SEC v. Harsh V. Patel, No. 1:26-cv-03203, Southern District of New York (Apr. 20, 2026) — Complaint

Joseph G. Sansone
Julia C. Green
Gregory R. Bockin
Karen M. Klotz*
SECURITIES AND EXCHANGE COMMISSION
Philadelphia Regional Office
1617 JFK Boulevard, Suite 520
Philadelphia, PA 19103
(215) 861-9613 (Klotz)
Email: [email protected]

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

SECURITIES AND EXCHANGE
COMMISSION,

Plaintiff,

v.

HARSH V. PATEL,

Defendant.

Case No.

COMPLAINT
JURY TRIAL DEMANDED

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

Demand for Jury Trial against defendant Harsh V. Patel (“Patel” or “Defendant”), alleges as

follows:

SUMMARY OF THE ALLEGATIONS

1. This case arises from defendant Patel’s scheme to manipulate the prices of

hundreds of securities, which distorted the market, deceived investors into buying the targeted

securities at artificially inflated prices, and netted Patel more than $5 million in illicit profits.

2. From at least May 2021 to at least January 2024 (the “Relevant Period”), Patel

used at least 10 different accounts at three different registered broker-dealers to carry out his

* Application for admission pro hac vice to be filed.

1:26-cv-3203

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scheme. As broker-dealers discovered Patel’s manipulative trading and restricted and closed his

accounts, Patel then used accounts in the name of an estranged family member, which he opened

without the family member’s knowledge or consent, and of a friend to continue his scheme and

avoid detection.

3. To carry out his scheme, Patel first rapidly placed a large number of small lot

market orders to purchase a single security, which increased the price of the security in a matter

of minutes. Patel typically did this in thinly traded securities, which are easier to manipulate.

4. Second, Patel placed non-bona fide limit orders to buy that same security, which

he did not intend to execute, to falsely indicate to the market that there was additional buying

interest in the security and to buoy the security’s price.

5. Third, Patel sold the same security that he had just acquired in a few large-lot

market orders at the now-inflated price. Finally, Patel quickly canceled the buy limit orders that

he had placed to keep the security at artificially inflated prices.

6. Patel often implemented and completed this trading strategy in a matter of

minutes and engaged in this conduct more than one thousand times, trading in hundreds of

different securities during the Relevant Period.

VIOLATIONS

7. By engaging in the conduct described in this complaint, Patel has violated, and

unless enjoined will continue to violate, Section 17(a) of the Securities Act of 1933 (“Securities

Act”) [15 U.S.C. § 77q(a)], and Sections 9(a)(2) and 10(b) of the Securities Exchange Act of

1934 (“Exchange Act”) [15 U.S.C. §§ 78i(a)(2) and 78j(b)] and Rule 10b-5 thereunder [17

C.F.R. § 240.10b-5(a)].

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NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT

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

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

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

9. The Commission seeks a final judgment: (a) permanently enjoining Defendant

from directly or indirectly engaging in conduct in violation of the laws this Complaint alleges he

has violated; (b) permanently enjoining Defendant from, directly or indirectly, opening,

maintaining or trading in any brokerage account(s) in his name, the names of any immediate

family members, the name of any company over which he has any control, or the name(s) of any

third party individuals, without providing the relevant broker-dealer(s) a copy of the Complaint

and any final judgment entered against him in this action; (c) ordering Defendant to disgorge all

ill-gotten gains received as a result of the violations alleged herein, and to pay prejudgment

interest thereon, pursuant to Sections 21(d)(3), 21(d)(5) and 21(d)(7) of the Exchange Act [15

U.S.C. §§ 78u(d)(3), 78u(d)(5) and 78u(d)(7)]; (d) ordering Defendant to pay civil money

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

21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)]; and (e) ordering any other and further

relief the Court may deem just and proper.

JURISDICTION AND VENUE

10. 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)], and Sections 21(d), 21(e),

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

11. Defendant directly and indirectly has made use of the means or instrumentalities

of interstate commerce, of the mails, or of the facilities of a national securities exchange in

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connection with the transactions, acts, practices, and courses of business alleged in this

Complaint.

12. Venue lies in this District pursuant to Section 22(a) of the Securities Act [15

U.S.C. § 77v(a)] and Section 27 of the Exchange Act [15 U.S.C. § 78aa]. Defendant transacts

business in this District, and certain of the acts, practices, transactions, and courses of conduct

alleged in this Complaint occurred within this District. For example, Defendant conducted his

manipulative trading scheme on exchanges located in this District, and many of the issuers

whose securities were manipulated by Defendant are headquartered in this District.

THE DEFENDANT

13. Harsh V. Patel, age 37, resided in San Juan, Puerto Rico during the Relevant

Period and is a full-time day trader.

RELEVANT ENTITY

14. NextGen Vision Inc. (“NextGen”) is an S corporation based in Puerto Rico and

was incorporated by Patel in Pennsylvania in February 2018. During the Relevant Period,

NextGen was controlled solely by Patel and was used for Patel’s securities trading.

TERMS USED IN THIS COMPLAINT

A. The National Best Bid and Offer

15. National Best Bid is the highest reported price a buyer is willing to pay to buy a

security.

16. National Best Offer is the lowest reported price that a seller is willing to accept to

sell a security.

17. The spread between the National Best Bid and the National Best Offer is referred

to as the “NBBO.” The NBBO is publicly reported to the market and represents the tightest bid-

ask spread for a particular security.

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B.  Thinly Traded Securities

18. Thinly traded securities are securities that have low trading volume. As compared

to more actively traded securities with a greater trading volume, thinly traded securities often

have fewer interested buyers and sellers and larger NBBO spreads. Thus, a small number of

orders or trades can significantly impact the market price of thinly traded securities, rendering

them more susceptible to manipulation than securities that are more actively traded.

C. Limit Orders

19. A limit order is an order to buy or sell a security at a specified price or better and

can only be executed if the market price reaches the limit price. A buy limit order can only be

executed at the limit price or lower, and a sell limit order can only be executed at the limit price

or higher.

20. While limit orders do not guarantee execution, they help ensure that an investor

does not buy for more than or sell for less than a pre-determined price.

D. Market Orders

21. A market order is an order to buy or sell a security at the current market price. A

small lot market order, also known as an “odd lot market order,” is an instruction to buy or sell

fewer than 100 shares of a security. A large lot market order, also known as a “round lot market

order,” is an instruction to buy or sell 100 shares or a multiple of 100 shares of a security at the

best available price.

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FACTS

I. Patel Implemented a Scheme to Manipulate the Price of Securities Using at Least 10
Accounts with Three Registered Broker-Dealers in his Name and the Names of
Others

A. Overview of Patel’s Manipulative Trading Scheme

22. To operate his scheme, Patel opened multiple accounts in his own name and in the

name of his company NextGen at three different registered broker-dealers.

23. Patel often used more than one account to place orders for the same securities as

part of his scheme, including one “helper” account that he generally used to place non-bona fide

limit orders, and another “winner” account to place trades that profited from the price

manipulation.

24. To manipulate the prices of the target securities, Patel generally first built a

position in a thinly traded target security by placing a large number of small lot market orders for

that security. He made these trades quickly, placing market orders to buy a single security

hundreds of times in rapid succession, giving the illusion of widespread demand for the security

and increasing the National Best Bid and National Best Offer of the targeted securities.

25. Because Patel made such a large number of trades in such a short period of time,

and generally in thinly traded securities, Patel’s trading moved the National Best Bid and

National Best Offer of the targeted securities to prices that, at times, were significantly higher

than the prices when he started buying.

26. Second, to keep the National Best Bid and National Best Offer artificially

inflated, Patel placed multiple limit buy orders for that same security that he did not intend to

execute. These limit buy orders were frequently priced at or just below the National Best Bid

price and were visible to the market. Patel sometimes disguised his manipulative trading by

placing these limit orders in a separate “helper” account.

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27. Third, with the non-bona fide limit buy orders creating the false appearance of

continued buying interest, Patel then rapidly sold off all his shares in the security that he had just

purchased. Unlike the market buy orders, which Patel made in large numbers of small lots, he

sold the securities in larger lots to sell them all quickly at the artificially inflated price.

28. The visible limit buy orders that Patel held on the buy side helped induce market

participants to purchase the shares that he simultaneously was selling at inflated prices.

29. Finally, once Patel closed out of his position, he immediately canceled the limit

orders that he used to help prop up the prices of the target security.

30. Patel engaged in this type of trading on more than one thousand occasions,

sometimes multiple times a day, across hundreds of different securities.

31. After broker-dealers detected and warned him to cease his manipulative trading,

and eventually restricted and/or shut down Patel’s accounts, Patel continued his scheme by

trading in accounts he opened in the name of an estranged family member (“Family Member”),

which he opened without Family Member’s knowledge or consent, and in accounts of a friend

(“Individual A”).

32. During the Relevant Period, Patel conducted this manipulative trading in more

than 400 different securities, the tickers of which are identified in Attachment A.

33. Overall, Patel used at least the following 10 trading accounts to carry out his

scheme and generated more than $5 million in illicit gains from at least May 2021 to at least

January 2024:

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Account Account Holder’s
Name

Account Number Broker-Dealer

Account 1 Harsh Patel xxxx-8644 Broker-Dealer 1
Account 2 Harsh Patel xxxx-0647 Broker-Dealer 2
Account 3 Harsh Patel xxxx-0990 Broker-Dealer 3
Account 4 NextGen xxxx-7041 Broker-Dealer 1
Account 5 NextGen xxxx-6284 Broker-Dealer 3
Account 6 Family Member xxxx-5036 Broker-Dealer 1
Account 7 Family Member  xxxx-0853 Broker-Dealer 3
Account 8 Family Member  xxxx-2163 Broker-Dealer 3
Account 9 Individual A  xxxx-7599 Broker-Dealer 3
Account 10 Individual A  xxxx-3220 Broker-Dealer 3

B.   Examples of Patel’s Manipulative Trading

1. AeroCentury Corp. on May 13, 2021

34. On May 13, 2021, at 2:45 p.m., the National Best Bid for shares of AeroCentury,

Corp. (“AeroCentury”) stock, which traded under the ticker symbol “ACY,” was approximately

$7.35 per share, and the National Best Offer was approximately $7.49 per share.

35. At approximately 2:45 p.m., Patel placed a market order to buy 2,900 shares of

AeroCentury in an account with a registered broker-dealer (“Broker-Dealer 1”) in the name of

his company, NextGen (identified in the chart above as “Account 4”). This order was

immediately filled.

36. Patel rapidly continued to place similarly sized market orders to buy shares of

AeroCentury, one after another, from 2:45 p.m. until approximately 2:56 p.m. During those 11

minutes, Patel placed 22 market orders to purchase a total of 31,800 shares of AeroCentury in

Account 4.

37. As Patel rapidly placed these orders, the National Best Bid began to rise, and by

the time of his last market order, the execution price had increased from $7.49 per share for his

first market order to $8.50 per share for the last one.

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38. Just a few minutes after placing his first market order to buy, beginning at

approximately 2:48 p.m., Patel placed limit orders to buy AeroCentury shares from the same

account, Account 4. From 2:48 p.m. until approximately 2:56 p.m., Patel placed nine limit buy

orders for a total of 28,100 shares of AeroCentury at prices ranging from $7.55 per share to

$8.11 per share, thereby displaying to the market demand for AeroCentury shares at those prices.

Three of these limit orders were either filled or partially filled and resulted in purchases of an

additional 2,145 shares, bringing Patel’s total position to 33,945 shares of AeroCentury.

39. By the time Patel placed his last market buy order at approximately 2:56 p.m., the

National Best Bid for AeroCentury had risen to $8.50 per share and the National Best Offer had

risen to $8.70 per share—an increase of approximately 16% in the 11 minutes that Patel was

trading the stock.

40. Seconds later, Patel began placing large lot market orders to sell AeroCentury

shares, which began executing at around $8.50 per share, while his remaining limit orders to buy

25,955 AeroCentury shares at prices ranging from $7.54 to $8.10 per share were still sitting

open, unexecuted, showing demand for AeroCentury shares.

41. Patel sold all 33,945 of his AeroCentury shares through 11 market orders at prices

ranging from $8.21 to $8.52 per share within 10 seconds. In the last second of those sales, Patel

canceled all of his open limit orders to buy AeroCentury shares.

42. Patel’s trading activity over the course of those 11 minutes and 20 seconds, all in

Account 4, made up approximately half of the volume of the market-wide trading activity in

AeroCentury shares during that time, and netted Patel $19,456 in profits.

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2. Arqit Quantum Inc. (“ARQQ”) on October 8, 2021

43. On October 8, 2021, at approximately 1:11 p.m., the National Best Bid for Arqit

Quantum Inc. (“Arqit”) stock, which traded under the ticker symbol “ARQQ,” was

approximately $16.80 per share, and the National Best Offer was approximately $17.00 per

share. At that time, Patel began purchasing shares of Arqit in Account 4.

44. From 1:11 p.m. through approximately 2:33 p.m., Patel purchased approximately

115,000 shares of Arqit in Account 4 by placing 49 market orders and 11 limit orders ranging in

price from $16.80 to $18.70 per share.

45. From approximately 2:19 p.m. to 2:32 p.m., Patel placed various limit orders to

buy shares of Arqit in an account with a registered broker-dealer (“Broker-Dealer 2”) in his own

name (identified in the chart above as “Account 2”) priced at $17.40 to $18.25 per share,

communicating interest to the market and supporting the increased price.

46. Starting a minute later, at approximately 2:33 p.m., Patel began to liquidate the

Arqit shares in Account 4, beginning with a market sell order that was executed at $18.65 per

share.

47. At approximately the same time, from 2:33 p.m. through 2:35 p.m., Patel placed

35 limit orders in Account 4, each to buy 3,700 shares of Arqit at $17.40 per share. Patel placed

these limit orders in Account 4 while he was rapidly selling Arqit shares and closing out his long

position.

48. By 2:35 p.m., Patel had sold most of his Arqit shares, and the National Best Bid

had dropped from $18.45 per share when he started selling 90 seconds earlier to $17.50 per

share.

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49. Patel then canceled the outstanding limit orders to buy Arqit shares that he placed

minutes earlier.

50. Patel’s trading from approximately 1:11 p.m. to 2:35 p.m. on October 8, 2021

accounted for over 31% of the total trading volume in Arqit and netted him approximately

$49,591 in profits.

C. Patel Repeatedly Received Compliance Warnings from Broker-Dealers, Lied
About his Trading Strategy, and Had his Accounts Restricted and/or Closed.

51. Patel’s trading during the Relevant Period triggered numerous warnings for

manipulative trading activity at the various broker-dealers where he held accounts, and, over

time, the broker-dealers restricted his trading privileges and/or closed his accounts.

52. For example, on or about May 25, 2021, after a registered broker-dealer firm

(“Broker-Dealer 3”) had placed a 14-day restriction on an account Patel held in his own name

(identified in the chart above as “Account 3”), a representative of Broker-Dealer 3 explained to

Patel in a recorded telephone call how his trading practices were manipulating the price of

certain securities.

53. The representative pointed out that Patel was taking a low volume stock, placing a

large amount of progressively higher-priced buy orders and boosting the price, and then “turning

around and selling on that … overly inflated price that you boosted up with the numerous buy

orders.”

54. The representative further suggested ways that Patel could alter his trading

practices to avoid manipulating the price of the stocks he traded.

55. Patel did not change his practices, and Broker-Dealer 3 alerted Patel in September

2021 that it was ending its relationship with him.

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56. In September and October 2021, after Broker-Dealer 3 would no longer service

Patel’s accounts, Patel moved approximately $3 million from his Broker-Dealer 3 accounts to

accounts with Broker-Dealer 1 and Broker-Dealer 2. Patel continued his manipulative practices

and received numerous warnings from Broker-Dealer 1 and Broker-Dealer 2 as well.

57. In October 2021, Broker-Dealer 1 identified trading activity in an account Patel

held in his own name (identified in the chart above as “Account 1”) that was “giving the

appearance of spoofing/layering,” because as Patel entered multiple market orders, the price of

the security rose, and Patel then placed buy limit orders at lower prices before he entered orders

selling the newly acquired shares. A representative of Broker-Dealer 1 warned Patel by

telephone in November 2021 to cease trading in the manner that he had been trading. Patel,

however, continued his manipulative trading.

58. Broker-Dealer 1 restricted Patel from placing any more trades in Account 1 and

Account 4 in July 2022. Broker-Dealer 2 terminated Account 3 in August 2022. Rather than

cease his manipulative trading scheme, Patel simply traded in accounts held in other people’s

names.

D. Patel Traded Using Accounts Held in Other People’s Names

59. After Broker-Dealer 1 and Broker-Dealer 2 restricted and/or terminated Patel’s

personal and NextGen accounts, Patel continued his manipulative trading scheme by trading in

accounts held in the names of Family Member and Individual A.

1. Patel Opened Trading Accounts in Family Member’s Name Without
Family Member’s Knowledge

60. In or around August 2022, Patel began to trade in three accounts held in Family

Member’s name at Broker-Dealer 1 (identified in the chart above as “Account 6”) and Broker-

Dealer 3 (identified in the chart above as “Account 7” and “Account 8”).

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61. Patel opened the accounts in Family Member’s name without Family Member’s

knowledge by using Family Member’s personal identity information, and by signing Family

Member’s name on account opening documents.

62. From on or about November 9, 2022 through July 30, 2023, Patel traded in

Account 6, Account 7, and Account 8 using login credentials he created to access the online

platforms of Broker-Dealer 1 and Broker-Dealer 3.

63. Patel’s trading in Account 6, Account 7, and Account 8 triggered warnings at

Broker-Dealer 1 and Broker-Dealer 3, just as it did with the trading in his personal and NextGen

accounts before they were restricted and/or terminated. Some warnings came through the broker-

dealer message systems, which Patel answered as Family Member by using Family Member’s

credentials to sign into the account without Family Member’s knowledge.

64. Broker-Dealer 1 and Broker-Dealer 3 froze and/or placed restrictions on accounts

held in Family Member’s name several times in 2023. Patel initially impersonated Family

Member on a phone call with Broker-Dealer 1 to address trading issues. Patel later had Family

Member speak directly with Broker-Dealer 1 and Broker-Dealer 3 while he listened in and

provided responses for Family Member to recite during the calls.

65. On June 21, 2023, Family Member discussed manipulative trading with a

representative from Broker-Dealer 3. The representative noted that the trading in the account

held in Family Member’s name “could give the impression that … you’re intentionally trying to

bump up the market in this security, so that you can later sell for a preferable price.”

66. Following Patel’s instructions via text message, Family Member told Broker-

Dealer 3 that the trading strategy would be modified. Patel, however, continued the manipulative

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trading in accounts held in Family Member’s name with Broker-Dealer 3 into at least July 2023,

when he then began trading in Individual A’s account.

2. Patel Continued his Manipulative Trading in Accounts Held in
Individual A’s Name

67. In August 2023, Patel discussed with a friend, Individual A, Patel trading under

Individual A’s name, to which Individual A agreed.

68. Pursuant to that agreement, Patel transferred approximately $847,000 from the

accounts he used in Family Member’s name to accounts held in Individual A’s name with

Broker-Dealer 3 (identified in the chart above as “Account 9” and “Account 10”), including an

account that Individual A opened in September 2023 for Patel’s use.

69. Patel and Individual A agreed that Patel was in charge of the trading activities in

Account 9 and Account 10 and would retain any profits from the trading and/or be responsible

for any losses.

70. Patel began trading in Account 9 and Account 10 at the end of August 2023.

71. Almost immediately after Patel began trading in Account 9 and Account 10,

Patel’s trading triggered warnings from Broker-Dealer 3.

72. Patel responded to those warnings using Broker-Dealer 3’s internal messaging

system, under Individual A’s username. Despite receiving multiple warnings, Patel continued his

manipulative trading in Account 9 and Account 10, and Broker-Dealer 3 continued to flag some

of the trading as potentially manipulative.

73. By early January 2024, Broker-Dealer 3 had restricted or closed Account 9 and

Account 10 due to Patel’s manipulative trading. In accordance with their agreement, Individual

A returned all funds remaining in the accounts to Patel.

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E. Patel Profited from his Manipulative Trading

74. Patel’s profits derived from his manipulative trading totaled more than $5 million.

75. Patel’s profits came from manipulative trading in more than 400 securities, as

reflected in Attachment A, and spanned from at least May 25, 2021, when Patel was very clearly

warned by Broker-Dealer 3 that his trading was manipulative, to at least January 2, 2024, when

Patel placed his last trade in an account in Individual A’s name.

II. Patel Violated the Federal Securities Laws

76. During the Relevant Period, Patel traded in ten different accounts, including

accounts in other people’s names, for the purpose of inducing other market participants to

purchase such securities. Patel’s orders included limit orders that were non-bona fide.

77. Patel’s trading practices, including his use of non-bona fide limit orders, an

overwhelming percentage of which he canceled, allowed him to sell securities at artificially

inflated prices.

78. Patel knew or was reckless in not knowing that his trading practices were

inducing others to purchase securities at inflated prices.

79. Patel had been warned by broker-dealers on multiple occasions that his trading

appeared to be manipulative and Patel refused to change his trading pattern. Patel ignored these

warnings.

80. Patel placed non-bona fide orders and used multiple accounts to obscure his

identity when trading.

81. Patel’s scheme was in the offer or sale of securities and was done in connection

with the purchase and sale of securities.

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82. Patel’s non-bona fide limit orders that he placed to deceive investors, only to later

cancel most of them, were manipulative. Patel placed these orders to prop up the price of the

security for as long as possible to ensure he could sell shares at artificially inflated prices.

83. Patel knew or was reckless in not knowing that his trading was deceptive.

84. After receiving numerous warnings and restrictions regarding his trading from

Broker-Dealer 1 and Broker Dealer 3, Patel began trading in accounts held in the names of

Family Member and Individual A to conceal from Broker-Dealer 1 and Broker-Dealer 3 that he

continued his manipulative trading.

85. Patel intentionally misrepresented information to Broker-Dealer 1 and Broker-

Dealer 3 when opening accounts in Family Member’s name. Patel falsely represented himself as

Family Member when electronically signing the forms and answering various identifying

questions.

86. Patel’s misrepresentations and omissions to Broker-Dealer 1 and Broker-Dealer 3

were material, because Broker-Dealer 1 and Broker-Dealer 3 had terminated and/or restricted

Patel’s trading privileges and would not have allowed him to trade in accounts held in Family

Member’s name.

87. Patel’s misrepresentations and omissions to Broker-Dealer 1 and Broker-Dealer 3

were in connection with the purchase or sale of a security and in the offer or sale of a security,

because the accounts were used to buy and sell securities.

88. Patel obtained money by making material misrepresentations and omissions to

Broker-Dealer 1 and Broker-Dealer 3 because he earned profits by trading in accounts held in the

name of Family Member after trading accounts in his own name had been terminated and/or

restricted.

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FIRST CLAIM FOR RELIEF
Fraud in the Offer or Sale of Securities

Violations of Securities Act Section 17(a)

89. The Commission re-alleges and incorporates by reference here the allegations in

paragraphs 1 through 88.

90. Defendant directly or indirectly, singly or in concert, by use of the means or

instruments of transportation or communication in interstate commerce, or of the mails, in the

offer or sale of securities: (a) knowingly or recklessly employed devices, schemes and artifices to

defraud; (b) knowingly, recklessly, or negligently obtained money or property by means of

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; and

(c) knowingly, recklessly, or negligently engaged in transactions, acts, practices and courses of

business which operated as a fraud or deceit upon the purchaser.

91. By reason of the foregoing, Defendant, directly or indirectly, has violated and,

unless enjoined, will again violate Securities Act Section 17(a) [15 U.S.C. § 77q(a)].

SECOND CLAIM FOR RELIEF
Fraud in the Purchase or Sale of Securities

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

92. The Commission re-alleges and incorporates by reference here the allegations in

paragraphs 1 through 88.

93. Defendant, directly or indirectly, singly or in concert, by use of the means or

instrumentalities of interstate commerce, or of the mails, or of the facilities of a national

securities exchange, in connection with the purchase or sale of securities, knowingly or

recklessly: (a) employed devices, schemes and 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; and (c) engaged in

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transactions, acts, practices and courses of business which operated or would have operated as a

fraud or deceit upon other persons.

94. By reason of the foregoing, Defendant, directly or indirectly, singly or in concert,

has violated and, unless enjoined, will again violate Exchange Act Section 10(b) [15 U.S.C. §

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

THIRD CLAIM FOR RELIEF
Market Manipulation

Violations of Section 9(a)(2) of the Exchange Act

95. The Commission re-alleges and incorporates by reference here the allegations in

paragraphs 1 through 88.

96. Defendant, directly or indirectly, by the use of the mails or any means or

instrumentality of interstate commerce, or of any facility of any national securities exchange,

effected, alone or with one or more other persons, a series of transactions in a security creating

actual or apparent active trading in such security, or raising or depressing the price of such

security, for the purpose of inducing the purchase or sale of such security by others.

97. By reason of the foregoing, Defendant, directly or indirectly, singly or in concert,

has violated and, unless enjoined, will again violate Exchange Act Section 9(a)(2) [15 U.S.C. §

78i(a)(2)].

PRAYER FOR RELIEF

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

Judgment:

I.

Permanently enjoining Defendant and his agents, servants, employees and attorneys and

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

indirectly, Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)], and Section 10(b) of the

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

committing or engaging in specified actions or activities relevant to such violations;

II.

Permanently enjoining Defendant and his agents, servants, employees and attorneys and

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

indirectly, Section 9(a)(2) of the Exchange Act [15 U.S.C. § 78i(a)(2)];

III.

Ordering Defendant to disgorge all ill-gotten gains received directly or indirectly, with

pre-judgment interest thereon, as a result of the alleged violations, pursuant to Exchange Act

Sections 21(d)(3), 21(d)(5) and 21(d)(7) [15 U.S.C. §§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)];

IV.

Ordering Defendant to pay a civil monetary penalty under Securities Act Section 20(d)

[15 U.S.C. § 77t(d)] and Exchange Act Section 21(d)(3) [15 U.S.C. § 78u(d)(3)];

V.

Permanently enjoining Defendant from, directly or indirectly, opening, maintaining or

trading in any brokerage account(s) in his name, the names of any immediate family members,

the name of any company over which he has any control or the name(s) of any third-party

individuals, without providing the relevant broker-dealer(s) a copy of the complaint and any final

judgment entered against him in this action; and

VI.

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

20

DEMAND FOR JURY TRIAL

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff demands that this

case be tried to a jury.

Dated:  Philadelphia, PA
April 20, 2026    SECURITIES AND EXCHANGE COMMISSION

     S/ Karen M. Klotz
Joseph G. Sansone
Julia C. Green
Gregory R. Bockin
Karen M. Klotz*
Attorneys for Plaintiff
Philadelphia Regional Office
1617 JFK Boulevard, Suite 520
Philadelphia, PA 19103
(215) 861-9613 (Klotz)
Email: [email protected]
Attorneys for Plaintiff
Securities and Exchange Commission

* Application for admission pro hac vice to be filed.

Tickers for
Manipulated

Securities

Account(s) Dates of Manipulative Trading

.MRNA210806P405 Account 3 Aug. 6, 2021

.MRNA210813C470 Account 3 Aug. 10, 2021

.TSLA210806C700 Account 3 Aug. 3, 2021
AAMC Account 5 Aug. 31, 2021; Sep. 1, 2021; Sep. 2, 2021;

Sep. 3, 2021
ACAQ Account 10 Oct. 5, 2023; Oct. 11, 2023
ACLX Account 1 June 9, 2022
ACXP Account 10 Oct. 13, 2023; Oct. 17, 2023
ACY Account 3; Account 4;

Account 5
July 9, 2021; July 13, 2021; Aug. 3, 2021;
Aug. 4, 2021; Aug. 5, 2021; Aug. 6, 2021;
Aug. 9, 2021; Aug. 10, 2021; Aug. 11,
2021; Aug. 12, 2021; Aug. 13, 2021; Aug.
16, 2021; Aug. 17, 2021; Aug. 23, 2021;
Aug. 25, 2021; Sep. 23, 2021; Oct. 11,
2021

ADGI Account 4 Dec. 1, 2021; Dec. 14, 2021
ADTX Account 9 Aug. 23, 2023; Aug. 30, 2023; Aug. 31,

2023; Sep. 1, 2023; Sep. 5, 2023; Sep. 6,
2023; Sep. 13, 2023; Sep. 15, 2023; Sep.
27, 2023; Sep. 28, 2023

AEHL Account 3 June 9, 2021
AERC Account 1; Account 4 Nov. 30, 2021; Dec. 1, 2021; Dec. 2, 2021;

Dec. 20, 2021; Dec. 22, 2021; Dec. 27,
2021; June 7, 2022; June 8, 2022; June 10,
2022; June 13, 2022; June 14, 2022; June
15, 2022; June 16, 2022; June 24, 2022;
June 27, 2022; June 29, 2022; July 1, 2022;
July 6, 2022; July 7, 2022; July 8, 2022

AGIL Account 5 Sep. 3, 2021
AHPI Account 5 July 13, 2021; July 19, 2021
AIRE Account 10 Nov. 6, 2023
AIRT Account 5 Sep. 7, 2021
AKAN Account 4 March 15, 2022; March 16, 2022; March

21, 2022
ALF Account 5 Aug. 17, 2021
ALGN Account 1 April 28, 2022
ALLG Account 1; Account 2;

Account 4
March 24, 2022; March 24, 2022; March 25,
2022; March 28, 2022; April 22, 2022; April
27, 2022; April 28, 2022

ATTACHMENT A

Tickers for
Manipulated

Securities

Account(s) Dates of Manipulative Trading

ALLR Account 8 July 5, 2023
ALNY Account 4 Dec. 27, 2021
AMBI Account 8 March 14, 2023; March 20, 2023; March

21, 2023
AMC Account 5 July 14, 2021; July 15, 2021
AMPX Account 8 March 23, 2023
AMV Account 7 Jan. 13, 2023
AMZN--
220218C03100000

Account 1 Feb. 14, 2022

AMZN--
220422C03050000

Account 1 April 19, 2022

ANGH Account 1 Feb. 10, 2022; Feb. 17, 2022; March 2,
2022; April 5, 2022; April 6, 2022

ANVS Account 3; Account 5;
Account 10

June 21, 2021; July 30, 2021; Dec. 27,
2023

AONC Account 9 Sep. 21, 2023; Sep. 22, 2023; Sep. 25, 2023
APLM Account 8 March 30, 2023; March 31, 2023; April 3,

2023
APPN Account 1 May 10, 2022
APRN Account 8 June 9, 2023; June 12, 2023
ARL Account 5 July 15, 2021
ARQQ Account 4 Sep. 17, 2021; Sep. 21, 2021; Sep. 22,

2021; Sep. 23, 2021; Sep. 28, 2021; Sep.
29, 2021; Oct. 1, 2021; Oct. 4, 2021; Oct.
7, 2021; Oct. 8, 2021; Oct. 12, 2021; Oct.
19, 2021; Oct. 20, 2021; Oct. 25, 2021;
Oct. 26, 2021; Nov. 1, 2021; Nov. 12, 2021

ASND Account 8 April 3, 2023
ASNS Account 8 May 4, 2023
ASTI Account 9 Sep. 13, 2023
ATGL Account 9; Account 10 Nov. 1, 2023; Nov. 15, 2023; Nov. 16,

2023; Nov. 20, 2023; Nov. 21, 2023; Nov.
27, 2023

ATLX Account 7; Account 8;
Account 9

Jan. 18, 2023; May 4, 2023; May 5, 2023;
May 9, 2023; May 10, 2023; May 11,
2023; May 16, 2023; May 23, 2023; Nov.
20, 2023

ATNF Account 7 Dec. 20, 2022
ATXG Account 8 July 11, 2023
AURC Account 8 July 25, 2023; July 26, 2023; July 27, 2023

ATTACHMENT A

Tickers for
Manipulated

Securities

Account(s) Dates of Manipulative Trading

AUVI Account 3 June 3, 2021; June 4, 2021
AVGR Account 9 Sep. 20, 2023; Sep. 27, 2023
AWX Account 3 Aug. 9, 2021
AXLA Account 9 Sep. 28, 2023; Sep. 29, 2023; Oct. 2, 2023
AXSM Account 1 April 19, 2022
BANL Account 8 March 27, 2023; March 28, 2023; March

29, 2023; March 30, 2023
BAOS Account 8 May 2, 2023; June 8, 2023; June 9, 2023
BBAI Account 1 May 18, 2022
BBBY Account 3 June 2, 2021
BDRX Account 8 July 14, 2023
BENF Account 8 June 14, 2023; June 15, 2023
BFRG Account 8 April 4, 2023; May 31, 2023
BGLC Account 8 July 21, 2023
BGXX Account 1 May 18, 2022
BIOC Account 8 May 24, 2023
BIVI Account 7 Dec. 15, 2022
BJDX Account 8 July 24, 2023; July 25, 2023; July 28, 2023
BKKT Account 4; Account 7 Nov. 11, 2021; Nov. 12, 2021; Nov. 19,

2021; Jan. 12, 2023
BLBD Account 8 May 12, 2023
BLBX Account 8 April 17, 2023
BLTE Account 1 May 3, 2022
BLUW Account 5 Sep. 8, 2021
BLZE Account 4 Nov. 17, 2021
BNTX Account 3; Account 5 Aug. 12, 2021; Aug. 17, 2021
BODI Account 9 Nov. 22, 2023
BOH Account 8 May 12, 2023
BON Account 4; Account 5 July 6, 2021; July 14, 2021; July 15, 2021;

July 16, 2021; Oct. 20, 2021
BRCC Account 1 Feb. 17, 2022; April 19, 2022; June 29,

2022
BRFH Account 4 Jan. 25, 2022
BROS Account 1; Account 4 Sep. 17, 2021; Feb. 1, 2022
BTAI Account 8 July 6, 2023
BTB Account 7 Jan. 17, 2023
BTCM Account 7 Jan. 17, 2023
BTTX Account 4 Nov. 1, 2021; Nov. 3, 2021

ATTACHMENT A

Tickers for
Manipulated

Securities

Account(s) Dates of Manipulative Trading

BWV Account 1 April 7, 2022; April 8, 2022; May 17, 2022
CAR Account 4 Nov. 5, 2021
CARG Account 1 Feb. 25, 2022
CARV Account 3; Account 4;

Account 5
June 7, 2021; June 8, 2021; June 11, 2021;
June 24, 2021; June 29, 2021; July 7, 2021;
July 8, 2021; July 9, 2021; July 13, 2021;
July 15, 2021; July 19, 2021; July 20, 2021;
July 21, 2021; Aug. 9, 2021; Aug. 10, 2021;
Aug. 16, 2021; Sep. 28, 2021; Oct. 1, 2021;
Oct. 25, 2021

CAVA Account 8 June 15, 2023; July 13, 2023
CCG Account 9 Sep. 18, 2023; Sep. 25, 2023; Sep. 26,

2023; Sep. 28, 2023; Oct. 3, 2023
CCXI Account 4 Oct. 8, 2021
CDT Account 9 Sep. 26, 2023; Sep. 27, 2023
CETX Account 6; Account 7 Feb. 1, 2023; Feb. 2, 2023; Feb. 9, 2023
CFFE Account 9 Sep. 20, 2023; Sep. 29, 2023; Oct. 2, 2023
CJET Account 8 June 5, 2023
CJJD Account 7 Dec. 12, 2022
CLBR Account 8 July 19, 2023
CLOV Account 3; Account 4 June 14, 2021
CMA Account 8 May 4, 2023
CMMB Account 3; Account 4;

Account 5
June 10, 2021; Aug. 27, 2021; Nov. 1,
2021; Dec. 21, 2021

COHN Account 3; Account 5 June 14, 2021; July 8, 2021; July 9, 2021;
July 16, 2021; Aug. 16, 2021

COSM Account 7 Jan. 24, 2023
CPOP Account 4; Account 5 July 1, 2021; July 2, 2021; July 7, 2021;

July 13, 2021; July 15, 2021; July 21, 2021;
Oct. 29, 2021

CPTN Account 1 Feb. 23, 2022
CVNA Account 1 Feb. 25, 2022
CWD Account 8 May 18, 2023
CXAI Account 8 April 13, 2023; April 14, 2023; April 17,

2023; April 18, 2023; April 19, 2023; April
20, 2023; April 25, 2023; April 26, 2023;
May 26, 2023; May 30, 2023; June 1, 2023;
June 5, 2023; June 6, 2023; June 7, 2023

DATS Account 4 Sep. 29, 2021; Oct. 5, 2021
DBGI Account 9 Sep. 5, 2023; Sep. 6, 2023; Sep. 12, 2023

ATTACHMENT A

Tickers for
Manipulated

Securities

Account(s) Dates of Manipulative Trading

DDL Account 3; Account 5 June 30, 2021; June 30, 2021
DFLI Account 7 Dec. 19, 2022
DHHC Account 8 March 23, 2023
DJT Account 9 Sep. 5, 2023
DKDCA Account 10  Oct. 25, 2023
DLPN Account 3; Account 5 June 9, 2021; July 26, 2021
DOCU Account 4 Dec. 3, 2021
DOGZ Account 4; Account 10 Jan. 6, 2022; Jan. 2, 2024
DPSI Account 1 May 9, 2022
DQ Account 5 July 23, 2021
DRTS Account 1; Account 4 March 24, 2022; April 21, 2022; July 5,

2022
DTOC Account 9 Sep. 19, 2023; Sep. 20, 2023
DUOL Account 5 July 28, 2021; Sep. 3, 2021
DWAC Account 1; Account 2;

Account 4
Oct. 26, 2021; Oct. 27, 2021; Oct. 28,
2021; Oct. 29, 2021; Nov. 4, 2021; Nov.
12, 2021; Nov. 16, 2021; Nov. 19, 2021;
Nov. 24, 2021; Dec. 2, 2021; Dec. 7, 2021;
Dec. 8, 2021; Dec. 13, 2021; Jan. 7, 2022;
Jan. 10, 2022; Jan. 12, 2022; Jan. 13, 2022;
Jan. 14, 2022; Jan. 18, 2022; Jan. 19, 2022
; Jan. 20, 2022 ; Jan. 24, 2022 ; July 12,
2022

DWACW Account 4 Oct. 22, 2021; Oct. 28, 2021
DY Account 7 Nov. 22, 2022
EAST Account 8 June 14, 2023
EBON Account 7; Account 8 Jan. 13, 2023; Jan. 17, 2023; July 11, 2023
EDBL Account 7 Jan. 30, 2023; Jan. 31, 2023; Feb. 1, 2023
EDRY Account 3 June 4, 2021; June 7, 2021; June 8, 2021
EDTX Account 8 June 15, 2023; June 20, 2023; July 7, 2023
EEIQ Account 4 Sep. 16, 2021; Sep. 27, 2021
EFTR Account 4; Account 5 Sep. 7, 2021; Sep. 8, 2021; Sep. 9, 2021;

Sep. 15, 2021; Sep. 16, 2021; Sep. 29,
2021; Oct. 4, 2021; Oct. 13, 2021; Oct. 14,
2021; Oct. 15, 2021

EH Account 3; Account 5 May 27, 2021; June 7, 2021
EHTH Account 1 March 1, 2022

ATTACHMENT A

Tickers for
Manipulated

Securities

Account(s) Dates of Manipulative Trading

ELOX Account 8 April 5, 2023; April 6, 2023; April 10,
2023; April 11, 2023; April 12, 2023; May
16, 2023; May 17, 2023

ENVB Account 8 May 18, 2023
EVBG Account 4 Dec. 10, 2021
EVLO Account 8 July 18, 2023; July 19, 2023; July 20, 2023
EVTL Account 1 April 13, 2022
FBYD Account 10 Oct. 18, 2023
FCUV Account 4; Account 5 Sep. 1, 2021; Sep. 3, 2021; Sep. 7, 2021;

Sep. 8, 2021; Oct. 12, 2021; Oct. 13, 2021;
Oct. 14, 2021; Nov. 11, 2021

FEMY Account 5 July 13, 2021; July 20, 2021; July 21, 2021
FFIE Account 1 July 5, 2022
FLGC Account 3; Account 5 Aug. 5, 2021; Aug. 6, 2021; Aug. 9, 2021;

Aug. 10, 2021; Aug. 24, 2021
FRGE Account 1; Account 4 March 22, 2022; March 25, 2022; March

28, 2022; March 30, 2022; March 31,
2022; April 18, 2022; April 22, 2022; April
27, 2022; April 29, 2022; May 2, 2022;
May 3, 2022; May 4, 2022; June 1, 2022

FRLN Account 5; Account 8 July 19, 2021; May 22, 2023; July 12,
2023; July 13, 2023

FULC Account 3 Aug. 10, 2021
FUTU Account 5 July 27, 2021
FWBI Account 7 Feb. 2, 2023
FWP Account 5 July 19, 2021; July 21, 2021; July 22,

2021; July 23, 2021; July 26, 2021
FZT Account 9 Sep. 26, 2023
G5140V112 Account 10 Dec. 22, 2023
G7244A119 Account 9; Account 10 Aug. 22, 2023; Oct. 10, 2023
GAMB Account 5 Aug. 30, 2021
GBR Account 3 June 1, 2021
GCT Account 7; Account 9 Nov. 28, 2022; Sep. 11, 2023
GDC Account 8 May 1, 2023
GDHG Account 10 Nov. 14, 2023
GDYN Account 1 Feb. 24, 2022

ATTACHMENT A

Tickers for
Manipulated

Securities

Account(s) Dates of Manipulative Trading

GFAI Account 6; Account 8 Feb. 14, 2023; March 31, 2023; April 3,
2023; April 4, 2023; April 5, 2023; April 6,
2023; April 10, 2023; April 11, 2023; April
12, 2023; April 13, 2023; April 14, 2023;
April 17, 2023; April 20, 2023; May 4,
2023; May 8, 2023

GLBE Account 1 May 17, 2022
GLSI Account 1; Account 5 Sep. 7, 2021; July 12, 2022
GLTA Account 8 July 7, 2023
GME Account 4; Account 5 July 20, 2021; Oct. 11, 2021
GME---
220401C00185000

Account 4 March 29, 2022

GMVD Account 7 Jan. 30, 2023
GNS Account 1 April 22, 2022; April29, 2022
GOCO Account 7 Nov. 28, 2022
GOOGL-
220204P02900000

Account 1 Feb. 2, 2022

GREE Account 2; Account 4;
Account 8

Sep. 21, 2021; Sep. 22, 2021; Sep. 30,
2021; Oct. 1, 2021; Oct. 4, 2021; Oct. 5,
2021; Oct. 11, 2021; Oct. 13, 2021; Oct. 18,
2021; Oct. 26, 2021; Oct. 27, 2021; Oct. 29,
2021; Nov. 1, 2021; Nov. 5, 2021; Nov. 30,
2021; July 10, 2023

GRND Account 7 Nov. 18, 2022
GROV Account 1 July 7, 2022; July 8, 2022
GRRR Account 7 Dec. 28, 2022; Jan. 19, 2023
GSUN Account 1 June 23, 2022
GWH Account 4 Oct. 12, 2021; Oct. 14, 2021; Oct. 15, 2021
GXGX Account 5 July 16, 2021
GYRE Account 9 Nov. 24, 2023; Nov. 28, 2023
HCDI Account 8 May 4, 2023; May 10, 2023
HEPA Account 8 May 23, 2023; May 24, 2023; May 25, 2023
HGTY Account 4 Dec. 3, 2021
HHGC Account 8 July 25, 2023
HIBB Account 7 Nov. 29, 2022
HKD Account 8 April 11, 2023
HKIT Account 9 Aug. 22, 2023; Aug. 25, 2023
HLBZ Account 4; Account 5 Sep. 9, 2021; Sep. 10, 2021; Sep. 16, 2021;

Sep. 22, 2021; Sep. 27, 2021; Sep. 28,
2021; Oct. 18, 2021; Oct. 19, 2021

ATTACHMENT A

Tickers for
Manipulated

Securities

Account(s) Dates of Manipulative Trading

HOOD Account 3 Aug. 6, 2021
HOTH Account 7 Jan. 4, 2023
HRMY Account 8 March 28, 2023
HTGM Account 7 Dec. 27, 2022
HUDI Account 1; Account 4;

Account 7; Account 8
Oct. 21, 2021; Oct. 25, 2021; Oct. 26, 2021;
Oct. 27, 2021; Nov. 10, 2021; May 10,
2022; Nov. 11, 2022; May 1, 2023

HX Account 4 Oct. 21, 2021
ICCT Account 9 Aug. 30, 2023; Aug. 31, 2023; Sep. 6, 2023
ICVX Account 3; Account 7 July 30, 2021; Aug. 2, 2021; Aug. 4, 2021;

Dec. 16, 2022
IEP Account 8 May 25, 2023
IHT Account 3 June 8, 2021
IKNA Account 5 July 20, 2021
IKNX Account 3; Account 5 June 28, 2021; Aug. 27, 2021
IMPL Account 3; Account 5 Aug. 19, 2021; Sep. 3, 2021
IMTE Account 1; Account 4 Jan. 14, 2022; Jan. 20, 2022; Jan. 28, 2022;

March 31, 2022; April 1, 2022; April 4,
2022

INDO Account 1; Account 4 Feb. 2, 2022; March 4, 2022; March 8,
2022; March 9, 2022; March 11, 2022;
March 14, 2022; March 17, 2022; May 16,
2022

INGN Account 3 Aug. 5, 2021
IPW Account 3 June 30, 2021
IRNT Account 4; Account 5 Sep. 7, 2021; Sep. 8, 2021; Sep. 10, 2021;

Sep. 21, 2021
ISIG Account 2; Account 4 Dec. 9, 2021; Dec. 13, 2021; Dec. 14, 2021;

Dec. 17, 2021; Dec. 29, 2021; Dec. 31,
2021; Jan. 3, 2022; Jan. 4, 2022; Jan. 6,
2022; Jan. 7, 2022; Jan. 10, 2022; Jan. 18,
2022; March 15, 2022; March 30, 2022;
April 4, 2022

ISPC Account 4 Nov. 23, 2021; Nov. 24, 2021; Nov. 29,
2021; Nov. 30, 2021; Dec. 3, 2021; Dec. 6,
2021

ISPO Account 1 Feb. 18, 2022; Feb. 22, 2022; Feb. 25, 2022
ISPR Account 10 Nov. 15, 2023
ISUN Account 3 June 8, 2021
JCS Account 4 Sep. 14, 2021

ATTACHMENT A

Tickers for
Manipulated

Securities

Account(s) Dates of Manipulative Trading

JCSE Account 1 April 27, 2022; May 10, 2022
JGGC Account 10 Oct. 25, 2023; Nov. 7, 2023; Nov. 10, 2023
JMAC Account 8 March 22, 2023
JSPR Account 4 Sep. 29, 2021; Oct. 4, 2021; Oct. 5, 2021;

Oct. 6, 2021; Oct. 8, 2021; Oct. 14, 2021
JWAC Account 8 May 3, 2023
JYNT Account 4 Oct. 7, 2021
KAL Account 7 Feb. 6, 2023
KALA Account 6; Account 7

Account 8
Jan. 12, 2023; Jan. 20, 2023; Jan. 26, 2023;
Jan. 27, 2023; Feb. 10, 2023; April 11, 2023

KAVL Account 5 Sep. 7, 2021
KBSF Account 5 July 7, 2021
KOSS Account 3; Account 4

Account 5
June 3, 2021; Aug. 13, 2021; Aug. 24,
2021; Jan. 3, 2022; Jan. 26, 2022

KPRX Account 6 Feb. 9, 2023
KRRO Account 10 Nov. 9, 2023; Nov. 10, 2023; Nov. 13, 2023
KSPN Account 1 July 12, 2022
KTRA Account 7 Dec. 9, 2022
LDWY Account 9 Aug. 25, 2023; Aug. 28, 2023
LEDS Account 3; Account 5 June 1, 2021; June 3, 2021; June 7, 2021;

June 23, 2021; June 24, 2021; July 14, 2021
LEJU Account 8 June 12, 2023
LFLY Account 9 Sep. 15, 2023; Sep. 18, 2023
LGVN Account 1; Account 4 Nov. 19, 2021; Nov. 23, 2021; Nov. 26,

2021; Nov. 29, 2021; Dec. 6, 2021; April
20, 2022

LIFW Account 10 Nov. 6, 2023
LIPO Account 7 Jan. 11, 2023
LIVE Account 3 Aug. 4, 2021
LIXT Account 8 July 17, 2023
LMDX Account 4 Sep. 30, 2021
LTRY Account 4 Nov. 8, 2021
LUNR Account 8 Feb. 17, 2023; Feb. 22, 2023; March 16,

2023; June 12, 2023
LWAY Account 10 Nov. 14, 2023
LYT Account 1 July 6, 2022
LZM Account 8 July 6, 2023

ATTACHMENT A

Tickers for
Manipulated

Securities

Account(s) Dates of Manipulative Trading

MARPS Account 1; Account 4 March 4, 2022; March 7, 2022; March 8,
2022; March 9, 2022; March 10, 2022;
March 17, 2022; May 16, 2022

MASI Account 1 Feb. 16, 2022
MCAF Account 9 Nov. 21, 2023
MDIA Account 3

Account 5
July 13, 2021; July 14, 2021; July 19, 2021;
July 29, 2021; Aug. 10, 2021

MGOL Account 8 June 12, 2023
MGRM Account 8 May 19, 2023; May 23, 2023
MINM Account 8 May 2, 2023; May 5, 2023; May 11, 2023
MITQ Account 5 July 9, 2021; July 14, 2021; July 26, 2021
MNDY Account 1 Feb. 23, 2022
MNTS Account 10 Oct. 12, 2023
MOH Account 10 Oct. 26, 2023
MOXC Account 3; Account 4

Account 5
June 21, 2021; June 22, 2021; June 23,
2021; June 24, 2021; June 25, 2021; June
29, 2021; June 30, 2021; July 2, 2021; July
6, 2021; July 8, 2021; July 9, 2021; July 12,
2021; July 13, 2021; July 13, 2021; July 15,
2021; July 16, 2021; July 19, 2021; July 23,
2021

MRIN Account 5 July 8, 2021; July 28, 2021
MRNA Account 4; Account 5  July 16, 2021; Dec. 10, 2021
MRVI Account 8 May 16, 2023
MSAI Account 10 Dec. 22, 2023
MSC Account 5 July 26, 2021
MSGM Account 6; Account 7

Account 8
Jan. 31, 2023; Feb. 1, 2023; Feb. 8, 2023;
Feb. 10, 2023; April 6, 2023

MSS Account 10 Oct. 6, 2023
MULN Account 10 Dec. 22, 2023
MURF Account 9 Sep. 19, 2023; Sep. 22, 2023
MWG Account 8 April 5, 2023; April 11, 2023
MXC Account 1; Account 4

Account 5
July 14, 2021; Oct. 4, 2021; Oct. 5, 2021;
March 4, 2022; March 7, 2022; March 8,
2022; March 17, 2022; April 14, 2022

MYNZ Account 4 Jan. 14, 2022
MYO Account 3; Account 4 Aug. 10, 2021; Jan. 10, 2022
NAAS Account 8 March 24, 2023
NARI Account 10 Nov. 2, 2023

ATTACHMENT A

Tickers for
Manipulated

Securities

Account(s) Dates of Manipulative Trading

NBTX Account 8 May 5, 2023
NEGG Account 3; Account 4

Account 5
July 1, 2021; July 2, 2021; July 12, 2021;
July 13, 2021; July 14, 2021; July 15, 2021;
July 16, 2021; July 19, 2021; July 20, 2021;
July 29, 2021; Aug. 9, 2021; Nov. 15, 2021

NFLX Account 4 Jan. 20, 2022
NIR Account 8 March 24, 2023; April 14, 2023; April 17,

2023; April 20, 2023
NKTX Account 1 April 25, 2022; April 27, 2022
NOGN Account 8 April 3, 2023
NRXP Account 5 July 26, 2021; July 27, 2021
NSYS Account 3; Account 5 June 29, 2021; July 26, 2021
NTRB Account 4 Oct. 7, 2021; Oct. 8, 2021; Jan. 4, 2022
NTRP Account 10 Oct. 18, 2023
NURO Account 5 July 21, 2021; July 22, 2021; July 23, 2021;

July 27, 2021; July 28, 2021
NUWE Account 7 Dec. 13, 2022
NUZE Account 7 Jan. 19, 2023
NVAX Account 4; Account 5 July 19, 2021; Dec. 2, 2021
NVCT Account 1 April 6, 2022; April 7, 2022
NVDA Account 4 Nov. 23, 2021
NVEI Account 4 Dec. 8, 2021
NWGL Account 9 Sep. 12, 2023
NXTT Account 9; Account 10 Aug. 24, 2023; Sep. 13, 2023; Oct. 10, 2023
OLIT Account 10 Nov. 2, 2023
OMH Account 8 May 11, 2023; May 15, 2023; May 16, 2023
ORPH Account 5 July 1, 2021; July 16, 2021
OTRK Account 3; Account 4 June 9, 2021; Dec. 7, 2021
PAPL Account 10 Nov. 9, 2023
PBLA Account 8 June 13, 2023
PETZ Account 5 June 15, 2021
PEV Account 1 June 27, 2022
PHIN Account 8 July 10, 2023
PIK Account 4 Jan. 12, 2022
PIXY Account 10 Nov.06, 2023; Nov. 7, 2023
PKBO Account 7 Dec. 5, 2022
PKST Account 8 June 12, 2023

ATTACHMENT A

Tickers for
Manipulated

Securities

Account(s) Dates of Manipulative Trading

PLSE Account 3; Account 5
Account 9

July 1, 2021; Aug. 4, 2021; Nov. 29, 2023

POLCQ Account 10 Dec. 29, 2023
PRAA Account 8 May 9, 2023
PRFX Account 8 July 14, 2023; July 17, 2023; July 20, 2023
PSQH Account 8 July 20, 2023; July 26, 2023; July 27, 2023
PTLO Account 4 Nov. 18, 2021
PTON Account 1 Feb. 8, 2022
PTPI Account 8 April 19, 2023
PUBM Account 3 June 9, 2021
PWM Account 8 July 7, 2023; July 10, 2023; July 12, 2023;

July 17, 2023; July 18, 2023; July 19, 2023
PXMD Account 10 Nov. 7, 2023
QSG Account 8 May 26, 2023
RANI Account 4; Account 5 Aug. 25, 2021; Aug. 26, 2021; Jan. 26,

2022
RAPT Account 3 June 14, 2021
RBLX Account 4 Nov. 16, 2021
RCLF Account 9 Sep. 7, 2023
RDBX Account 1; Account 4 Oct. 26, 2021; Oct. 28, 2021; Nov. 5, 2021;

Nov. 8, 2021; April 29, 2022; May 4, 2022;
June 10, 2022

RGC Account 4; Account 5 Aug. 23, 2021; Aug. 26, 2021; Aug. 31,
2021; Sep. 1, 2021; Sep. 22, 2021; Oct. 1,
2021; Oct. 11, 2021

RHE Account 3; Account 4 June 24, 2021; Dec. 16, 2021
RILY Account 10 Nov. 13, 2023
RIVN Account 1; Account 4 Nov. 19, 2021; Nov. 22, 2021; Nov. 23,

2021; Dec. 1, 2021; Dec. 2, 2021; Dec. 7,
2021; Jan. 6, 2022; Feb 1, 2022

RIVN--
211119C00160000

Account 4 Nov. 16, 2021

RLMD Account 5 July 27, 2021
RMED Account 7 Dec. 9, 2022
RNA Account 8 March 30, 2023
RNXT Account 5 Aug. 31, 2021; Sep. 1, 2021
RSLS Account 3; Account 7

Account 8
June 28, 2021; Feb. 3, 2023; April 11, 2023

RZLT Account 5 May 27, 2021

ATTACHMENT A

Tickers for
Manipulated

Securities

Account(s) Dates of Manipulative Trading

SATX Account 7 Dec. 5, 2022
SAVA Account 5 July 21, 2021; Aug. 27, 2021
SCKT Account 5 July 26, 2021
SCLX Account 8 April 5, 2023
SDA Account 8 May 23, 2023; May 24, 2023; May 26,

2023; June 1, 2023; June 5, 2023; June 8,
2023; June 12, 2023; June 15, 2023; July
19, 2023; July 20, 2023; July 24, 2023

SECO Account 7 Feb. 6, 2023
SEED Account 1

Account 5
July 12, 2021; July 28, 2021; March 10,
2022

SEQL Account 9 Sep. 18, 2023
SEV Account 1

Account 4
Nov. 18, 2021; Nov. 19, 2021; Nov. 22,
2021; April 19, 2022

SEZL Account 10 Nov. 10, 2023; Dec. 22, 2023; Dec. 28,
2023

SFWL Account 8 May 9, 2023
SGMA Account 4; Account 8 Dec. 13, 2021; Dec. 27, 2021; May 4, 2023
SGOC Account 5 July 9, 2021; July 12, 2021; July 14, 2021;

July 16, 2021
SHOP Account 1 April 22, 2022
SI Account 4 Oct. 7, 2021
SIDU Account 1 March 4, 2022
SJ Account 5 July 15, 2021
SKYH Account 1; Account 4 March 1, 2022; March 2, 2022; March 18,

2022; April 13, 2022; April 25, 2022;
May 6, 2022; May 10, 2022

SMCI Account 8 May 26, 2023
SMLR Account 1

Account 7
March 1, 2022; Feb. 6, 2023

SNCE Account 4 Oct. 14, 2021
SNOW Account 1 March 3, 2022
SNPX Account 4 Sep. 30, 2021; Oct. 12, 2021; Oct. 13, 2021
SNTG Account 3; Account 5 July 30, 2021; Aug. 24, 2021
SOAR Account 9 Nov. 29, 2023
SOPA Account 1; Account 4 Nov. 10, 2021; Nov. 15, 2021; Dec. 23,

2021; Dec. 29, 2021; June 7, 2022
SOS Account 7 Jan. 17, 2023
SOUN Account 1 May 2, 2022; May 3, 2022; May 4, 2022

ATTACHMENT A

Tickers for
Manipulated

Securities

Account(s) Dates of Manipulative Trading

SPPL Account 9 Sep. 15, 2023
SPRC Account 10 Oct. 17, 2023; Oct. 20, 2023; Oct. 31, 2023
SPXW--
211203P04530000

Account 4 Dec. 2, 2021

SQBG Account 5 July 2, 2021; July 7, 2021; July 12, 2021;
July 14, 2021; July 16, 2021; July 19, 2021;
July 22, 2021; July 27, 2021; July 28, 2021;
Aug. 30, 2021

SRPT Account 10 Oct. 31, 2023
SRZN Account 5 Sep. 7, 2021
SSNT Account 3; Account 5 June 22, 2021; June 30, 2021
SST Account 1 April 8, 2022; April 12, 2022; April 13,

2022; April 14, 2022
SWAV Account 10 Nov. 7, 2023
SWIN Account 9 Sep. 7, 2023; Sep. 8, 2023
SWVL Account 1 April 21, 2022; April 22, 2022; April 25,

2022; April 28, 2022
SYM Account 1 June 22, 2022
TBLT Account 1 May 2, 2022
TCBP Account 7 Jan. 18, 2023
TCJH Account 8 May 16, 2023; May 23, 2023; May 25, 2023
TKAT Account 3; Account 5 May 26, 2021; June 2, 2021; June 9, 2021;

June 10, 2021; June 23, 2021; July 26,
2021; Aug. 2, 2021

TKLF Account 4 Jan. 18, 2022
TMC Account 4 Sep. 13, 2021; Sep. 14, 2021
TNON Account 1 May 3, 2022
TOP Account 1; Account 8 June 1, 2022; June 23, 2022; April 27,

2023; May 1, 2023; May 4, 2023; May 5,
2023; May 8, 2023

TPST Account 5; Account 10 July 9, 2021; July 12, 2021; July 20, 2021;
Oct. 12, 2023

TRU Account 10 Oct. 24, 2023
TRUP Account 8 March 23, 2023

ATTACHMENT A

Tickers for
Manipulated

Securities

Account(s) Dates of Manipulative Trading

TSLA Account 1; Account 4 Nov. 15, 2021; Dec. 20, 2021; Jan. 6, 2022;
Jan. 10, 2022; Jan. 13, 2022; Jan. 14, 2022;
Jan. 18, 2022; Jan. 20, 2022; Jan. 21, 2022;
Jan. 24, 2022; Jan. 25, 2022; Jan. 27, 2022;
Jan. 28, 2022; Jan. 31, 2022; April 12,
2022; April 20, 2022; April 28, 2022; April
29, 2022; May 20, 2022; May 25, 2022

TSLA--
220114C01040000

Account 4 Jan. 13, 2022

TSLA--
220204C00900000

Account 1 Feb. 3, 2022

TSLA--
220325C00920000

Account 4 March 21, 2022

TSLA--
220325C01000000

Account 4 March 23, 2022

TSLA--
220325C01020000

Account 4 March 23, 2022

TSLA--
220408C01040000

Account 1 April 6, 2022

TSLA--
220408C01080000

Account 4 April 4, 2022

TSLA--
220408P01045000

Account 1 April 7, 2022

TSLA--
220414C00995000

Account 1 April 12, 2022

TSLA--
220414C01005000

Account 1 April 12, 2022

TSLA--
220414C01015000

Account 1 April 12, 2022

TSLA--
220422C01000000

Account 1 April 12, 2022

TSLA--
220429C01020000

Account 1 April 21, 2022

TSLA--
220513C00775000

Account 1 May 13, 2022

TSLA--
220603C00730000

Account 1 June 3, 2022

TSLA--
220715C00705000

Account 1 July 11, 2022

TSP Account 3 June 14, 2021; June 30, 2021
TSRI Account 1; Account 5 Sep. 9, 2021; Jan. 27, 2022

ATTACHMENT A

Tickers for
Manipulated

Securities

Account(s) Dates of Manipulative Trading

TTOO Account 10 Oct. 17, 2023
TYGO Account 8 May 24, 2023
TYHT Account 4; Account 5 July 8, 2021; Sep. 7, 2021; Sep. 23, 2021
UCAR Account 8 April 20, 2023; April 21, 2023; June 1,

2023; June 7, 2023
UHG Account 8 March 31, 2023
ULBI Account 8 July 27, 2023
UONE Account 3; Account 5 June 4, 2021; July 8, 2021
UPST Account 1; Account 4

Account 5
Sep. 8, 2021; Nov. 12, 2021; May 19, 2022;
May 20, 2022

UPTD Account 9 Sep. 5, 2023; Sep. 6, 2023; Sep. 14, 2023;
Sep. 18, 2023; Sep. 20, 2023; Sep. 22, 2023

URGN Account 8 July 28, 2023
UTME Account 3; Account 5 June 21, 2021; June 23, 2021; July 8, 2021;

July 15, 2021
UUU Account 1 Feb. 24, 2022
VCIG Account 8; Account 9 May 8, 2023; Aug. 23, 2023
VERV Account 3; Account 5 June 30, 2021; June 30, 2021
VFS Account 9 Aug. 22, 2023; Aug. 23, 2023; Aug. 24,

2023; Aug. 25, 2023; Aug. 28, 2023; Aug.
31, 2023

VIEW Account 8 July 28, 2023
VIEWQ Account 10 Nov. 14, 2023
VLN Account 4 Oct. 12, 2021
VRAR Account 4; Account 5 July 13, 2021; Nov. 2, 2021; Nov. 15, 2021
VRPX Account 3; Account 5 Aug. 17, 2021; Aug. 19, 2021; Aug. 20,

2021; Aug. 23, 2021; Aug. 31, 2021
VSCO Account 3; Account 5 Aug. 10, 2021; Aug. 13, 2021
VTVT Account 9; Account 10 Nov. 29, 2023; Dec. 29, 2023
VYGR Account 1 April 21, 2022
VZIO Account 5 June 15, 2021
W Account 1 Feb. 24, 2022
WAFU Account 4; Account 5 July 28, 2021; Oct. 11, 2021; Oct. 12, 2021
WAL Account 8 May 4, 2023
WAVE Account 4; Account 5 July 6, 2021; July 8, 2021
WAVS Account 8 July 14, 2023
WBEV Account 1 April 21, 2022

ATTACHMENT A

Tickers for
Manipulated

Securities

Account(s) Dates of Manipulative Trading

WBX Account 4 Oct. 26, 2021; Oct. 28, 2021; Nov. 3, 2021;
Nov. 8, 2021

WETG Account 8 June 14, 2023; June 15, 2023
WHLR Account 9 Sep. 7, 2023
WINT Account 8 April 17, 2023; April 18, 2023
WISA Account 7 Jan. 30, 2023
WISH Account 3 June 14, 2021; June 22, 2021
WIX Account 1 Feb. 16, 2022
WNW Account 3 June 25, 2021
WOLF Account 8 April 27, 2023
XELA Account 8 May 17, 2023; May 18, 2023
XMTR Account 4; Account 5 July 19, 2021; Nov. 12, 2021
XPOF Account 4 Oct. 15, 2021; Oct. 18, 2021
XPON Account 7 Jan. 12, 2023
XYF Account 4; Account 5 June 15, 2021; July 8, 2021
YOSH Account 10 Jan. 2, 2024
Z Account 4 Nov. 23, 2021
ZJYL Account 8 June 12, 2023
ZURA Account 8 March 23, 2023; March 24, 2023; March

27, 2023; May 16, 2023
ZY Account 3 Aug. 5, 2021

Joseph G. Sansone 
Julia C. Green 
Gregory R. Bockin 
Karen M. Klotz* 
SECURITIES AND EXCHANGE COMMISSION 
Philadelphia Regional Office 
1617 JFK Boulevard, Suite 520 
Philadelphia, PA 19103 
(215) 861-9613 (Klotz)
Email: [email protected]

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 

SECURITIES AND EXCHANGE 
COMMISSION, 

Plaintiff, 

v. 

HARSH V. PATEL,

Defendant. 

Case No.  

COMPLAINT 
JURY TRIAL DEMANDED  

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

Demand for Jury Trial against defendant Harsh V. Patel (“Patel” or “Defendant”), alleges as 

follows:  

SUMMARY OF THE ALLEGATIONS 

1. This case arises from defendant Patel’s scheme to manipulate the prices of

hundreds of securities, which distorted the market, deceived investors into buying the targeted 

securities at artificially inflated prices, and netted Patel more than $5 million in illicit profits. 

2. From at least May 2021 to at least January 2024 (the “Relevant Period”), Patel

used at least 10 different accounts at three different registered broker-dealers to carry out his 

* Application for admission pro hac vice to be filed.

1:26-cv-3203

Case 1:26-cv-03203     Document 1     Filed 04/20/26     Page 1 of 20



2 
 

scheme. As broker-dealers discovered Patel’s manipulative trading and restricted and closed his 

accounts, Patel then used accounts in the name of an estranged family member, which he opened 

without the family member’s knowledge or consent, and of a friend to continue his scheme and 

avoid detection.  

3. To carry out his scheme, Patel first rapidly placed a large number of small lot 

market orders to purchase a single security, which increased the price of the security in a matter 

of minutes. Patel typically did this in thinly traded securities, which are easier to manipulate. 

4. Second, Patel placed non-bona fide limit orders to buy that same security, which 

he did not intend to execute, to falsely indicate to the market that there was additional buying 

interest in the security and to buoy the security’s price.  

5. Third, Patel sold the same security that he had just acquired in a few large-lot 

market orders at the now-inflated price. Finally, Patel quickly canceled the buy limit orders that 

he had placed to keep the security at artificially inflated prices.  

6. Patel often implemented and completed this trading strategy in a matter of 

minutes and engaged in this conduct more than one thousand times, trading in hundreds of 

different securities during the Relevant Period.  

VIOLATIONS 

7. By engaging in the conduct described in this complaint, Patel has violated, and 

unless enjoined will continue to violate, Section 17(a) of the Securities Act of 1933 (“Securities 

Act”) [15 U.S.C. § 77q(a)], and Sections 9(a)(2) and 10(b) of the Securities Exchange Act of 

1934 (“Exchange Act”) [15 U.S.C. §§ 78i(a)(2) and 78j(b)] and Rule 10b-5 thereunder [17 

C.F.R. § 240.10b-5(a)].  

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NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT 

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

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

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

9. The Commission seeks a final judgment: (a) permanently enjoining Defendant 

from directly or indirectly engaging in conduct in violation of the laws this Complaint alleges he 

has violated; (b) permanently enjoining Defendant from, directly or indirectly, opening, 

maintaining or trading in any brokerage account(s) in his name, the names of any immediate 

family members, the name of any company over which he has any control, or the name(s) of any 

third party individuals, without providing the relevant broker-dealer(s) a copy of the Complaint 

and any final judgment entered against him in this action; (c) ordering Defendant to disgorge all 

ill-gotten gains received as a result of the violations alleged herein, and to pay prejudgment 

interest thereon, pursuant to Sections 21(d)(3), 21(d)(5) and 21(d)(7) of the Exchange Act [15 

U.S.C. §§ 78u(d)(3), 78u(d)(5) and 78u(d)(7)]; (d) ordering Defendant to pay civil money 

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

21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)]; and (e) ordering any other and further 

relief the Court may deem just and proper. 

JURISDICTION AND VENUE 

10. 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)], and Sections 21(d), 21(e), 

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

11. Defendant directly and indirectly has made use of the means or instrumentalities 

of interstate commerce, of the mails, or of the facilities of a national securities exchange in 

Case 1:26-cv-03203     Document 1     Filed 04/20/26     Page 3 of 20



4 
 

connection with the transactions, acts, practices, and courses of business alleged in this 

Complaint.  

12. Venue lies in this District pursuant to Section 22(a) of the Securities Act [15 

U.S.C. § 77v(a)] and Section 27 of the Exchange Act [15 U.S.C. § 78aa]. Defendant transacts 

business in this District, and certain of the acts, practices, transactions, and courses of conduct 

alleged in this Complaint occurred within this District. For example, Defendant conducted his 

manipulative trading scheme on exchanges located in this District, and many of the issuers 

whose securities were manipulated by Defendant are headquartered in this District. 

THE DEFENDANT 

13. Harsh V. Patel, age 37, resided in San Juan, Puerto Rico during the Relevant 

Period and is a full-time day trader. 

RELEVANT ENTITY 

14. NextGen Vision Inc. (“NextGen”) is an S corporation based in Puerto Rico and 

was incorporated by Patel in Pennsylvania in February 2018. During the Relevant Period, 

NextGen was controlled solely by Patel and was used for Patel’s securities trading.   

TERMS USED IN THIS COMPLAINT 

A. The National Best Bid and Offer 

15. National Best Bid is the highest reported price a buyer is willing to pay to buy a 

security.  

16. National Best Offer is the lowest reported price that a seller is willing to accept to 

sell a security.  

17. The spread between the National Best Bid and the National Best Offer is referred 

to as the “NBBO.” The NBBO is publicly reported to the market and represents the tightest bid-

ask spread for a particular security.  

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5 
 

B.  Thinly Traded Securities 

18. Thinly traded securities are securities that have low trading volume. As compared 

to more actively traded securities with a greater trading volume, thinly traded securities often 

have fewer interested buyers and sellers and larger NBBO spreads. Thus, a small number of 

orders or trades can significantly impact the market price of thinly traded securities, rendering 

them more susceptible to manipulation than securities that are more actively traded.  

C. Limit Orders 

19. A limit order is an order to buy or sell a security at a specified price or better and 

can only be executed if the market price reaches the limit price. A buy limit order can only be 

executed at the limit price or lower, and a sell limit order can only be executed at the limit price 

or higher.  

20. While limit orders do not guarantee execution, they help ensure that an investor 

does not buy for more than or sell for less than a pre-determined price. 

D. Market Orders 

21. A market order is an order to buy or sell a security at the current market price. A 

small lot market order, also known as an “odd lot market order,” is an instruction to buy or sell 

fewer than 100 shares of a security. A large lot market order, also known as a “round lot market 

order,” is an instruction to buy or sell 100 shares or a multiple of 100 shares of a security at the 

best available price. 

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FACTS 

I. Patel Implemented a Scheme to Manipulate the Price of Securities Using at Least 10 
Accounts with Three Registered Broker-Dealers in his Name and the Names of 
Others 

A. Overview of Patel’s Manipulative Trading Scheme 

22. To operate his scheme, Patel opened multiple accounts in his own name and in the 

name of his company NextGen at three different registered broker-dealers.  

23. Patel often used more than one account to place orders for the same securities as 

part of his scheme, including one “helper” account that he generally used to place non-bona fide 

limit orders, and another “winner” account to place trades that profited from the price 

manipulation. 

24. To manipulate the prices of the target securities, Patel generally first built a 

position in a thinly traded target security by placing a large number of small lot market orders for 

that security. He made these trades quickly, placing market orders to buy a single security 

hundreds of times in rapid succession, giving the illusion of widespread demand for the security 

and increasing the National Best Bid and National Best Offer of the targeted securities.  

25. Because Patel made such a large number of trades in such a short period of time, 

and generally in thinly traded securities, Patel’s trading moved the National Best Bid and 

National Best Offer of the targeted securities to prices that, at times, were significantly higher 

than the prices when he started buying.  

26. Second, to keep the National Best Bid and National Best Offer artificially 

inflated, Patel placed multiple limit buy orders for that same security that he did not intend to 

execute. These limit buy orders were frequently priced at or just below the National Best Bid 

price and were visible to the market. Patel sometimes disguised his manipulative trading by 

placing these limit orders in a separate “helper” account. 

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7 
 

27. Third, with the non-bona fide limit buy orders creating the false appearance of 

continued buying interest, Patel then rapidly sold off all his shares in the security that he had just 

purchased. Unlike the market buy orders, which Patel made in large numbers of small lots, he 

sold the securities in larger lots to sell them all quickly at the artificially inflated price.  

28. The visible limit buy orders that Patel held on the buy side helped induce market 

participants to purchase the shares that he simultaneously was selling at inflated prices.  

29. Finally, once Patel closed out of his position, he immediately canceled the limit 

orders that he used to help prop up the prices of the target security.  

30. Patel engaged in this type of trading on more than one thousand occasions, 

sometimes multiple times a day, across hundreds of different securities. 

31. After broker-dealers detected and warned him to cease his manipulative trading, 

and eventually restricted and/or shut down Patel’s accounts, Patel continued his scheme by 

trading in accounts he opened in the name of an estranged family member (“Family Member”), 

which he opened without Family Member’s knowledge or consent, and in accounts of a friend 

(“Individual A”). 

32. During the Relevant Period, Patel conducted this manipulative trading in more 

than 400 different securities, the tickers of which are identified in Attachment A. 

33. Overall, Patel used at least the following 10 trading accounts to carry out his 

scheme and generated more than $5 million in illicit gains from at least May 2021 to at least 

January 2024:   

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8 
 

Account Account Holder’s  
Name 

Account Number Broker-Dealer 

Account 1 Harsh Patel xxxx-8644 Broker-Dealer 1 
Account 2 Harsh Patel xxxx-0647 Broker-Dealer 2 
Account 3 Harsh Patel xxxx-0990 Broker-Dealer 3 
Account 4 NextGen xxxx-7041 Broker-Dealer 1 
Account 5 NextGen xxxx-6284 Broker-Dealer 3 
Account 6 Family Member xxxx-5036 Broker-Dealer 1 
Account 7 Family Member  xxxx-0853 Broker-Dealer 3 
Account 8 Family Member  xxxx-2163 Broker-Dealer 3 
Account 9 Individual A  xxxx-7599 Broker-Dealer 3 
Account 10 Individual A  xxxx-3220 Broker-Dealer 3 

B.   Examples of Patel’s Manipulative Trading 

1. AeroCentury Corp. on May 13, 2021 

34. On May 13, 2021, at 2:45 p.m., the National Best Bid for shares of AeroCentury, 

Corp. (“AeroCentury”) stock, which traded under the ticker symbol “ACY,” was approximately 

$7.35 per share, and the National Best Offer was approximately $7.49 per share.     

35. At approximately 2:45 p.m., Patel placed a market order to buy 2,900 shares of 

AeroCentury in an account with a registered broker-dealer (“Broker-Dealer 1”) in the name of 

his company, NextGen (identified in the chart above as “Account 4”). This order was 

immediately filled.  

36. Patel rapidly continued to place similarly sized market orders to buy shares of 

AeroCentury, one after another, from 2:45 p.m. until approximately 2:56 p.m. During those 11 

minutes, Patel placed 22 market orders to purchase a total of 31,800 shares of AeroCentury in 

Account 4.   

37. As Patel rapidly placed these orders, the National Best Bid began to rise, and by 

the time of his last market order, the execution price had increased from $7.49 per share for his 

first market order to $8.50 per share for the last one. 

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9 
 

38. Just a few minutes after placing his first market order to buy, beginning at 

approximately 2:48 p.m., Patel placed limit orders to buy AeroCentury shares from the same 

account, Account 4. From 2:48 p.m. until approximately 2:56 p.m., Patel placed nine limit buy 

orders for a total of 28,100 shares of AeroCentury at prices ranging from $7.55 per share to 

$8.11 per share, thereby displaying to the market demand for AeroCentury shares at those prices. 

Three of these limit orders were either filled or partially filled and resulted in purchases of an 

additional 2,145 shares, bringing Patel’s total position to 33,945 shares of AeroCentury. 

39. By the time Patel placed his last market buy order at approximately 2:56 p.m., the 

National Best Bid for AeroCentury had risen to $8.50 per share and the National Best Offer had 

risen to $8.70 per share—an increase of approximately 16% in the 11 minutes that Patel was 

trading the stock.   

40. Seconds later, Patel began placing large lot market orders to sell AeroCentury 

shares, which began executing at around $8.50 per share, while his remaining limit orders to buy 

25,955 AeroCentury shares at prices ranging from $7.54 to $8.10 per share were still sitting 

open, unexecuted, showing demand for AeroCentury shares.   

41. Patel sold all 33,945 of his AeroCentury shares through 11 market orders at prices 

ranging from $8.21 to $8.52 per share within 10 seconds. In the last second of those sales, Patel 

canceled all of his open limit orders to buy AeroCentury shares.   

42. Patel’s trading activity over the course of those 11 minutes and 20 seconds, all in 

Account 4, made up approximately half of the volume of the market-wide trading activity in 

AeroCentury shares during that time, and netted Patel $19,456 in profits.  

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10 
 

2. Arqit Quantum Inc. (“ARQQ”) on October 8, 2021 

43. On October 8, 2021, at approximately 1:11 p.m., the National Best Bid for Arqit 

Quantum Inc. (“Arqit”) stock, which traded under the ticker symbol “ARQQ,” was 

approximately $16.80 per share, and the National Best Offer was approximately $17.00 per 

share. At that time, Patel began purchasing shares of Arqit in Account 4. 

44. From 1:11 p.m. through approximately 2:33 p.m., Patel purchased approximately 

115,000 shares of Arqit in Account 4 by placing 49 market orders and 11 limit orders ranging in 

price from $16.80 to $18.70 per share.  

45. From approximately 2:19 p.m. to 2:32 p.m., Patel placed various limit orders to 

buy shares of Arqit in an account with a registered broker-dealer (“Broker-Dealer 2”) in his own 

name (identified in the chart above as “Account 2”) priced at $17.40 to $18.25 per share, 

communicating interest to the market and supporting the increased price.  

46. Starting a minute later, at approximately 2:33 p.m., Patel began to liquidate the 

Arqit shares in Account 4, beginning with a market sell order that was executed at $18.65 per 

share.  

47. At approximately the same time, from 2:33 p.m. through 2:35 p.m., Patel placed 

35 limit orders in Account 4, each to buy 3,700 shares of Arqit at $17.40 per share. Patel placed 

these limit orders in Account 4 while he was rapidly selling Arqit shares and closing out his long 

position.  

48. By 2:35 p.m., Patel had sold most of his Arqit shares, and the National Best Bid 

had dropped from $18.45 per share when he started selling 90 seconds earlier to $17.50 per 

share.   

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11 
 

49. Patel then canceled the outstanding limit orders to buy Arqit shares that he placed 

minutes earlier.   

50. Patel’s trading from approximately 1:11 p.m. to 2:35 p.m. on October 8, 2021 

accounted for over 31% of the total trading volume in Arqit and netted him approximately 

$49,591 in profits. 

C. Patel Repeatedly Received Compliance Warnings from Broker-Dealers, Lied 
About his Trading Strategy, and Had his Accounts Restricted and/or Closed. 

51. Patel’s trading during the Relevant Period triggered numerous warnings for 

manipulative trading activity at the various broker-dealers where he held accounts, and, over 

time, the broker-dealers restricted his trading privileges and/or closed his accounts.   

52. For example, on or about May 25, 2021, after a registered broker-dealer firm 

(“Broker-Dealer 3”) had placed a 14-day restriction on an account Patel held in his own name 

(identified in the chart above as “Account 3”), a representative of Broker-Dealer 3 explained to 

Patel in a recorded telephone call how his trading practices were manipulating the price of 

certain securities.   

53. The representative pointed out that Patel was taking a low volume stock, placing a 

large amount of progressively higher-priced buy orders and boosting the price, and then “turning 

around and selling on that … overly inflated price that you boosted up with the numerous buy 

orders.”   

54. The representative further suggested ways that Patel could alter his trading 

practices to avoid manipulating the price of the stocks he traded.   

55. Patel did not change his practices, and Broker-Dealer 3 alerted Patel in September 

2021 that it was ending its relationship with him.  

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12 
 

56. In September and October 2021, after Broker-Dealer 3 would no longer service 

Patel’s accounts, Patel moved approximately $3 million from his Broker-Dealer 3 accounts to 

accounts with Broker-Dealer 1 and Broker-Dealer 2. Patel continued his manipulative practices 

and received numerous warnings from Broker-Dealer 1 and Broker-Dealer 2 as well.   

57. In October 2021, Broker-Dealer 1 identified trading activity in an account Patel 

held in his own name (identified in the chart above as “Account 1”) that was “giving the 

appearance of spoofing/layering,” because as Patel entered multiple market orders, the price of 

the security rose, and Patel then placed buy limit orders at lower prices before he entered orders 

selling the newly acquired shares. A representative of Broker-Dealer 1 warned Patel by 

telephone in November 2021 to cease trading in the manner that he had been trading. Patel, 

however, continued his manipulative trading.  

58. Broker-Dealer 1 restricted Patel from placing any more trades in Account 1 and 

Account 4 in July 2022. Broker-Dealer 2 terminated Account 3 in August 2022. Rather than 

cease his manipulative trading scheme, Patel simply traded in accounts held in other people’s 

names. 

D. Patel Traded Using Accounts Held in Other People’s Names 

59. After Broker-Dealer 1 and Broker-Dealer 2 restricted and/or terminated Patel’s 

personal and NextGen accounts, Patel continued his manipulative trading scheme by trading in 

accounts held in the names of Family Member and Individual A.  

1. Patel Opened Trading Accounts in Family Member’s Name Without 
Family Member’s Knowledge 

60. In or around August 2022, Patel began to trade in three accounts held in Family 

Member’s name at Broker-Dealer 1 (identified in the chart above as “Account 6”) and Broker-

Dealer 3 (identified in the chart above as “Account 7” and “Account 8”).  

Case 1:26-cv-03203     Document 1     Filed 04/20/26     Page 12 of 20



13 
 

61. Patel opened the accounts in Family Member’s name without Family Member’s 

knowledge by using Family Member’s personal identity information, and by signing Family 

Member’s name on account opening documents. 

62. From on or about November 9, 2022 through July 30, 2023, Patel traded in 

Account 6, Account 7, and Account 8 using login credentials he created to access the online 

platforms of Broker-Dealer 1 and Broker-Dealer 3.  

63. Patel’s trading in Account 6, Account 7, and Account 8 triggered warnings at 

Broker-Dealer 1 and Broker-Dealer 3, just as it did with the trading in his personal and NextGen 

accounts before they were restricted and/or terminated. Some warnings came through the broker-

dealer message systems, which Patel answered as Family Member by using Family Member’s 

credentials to sign into the account without Family Member’s knowledge.  

64. Broker-Dealer 1 and Broker-Dealer 3 froze and/or placed restrictions on accounts 

held in Family Member’s name several times in 2023. Patel initially impersonated Family 

Member on a phone call with Broker-Dealer 1 to address trading issues. Patel later had Family 

Member speak directly with Broker-Dealer 1 and Broker-Dealer 3 while he listened in and 

provided responses for Family Member to recite during the calls. 

65. On June 21, 2023, Family Member discussed manipulative trading with a 

representative from Broker-Dealer 3. The representative noted that the trading in the account 

held in Family Member’s name “could give the impression that … you’re intentionally trying to 

bump up the market in this security, so that you can later sell for a preferable price.”  

66. Following Patel’s instructions via text message, Family Member told Broker-

Dealer 3 that the trading strategy would be modified. Patel, however, continued the manipulative 

Case 1:26-cv-03203     Document 1     Filed 04/20/26     Page 13 of 20



14 
 

trading in accounts held in Family Member’s name with Broker-Dealer 3 into at least July 2023, 

when he then began trading in Individual A’s account.  

2. Patel Continued his Manipulative Trading in Accounts Held in 
Individual A’s Name  

 
67. In August 2023, Patel discussed with a friend, Individual A, Patel trading under 

Individual A’s name, to which Individual A agreed.  

68. Pursuant to that agreement, Patel transferred approximately $847,000 from the 

accounts he used in Family Member’s name to accounts held in Individual A’s name with 

Broker-Dealer 3 (identified in the chart above as “Account 9” and “Account 10”), including an 

account that Individual A opened in September 2023 for Patel’s use. 

69. Patel and Individual A agreed that Patel was in charge of the trading activities in 

Account 9 and Account 10 and would retain any profits from the trading and/or be responsible 

for any losses.  

70. Patel began trading in Account 9 and Account 10 at the end of August 2023. 

71. Almost immediately after Patel began trading in Account 9 and Account 10, 

Patel’s trading triggered warnings from Broker-Dealer 3.  

72. Patel responded to those warnings using Broker-Dealer 3’s internal messaging 

system, under Individual A’s username. Despite receiving multiple warnings, Patel continued his 

manipulative trading in Account 9 and Account 10, and Broker-Dealer 3 continued to flag some 

of the trading as potentially manipulative.  

73. By early January 2024, Broker-Dealer 3 had restricted or closed Account 9 and 

Account 10 due to Patel’s manipulative trading. In accordance with their agreement, Individual 

A returned all funds remaining in the accounts to Patel. 

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15 
 

E. Patel Profited from his Manipulative Trading 

74. Patel’s profits derived from his manipulative trading totaled more than $5 million.   

75. Patel’s profits came from manipulative trading in more than 400 securities, as 

reflected in Attachment A, and spanned from at least May 25, 2021, when Patel was very clearly 

warned by Broker-Dealer 3 that his trading was manipulative, to at least January 2, 2024, when 

Patel placed his last trade in an account in Individual A’s name. 

II. Patel Violated the Federal Securities Laws 

76. During the Relevant Period, Patel traded in ten different accounts, including 

accounts in other people’s names, for the purpose of inducing other market participants to 

purchase such securities. Patel’s orders included limit orders that were non-bona fide. 

77. Patel’s trading practices, including his use of non-bona fide limit orders, an 

overwhelming percentage of which he canceled, allowed him to sell securities at artificially 

inflated prices.  

78. Patel knew or was reckless in not knowing that his trading practices were 

inducing others to purchase securities at inflated prices.  

79. Patel had been warned by broker-dealers on multiple occasions that his trading 

appeared to be manipulative and Patel refused to change his trading pattern. Patel ignored these 

warnings. 

80. Patel placed non-bona fide orders and used multiple accounts to obscure his 

identity when trading. 

81. Patel’s scheme was in the offer or sale of securities and was done in connection 

with the purchase and sale of securities.  

Case 1:26-cv-03203     Document 1     Filed 04/20/26     Page 15 of 20



16 
 

82. Patel’s non-bona fide limit orders that he placed to deceive investors, only to later 

cancel most of them, were manipulative. Patel placed these orders to prop up the price of the 

security for as long as possible to ensure he could sell shares at artificially inflated prices.  

83. Patel knew or was reckless in not knowing that his trading was deceptive.  

84. After receiving numerous warnings and restrictions regarding his trading from 

Broker-Dealer 1 and Broker Dealer 3, Patel began trading in accounts held in the names of 

Family Member and Individual A to conceal from Broker-Dealer 1 and Broker-Dealer 3 that he 

continued his manipulative trading.   

85. Patel intentionally misrepresented information to Broker-Dealer 1 and Broker-

Dealer 3 when opening accounts in Family Member’s name. Patel falsely represented himself as 

Family Member when electronically signing the forms and answering various identifying 

questions.  

86. Patel’s misrepresentations and omissions to Broker-Dealer 1 and Broker-Dealer 3 

were material, because Broker-Dealer 1 and Broker-Dealer 3 had terminated and/or restricted 

Patel’s trading privileges and would not have allowed him to trade in accounts held in Family 

Member’s name.  

87. Patel’s misrepresentations and omissions to Broker-Dealer 1 and Broker-Dealer 3 

were in connection with the purchase or sale of a security and in the offer or sale of a security, 

because the accounts were used to buy and sell securities.  

88. Patel obtained money by making material misrepresentations and omissions to 

Broker-Dealer 1 and Broker-Dealer 3 because he earned profits by trading in accounts held in the 

name of Family Member after trading accounts in his own name had been terminated and/or 

restricted.  

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17 
 

FIRST CLAIM FOR RELIEF 
Fraud in the Offer or Sale of Securities 

Violations of Securities Act Section 17(a) 

89. The Commission re-alleges and incorporates by reference here the allegations in 

paragraphs 1 through 88. 

90. Defendant directly or indirectly, singly or in concert, by use of the means or 

instruments of transportation or communication in interstate commerce, or of the mails, in the 

offer or sale of securities: (a) knowingly or recklessly employed devices, schemes and artifices to 

defraud; (b) knowingly, recklessly, or negligently obtained money or property by means of 

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; and 

(c) knowingly, recklessly, or negligently engaged in transactions, acts, practices and courses of 

business which operated as a fraud or deceit upon the purchaser.  

91. By reason of the foregoing, Defendant, directly or indirectly, has violated and, 

unless enjoined, will again violate Securities Act Section 17(a) [15 U.S.C. § 77q(a)].  

SECOND CLAIM FOR RELIEF 
Fraud in the Purchase or Sale of Securities 

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

92. The Commission re-alleges and incorporates by reference here the allegations in 

paragraphs 1 through 88.  

93. Defendant, directly or indirectly, singly or in concert, by use of the means or 

instrumentalities of interstate commerce, or of the mails, or of the facilities of a national 

securities exchange, in connection with the purchase or sale of securities, knowingly or 

recklessly: (a) employed devices, schemes and 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; and (c) engaged in 

Case 1:26-cv-03203     Document 1     Filed 04/20/26     Page 17 of 20



18 
 

transactions, acts, practices and courses of business which operated or would have operated as a 

fraud or deceit upon other persons.  

94. By reason of the foregoing, Defendant, directly or indirectly, singly or in concert, 

has violated and, unless enjoined, will again violate Exchange Act Section 10(b) [15 U.S.C. § 

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

THIRD CLAIM FOR RELIEF 
Market Manipulation 

Violations of Section 9(a)(2) of the Exchange Act 

95. The Commission re-alleges and incorporates by reference here the allegations in 

paragraphs 1 through 88.  

96. Defendant, directly or indirectly, by the use of the mails or any means or 

instrumentality of interstate commerce, or of any facility of any national securities exchange, 

effected, alone or with one or more other persons, a series of transactions in a security creating 

actual or apparent active trading in such security, or raising or depressing the price of such 

security, for the purpose of inducing the purchase or sale of such security by others.  

97. By reason of the foregoing, Defendant, directly or indirectly, singly or in concert, 

has violated and, unless enjoined, will again violate Exchange Act Section 9(a)(2) [15 U.S.C. § 

78i(a)(2)].  

PRAYER FOR RELIEF 

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

Judgment: 

I. 

Permanently enjoining Defendant and his agents, servants, employees and attorneys and 

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

indirectly, Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)], and Section 10(b) of the 

Case 1:26-cv-03203     Document 1     Filed 04/20/26     Page 18 of 20



19 
 

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

committing or engaging in specified actions or activities relevant to such violations;  

II. 

Permanently enjoining Defendant and his agents, servants, employees and attorneys and 

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

indirectly, Section 9(a)(2) of the Exchange Act [15 U.S.C. § 78i(a)(2)];  

III. 

Ordering Defendant to disgorge all ill-gotten gains received directly or indirectly, with 

pre-judgment interest thereon, as a result of the alleged violations, pursuant to Exchange Act 

Sections 21(d)(3), 21(d)(5) and 21(d)(7) [15 U.S.C. §§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)];  

IV. 

Ordering Defendant to pay a civil monetary penalty under Securities Act Section 20(d) 

[15 U.S.C. § 77t(d)] and Exchange Act Section 21(d)(3) [15 U.S.C. § 78u(d)(3)];  

V. 

Permanently enjoining Defendant from, directly or indirectly, opening, maintaining or 

trading in any brokerage account(s) in his name, the names of any immediate family members, 

the name of any company over which he has any control or the name(s) of any third-party 

individuals, without providing the relevant broker-dealer(s) a copy of the complaint and any final 

judgment entered against him in this action; and 

VI. 

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

Case 1:26-cv-03203     Document 1     Filed 04/20/26     Page 19 of 20



20 
 

DEMAND FOR JURY TRIAL 

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff demands that this 

case be tried to a jury. 

Dated:  Philadelphia, PA 
April 20, 2026    SECURITIES AND EXCHANGE COMMISSION  

     S/ Karen M. Klotz                       
Joseph G. Sansone 
Julia C. Green 
Gregory R. Bockin 
Karen M. Klotz* 
Attorneys for Plaintiff 
Philadelphia Regional Office 
1617 JFK Boulevard, Suite 520 
Philadelphia, PA 19103 
(215) 861-9613 (Klotz) 
Email: [email protected] 
Attorneys for Plaintiff 
Securities and Exchange Commission 

 

 
* Application for admission pro hac vice to be filed.  

Case 1:26-cv-03203     Document 1     Filed 04/20/26     Page 20 of 20ATTACHMENT A 
 

Page 1 of 17 
 

Tickers for 
Manipulated 

Securities 

Account(s) Dates of Manipulative Trading 

.MRNA210806P405 Account 3 Aug. 6, 2021 

.MRNA210813C470 Account 3 Aug. 10, 2021 

.TSLA210806C700 Account 3 Aug. 3, 2021 
AAMC Account 5 Aug. 31, 2021; Sep. 1, 2021; Sep. 2, 2021; 

Sep. 3, 2021 
ACAQ Account 10 Oct. 5, 2023; Oct. 11, 2023 
ACLX Account 1 June 9, 2022 
ACXP Account 10 Oct. 13, 2023; Oct. 17, 2023 
ACY Account 3; Account 4; 

Account 5 
July 9, 2021; July 13, 2021; Aug. 3, 2021; 
Aug. 4, 2021; Aug. 5, 2021; Aug. 6, 2021; 
Aug. 9, 2021; Aug. 10, 2021; Aug. 11, 
2021; Aug. 12, 2021; Aug. 13, 2021; Aug. 
16, 2021; Aug. 17, 2021; Aug. 23, 2021; 
Aug. 25, 2021; Sep. 23, 2021; Oct. 11, 
2021 

ADGI Account 4 Dec. 1, 2021; Dec. 14, 2021 
ADTX Account 9 Aug. 23, 2023; Aug. 30, 2023; Aug. 31, 

2023; Sep. 1, 2023; Sep. 5, 2023; Sep. 6, 
2023; Sep. 13, 2023; Sep. 15, 2023; Sep. 
27, 2023; Sep. 28, 2023 

AEHL Account 3 June 9, 2021 
AERC Account 1; Account 4 Nov. 30, 2021; Dec. 1, 2021; Dec. 2, 2021; 

Dec. 20, 2021; Dec. 22, 2021; Dec. 27, 
2021; June 7, 2022; June 8, 2022; June 10, 
2022; June 13, 2022; June 14, 2022; June 
15, 2022; June 16, 2022; June 24, 2022; 
June 27, 2022; June 29, 2022; July 1, 2022; 
July 6, 2022; July 7, 2022; July 8, 2022 

AGIL Account 5 Sep. 3, 2021 
AHPI Account 5 July 13, 2021; July 19, 2021 
AIRE Account 10 Nov. 6, 2023 
AIRT Account 5 Sep. 7, 2021 
AKAN Account 4 March 15, 2022; March 16, 2022; March 

21, 2022 
ALF Account 5 Aug. 17, 2021 
ALGN Account 1 April 28, 2022 
ALLG Account 1; Account 2; 

Account 4 
March 24, 2022; March 24, 2022; March 25, 
2022; March 28, 2022; April 22, 2022; April 
27, 2022; April 28, 2022 

  

Case 1:26-cv-03203     Document 1-1     Filed 04/20/26     Page 1 of 17



ATTACHMENT A 
 

Page 2 of 17 
 

Tickers for 
Manipulated 

Securities 

Account(s) Dates of Manipulative Trading 

ALLR Account 8 July 5, 2023 
ALNY Account 4 Dec. 27, 2021 
AMBI Account 8 March 14, 2023; March 20, 2023; March 

21, 2023 
AMC Account 5 July 14, 2021; July 15, 2021 
AMPX Account 8 March 23, 2023 
AMV Account 7 Jan. 13, 2023 
AMZN--
220218C03100000 

Account 1 Feb. 14, 2022 

AMZN--
220422C03050000 

Account 1 April 19, 2022 

ANGH Account 1 Feb. 10, 2022; Feb. 17, 2022; March 2, 
2022; April 5, 2022; April 6, 2022 

ANVS Account 3; Account 5; 
Account 10 

June 21, 2021; July 30, 2021; Dec. 27, 
2023 

AONC Account 9 Sep. 21, 2023; Sep. 22, 2023; Sep. 25, 2023 
APLM Account 8 March 30, 2023; March 31, 2023; April 3, 

2023 
APPN Account 1 May 10, 2022 
APRN Account 8 June 9, 2023; June 12, 2023 
ARL Account 5 July 15, 2021 
ARQQ Account 4 Sep. 17, 2021; Sep. 21, 2021; Sep. 22, 

2021; Sep. 23, 2021; Sep. 28, 2021; Sep. 
29, 2021; Oct. 1, 2021; Oct. 4, 2021; Oct. 
7, 2021; Oct. 8, 2021; Oct. 12, 2021; Oct. 
19, 2021; Oct. 20, 2021; Oct. 25, 2021; 
Oct. 26, 2021; Nov. 1, 2021; Nov. 12, 2021 

ASND Account 8 April 3, 2023 
ASNS Account 8 May 4, 2023 
ASTI Account 9 Sep. 13, 2023 
ATGL Account 9; Account 10 Nov. 1, 2023; Nov. 15, 2023; Nov. 16, 

2023; Nov. 20, 2023; Nov. 21, 2023; Nov. 
27, 2023 

ATLX Account 7; Account 8; 
Account 9 

Jan. 18, 2023; May 4, 2023; May 5, 2023; 
May 9, 2023; May 10, 2023; May 11, 
2023; May 16, 2023; May 23, 2023; Nov. 
20, 2023 

ATNF Account 7 Dec. 20, 2022 
ATXG Account 8 July 11, 2023 
AURC Account 8 July 25, 2023; July 26, 2023; July 27, 2023 

  

Case 1:26-cv-03203     Document 1-1     Filed 04/20/26     Page 2 of 17



ATTACHMENT A 
 

Page 3 of 17 
 

Tickers for 
Manipulated 

Securities 

Account(s) Dates of Manipulative Trading 

AUVI Account 3 June 3, 2021; June 4, 2021 
AVGR Account 9 Sep. 20, 2023; Sep. 27, 2023 
AWX Account 3 Aug. 9, 2021 
AXLA Account 9 Sep. 28, 2023; Sep. 29, 2023; Oct. 2, 2023 
AXSM Account 1 April 19, 2022 
BANL Account 8 March 27, 2023; March 28, 2023; March 

29, 2023; March 30, 2023 
BAOS Account 8 May 2, 2023; June 8, 2023; June 9, 2023 
BBAI Account 1 May 18, 2022 
BBBY Account 3 June 2, 2021 
BDRX Account 8 July 14, 2023 
BENF Account 8 June 14, 2023; June 15, 2023 
BFRG Account 8 April 4, 2023; May 31, 2023 
BGLC Account 8 July 21, 2023 
BGXX Account 1 May 18, 2022 
BIOC Account 8 May 24, 2023 
BIVI Account 7 Dec. 15, 2022 
BJDX Account 8 July 24, 2023; July 25, 2023; July 28, 2023 
BKKT Account 4; Account 7 Nov. 11, 2021; Nov. 12, 2021; Nov. 19, 

2021; Jan. 12, 2023 
BLBD Account 8 May 12, 2023 
BLBX Account 8 April 17, 2023 
BLTE Account 1 May 3, 2022 
BLUW Account 5 Sep. 8, 2021 
BLZE Account 4 Nov. 17, 2021 
BNTX Account 3; Account 5 Aug. 12, 2021; Aug. 17, 2021 
BODI Account 9 Nov. 22, 2023 
BOH Account 8 May 12, 2023 
BON Account 4; Account 5 July 6, 2021; July 14, 2021; July 15, 2021; 

July 16, 2021; Oct. 20, 2021 
BRCC Account 1 Feb. 17, 2022; April 19, 2022; June 29, 

2022 
BRFH Account 4 Jan. 25, 2022 
BROS Account 1; Account 4 Sep. 17, 2021; Feb. 1, 2022 
BTAI Account 8 July 6, 2023 
BTB Account 7 Jan. 17, 2023 
BTCM Account 7 Jan. 17, 2023 
BTTX Account 4 Nov. 1, 2021; Nov. 3, 2021 

  

Case 1:26-cv-03203     Document 1-1     Filed 04/20/26     Page 3 of 17



ATTACHMENT A 
 

Page 4 of 17 
 

Tickers for 
Manipulated 

Securities 

Account(s) Dates of Manipulative Trading 

BWV Account 1 April 7, 2022; April 8, 2022; May 17, 2022 
CAR Account 4 Nov. 5, 2021 
CARG Account 1 Feb. 25, 2022 
CARV Account 3; Account 4; 

Account 5 
June 7, 2021; June 8, 2021; June 11, 2021; 
June 24, 2021; June 29, 2021; July 7, 2021; 
July 8, 2021; July 9, 2021; July 13, 2021; 
July 15, 2021; July 19, 2021; July 20, 2021; 
July 21, 2021; Aug. 9, 2021; Aug. 10, 2021; 
Aug. 16, 2021; Sep. 28, 2021; Oct. 1, 2021; 
Oct. 25, 2021 

CAVA Account 8 June 15, 2023; July 13, 2023 
CCG Account 9 Sep. 18, 2023; Sep. 25, 2023; Sep. 26, 

2023; Sep. 28, 2023; Oct. 3, 2023 
CCXI Account 4 Oct. 8, 2021 
CDT Account 9 Sep. 26, 2023; Sep. 27, 2023 
CETX Account 6; Account 7 Feb. 1, 2023; Feb. 2, 2023; Feb. 9, 2023 
CFFE Account 9 Sep. 20, 2023; Sep. 29, 2023; Oct. 2, 2023 
CJET Account 8 June 5, 2023 
CJJD Account 7 Dec. 12, 2022 
CLBR Account 8 July 19, 2023 
CLOV Account 3; Account 4 June 14, 2021 
CMA Account 8 May 4, 2023 
CMMB Account 3; Account 4; 

Account 5 
June 10, 2021; Aug. 27, 2021; Nov. 1, 
2021; Dec. 21, 2021 

COHN Account 3; Account 5 June 14, 2021; July 8, 2021; July 9, 2021; 
July 16, 2021; Aug. 16, 2021 

COSM Account 7 Jan. 24, 2023 
CPOP Account 4; Account 5 July 1, 2021; July 2, 2021; July 7, 2021; 

July 13, 2021; July 15, 2021; July 21, 2021; 
Oct. 29, 2021 

CPTN Account 1 Feb. 23, 2022 
CVNA Account 1 Feb. 25, 2022 
CWD Account 8 May 18, 2023 
CXAI Account 8 April 13, 2023; April 14, 2023; April 17, 

2023; April 18, 2023; April 19, 2023; April 
20, 2023; April 25, 2023; April 26, 2023; 
May 26, 2023; May 30, 2023; June 1, 2023; 
June 5, 2023; June 6, 2023; June 7, 2023 

DATS Account 4 Sep. 29, 2021; Oct. 5, 2021 
DBGI Account 9 Sep. 5, 2023; Sep. 6, 2023; Sep. 12, 2023 

  

Case 1:26-cv-03203     Document 1-1     Filed 04/20/26     Page 4 of 17



ATTACHMENT A 
 

Page 5 of 17 
 

Tickers for 
Manipulated 

Securities 

Account(s) Dates of Manipulative Trading 

DDL Account 3; Account 5 June 30, 2021; June 30, 2021 
DFLI Account 7 Dec. 19, 2022 
DHHC Account 8 March 23, 2023 
DJT Account 9 Sep. 5, 2023 
DKDCA Account 10  Oct. 25, 2023 
DLPN Account 3; Account 5 June 9, 2021; July 26, 2021 
DOCU Account 4 Dec. 3, 2021 
DOGZ Account 4; Account 10 Jan. 6, 2022; Jan. 2, 2024 
DPSI Account 1 May 9, 2022 
DQ Account 5 July 23, 2021 
DRTS Account 1; Account 4 March 24, 2022; April 21, 2022; July 5, 

2022 
DTOC Account 9 Sep. 19, 2023; Sep. 20, 2023 
DUOL Account 5 July 28, 2021; Sep. 3, 2021 
DWAC Account 1; Account 2; 

Account 4 
Oct. 26, 2021; Oct. 27, 2021; Oct. 28, 
2021; Oct. 29, 2021; Nov. 4, 2021; Nov. 
12, 2021; Nov. 16, 2021; Nov. 19, 2021; 
Nov. 24, 2021; Dec. 2, 2021; Dec. 7, 2021; 
Dec. 8, 2021; Dec. 13, 2021; Jan. 7, 2022; 
Jan. 10, 2022; Jan. 12, 2022; Jan. 13, 2022; 
Jan. 14, 2022; Jan. 18, 2022; Jan. 19, 2022 
; Jan. 20, 2022 ; Jan. 24, 2022 ; July 12, 
2022 

DWACW Account 4 Oct. 22, 2021; Oct. 28, 2021 
DY Account 7 Nov. 22, 2022 
EAST Account 8 June 14, 2023 
EBON Account 7; Account 8 Jan. 13, 2023; Jan. 17, 2023; July 11, 2023 
EDBL Account 7 Jan. 30, 2023; Jan. 31, 2023; Feb. 1, 2023 
EDRY Account 3 June 4, 2021; June 7, 2021; June 8, 2021 
EDTX Account 8 June 15, 2023; June 20, 2023; July 7, 2023 
EEIQ Account 4 Sep. 16, 2021; Sep. 27, 2021 
EFTR Account 4; Account 5 Sep. 7, 2021; Sep. 8, 2021; Sep. 9, 2021; 

Sep. 15, 2021; Sep. 16, 2021; Sep. 29, 
2021; Oct. 4, 2021; Oct. 13, 2021; Oct. 14, 
2021; Oct. 15, 2021 

EH Account 3; Account 5 May 27, 2021; June 7, 2021 
EHTH Account 1 March 1, 2022 

  

Case 1:26-cv-03203     Document 1-1     Filed 04/20/26     Page 5 of 17



ATTACHMENT A 
 

Page 6 of 17 
 

Tickers for 
Manipulated 

Securities 

Account(s) Dates of Manipulative Trading 

ELOX Account 8 April 5, 2023; April 6, 2023; April 10, 
2023; April 11, 2023; April 12, 2023; May 
16, 2023; May 17, 2023 

ENVB Account 8 May 18, 2023 
EVBG Account 4 Dec. 10, 2021 
EVLO Account 8 July 18, 2023; July 19, 2023; July 20, 2023 
EVTL Account 1 April 13, 2022 
FBYD Account 10 Oct. 18, 2023 
FCUV Account 4; Account 5 Sep. 1, 2021; Sep. 3, 2021; Sep. 7, 2021; 

Sep. 8, 2021; Oct. 12, 2021; Oct. 13, 2021; 
Oct. 14, 2021; Nov. 11, 2021 

FEMY Account 5 July 13, 2021; July 20, 2021; July 21, 2021 
FFIE Account 1 July 5, 2022 
FLGC Account 3; Account 5 Aug. 5, 2021; Aug. 6, 2021; Aug. 9, 2021; 

Aug. 10, 2021; Aug. 24, 2021 
FRGE Account 1; Account 4 March 22, 2022; March 25, 2022; March 

28, 2022; March 30, 2022; March 31, 
2022; April 18, 2022; April 22, 2022; April 
27, 2022; April 29, 2022; May 2, 2022; 
May 3, 2022; May 4, 2022; June 1, 2022 

FRLN Account 5; Account 8 July 19, 2021; May 22, 2023; July 12, 
2023; July 13, 2023 

FULC Account 3 Aug. 10, 2021 
FUTU Account 5 July 27, 2021 
FWBI Account 7 Feb. 2, 2023 
FWP Account 5 July 19, 2021; July 21, 2021; July 22, 

2021; July 23, 2021; July 26, 2021 
FZT Account 9 Sep. 26, 2023 
G5140V112 Account 10 Dec. 22, 2023 
G7244A119 Account 9; Account 10 Aug. 22, 2023; Oct. 10, 2023 
GAMB Account 5 Aug. 30, 2021 
GBR Account 3 June 1, 2021 
GCT Account 7; Account 9 Nov. 28, 2022; Sep. 11, 2023 
GDC Account 8 May 1, 2023 
GDHG Account 10 Nov. 14, 2023 
GDYN Account 1 Feb. 24, 2022 

  

Case 1:26-cv-03203     Document 1-1     Filed 04/20/26     Page 6 of 17



ATTACHMENT A 
 

Page 7 of 17 
 

Tickers for 
Manipulated 

Securities 

Account(s) Dates of Manipulative Trading 

GFAI Account 6; Account 8 Feb. 14, 2023; March 31, 2023; April 3, 
2023; April 4, 2023; April 5, 2023; April 6, 
2023; April 10, 2023; April 11, 2023; April 
12, 2023; April 13, 2023; April 14, 2023; 
April 17, 2023; April 20, 2023; May 4, 
2023; May 8, 2023 

GLBE Account 1 May 17, 2022 
GLSI Account 1; Account 5 Sep. 7, 2021; July 12, 2022 
GLTA Account 8 July 7, 2023 
GME Account 4; Account 5 July 20, 2021; Oct. 11, 2021 
GME---
220401C00185000 

Account 4 March 29, 2022 

GMVD Account 7 Jan. 30, 2023 
GNS Account 1 April 22, 2022; April29, 2022 
GOCO Account 7 Nov. 28, 2022 
GOOGL-
220204P02900000 

Account 1 Feb. 2, 2022 

GREE Account 2; Account 4; 
Account 8 

Sep. 21, 2021; Sep. 22, 2021; Sep. 30, 
2021; Oct. 1, 2021; Oct. 4, 2021; Oct. 5, 
2021; Oct. 11, 2021; Oct. 13, 2021; Oct. 18, 
2021; Oct. 26, 2021; Oct. 27, 2021; Oct. 29, 
2021; Nov. 1, 2021; Nov. 5, 2021; Nov. 30, 
2021; July 10, 2023 

GRND Account 7 Nov. 18, 2022 
GROV Account 1 July 7, 2022; July 8, 2022 
GRRR Account 7 Dec. 28, 2022; Jan. 19, 2023 
GSUN Account 1 June 23, 2022 
GWH Account 4 Oct. 12, 2021; Oct. 14, 2021; Oct. 15, 2021 
GXGX Account 5 July 16, 2021 
GYRE Account 9 Nov. 24, 2023; Nov. 28, 2023 
HCDI Account 8 May 4, 2023; May 10, 2023 
HEPA Account 8 May 23, 2023; May 24, 2023; May 25, 2023 
HGTY Account 4 Dec. 3, 2021 
HHGC Account 8 July 25, 2023 
HIBB Account 7 Nov. 29, 2022 
HKD Account 8 April 11, 2023 
HKIT Account 9 Aug. 22, 2023; Aug. 25, 2023 
HLBZ Account 4; Account 5 Sep. 9, 2021; Sep. 10, 2021; Sep. 16, 2021; 

Sep. 22, 2021; Sep. 27, 2021; Sep. 28, 
2021; Oct. 18, 2021; Oct. 19, 2021 

  

Case 1:26-cv-03203     Document 1-1     Filed 04/20/26     Page 7 of 17



ATTACHMENT A 
 

Page 8 of 17 
 

Tickers for 
Manipulated 

Securities 

Account(s) Dates of Manipulative Trading 

HOOD Account 3 Aug. 6, 2021 
HOTH Account 7 Jan. 4, 2023 
HRMY Account 8 March 28, 2023 
HTGM Account 7 Dec. 27, 2022 
HUDI Account 1; Account 4; 

Account 7; Account 8 
Oct. 21, 2021; Oct. 25, 2021; Oct. 26, 2021; 
Oct. 27, 2021; Nov. 10, 2021; May 10, 
2022; Nov. 11, 2022; May 1, 2023 

HX Account 4 Oct. 21, 2021 
ICCT Account 9 Aug. 30, 2023; Aug. 31, 2023; Sep. 6, 2023 
ICVX Account 3; Account 7 July 30, 2021; Aug. 2, 2021; Aug. 4, 2021; 

Dec. 16, 2022 
IEP Account 8 May 25, 2023 
IHT Account 3 June 8, 2021 
IKNA Account 5 July 20, 2021 
IKNX Account 3; Account 5 June 28, 2021; Aug. 27, 2021 
IMPL Account 3; Account 5 Aug. 19, 2021; Sep. 3, 2021 
IMTE Account 1; Account 4 Jan. 14, 2022; Jan. 20, 2022; Jan. 28, 2022; 

March 31, 2022; April 1, 2022; April 4, 
2022 

INDO Account 1; Account 4 Feb. 2, 2022; March 4, 2022; March 8, 
2022; March 9, 2022; March 11, 2022; 
March 14, 2022; March 17, 2022; May 16, 
2022 

INGN Account 3 Aug. 5, 2021 
IPW Account 3 June 30, 2021 
IRNT Account 4; Account 5 Sep. 7, 2021; Sep. 8, 2021; Sep. 10, 2021; 

Sep. 21, 2021 
ISIG Account 2; Account 4 Dec. 9, 2021; Dec. 13, 2021; Dec. 14, 2021; 

Dec. 17, 2021; Dec. 29, 2021; Dec. 31, 
2021; Jan. 3, 2022; Jan. 4, 2022; Jan. 6, 
2022; Jan. 7, 2022; Jan. 10, 2022; Jan. 18, 
2022; March 15, 2022; March 30, 2022; 
April 4, 2022 

ISPC Account 4 Nov. 23, 2021; Nov. 24, 2021; Nov. 29, 
2021; Nov. 30, 2021; Dec. 3, 2021; Dec. 6, 
2021 

ISPO Account 1 Feb. 18, 2022; Feb. 22, 2022; Feb. 25, 2022 
ISPR Account 10 Nov. 15, 2023 
ISUN Account 3 June 8, 2021 
JCS Account 4 Sep. 14, 2021 

  

Case 1:26-cv-03203     Document 1-1     Filed 04/20/26     Page 8 of 17



ATTACHMENT A 
 

Page 9 of 17 
 

Tickers for 
Manipulated 

Securities 

Account(s) Dates of Manipulative Trading 

JCSE Account 1 April 27, 2022; May 10, 2022 
JGGC Account 10 Oct. 25, 2023; Nov. 7, 2023; Nov. 10, 2023 
JMAC Account 8 March 22, 2023 
JSPR Account 4 Sep. 29, 2021; Oct. 4, 2021; Oct. 5, 2021; 

Oct. 6, 2021; Oct. 8, 2021; Oct. 14, 2021 
JWAC Account 8 May 3, 2023 
JYNT Account 4 Oct. 7, 2021 
KAL Account 7 Feb. 6, 2023 
KALA Account 6; Account 7 

Account 8 
Jan. 12, 2023; Jan. 20, 2023; Jan. 26, 2023; 
Jan. 27, 2023; Feb. 10, 2023; April 11, 2023 

KAVL Account 5 Sep. 7, 2021 
KBSF Account 5 July 7, 2021 
KOSS Account 3; Account 4 

Account 5 
June 3, 2021; Aug. 13, 2021; Aug. 24, 
2021; Jan. 3, 2022; Jan. 26, 2022 

KPRX Account 6 Feb. 9, 2023 
KRRO Account 10 Nov. 9, 2023; Nov. 10, 2023; Nov. 13, 2023 
KSPN Account 1 July 12, 2022 
KTRA Account 7 Dec. 9, 2022 
LDWY Account 9 Aug. 25, 2023; Aug. 28, 2023 
LEDS Account 3; Account 5 June 1, 2021; June 3, 2021; June 7, 2021; 

June 23, 2021; June 24, 2021; July 14, 2021 
LEJU Account 8 June 12, 2023 
LFLY Account 9 Sep. 15, 2023; Sep. 18, 2023 
LGVN Account 1; Account 4 Nov. 19, 2021; Nov. 23, 2021; Nov. 26, 

2021; Nov. 29, 2021; Dec. 6, 2021; April 
20, 2022 

LIFW Account 10 Nov. 6, 2023 
LIPO Account 7 Jan. 11, 2023 
LIVE Account 3 Aug. 4, 2021 
LIXT Account 8 July 17, 2023 
LMDX Account 4 Sep. 30, 2021 
LTRY Account 4 Nov. 8, 2021 
LUNR Account 8 Feb. 17, 2023; Feb. 22, 2023; March 16, 

2023; June 12, 2023 
LWAY Account 10 Nov. 14, 2023 
LYT Account 1 July 6, 2022 
LZM Account 8 July 6, 2023 

  

Case 1:26-cv-03203     Document 1-1     Filed 04/20/26     Page 9 of 17



ATTACHMENT A 
 

Page 10 of 17 
 

Tickers for 
Manipulated 

Securities 

Account(s) Dates of Manipulative Trading 

MARPS Account 1; Account 4 March 4, 2022; March 7, 2022; March 8, 
2022; March 9, 2022; March 10, 2022; 
March 17, 2022; May 16, 2022 

MASI Account 1 Feb. 16, 2022 
MCAF Account 9 Nov. 21, 2023 
MDIA Account 3  

Account 5 
July 13, 2021; July 14, 2021; July 19, 2021; 
July 29, 2021; Aug. 10, 2021 

MGOL Account 8 June 12, 2023 
MGRM Account 8 May 19, 2023; May 23, 2023 
MINM Account 8 May 2, 2023; May 5, 2023; May 11, 2023 
MITQ Account 5 July 9, 2021; July 14, 2021; July 26, 2021 
MNDY Account 1 Feb. 23, 2022 
MNTS Account 10 Oct. 12, 2023 
MOH Account 10 Oct. 26, 2023 
MOXC Account 3; Account 4 

Account 5 
June 21, 2021; June 22, 2021; June 23, 
2021; June 24, 2021; June 25, 2021; June 
29, 2021; June 30, 2021; July 2, 2021; July 
6, 2021; July 8, 2021; July 9, 2021; July 12, 
2021; July 13, 2021; July 13, 2021; July 15, 
2021; July 16, 2021; July 19, 2021; July 23, 
2021 

MRIN Account 5 July 8, 2021; July 28, 2021 
MRNA Account 4; Account 5  July 16, 2021; Dec. 10, 2021 
MRVI Account 8 May 16, 2023 
MSAI Account 10 Dec. 22, 2023 
MSC Account 5 July 26, 2021 
MSGM Account 6; Account 7 

Account 8 
Jan. 31, 2023; Feb. 1, 2023; Feb. 8, 2023; 
Feb. 10, 2023; April 6, 2023 

MSS Account 10 Oct. 6, 2023 
MULN Account 10 Dec. 22, 2023 
MURF Account 9 Sep. 19, 2023; Sep. 22, 2023 
MWG Account 8 April 5, 2023; April 11, 2023 
MXC Account 1; Account 4 

Account 5 
July 14, 2021; Oct. 4, 2021; Oct. 5, 2021; 
March 4, 2022; March 7, 2022; March 8, 
2022; March 17, 2022; April 14, 2022 

MYNZ Account 4 Jan. 14, 2022 
MYO Account 3; Account 4 Aug. 10, 2021; Jan. 10, 2022 
NAAS Account 8 March 24, 2023 
NARI Account 10 Nov. 2, 2023 

  

Case 1:26-cv-03203     Document 1-1     Filed 04/20/26     Page 10 of 17



ATTACHMENT A 
 

Page 11 of 17 
 

Tickers for 
Manipulated 

Securities 

Account(s) Dates of Manipulative Trading 

NBTX Account 8 May 5, 2023 
NEGG Account 3; Account 4 

Account 5 
July 1, 2021; July 2, 2021; July 12, 2021; 
July 13, 2021; July 14, 2021; July 15, 2021; 
July 16, 2021; July 19, 2021; July 20, 2021; 
July 29, 2021; Aug. 9, 2021; Nov. 15, 2021 

NFLX Account 4 Jan. 20, 2022 
NIR Account 8 March 24, 2023; April 14, 2023; April 17, 

2023; April 20, 2023 
NKTX Account 1 April 25, 2022; April 27, 2022 
NOGN Account 8 April 3, 2023 
NRXP Account 5 July 26, 2021; July 27, 2021 
NSYS Account 3; Account 5 June 29, 2021; July 26, 2021 
NTRB Account 4 Oct. 7, 2021; Oct. 8, 2021; Jan. 4, 2022 
NTRP Account 10 Oct. 18, 2023 
NURO Account 5 July 21, 2021; July 22, 2021; July 23, 2021; 

July 27, 2021; July 28, 2021 
NUWE Account 7 Dec. 13, 2022 
NUZE Account 7 Jan. 19, 2023 
NVAX Account 4; Account 5 July 19, 2021; Dec. 2, 2021 
NVCT Account 1 April 6, 2022; April 7, 2022 
NVDA Account 4 Nov. 23, 2021 
NVEI Account 4 Dec. 8, 2021 
NWGL Account 9 Sep. 12, 2023 
NXTT Account 9; Account 10 Aug. 24, 2023; Sep. 13, 2023; Oct. 10, 2023 
OLIT Account 10 Nov. 2, 2023 
OMH Account 8 May 11, 2023; May 15, 2023; May 16, 2023 
ORPH Account 5 July 1, 2021; July 16, 2021 
OTRK Account 3; Account 4 June 9, 2021; Dec. 7, 2021 
PAPL Account 10 Nov. 9, 2023 
PBLA Account 8 June 13, 2023 
PETZ Account 5 June 15, 2021 
PEV Account 1 June 27, 2022 
PHIN Account 8 July 10, 2023 
PIK Account 4 Jan. 12, 2022 
PIXY Account 10 Nov.06, 2023; Nov. 7, 2023 
PKBO Account 7 Dec. 5, 2022 
PKST Account 8 June 12, 2023 

  

Case 1:26-cv-03203     Document 1-1     Filed 04/20/26     Page 11 of 17



ATTACHMENT A 
 

Page 12 of 17 
 

Tickers for 
Manipulated 

Securities 

Account(s) Dates of Manipulative Trading 

PLSE Account 3; Account 5 
Account 9 

July 1, 2021; Aug. 4, 2021; Nov. 29, 2023 

POLCQ Account 10 Dec. 29, 2023 
PRAA Account 8 May 9, 2023 
PRFX Account 8 July 14, 2023; July 17, 2023; July 20, 2023 
PSQH Account 8 July 20, 2023; July 26, 2023; July 27, 2023 
PTLO Account 4 Nov. 18, 2021 
PTON Account 1 Feb. 8, 2022 
PTPI Account 8 April 19, 2023 
PUBM Account 3 June 9, 2021 
PWM Account 8 July 7, 2023; July 10, 2023; July 12, 2023; 

July 17, 2023; July 18, 2023; July 19, 2023 
PXMD Account 10 Nov. 7, 2023 
QSG Account 8 May 26, 2023 
RANI Account 4; Account 5 Aug. 25, 2021; Aug. 26, 2021; Jan. 26, 

2022 
RAPT Account 3 June 14, 2021 
RBLX Account 4 Nov. 16, 2021 
RCLF Account 9 Sep. 7, 2023 
RDBX Account 1; Account 4 Oct. 26, 2021; Oct. 28, 2021; Nov. 5, 2021; 

Nov. 8, 2021; April 29, 2022; May 4, 2022; 
June 10, 2022 

RGC Account 4; Account 5 Aug. 23, 2021; Aug. 26, 2021; Aug. 31, 
2021; Sep. 1, 2021; Sep. 22, 2021; Oct. 1, 
2021; Oct. 11, 2021 

RHE Account 3; Account 4 June 24, 2021; Dec. 16, 2021 
RILY Account 10 Nov. 13, 2023 
RIVN Account 1; Account 4 Nov. 19, 2021; Nov. 22, 2021; Nov. 23, 

2021; Dec. 1, 2021; Dec. 2, 2021; Dec. 7, 
2021; Jan. 6, 2022; Feb 1, 2022 

RIVN--
211119C00160000 

Account 4 Nov. 16, 2021 

RLMD Account 5 July 27, 2021 
RMED Account 7 Dec. 9, 2022 
RNA Account 8 March 30, 2023 
RNXT Account 5 Aug. 31, 2021; Sep. 1, 2021 
RSLS Account 3; Account 7 

Account 8 
June 28, 2021; Feb. 3, 2023; April 11, 2023 

RZLT Account 5 May 27, 2021 
  

Case 1:26-cv-03203     Document 1-1     Filed 04/20/26     Page 12 of 17



ATTACHMENT A 
 

Page 13 of 17 
 

Tickers for 
Manipulated 

Securities 

Account(s) Dates of Manipulative Trading 

SATX Account 7 Dec. 5, 2022 
SAVA Account 5 July 21, 2021; Aug. 27, 2021 
SCKT Account 5 July 26, 2021 
SCLX Account 8 April 5, 2023 
SDA Account 8 May 23, 2023; May 24, 2023; May 26, 

2023; June 1, 2023; June 5, 2023; June 8, 
2023; June 12, 2023; June 15, 2023; July 
19, 2023; July 20, 2023; July 24, 2023 

SECO Account 7 Feb. 6, 2023 
SEED Account 1 

Account 5 
July 12, 2021; July 28, 2021; March 10, 
2022 

SEQL Account 9 Sep. 18, 2023 
SEV Account 1 

Account 4 
Nov. 18, 2021; Nov. 19, 2021; Nov. 22, 
2021; April 19, 2022 

SEZL Account 10 Nov. 10, 2023; Dec. 22, 2023; Dec. 28, 
2023 

SFWL Account 8 May 9, 2023 
SGMA Account 4; Account 8 Dec. 13, 2021; Dec. 27, 2021; May 4, 2023 
SGOC Account 5 July 9, 2021; July 12, 2021; July 14, 2021; 

July 16, 2021 
SHOP Account 1 April 22, 2022 
SI Account 4 Oct. 7, 2021 
SIDU Account 1 March 4, 2022 
SJ Account 5 July 15, 2021 
SKYH Account 1; Account 4 March 1, 2022; March 2, 2022; March 18, 

2022; April 13, 2022; April 25, 2022;  
May 6, 2022; May 10, 2022 

SMCI Account 8 May 26, 2023 
SMLR Account 1 

Account 7 
March 1, 2022; Feb. 6, 2023 

SNCE Account 4 Oct. 14, 2021 
SNOW Account 1 March 3, 2022 
SNPX Account 4 Sep. 30, 2021; Oct. 12, 2021; Oct. 13, 2021 
SNTG Account 3; Account 5 July 30, 2021; Aug. 24, 2021 
SOAR Account 9 Nov. 29, 2023 
SOPA Account 1; Account 4 Nov. 10, 2021; Nov. 15, 2021; Dec. 23, 

2021; Dec. 29, 2021; June 7, 2022 
SOS Account 7 Jan. 17, 2023 
SOUN Account 1 May 2, 2022; May 3, 2022; May 4, 2022 

  

Case 1:26-cv-03203     Document 1-1     Filed 04/20/26     Page 13 of 17



ATTACHMENT A 
 

Page 14 of 17 
 

Tickers for 
Manipulated 

Securities 

Account(s) Dates of Manipulative Trading 

SPPL Account 9 Sep. 15, 2023 
SPRC Account 10 Oct. 17, 2023; Oct. 20, 2023; Oct. 31, 2023 
SPXW--
211203P04530000 

Account 4 Dec. 2, 2021 

SQBG Account 5 July 2, 2021; July 7, 2021; July 12, 2021; 
July 14, 2021; July 16, 2021; July 19, 2021;  
July 22, 2021; July 27, 2021; July 28, 2021; 
Aug. 30, 2021 

SRPT Account 10 Oct. 31, 2023 
SRZN Account 5 Sep. 7, 2021 
SSNT Account 3; Account 5 June 22, 2021; June 30, 2021 
SST Account 1 April 8, 2022; April 12, 2022; April 13, 

2022; April 14, 2022 
SWAV Account 10 Nov. 7, 2023 
SWIN Account 9 Sep. 7, 2023; Sep. 8, 2023 
SWVL Account 1 April 21, 2022; April 22, 2022; April 25, 

2022; April 28, 2022 
SYM Account 1 June 22, 2022 
TBLT Account 1 May 2, 2022 
TCBP Account 7 Jan. 18, 2023 
TCJH Account 8 May 16, 2023; May 23, 2023; May 25, 2023 
TKAT Account 3; Account 5 May 26, 2021; June 2, 2021; June 9, 2021; 

June 10, 2021; June 23, 2021; July 26, 
2021; Aug. 2, 2021 

TKLF Account 4 Jan. 18, 2022 
TMC Account 4 Sep. 13, 2021; Sep. 14, 2021 
TNON Account 1 May 3, 2022 
TOP Account 1; Account 8 June 1, 2022; June 23, 2022; April 27, 

2023; May 1, 2023; May 4, 2023; May 5, 
2023; May 8, 2023 

TPST Account 5; Account 10 July 9, 2021; July 12, 2021; July 20, 2021; 
Oct. 12, 2023 

TRU Account 10 Oct. 24, 2023 
TRUP Account 8 March 23, 2023 

  

Case 1:26-cv-03203     Document 1-1     Filed 04/20/26     Page 14 of 17



ATTACHMENT A 
 

Page 15 of 17 
 

Tickers for 
Manipulated 

Securities 

Account(s) Dates of Manipulative Trading 

TSLA Account 1; Account 4 Nov. 15, 2021; Dec. 20, 2021; Jan. 6, 2022; 
Jan. 10, 2022; Jan. 13, 2022; Jan. 14, 2022; 
Jan. 18, 2022; Jan. 20, 2022; Jan. 21, 2022; 
Jan. 24, 2022; Jan. 25, 2022; Jan. 27, 2022; 
Jan. 28, 2022; Jan. 31, 2022; April 12, 
2022; April 20, 2022; April 28, 2022; April 
29, 2022; May 20, 2022; May 25, 2022 

TSLA--
220114C01040000 

Account 4 Jan. 13, 2022 

TSLA--
220204C00900000 

Account 1 Feb. 3, 2022 

TSLA--
220325C00920000 

Account 4 March 21, 2022 

TSLA--
220325C01000000 

Account 4 March 23, 2022 

TSLA--
220325C01020000 

Account 4 March 23, 2022 

TSLA--
220408C01040000 

Account 1 April 6, 2022 

TSLA--
220408C01080000 

Account 4 April 4, 2022 

TSLA--
220408P01045000 

Account 1 April 7, 2022 

TSLA--
220414C00995000 

Account 1 April 12, 2022 

TSLA--
220414C01005000 

Account 1 April 12, 2022 

TSLA--
220414C01015000 

Account 1 April 12, 2022 

TSLA--
220422C01000000 

Account 1 April 12, 2022 

TSLA--
220429C01020000 

Account 1 April 21, 2022 

TSLA--
220513C00775000 

Account 1 May 13, 2022 

TSLA--
220603C00730000 

Account 1 June 3, 2022 

TSLA--
220715C00705000 

Account 1 July 11, 2022 

TSP Account 3 June 14, 2021; June 30, 2021 
TSRI Account 1; Account 5 Sep. 9, 2021; Jan. 27, 2022 

  

Case 1:26-cv-03203     Document 1-1     Filed 04/20/26     Page 15 of 17



ATTACHMENT A 
 

Page 16 of 17 
 

Tickers for 
Manipulated 

Securities 

Account(s) Dates of Manipulative Trading 

TTOO Account 10 Oct. 17, 2023 
TYGO Account 8 May 24, 2023 
TYHT Account 4; Account 5 July 8, 2021; Sep. 7, 2021; Sep. 23, 2021 
UCAR Account 8 April 20, 2023; April 21, 2023; June 1, 

2023; June 7, 2023 
UHG Account 8 March 31, 2023 
ULBI Account 8 July 27, 2023 
UONE Account 3; Account 5 June 4, 2021; July 8, 2021 
UPST Account 1; Account 4 

Account 5 
Sep. 8, 2021; Nov. 12, 2021; May 19, 2022; 
May 20, 2022 

UPTD Account 9 Sep. 5, 2023; Sep. 6, 2023; Sep. 14, 2023; 
Sep. 18, 2023; Sep. 20, 2023; Sep. 22, 2023 

URGN Account 8 July 28, 2023 
UTME Account 3; Account 5 June 21, 2021; June 23, 2021; July 8, 2021; 

July 15, 2021 
UUU Account 1 Feb. 24, 2022 
VCIG Account 8; Account 9 May 8, 2023; Aug. 23, 2023 
VERV Account 3; Account 5 June 30, 2021; June 30, 2021 
VFS Account 9 Aug. 22, 2023; Aug. 23, 2023; Aug. 24, 

2023; Aug. 25, 2023; Aug. 28, 2023; Aug. 
31, 2023 

VIEW Account 8 July 28, 2023 
VIEWQ Account 10 Nov. 14, 2023 
VLN Account 4 Oct. 12, 2021 
VRAR Account 4; Account 5 July 13, 2021; Nov. 2, 2021; Nov. 15, 2021 
VRPX Account 3; Account 5 Aug. 17, 2021; Aug. 19, 2021; Aug. 20, 

2021; Aug. 23, 2021; Aug. 31, 2021 
VSCO Account 3; Account 5 Aug. 10, 2021; Aug. 13, 2021 
VTVT Account 9; Account 10 Nov. 29, 2023; Dec. 29, 2023 
VYGR Account 1 April 21, 2022 
VZIO Account 5 June 15, 2021 
W Account 1 Feb. 24, 2022 
WAFU Account 4; Account 5 July 28, 2021; Oct. 11, 2021; Oct. 12, 2021 
WAL Account 8 May 4, 2023 
WAVE Account 4; Account 5 July 6, 2021; July 8, 2021 
WAVS Account 8 July 14, 2023 
WBEV Account 1 April 21, 2022 

  

Case 1:26-cv-03203     Document 1-1     Filed 04/20/26     Page 16 of 17



ATTACHMENT A 
 

Page 17 of 17 
 

Tickers for 
Manipulated 

Securities 

Account(s) Dates of Manipulative Trading 

WBX Account 4 Oct. 26, 2021; Oct. 28, 2021; Nov. 3, 2021; 
Nov. 8, 2021 

WETG Account 8 June 14, 2023; June 15, 2023 
WHLR Account 9 Sep. 7, 2023 
WINT Account 8 April 17, 2023; April 18, 2023 
WISA Account 7 Jan. 30, 2023 
WISH Account 3 June 14, 2021; June 22, 2021 
WIX Account 1 Feb. 16, 2022 
WNW Account 3 June 25, 2021 
WOLF Account 8 April 27, 2023 
XELA Account 8 May 17, 2023; May 18, 2023 
XMTR Account 4; Account 5 July 19, 2021; Nov. 12, 2021 
XPOF Account 4 Oct. 15, 2021; Oct. 18, 2021 
XPON Account 7 Jan. 12, 2023 
XYF Account 4; Account 5 June 15, 2021; July 8, 2021 
YOSH Account 10 Jan. 2, 2024 
Z Account 4 Nov. 23, 2021 
ZJYL Account 8 June 12, 2023 
ZURA Account 8 March 23, 2023; March 24, 2023; March 

27, 2023; May 16, 2023 
ZY Account 3 Aug. 5, 2021 

 
 

Case 1:26-cv-03203     Document 1-1     Filed 04/20/26     Page 17 of 17