission requests to produce books and 
records subject to examination.  
34. Given the above facts, a reasonable investor would have considered it important in 
making their decision to invest with AI Financial to know complete and accurate information about 
its organizational structure and management personnel, office location, amount of assets under 
management in the United States, and private fund clients. 
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FIRST CLAIM FOR RELIEF 
Violation of Advisers Act Section 204(a) 
 
35. The Commission realleges and incorporates by reference here the allegations in 
paragraphs 1 through 34. 
36. AI Financial failed to make its books and records available to Commission attorneys 
for examination. 
37. By reason of the foregoing, AI Financial has violated and, unless enjoined, will again 
violate Section 204(a) of the Advisers Act [15 U.S.C. § 80b-4(a)]. 
SECOND CLAIM FOR RELIEF 
Violation of Advisers Act Section 207 
 
38. The Commission realleges and incorporates by reference here the allegations in 
paragraphs 1 through 34. 
39. AI Financial, by use of the mails, and the means and instruments of interstate 
commerce, directly and indirectly, willfully made untrue statements of material fact in, and omitted 
to state material facts required to be stated in, reports filed with the Commission. 
40. By reason of the foregoing, AI Financial, directly or indirectly, has violated and, 
unless enjoined, will again violate Section 207 of the Advisers Act [15 U.S.C. § 80b-7]. 
PRAYER FOR RELIEF 
 
WHEREFORE, the Commission requests that this Court enter a Final Judgment: 
I. 
 Permanently restraining and enjoining AI Financial and its agents, servants, employees and 
attorneys and all persons in active concert or participation with any of them from violating, directly 
or indirectly, Sections 204(a) and 207 of the Advisers Act [15 U.S.C. §§ 80b-4(a); 80b-7]. 
 
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II. 
Permanently restraining and enjoining AI Financial, its owners, and its executive officers, 
from filing a Form ADV as an ERA. 
III. 
Ordering AI Financial to pay a civil monetary penalty under Section 209(e) of the Advisers 
Act [15 U.S.C. § 80b-9(e)]. 
IV. 
Granting any other and further relief this Court may deem just and proper. 
 
JURY DEMAND 
Under Rule 38 of the Federal Rules of Civil Procedure, Plaintiff demands that this case be 
tried to a jury.  
 
 
Dated: November 13, 2025   Respectfully submitted, 
/s/  David H. London    
David H. London 
Alexandra Lavin 
Xinyue Angela Lin 
Sarah McAteer 
Dahlia Rin 
Attorneys for Plaintiff 
U.S.
 SECURITIES AND EXCHANGE COMMISSION 
Boston Regional Office 
33 Arch Street, 24th Floor 
Boston, MA 02110 
Phone: 617-573-8997 (London) 
Email: [email protected] 
 
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UNITED STATES DISTRICT COURT 
DISTRICT OF COLORADO 

 
Case No.  

 
SECURITIES AND EXCHANGE COMMISSION, 

 
Plaintiff, 

 
v. 

 
AI FINANCIAL EDUCATION FOUNDATION LTD. 

 
Defendant. 

 
 

COMPLAINT AND JURY TRIAL DEMAND 
 
 

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

Financial Education Foundation Ltd. (“AI Financial”), alleges as follows: 

SUMMARY OF ALLEGATIONS 
 

1. This case concerns material misrepresentations and statements that could not be 

substantiated made by AI Financial, a purported investment adviser, in a form filed with the 

Commission and made available to the public on July 3, 2024, about AI Financial’s organization, 

office location, assets under management, and clients. 

2. Specifically, AI Financial represented in its Form ADV (a form used by investment 

advisers to register with both the Commission and state securities regulators) that it operates out of 

office space at 9888 W. Belleview Avenue, Suite 2234, Denver, Colorado 80123 (“9888 W. 

Belleview”); that Sky Zeng serves as its Chief Executive Officer (“CEO”); that it manages $10 

million in assets in the United States; that it advises a private fund (with the same name as the 

defendant: AI Financial Education Foundation Ltd.); and that a separate registered investment 

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adviser (“RIA”) reports information about this private fund to the Commission on its own Form 

ADV. 

3. There is no 9888 W. Belleview Avenue with the zip code 80123 in Denver, but there 

is such an address with that zip code in Littleton, Colorado, which is part of the Denver 

metropolitan area. 

4. Contrary to AI Financial’s representations, the current business occupant of 9888 W. 

Belleview has no knowledge of AI Financial or its purported CEO, and the separate RIA has not 

reported information about the purported private fund. Moreover, the Commission has not found 

any reporting of information about the private fund on other filings made with the Commission. 

5. In addition, AI Financial failed to respond to a request by Commission attorneys to 

provide records to substantiate the information on the Form ADV, including the amount of private 

fund assets under management in the United States. 

6. By engaging in the conduct described in this Complaint, AI Financial violated, and 

unless enjoined will continue to violate, Sections 204(a) and 207 of the Investment Advisers Act of 

1940 (the “Advisers Act”) [15 U.S.C. §§ 80b-4(a), 80b-7]. 

NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT 
 

7. The Commission brings this action under enforcement authority conferred by 

Sections 209(d) and 209(e) of the Advisers Act [15 U.S.C. §§ 80b-9(d) and 80b-9(e)]. 

8. The Commission seeks a final judgment: (a) permanently enjoining AI Financial 

from violating the federal securities laws this Complaint alleges it has violated; (b) permanently 

enjoining AI Financial, its owners, and its executive officers, from filing a Form ADV as an exempt 

reporting adviser; (c) ordering AI Financial to pay a civil money penalty under Section 209(e) of 

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the Advisers Act [15 U.S.C. § 80b-209(e)]; and (d) ordering any other and further relief the Court 

may deem just and proper. 

JURISDICTION AND VENUE 
 

9. This Court has jurisdiction over this action under Section 214 of the Advisers Act 

[15 U.S.C. § 80b-14]. 

10. Defendant, directly or indirectly, made use of the means or instrumentalities of 

interstate commerce or of the mails in connection with the transactions, acts, practices, and course 

of business alleged. 

11. Venue is proper in the District of Colorado under Section 214 of the Advisers Act 

[15 U.S.C. § 80b-14]. Certain of the acts, practices, transactions, and courses of business alleged in 

this Complaint occurred within this District. Specifically, AI Financial represented on corporate 

filings with both the Commission and the Colorado Secretary of State that its primary business 

address is 9888 W. Belleview, which is located in the District. 

DEFENDANT 

12. AI Financial Education Foundation Ltd. claims that it is a Colorado corporation. 

On June 23, 2024, AI Financial filed a certificate of incorporation with the Colorado Secretary of 

State, in which it used the name “Denggao Peng” as the filer and incorporator. On the certificate of 

incorporation, AI Financial listed 1312 17th Street, Suite 600, Denver CO 80202 as both its 

principal office address and Peng’s address. On June 30, 2024, AI Financial filed a Statement of 

Change with the Colorado Secretary of State, changing its principal office address to 9888 W. 

Belleview. 

  

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FACTS 
 

I. Investment Adviser Registration and Commission Form ADV 

13. The Commission regulates investment advisers, primarily under the Advisers Act 

and the rules adopted under that statute. One of the central elements of the regulatory program is 

the requirement that an “investment adviser” under the Advisers Act register with the Commission, 

unless exempt or prohibited from registration. Generally, only larger advisers that have $100 

million or more of regulatory assets under management, or that provide advice to investment 

company clients, are permitted to register with the Commission. Smaller advisers register under 

state law with state securities authorities. 

14. Exempt reporting advisers (“ERAs”) are a category of investment advisers who 

would otherwise be required to register with the Commission under the Advisers Act but for the 

specific exemptions outlined in Section 203 of the Advisers Act. ERAs include an adviser to private 

funds with less than $150 million in assets under management in the United States. The registration 

exemption for such private fund advisers is Section 203(m) of the Advisers Act and Rule 203(m)-1 

thereunder. 

15. While ERAs are exempt from the registration requirements, any books or records 

they do maintain are subject to examination by the Commission under Section 204(a) of the 

Advisers Act. 

16. Form ADV is the form used by investment advisers to register with the Commission 

and with state securities authorities. It consists of two parts, both of which are required to be filed 

with the Commission, and both of which are publicly available once filed: Form ADV Part 1 and 

Form ADV Part 2. 

17. ERAs, while exempt from registration, are still required to file certain items in Form 

ADV Part 1. ERAs do not complete Part 2. 

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18. Part 1 asks for information about, among other things, an adviser’s business, amount 

of assets under management, ownership, and clients. 

19. Form ADV is filed electronically with the Commission through the Investment 

Adviser Registration Depository (“IARD”), a secure Internet based filing system that collects and 

maintains the registration, reporting, and disclosure information for investment advisers. The 

Financial Industry Regulatory Authority (“FINRA”), under contract with the Commission, is the 

developer and operator of the IARD system. Once filed, the Form ADV is available to the public 

through the Commission’s Investment Adviser Public Disclosure database, located at 

https://adviserinfo.sec.gov. 

II. AI Financial Made Material Misstatements and Statements in its Form ADV Filed 
with the Commission That Could Not Be Substantiated. 

 
20. On July 3, 2024, AI Financial filed its Form ADV with the Commission as an ERA. 

In that filing, AI Financial claims that it qualifies for a registration exemption because it acts solely 

as an adviser to private funds and has assets under management in the United States of less than 

$150 million. 

21. In the Form ADV, AI Financial lists 9888 W. Belleview as its principal office and 

place of business, and states that Sky Zeng serves as its CEO. AI Financial also provides a 

telephone number with a (202) area code as the main number for its Colorado office, even though 

(202) is the area code for Washington, D.C. 

22. In the Form ADV, AI Financial provides two Central Index Key (“CIK”) numbers, 

which are numbers that the Commission assigns to a public reporting company and that can be 

searched on the Commission’s computer systems to identify corporations and individuals required 

to file certain disclosure information. 

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23. The Form ADV represents that the amount of AI Financial’s private fund assets 

under management in the United States is $10 million. 

24. In addition, the Form ADV represents that AI Financial advises a private fund, also 

named “AI Financial Education Foundation Ltd.,” and lists a private fund identification number. 

The private fund identification number is a unique identification number assigned to a private fund. 

25. AI Financial further states in its Form ADV that a separate RIA “provides 

information” about AI Financial’s private fund on its own Form ADV filing.  

26. Contrary to AI Financial’s representations in the Form ADV: 

a. the individual who has owned the business located at 9888 W. Belleview 

since 2022 stated that he has no knowledge of, nor any affiliation with, AI Financial or Sky Zeng; 

b. the third-party RIA has not reported the AI Financial private fund on its Form 

ADV filings. Further, the Commission has not found reporting of the private fund or the associated 

identification number on other filings; and 

c. a search for either AI Financial or its purported CIK numbers on the 

Commission’s public reporting company database yields no information. 

III. AI Financial Failed to Produce Records for Examination. 

27. Section 204(a) of the Advisers Act provides that all records of investment advisers 

are “subject at any time, or from time to time, to such reasonable periodic, special, or other 

examinations by representatives of the Commission as the Commission deems necessary or 

appropriate in the public interest or for the protection of investors.” 15 U.S.C. § 80b-4(a). 

28. Although ERAs are exempt from the registration requirements, any books and 

records they do maintain are subject to examination under Section 204(a). 

29. Since November 19, 2024, Commission attorneys have attempted to obtain books 

and records from AI Financial that it is required to produce under the Advisers Act.  

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30. On November 19 and November 21, 2024, a Commission attorney emailed AI 

Financial a letter requesting production of books and records regarding the information on the Form 

ADV, including its organizational information and the private fund assets under management in the 

United States. Although the Form ADV itself does not contain an email address for AI Financial, 

the Commission attorney used email addresses that AI Financial provided to (i) FINRA in 

connection with the Form ADV filing process and (ii) the Colorado Department of State in 

connection with filing its incorporation documents. 

31. On November 21, 2024, Commission attorneys called telephone numbers that AI 

Financial provided on the Form ADV and to FINRA in connection with the Form ADV filing 

process. One number went to a busy tone; the other number reached a voicemail recording and the 

Commission attorney left a message that was never returned. 

32. On April 15, 2025, a Commission attorney again emailed AI Financial at the same 

addresses that AI Financial provided to FINRA and the Colorado Department of State. To date, AI 

Financial has not responded to any emails or returned the voicemail message. 

33. In sum, the Form ADV materially misrepresented information about AI Financial’s 

primary business location and reporting of private fund clients; and it provided information about 

its CEO and the amount of private fund assets under management in the United States that (1) could 

not be substantiated, (2) AI Financial failed to provide information about when requested, and (3) is 

likely false. Further, AI Financial failed to respond to Commission requests to produce books and 

records subject to examination.  

34. Given the above facts, a reasonable investor would have considered it important in 

making their decision to invest with AI Financial to know complete and accurate information about 

its organizational structure and management personnel, office location, amount of assets under 

management in the United States, and private fund clients. 

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FIRST CLAIM FOR RELIEF 
Violation of Advisers Act Section 204(a) 

 
35. The Commission realleges and incorporates by reference here the allegations in 

paragraphs 1 through 34. 

36. AI Financial failed to make its books and records available to Commission attorneys 

for examination. 

37. By reason of the foregoing, AI Financial has violated and, unless enjoined, will again 

violate Section 204(a) of the Advisers Act [15 U.S.C. § 80b-4(a)]. 

SECOND CLAIM FOR RELIEF 
Violation of Advisers Act Section 207 

 
38. The Commission realleges and incorporates by reference here the allegations in 

paragraphs 1 through 34. 

39. AI Financial, by use of the mails, and the means and instruments of interstate 

commerce, directly and indirectly, willfully made untrue statements of material fact in, and omitted 

to state material facts required to be stated in, reports filed with the Commission. 

40. By reason of the foregoing, AI Financial, directly or indirectly, has violated and, 

unless enjoined, will again violate Section 207 of the Advisers Act [15 U.S.C. § 80b-7]. 

PRAYER FOR RELIEF 
 

WHEREFORE, the Commission requests that this Court enter a Final Judgment: 

I. 

 Permanently restraining and enjoining AI Financial and its agents, servants, employees and 

attorneys and all persons in active concert or participation with any of them from violating, directly 

or indirectly, Sections 204(a) and 207 of the Advisers Act [15 U.S.C. §§ 80b-4(a); 80b-7]. 

 

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II. 

Permanently restraining and enjoining AI Financial, its owners, and its executive officers, 

from filing a Form ADV as an ERA. 

III. 

Ordering AI Financial to pay a civil monetary penalty under Section 209(e) of the Advisers 

Act [15 U.S.C. § 80b-9(e)]. 

IV. 

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

 

JURY DEMAND 

Under Rule 38 of the Federal Rules of Civil Procedure, Plaintiff demands that this case be 

tried to a jury.  

 

 

Dated: November 13, 2025   Respectfully submitted, 

/s/ David H. London    
David H. London 
Alexandra Lavin 
Xinyue Angela Lin 
Sarah McAteer 
Dahlia Rin 
Attorneys for Plaintiff 
U.S. SECURITIES AND EXCHANGE COMMISSION 
Boston Regional Office 
33 Arch Street, 24th Floor 
Boston, MA 02110 
Phone: 617-573-8997 (London) 
Email: [email protected] 

 

Case No. 1:25-cv-03649     Document 1     filed 11/13/25     USDC Colorado     pg 9 of 9

mailto:[email protected]

	UNITED STATES DISTRICT COURT
	DISTRICT OF COLORADO
	SECURITIES AND EXCHANGE COMMISSION,
	AI FINANCIAL EDUCATION FOUNDATION LTD.
	COMPLAINT AND JURY TRIAL DEMAND
	SUMMARY OF ALLEGATIONS
	NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT
	JURISDICTION AND VENUE
	FACTS
	PRAYER FOR RELIEF