SEC v. JOSEPH MELI

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

SECURITIES AND EXCHANGE
COMMISSION,
  Plaintiff,

 v.

JOSEPH MELI,
MATTHEW HARRITON,
875 HOLDINGS, LLC,
127 HOLDINGS, LLC,
ADVANCE ENTERTAINMENT, LLC, and
ADVANCE ENTERTAINMENT II, LLC,

                                             Defendants, and

JESSICA INGBER MELI,
127 PARTNERS, LLC,
127 ICONIC HOLDINGS, LLC,
ANNA MELI,
NINETEEN TWO PRODUCTIONS, LLC,
MXCU HOLDINGS, LLC, and
MASH TRANSACTIONS, LLC,

                                             Relief Defendants.

     Civil Action No. 17-cv-632-LLS

     JURY TRIAL DEMANDED

FIRST AMENDED COMPLAINT
 Plaintiff, Securities and Exchange Commission (the “Commission” or “SEC”), alleges as
follows:
SUMMARY
1. This case involves an ongoing fraudulent scheme in which defendants Joseph
Meli (“Meli”), Matthew Harriton (“Harriton”), 875 Holdings, LLC (“875 Holdings”), 127
Holdings, LLC (“127 Holdings”), Advance Entertainment,  LLC (“Advance Entertainment”), and
Advance Entertainment II, LLC (“Advance Entertainment II”) (collectively, the “Defendants”)

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raised, and are continuing to raise, more than $97 million from 2015 to the present from at least
138 investors located in 17 states, for purported investment in ticket reselling enterprises
involving high profile events including, among others: the Broadway musical Hamilton; Adele,
Metallica, and Nine Inch Nails concerts; a concert festival known as Desert Trip, featuring artists
including The Rolling Stones, Bob Dylan, Paul McCartney, and others; and advance sales for the
upcoming Broadway play Harry Potter and the Cursed Child, currently playing in London.
From 2015 to the present, Defendants diverted at least $74 million of the more than $97 million
raised from investors to perpetuate a Ponzi scheme and to enrich themselves and certain family
members and others.
2. From at least 2015 to the present, Meli and Harriton have represented to investors
and prospective investors that they would pool investor funds to purchase large blocks of tickets
for major concerts and theatrical performances.  Meli and Harriton further represented that the
tickets then would be resold at a profit to produce high returns for the investors.  Investors
received written contracts with 875 Holdings, 127 Holdings, Advance Entertainment, and
Advance Entertainment II  (collectively, the “Four Entities”) which typically promised that
proceeds from ticket resales would be distributed first toward full repayment of principal plus a
10% annualized profit, to be paid in less than one year from investment.  In addition, investors
were typically promised 50% of any profits from the ticket resales that remained after investors
received their return of principal and 10% annualized profit.
3. Meli and Harriton represented to investors that all or substantially all of their
investment would be used to purchase tickets in bulk for resale.  Contrary to the representations
by Meli and Harriton, only a small fraction (less than 14%) of investor funds raised was used to
make payments to entities with any apparent connection to ticket sales or live event production.

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Instead, from 2015 to the present, more than $59 million of incoming funds from investors were
used to repay and provide purported investment returns to other investors, thereby perpetuating
the illusion of a profitable, ongoing investment.  This enabled Meli and Harriton to raise even
more money from investors and to fraudulently use investor money for personal benefit.
4. From 2015 to the present, i  nvestor funds totaling approximately $1.3 million were
transferred from one or more of the Four Entities to Harriton.  During this same timeframe,
investor funds totaling approximately $1.5 million were withdrawn from bank accounts in the
name of 127 Holdings and Advance Entertainment, which accounts are controlled by Meli.
Investor funds also have been used from 127 Holdings and Advance Entertainment to make
payments for what appear to be personal expenses, including, from 2015 to the present: at least
$5 million in payments for jewelry and other retail purchases, private school and camp tuition,
automobiles, private club memberships and expenses, wine, restaurants, driving services
(including limousines), travel expenses and hotels, and payments to casinos; and at least an
additional $1.8 million in payments made to architecture, design, or construction firms.  Investor
funds also have been transferred between and among the Four Entities, all of which are entities
Meli or Harriton control.  These payments were not disclosed to investors and were used for
purposes inconsistent with representations made to investors by the Defendants.
5. From 2015 to the present, investor funds also have been transferred from one or
more of the Four Entities to: Jessica Ingber Meli (Joseph Meli’s spouse) and personal credit card
accounts in the name of Jessica Ingber Meli, totaling more than $710,000; Anna Meli (Joseph
Meli’s mother), totaling at least $405,000; 127 Partners, LLC (“127 Partners”), an entity
controlled by Meli, totaling at least $307,000; 127 Iconic Holdings, LLC (“127 Iconic
Holdings”), an entity controlled by Meli, totaling at least $489,000; Nineteen Two Productions,

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LLC (“Nineteen Two Productions”), an entity controlled by Meli, totaling at least $260,000;
MXCU Holdings, LLC (“MXCU Holdings”), an entity controlled by Harriton, totaling at least
$325,000; and Mash Transactions, LLC (“Mash Transactions”), an entity controlled by Harriton,
totaling more than $70,000 (collectively, the “Relief Defendants”).  In addition, in or around
October 2015, a property was purchased in East Hampton, New York for approximately $3
million in cash in the name of Jessica Ingber Meli.  The purchase was funded by investor funds
transferred from a bank account in the name of Advance Entertainment, which account is
controlled by Joseph Meli.  The Relief Defendants have no legitimate interest in, or right to, the
funds they received, which represent proceeds of the fraudulent scheme.
6. As a result of the conduct alleged herein, the Defendants violated, and unless
restrained and enjoined will continue to violate, Section 17(a) of the Securities Act of 1933
(“Securities Act”) [15 U.S.C. § 77q(a)], and Section 10(b) of the Securities Exchange Act of
1934 (“Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 340.10b-5].
7. The Commission seeks emergency preliminary relief, including a temporary
restraining order against further violations of the federal securities laws and an emergency asset
freeze to preserve assets necessary to satisfy any eventual judgment against the Defendants.  The
Commission also requests an immediate accounting, expedited discovery, a repatriation order, an
order prohibiting the Defendants from continuing to accept or deposit additional investor funds,
and an order prohibiting the alteration or destruction of relevant documents.
8. The Commission also seeks a permanent injunction against the Defendants,
enjoining them from engaging in the transactions, acts, practices, and courses of business alleged
in this Complaint, disgorgement of all ill-gotten gains from the unlawful conduct set forth in this
Complaint, together with prejudgment interest, civil penalties pursuant to Section 20(d) of the

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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 such other relief as the Court may deem appropriate.
9. The Commission also seeks an order requiring all Relief Defendants to disgorge,
with prejudgment interest, all ill-gotten gains obtained from any of the Defendants.
10. The Commission further seeks appointment of a receiver over Defendants and
Relief Defendants pursuant to Federal Rule of Civil Procedure 66.
JURISDICTION AND VENUE
11. This Court has jurisdiction over this action pursuant to Section 22(a) of the
Securities Act [15 U.S.C. § 77v(a)] and Sections 21(d), 21(e), and 27 of the Exchange Act [15
U.S.C. §§ 78u(d), 78u(e), and 78aa].
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].  Certain of the acts,
practices, transactions and courses of business alleged in this Complaint, including
communications with investors and prospective investors, occurred within the Southern District
of New York, and were effected, directly or indirectly, by making use of means or
instrumentalities of transportation or communication in interstate commerce, or the mails.  In
addition, Meli and Harriton reside in the district.
DEFENDANTS
13. Joseph Meli, age 42, lives in New York, New York.  He and Harriton are the
direct or indirect owners of Advance Entertainment II.  Meli owns 100% of Advance
Entertainment which, in turn, owns an 80% interest in Advance Entertainment II.  Meli also
controls 127 Holdings, 127 Partners, 127 Iconic Holdings, and Nineteen Two Productions.  Meli,
with Harriton, manages 875 Holdings, which Harriton controls.

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14. Matthew Harriton, age 52, lives in New York, New York.  He and Meli are the
direct or indirect owners of Advance Entertainment II, and Harriton, with Meli, manages 875
Holdings.  Harriton owns an 80% interest (through two intermediary LLCs) in 875 Holdings.
Harriton directly owns a 20% interest in Advance Entertainment II.  Harriton also controls Mash
Transactions and MXCU Holdings.
15. 875 Holdings, LLC is a Delaware limited liability company organized in 2015
with a principal place of business in Stamford, Connecticut.  Meli and Harriton together manage
875 Holdings, which Harriton controls.  Meli and Harriton are the named signers for an 875
Holdings bank account that received investor funds and was used to make payments as part of
the ticket investment scheme.
16. 127 Holdings, LLC is a Delaware limited liability company controlled by Meli
and organized in 2009 with a principal place of business at what appears to be Meli’s residence
in New York, New York.  Meli is the sole named account signer for a 127 Holdings bank
account that received investor funds and was used to make payments as part of the ticket
investment scheme.
17. Advance Entertainment, LLC is a Delaware limited liability company controlled
by Meli and organized in 2011 with a principal place of business in New York, New York at
what appears to be Meli’s residence.  Meli is a named signer for one or more Advance
Entertainment bank accounts that received investor funds and were used to make payments as
part of the ticket investment scheme.
18. Advance Entertainment II, LLC is a Delaware limited liability company
organized in 2016 with a principal place of business in New Canaan, Connecticut.  Harriton
manages Advance Entertainment II, and Meli and Harriton directly or indirectly own Advance

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Entertainment II.  Harriton is the sole named signer for Advance Entertainment II bank accounts
that received investor funds and were used to make payments as part of the ticket investment
scheme.
RELIEF DEFENDANTS
19. Jessica Ingber Meli is the spouse of and lives at the same address as Joseph Meli
in New York, New York.  From January 2015 to January 2017, she and personal credit card
accounts in her name received more than $710,000 of investor funds from the ticket investment
scheme through transfers and payments from 127 Holdings.  Additionally, in or around October
2015, a property was purchased in East Hampton, New York for approximately $3 million in
cash in the name of Jessica Ingber Meli.  The purchase of the property was funded by investor
funds from the ticket investment scheme transferred from a bank account in the name of
Advance Entertainment.
20. Anna Meli is the mother of Joseph Meli and maintains an address in the same
building as Joseph Meli in New York, New York.  From January 2015 to January 2017, she
received at least $405,000 of investor funds from the ticket investment scheme through transfers
and payments from Advance Entertainment and 127 Holdings.
21. 127 Partners,  LLC is a Delaware limited liability company controlled by Meli and
organized in 2009 with a principal place of business at what appears to be Meli’s residence in
New York, New York.  From January 2015 to January 2017, a 127 Partners bank account
received at least $307,000 of investor funds from the ticket investment scheme through transfers
and payments from 127 Holdings.
22. 127 Iconic Holdings, LLC is a Delaware limited liability company controlled by
Meli and organized in 2013 with a principal place of business at what appears to be Meli’s

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residence in New York, New York.  From January 2015 to January 2017, a 127 Iconic Holdings
bank account received at least $489,000 of investor funds from the ticket investment scheme
through transfers and payments from 127 Holdings.
23. Nineteen Two Productions, LLC is a New York limited liability company
organized in 2015 with a principal place of business at what appears to be Joseph Meli’s
residence in New York, New York.  Joseph Meli and another individual were the named signers
for a bank account in the name of Nineteen Two Productions that is now closed.  From January
2015 to January 2017, this Nineteen Two Productions bank account received at least $260,000 of
investor funds from the ticket investment scheme through transfers and payments from Advance
Entertainment and 127 Holdings.
24. MXCU Holdings, LLC is a Delaware limited liability company managed and
controlled by Harriton and organized in 2013 with a principal place of business in New York,
New York.   Harriton is the sole named signer for a bank account in the name of MXCU
Holdings, and Harriton is identified as MXCU Holdings’ manager in the account opening
documents.  From January 2015 to January 2017, this MXCU Holdings bank account received at
least $325,000 of investor funds from the ticket investment scheme through transfers and
payments from Advance Entertainment.
25. Mash Transactions, LLC is a Delaware limited liability company controlled by
Harriton and organized in 2011 with a principal place of business in New York, New
York.  Mash Transactions indirectly owns 875 Holdings (through another intermediate
entity).  Harriton is the sole authorized signer on a bank account in the name of Mash
Transactions, and Harriton is identified as an officer, member, and 100% beneficial owner in the
account opening documents.  From January 2015 to January 2017, this Mash Transactions bank

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account received more than $70,000 of investor funds from the ticket investment scheme through
transfers and payments from 127 Holdings and 875 Holdings.
FACTS
26. From January 2015 to January 2017, Meli and Harriton offered and sold a total of
more than $97 million of interests in the Four Entities (Advance Entertainment, Advance
Entertainment II, 875 Holdings and 127 Holdings), all of which purportedly engaged in bulk
ticket purchases and resales.  Investors frequently invested in more than one entity at various
times and may not have clearly distinguished among the entities, which made similar
representations about their businesses.
875 Holdings
27. 875 Holdings was organized in or around July 2015.  The next month, 875
Holdings filed a Form D with the SEC stating that the company was making a private offering of
equities in an unspecified business with no revenue, and had sold $1,050,000 to date.  In
February 2016, 875 Holdings filed an amended Form D stating that 25 persons had invested in
the offering, with a total amount sold of $3.4 million.
28. From in or around July 2015 through January 2017, 875 Holdings received a total
of at least $7.1 million from investors.  In soliciting the investments, Meli and Harriton
represented that investor money would be pooled and used to buy a participation interest in
profits from the resale of tickets for high profile events.  Investors were further told that 875
Holdings was a diversified fund whose purpose was to purchase tickets to various shows, and
that the fund would have discretion as to which shows or events to purchase tickets for.  Funds
raised from investors into 875 Holdings were spent or transferred contrary to representations

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made to investors, including for the purpose of repaying other investors and making transfers to
Harriton and Mash Transactions, an entity controlled by Harriton.
Advance Entertainment
29.  From January 2015 to January 2017, Advance Entertainment, which was formed
in 2011, received more than $64 million from investors.  Funds raised from investors into
Advance Entertainment were spent or transferred contrary to representations made to investors,
including for the purpose of repaying other investors, withdrawals, paying for personal and legal
expenses, funding the purchase of a property in the Hamptons in the name of Jessica Ingber
Meli, and making transfers to Harriton and several Relief Defendants.
30. In December 2015, Meli signed a “Funding Agreement” on behalf of Advance
Entertainment with an investor.  In the Funding Agreement, Advance Entertainment falsely
represented that it had a signed agreement with the producer of the Broadway musical Hamilton
to purchase 35,000 tickets to the musical and that the investor’s money would be used to pay part
of the cost of obtaining the tickets.  The Funding Agreement provided that within eight months,
the investor would receive, from the proceeds of the resale of Hamilton tickets, the return of its
principal, along with “an amount sufficient to generate a 10% annualized return” on the
investment, and that the investor would also receive 50% of any further proceeds less Advance
Entertainment’s reasonable expenses incurred in reselling the tickets.  Similar representations
were made to other investors and potential investors.  Some investors were provided with a
signed “Letter Agreement” between Advance Entertainment (signed by Meli) and the producer
of Hamilton purporting to show that Advance Entertainment had an agreement to purchase
35,000 tickets to Hamilton on Broadway for a total of $7 million.  On some occasions, Harriton
provided this signed “Letter Agreement” with the producer of Hamilton to investors or

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prospective investors.  Meli and Harriton sometimes referred to the “Letter Agreement” with the
Hamilton producer as a “vault agreement.”  The representations in the Funding Agreement were
false, and the “Letter Agreement” with the Hamilton producer was fraudulent.  Neither Advance
Entertainment nor any of Meli or Harriton’s other entities had any legitimate agreement with the
Hamilton producer to purchase tickets to the musical, and no purchase of 35,000 tickets to the
musical was made with investor money.
31. In January 2017, Meli signed another “Funding Agreement” on behalf of Advance
Entertainment with an investor.  In the Funding Agreement, Advance Entertainment falsely
represented that it had entered into an agreement with the theater company associated with Harry
Potter and the Cursed Child to purchase 250,000 tickets for a total of $62.5 million to an
upcoming Broadway run of the play, and that the investor’s money would be used to pay part of
the cost of obtaining the tickets.  The Funding Agreement provided that the investor would
receive, from the proceeds of the resale of tickets to Harry Potter and the Cursed Child, the
return of its principal, followed by a pro rata share of certain profits.  Meli provided the investor
with a signed “Letter Agreement” (which he referred to as a “vault agreement”) between
Advance Entertainment and the theater company purporting to show that Advance Entertainment
had an agreement to purchase 250,000 tickets to Harry Potter and the Cursed Child on
Broadway for a total of $62.5 million.  The representations in the Funding Agreement were false,
and the “Letter Agreement” with the theater company was fraudulent.  Neither Advance
Entertainment nor any of Meli or Harriton’s other entities had any agreement with the theater
company to purchase tickets to the Harry Potter play on Broadway, and no purchase of 250,000
tickets to the play was made with investor money.

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32. In or around January 2017, Meli solicited and obtained an investment with
Advance Entertainment to be used for the purchase of block tickets to Metallica concerts.  Meli
and Advance Entertainment falsely represented that the investment would be used to purchase
tickets to an upcoming Metallica concert tour, and that the investor would receive certain profits
from the resale of the Metallica tickets.  In fact, the investment was used in a manner not
consistent with these representations, including to repay earlier investors and to transfer money
for legal expenses.
33. In or around January 2017, Meli solicited and obtained an investment with
Advance Entertainment to be used for the purchase of block tickets to Nine Inch Nails concerts.
Meli and Advance Entertainment falsely represented that the investment would be used to
purchase tickets to Nine Inch Nails concerts, and that the investor would receive certain profits
from the resale of the Nine Inch Nails tickets.  In fact, the investment was used in a manner not
consistent with these representations, including to repay an earlier investor and to transfer money
for legal expenses.
Advance Entertainment II
34. Advance Entertainment II was organized in or around February 2016. The next
month, Advance Entertainment II filed a Form D with the SEC stating that the company was
making a private offering of equities in an unspecified business with no revenue, and had made
sales totaling $10,220,000 to date.  Advance Entertainment II filed a second Form D in August
2016 for another offering of $13,000,000.
35. From February 2016 to January 2017, Advance Entertainment II received at least
$17.5 million of investor funds.  In soliciting investments for Advance Entertainment II, Meli
and Harriton each represented to investors that money invested with the company would be

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pooled to buy a participation interest in profits from the resale of tickets to high profile events,
including the Broadway musical Hamilton (which Meli and Harriton sometimes referred to as
“Event I”), Adele concerts (which Meli and Harriton sometimes referred to as “Event II”), and a
concert festival known as Desert Trip (which Meli and Harriton sometimes referred to as “Event
III”).   Investors typically received a “Profit Participation Purchase Agreement” which confirmed
that they were “acquiring a participation interest in a portion of the proceeds derived by the
Company from the re-sale of tickets it intends to acquire for a specific Event.”  The agreement
typically included a “participation schedule” stating that within nine months from the
investment, the investor would receive a 10% “preference percentage,” or return on investment,
and a “remainder percentage” of 50%, meaning 50% of any additional profits from the ticket
resales.  Funds raised from investors into Advance Entertainment II  were spent or transferred
contrary to representations made to investors, including for the purpose of repaying other
investors and making transfers to Harriton.
127 Holdings
36. 127 Holdings was organized in or around 2009.  From January 2015 to January
2017, 127 Holdings received more than $8 million of investor funds.  Funds raised from
investors into 127 Holdings were spent or transferred contrary to representations made to
investors, including for the purpose of repaying other investors, withdrawals, paying for personal
and legal expenses, and making transfers to several Relief Defendants.
37. According to an individual who invested $500,000 in 127 Holdings in or around
June 2015, and who later invested additional funds in Advance Entertainment, Meli made
substantially the same representations to the investor concerning 127 Holdings as he made
concerning Advance Entertainment.  In particular, Meli represented that an agreement was in

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place with the producer of Hamilton to purchase tickets to the musical in bulk, that the investor’s
money would be used to pay part of the cost of obtaining these tickets from the Hamilton
producer, and that the investor would receive a return on his investment from the resale of tickets
obtained from the Hamilton producer.    Those representations were false.  None of Meli or
Harriton’s entities had any legitimate agreement with the Hamilton producer to purchase tickets
to the musical in bulk, and no bulk purchase of tickets from the Hamilton producer was made
with investor money.
Defendants Use Investor Funds to Pay Obligations to Prior Investors
38. From January 2015 to January 2017, Meli and Harriton caused the Four Entities
to receive funds totaling more than $97 million from investors.  During that same period, Meli
and Harriton caused the Four Entities to spend less than 14% of that amount (approximately
$13.4 million) to make payments to third parties that appear to have any connection with ticket
sales or live event production.
39. The largest category of payments the Four Entities made was to individuals and
entities that appear to have made earlier investments in the Four Entities, providing purported
returns on their investments.  From January 2015 to January 2017, the Four Entities received less
than $6.5 million from third parties with any apparent connection to the ticket sales or live event
industries, yet they paid out over $59 million to investors.  A significant portion of these
payments to earlier investors came directly from the funds of later investors.
40. Defendants did not pool the more than $97 million received from investors to buy
bulk tickets to high profile events for resale at a profit to be distributed to investors.  Instead,
Defendants operated a Ponzi scheme, making payments to prior investors from new investor
funds.  Defendants did not tell investors that, contrary to their representations and contrary to the

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terms of the written agreements with investors signed by Meli and Harriton, a significant portion
of the invested funds would be used for purposes other than purchasing tickets for resale.
Investor A
41. Between January and August 2016, Investor A invested a total $1.85 million with
Meli and Harriton; specifically, he made separate investments in 875 Holdings, Advance
Entertainment and Advance Entertainment II.  Investor A first met Meli and Harriton in
December 2015 or January 2016.  Investor A met both Meli and Harriton in person, and he also
spoke with each of them on the phone.  Investor A learned from Meli and Harriton that they were
in the business of purchasing tickets in bulk and reselling them on the secondary market.  Meli
and Harriton represented to Investor A that his money would be pooled with other investors’
funds and used solely for the purchases of tickets associated with events or shows.
42. Between January and August 2016, Investor A invested $1.85 million with Meli
and Harriton in four tranches.  First, on or about January 11, 2016, Investor A invested $500,000
into 875 Holdings.  Meli and Harriton told Investor A that 875 Holdings was a diversified fund
whose purpose was to purchase tickets for various shows, and that 875 Holdings would have
discretion as to which shows or events to purchase tickets for.  Next, in January and February
2016, Investor A invested a total of $350,000 (consisting of $250,000 on or about January 22,
2016, and $100,000 on or about February 12, 2016) into Advance Entertainment to be used for
an investment into a ticket purchase for the Broadway musical Hamilton.  Third, on or about
March 3, 2016, Investor A invested $700,000 into Advance Entertainment II.  His understanding
based on communications with Meli and Harriton was that $200,000 of that investment would be
used to fund further purchases of Hamilton tickets, and that $500,000 of that investment would
be used to fund tickets to Adele concerts.   Finally, on or about August 23, 2016, Investor A

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invested an additional $300,000 into Advance Entertainment II to be used to fund the bulk
purchase and resale tickets to Desert Trip, a concert festival featuring The Rolling Stones, Bob
Dylan, Paul McCartney and other high profile musicians.
43. At or around the times of each of his investments, Investor A signed investment
contracts with the entities into which he was investing his funds.
44. Investor A’s funds were deposited into several different bank accounts controlled
by one or more of the Defendants and then spent or transferred contrary to the representations
made to him by Meli and Harriton, and not consistent with the purported investment into event
ticket purchases and resales.  Payments and transfers included, by way of example:
a. Investor A’s initial investment of $500,000 into 875 Holdings was used, in whole
or in part, to fund a payment to another investor, rather than for ticket purchases
and resales.  On or about January 11, 2016, the $500,000 investment was
deposited into an 875 Holdings account at Signature Bank ending in ‘1199.  On or
about January 12, 2016, all, or at least a significant portion of this investment,
along with other available account funds totaling $650,000, was transferred to an
Advance Entertainment account at Merrill Lynch ending in ‘3098.  On or about
January 14, 2016, Advance Entertainment used $1.2 million from the Merrill
Lynch ‘3098 account to pay another investor.  This payment was funded in part
by the transfer from 875 Holdings, including Investor A’s funds.
b. On or about January 22, 2016, Investor A’s $250,000 investment into Advance
Entertainment was deposited into an Advance Entertainment account at Merrill
Lynch ending in ‘3098.  On or about January 26, 2016, all, or at least a significant
portion of this investment, along with other available account funds totaling

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$600,000, was used to pay another investor out of the Advance Entertainment
account.
c. On or about March 3, 2016, Investor A’s $700,000 investment was deposited into
an Advance Entertainment II account at Signature Bank ending in ‘2528.  On the
same day, $500,000 was transferred from the Advance Entertainment II account
to Advance Entertainment, and another $200,000 was transferred from the
Advance Entertainment II account to Harriton’s father.
Investor B
45.   On or about December 16, 2015, Investor B signed a Funding Agreement to
invest $1.25 million into Advance Entertainment to fund a portion of a pooled investment to
purchase and resell 35,000 tickets to the Hamilton musical.  The F unding Agreement referenced
an underlying letter agreement dated in October 2015 between Advance Entertainment and the
Hamilton producer for the purchase of 35,000 tickets.  In reality, neither Advance Entertainment
nor any of Meli or Harriton’s other entities had any legitimate agreement with the Hamilton
producer to purchase tickets to the musical, and no purchase of 35,000 tickets to the musical was
made with investor money.  Advance Entertainment received Investor B’s $1.25 million on or
about December 28, 2015, deposited in Advance Entertainment’s Merrill Lynch account ending
in ‘3098.  After the deposit of this $1.25 million of investor funds, the daily balance of the
Advance Entertainment account was approximately $1.94 million.  The following day, Advance
Entertainment disbursed $1.5 million from this account to a third party who has no involvement
in ticket sales or live event production, for Hamilton or any other event.
Investor C
46. Between approximately June and October 2015, another individual and his

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affiliated business (collectively, “Investor C”) invested $6 million into Advance Entertainment
and 127 Holdings.  Similar to Investor B, all or a significant portion of Investor C’s funds were
invested for the bulk purchase of Hamilton tickets based on false representations from Meli, who
claimed that an agreement was in place with the producer of Hamilton to purchase $7 million
worth of tickets for resale.  Investor C’s funds were deposited into company bank accounts
controlled by Meli and then spent or transferred contrary to representations made to Investor C,
including to fund the purchase of a property in East Hampton, New York in the name of Jessica
Ingber Meli.
Investor D
47. On or about January 12, 2017, Investor D invested $2 million into Advance
Entertainment for the purchase of block tickets to Metallica concerts.  Meli and Advance
Entertainment falsely represented that the investment would be used to purchase tickets to an
upcoming Metallica concert tour, and that Investor D would receive certain profits from the
resale of the Metallica tickets.   In fact, the investment was used in a manner not consistent with
these representations.  By January 26, 2017, all or the vast majority of Investor D’s $2 million
investment had been used for purposes inconsistent with Meli and Advance Entertainment’s
representations, including to repay earlier investors and to pay for legal expenses.
Investor E
48. In January 2017, Investor E invested a total of $7.86 million into Advance
Entertainment (paid through five payments to an Advance Entertainment account at Merrill
Lynch ending in ‘3098 from on or about January 18, 2017 to on or about January 24, 2017).
Investor E entered into a Funding Agreement with Advance Entertainment, signed by Meli,
which falsely represented that Advance Entertainment had entered into an agreement with the

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theater company associated with Harry Potter and the Cursed Child to purchase 250,000 tickets
for a total of $62.5 million to an upcoming Broadway run of the play, and that the investor’s
money would be used to pay part of the cost of obtaining the tickets, with the principal and
certain profits from the ticket sales to be returned to the investor.  Meli provided Investor E with
a “Letter Agreement” (which he referred to as a “vault agreement”) between Advance
Entertainment and the theater company purporting to show that Advance Entertainment had
secured an agreement to purchase 250,000 tickets.  The representations in the Funding
Agreement were false, and the “Letter Agreement” that Meli provided to the investor was
fraudulent.  Advance Entertainment did not have any agreement with the theater company to
purchase tickets to the Harry Potter play, and no purchase of 250,000 tickets was made with
investor money.  Instead, by January 26, 2017, just two days after Investor E’s last payment was
sent to Advance Entertainment, all or the vast majority of Investor E’s $7.86 million investment
had been used for purposes inconsistent with Meli and Advance Entertainment’s representations,
including to repay earlier investors and to pay for legal expenses.
Investor F
49. On or about January 25, 2017, Investor F invested $500,000 into Advance
Entertainment for the purchase of block tickets to Nine Inch Nails concerts.  Meli and Advance
Entertainment falsely represented that the investment would be used to purchase tickets to Nine
Inch Nails concerts, and that Investor F would receive certain profits from the resale of the Nine
Inch Nails tickets.  In fact, the investment was used in a manner not consistent with these
representations.  On or about January 26, 2017, one day after Investor F’s investment, all or the
vast majority of the $500,000 investment was used for purposes inconsistent with Meli and
Advance Entertainment’s representations, including to repay Investor B and for legal expenses.

20

50. On or about January 26, 2017, Investor B received a wire transfer of $1,250,000
as a purported return of principal and/or a return on an earlier investment.  The funds for this
transfer appear to have come from deposits during January 2017 by other investors, including
Investors D, E, and F.
Defendants Use Investor Funds for Other Undisclosed Purposes
51. In addition to using new investor funds to make payments owed to existing
investors, from January 2015 to January 2017, at least $5 million of investor funds was used
from 127 Holdings and Advance Entertainment to pay for jewelry and other retail purchases,
private school and camp tuition, automobiles, private club memberships and expenses, wine,
restaurants, driving services (including limousines), travel expenses and hotels, and payments to
casinos; and at least an additional $1.8 million in payments were made to architecture, design, or
construction firms.  These payments were not disclosed to investors and were used for purposes
inconsistent with representations made to investors by the Defendants.
52. From January 2015 to January 2017, investor funds totaling approximately $1.3
million were transferred from one or more of the Four Entities to Harriton.  These payments
were not disclosed to investors a nd were used for purposes inconsistent with representations
made to investors by the Defendants.
53. From January 2015 to January 2017, an additional approximately $1.5 million of
investor funds were withdrawn from bank accounts in the name of 127 Holdings and Advance
Entertainment, which accounts are controlled by Meli.  These withdrawals were not disclosed to
investors and were used for purposes inconsistent with representations made to investors by the
Defendants.

21

54. On or about January 26, 2017, investor funds totaling $685,000 were transferred
from bank accounts in the name of 127 Holdings and Advance Entertainment, which accounts
are both controlled by Meli, to pay for legal services.  The funds for these payments appear to
have come from deposits earlier in January 2017 by investors, including Investors D, E, and F.
These payments were not disclosed to investors and were used for purposes inconsistent with
representations made to investors by the Defendants.
55. As a supposed benefit of investing in their ticket resale enterprise, Meli and
Harriton offered certain investors complimentary, premium tickets for their personal use to live
performances, including the Hamilton musical and Adele concerts.  On multiple occasions, after
receiving a request from an investor for tickets for personal use to a particular performance and
date, Harriton used investor funds from one or more of the Four Entities’ bank accounts to
purchase several premium tickets on the secondary market, often paying in excess of $1,000 per
ticket, well above face value, and sometimes paying significantly more than $1,000 per ticket.
Harriton personally placed these ticket orders and arranged for payment of the tickets from
investor funds.  The tickets were then provided to the requesting investor at no cost to the
investor.  This supposed benefit was offered at least in part for the purpose of duping investors
into believing that Meli and Harriton were actually engaged in a large-scale ticket reselling
enterprise.  The use of funds from certain investors to purchase tickets for other investors’
personal use was not disclosed and was inconsistent with representations made to investors by
the Defendants.
Meli’s Recorded Statements to a Cooperating Witness
56. In or around December 2016, an individual agreed to cooperate with law
enforcement authorities, including the Federal Bureau of Investigation, as a cooperating witness

22

in an undercover criminal investigation.  On multiple instances in December 2016 and January
2017, the cooperating witness (the “CW”) consensually recorded conversations with Meli,
unbeknownst to Meli.  In one such recorded conversation in December 2016, Meli stated to the
CW, among other things: “All I’ve been doing all along is the shell game.  You know how it
works, right?  You take money from one guy to pay off the other guy.”  In a separate recorded
conversation in December 2016, referring to the source of funds used to repay a particular
investor, Meli stated to the CW: “Everything is fungible.  I’ve been moving things around and
playing the shell game to keep that prick at bay by giving him little payments.  But I’ve been
taking it from other people.”  Meli also stated to the CW in a December 2016 recorded
conversation: “The Advance Entertainment account might as well be my personal account.”
Relief Defendants
57. From January 2015 to January 2017, relief defendant Jessica Ingber Meli or her
personal credit card accounts received payments totaling more than $710,000 from 127
Holdings.  Additionally, in or around October 2015, a property was purchased in the name of
Jessica Ingber Meli in East Hampton, New York for approximately $3 million in cash funded by
investor funds invested in Advance Entertainment.  There is no indication that Jessica Ingber
Meli provided services in exchange for these payments to her or her credit card accounts, or for
the funds used to purchase the East Hampton property in her name.  These payments were not
disclosed to investors and were used for purposes inconsistent with representations made to
investors by the Defendants.  Jessica Ingber Meli has no legitimate interest in, or right to, the
funds she and her personal credit card accounts received or which were used to purchase a
property in her name and which funds represented proceeds of the fraudulent scheme.

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58. From January 2015 to January 2017, relief defendant Anna Meli received
payments totaling at least $405,000 from 127 Holdings and Advance Entertainment.  There is no
indication that Anna Meli provided services in exchange for these payments to her.  These
payments were not disclosed to investors and were used for purposes inconsistent with
representations made to investors by the Defendants.  Anna Meli has no legitimate interest in, or
right to, the funds she received and which funds represented proceeds of the fraudulent scheme.
59. From January 2015 to January 2017, relief defendant 127 Partners, an entity
controlled by Meli, received payments totaling at least $307,000 from 127 Holdings.  There is no
indication that 127 Partners provided services in exchange for these payments.  The payments to
it were not disclosed to investors and were used for purposes inconsistent with representations
made to investors by the Defendants.  127 Partners has no legitimate interest in, or right to, the
funds it received and which funds represented proceeds of the fraudulent scheme.
60. From January 2015 to January 2017, relief defendant 127 Iconic Holdings, an
entity controlled by Meli, received payments totaling at least $489,000 from 127 Holdings.
There is no indication that 127 Iconic Holdings provided services in exchange for these
payments.  The payments to it were not disclosed to investors and were used for purposes
inconsistent with representations made to investors by the Defendants.  127 Iconic Holdings has
no legitimate interest in, or right to, the funds it received and which funds represented proceeds
of the fraudulent scheme.
61. From January 2015 to January 2017, relief defendant Nineteen Two Productions,
an entity controlled by Meli, received payments totaling at least $260,000 from Advance
Entertainment and 127 Holdings.  There is no indication that Nineteen Two Productions
provided services in exchange for these payments.  The payments to it were not disclosed to

24

investors and were used for purposes inconsistent with representations made to investors by the
Defendants.  Nineteen Two Productions has no legitimate interest in, or right to, the funds it
received and which funds represented proceeds of the fraudulent scheme.
62. From January 2015 to January 2017, relief defendant MXCU Holdings, an entity
controlled by Harriton, received payments totaling at least $325,000 from Advance
Entertainment.  There is no indication that MXCU Holdings provided services in exchange for
these payments.  The payments to it were not disclosed to investors and were used for purposes
inconsistent with representations made to investors by the Defendants.  MXCU Holdings has no
legitimate interest in, or right to, the funds it received and which funds represented proceeds of
the fraudulent scheme.
63. From January 2015 to January 2017, relief defendant Mash Transactions, an
entity controlled by Harriton, received payments totaling more than $70,000 from 127 Holdings
and 875 Holdings.  There is no indication that Mash Transactions provided services in exchange
for these payments.  The payments to it were not disclosed to investors and were used for
purposes inconsistent with representations made to investors by the Defendants.  Mash
Transactions has no legitimate interest in, or right to, the funds it received and which funds
represented proceeds of the fraudulent scheme.
FIRST CLAIM FOR RELIEF
FRAUD IN THE OFFER OR SALE OF SECURITIES
(Violations of Section 17(a)(1), (2) and (3) of the Securities Act)

64. Paragraphs 1 through 63 are re-alleged and incorporated by reference.
65. By reason of the conduct described above, defendants Joseph Meli, Matthew
Harriton, 875 Holdings, LLC, 127 Holdings, LLC, Advance Entertainment, LLC, and Advance
Entertainment II, LLC, in connection with the offer or sale of securities, by the use of the means

25

or instrumentalities of interstate commerce or of the mails, directly or indirectly, acting with the
requisite degree of knowledge or state of mind (i) employed devices, schemes, or artifices to
defraud; (ii) obtained money or property by means of untrue statements of a material fact or
omitted to state a material fact necessary in order to make the statements made, in the light of the
circumstances under which they were made, not misleading; and (iii) engaged in transactions,
practices, or courses of business which operated or would operate as a fraud or deceit upon any
persons, including purchasers or sellers of the securities.
66. By reason of the conduct described above, Defendants violated Securities Act
Section 17(a) [15 U.S.C. § 77q(a)].
SECOND CLAIM FOR RELIEF
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES
(Violations of Section 10(b) of the Exchange Act and Rule 10b-5(a), (b) and (c) thereunder)

67. Paragraphs 1 through 63 are re-alleged and incorporated by reference.
68. By reason of the conduct described above, defendants Joseph Meli, Matthew
Harriton, 875 Holdings, LLC, 127 Holdings, LLC, Advance Entertainment, LLC, and Advance
Entertainment II, LLC, directly or indirectly, in connection with the purchase or sale of
securities, by the use of the means or instrumentalities of interstate commerce or of the mails, or
of any facility of any national securities exchange, intentionally, knowingly or recklessly, (i)
employed devices, schemes, or artifices to defraud; (ii) made untrue statements of a material fact
or omitted to state a material fact necessary in order to make the statements made, in the light of
the circumstances under which they were made, not misleading; and (iii) engaged in acts,
practices, or courses of business which operated or would operate as a fraud or deceit upon any
persons, including purchasers or sellers of the securities.

26

69. By reason of the conduct described above, Defendants violated Exchange Act
Section 10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5 [17 C.F.R. § 240.10b-5] thereunder.
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that this Court:
 A. Temporarily, preliminarily, and permanently restrain and enjoin Joseph Meli,
Matthew Harriton, 875 Holdings, LLC, 127 Holdings, LLC, Advance Entertainment, LLC, and
Advance Entertainment II, LLC, their officers, agents, servants, employees and attorneys, and
those persons in active concert or participation with them who receive actual notice of the
injunction by personal service or otherwise, and each of them, from violating Section 17(a) of
the Securities Act [15 U.S.C. § 77q(a)], Section 10(b) of the Exchange Act [15 U.S.C. 78j(b)],
and Rule 10b-5 thereunder [17 C.F.R. 240.10b-5];
 B. Enter a temporary restraining order, preliminary injunction, order freezing assets,
order requiring an accounting of assets and liabilities, order requiring repatriation of assets, order
prohibiting the accepting or depositing of additional investor funds, order allowing expedited
discovery, order prohibiting the alteration or destruction of relevant documents, and order for
other equitable relief in the form submitted with the Commission’s motion for such relief, as to
Joseph Meli, Matthew Harriton, 875 Holdings, LLC, 127 Holdings, LLC, Advance
Entertainment, LLC, and Advance Entertainment II, LLC;
 C. Order Joseph Meli, Matthew Harriton, 875 Holdings, LLC, 127 Holdings, LLC,
Advance Entertainment, LLC, and Advance Entertainment II, LLC,  to disgorge, with
prejudgment interest, all ill-gotten gains obtained by reason of the unlawful conduct alleged in
this Complaint;

27

 D. Order Relief Defendant Jessica Ingber Meli to disgorge, with prejudgment
interest, all ill-gotten gains obtained by her from any of the Defendants including, but not limited
to, payments to her, her personal credit card accounts, and funds used to purchase a property in
her name totaling more than $3,710,000, which were transferred from 127 Holdings and
Advance Entertainment;
 E. Order Relief Defendant Anna Meli to disgorge, with prejudgment interest, all ill-
gotten gains obtained by her from any of the Defendants including, but not limited to, payments
to her totaling at least $405,000 from 127 Holdings and Advance Entertainment;
 F. Order Relief Defendant 127 Partners, LLC to disgorge, with prejudgment interest,
all ill-gotten gains obtained by it from any of the Defendants including, but not limited to,
payments to it totaling at least $307,000 from 127 Holdings;
 G. Order Relief Defendant 127 Iconic Holdings, LLC to disgorge, with prejudgment
interest, all ill-gotten gains obtained by it from any of the Defendants including, but not limited
to, payments to it totaling at least $489,000 from 127 Holdings;
 H. Order Relief Defendant Nineteen Two Productions, LLC to disgorge, with
prejudgment interest, all ill-gotten gains obtained by it from any of the Defendants including, but
not limited to, payments to it totaling at least $260,000 from Advance Entertainment and 127
Holdings;
 I. Order Relief Defendant MXCU Holdings, LLC to disgorge, with prejudgment
interest, all ill-gotten gains obtained by it from any of the Defendants including, but not limited
to, payments to it totaling at least $325,000 from Advance Entertainment;

28

 J. Order Relief Defendant Mash Transactions, LLC to disgorge, with prejudgment
interest, all ill-gotten gains obtained by it from any of the Defendants including, but not limited
to, payments to it totaling more than $70,000 from 127 Holdings and 875 Holdings;
 K. Order Joseph Meli, Matthew Harriton, 875 Holdings, LLC, 127 Holdings, LLC,
Advance Entertainment, LLC, and Advance Entertainment II, LLC, to pay civil monetary
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)];
 L. Appoint a receiver over Defendants and Relief Defendants pursuant to Federal
Rule of Civil Procedure 66;
M. Retain jurisdiction over this action to implement and carry out the terms of all
orders and decrees that may be entered; and
N. Grant such other and further relief as this Court may deem just and proper.
JURY DEMAND
The Commission hereby demands a trial by jury on all claims so triable.
Dated:  March 7, 2017    On behalf of the Commission,
 Boston, MA

//s// Dahlia Rin
      Alicia M. Reed (NY Bar # 4913596)
Dahlia Rin* (MA Bar # 674137)
Rebecca Israel** (NY Bar # 4783304)
Martin F. Healey* (MA Bar # 227550)
U.S. Securities and Exchange Commission
Boston Regional Office
33 Arch Street, 24th Floor
Boston, MA  02110
(617) 573-8807 (Rin)
[email protected]

*Admitted Pro Hac Vice
**Not admitted in the S.D.N.Y.

29

CERTIFICATE OF SERVICE
 I certify that on March 7, 2017, I caused a copy of the foregoing document to be filed
through the ECF system and, accordingly, the document will be sent electronically to all
registered participants as identified on the Notice of Electronic Filing (“NEF”).
//s// Dahlia Rin
Dahlia Rin

1 
 

 
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF NEW YORK 
 

 
SECURITIES AND EXCHANGE 
COMMISSION, 

  Plaintiff, 
 

 v. 
 

JOSEPH MELI, 
MATTHEW HARRITON, 
875 HOLDINGS, LLC, 
127 HOLDINGS, LLC, 
ADVANCE ENTERTAINMENT, LLC, and  
ADVANCE ENTERTAINMENT II, LLC, 
   
                                             Defendants, and 
 
JESSICA INGBER MELI,  
127 PARTNERS, LLC, 
127 ICONIC HOLDINGS, LLC, 
ANNA MELI, 
NINETEEN TWO PRODUCTIONS, LLC, 
MXCU HOLDINGS, LLC, and 
MASH TRANSACTIONS, LLC, 
 
                                             Relief Defendants. 

 

 
 
 
 
 

 
     Civil Action No. 17-cv-632-LLS 
 
 
 
     JURY TRIAL DEMANDED 

 
FIRST AMENDED COMPLAINT 

 Plaintiff, Securities and Exchange Commission (the “Commission” or “SEC”), alleges as 

follows: 

SUMMARY 

1. This case involves an ongoing fraudulent scheme in which defendants Joseph 

Meli (“Meli”), Matthew Harriton (“Harriton”), 875 Holdings, LLC (“875 Holdings”), 127 

Holdings, LLC (“127 Holdings”), Advance Entertainment, LLC (“Advance Entertainment”), and 

Advance Entertainment II, LLC (“Advance Entertainment II”) (collectively, the “Defendants”) 

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raised, and are continuing to raise, more than $97 million from 2015 to the present from at least 

138 investors located in 17 states, for purported investment in ticket reselling enterprises 

involving high profile events including, among others: the Broadway musical Hamilton; Adele, 

Metallica, and Nine Inch Nails concerts; a concert festival known as Desert Trip, featuring artists 

including The Rolling Stones, Bob Dylan, Paul McCartney, and others; and advance sales for the 

upcoming Broadway play Harry Potter and the Cursed Child, currently playing in London.  

From 2015 to the present, Defendants diverted at least $74 million of the more than $97 million 

raised from investors to perpetuate a Ponzi scheme and to enrich themselves and certain family 

members and others. 

2. From at least 2015 to the present, Meli and Harriton have represented to investors 

and prospective investors that they would pool investor funds to purchase large blocks of tickets 

for major concerts and theatrical performances.  Meli and Harriton further represented that the 

tickets then would be resold at a profit to produce high returns for the investors.  Investors 

received written contracts with 875 Holdings, 127 Holdings, Advance Entertainment, and 

Advance Entertainment II (collectively, the “Four Entities”) which typically promised that 

proceeds from ticket resales would be distributed first toward full repayment of principal plus a 

10% annualized profit, to be paid in less than one year from investment.  In addition, investors 

were typically promised 50% of any profits from the ticket resales that remained after investors 

received their return of principal and 10% annualized profit. 

3. Meli and Harriton represented to investors that all or substantially all of their 

investment would be used to purchase tickets in bulk for resale.  Contrary to the representations 

by Meli and Harriton, only a small fraction (less than 14%) of investor funds raised was used to 

make payments to entities with any apparent connection to ticket sales or live event production.  

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Instead, from 2015 to the present, more than $59 million of incoming funds from investors were 

used to repay and provide purported investment returns to other investors, thereby perpetuating 

the illusion of a profitable, ongoing investment.  This enabled Meli and Harriton to raise even 

more money from investors and to fraudulently use investor money for personal benefit.  

4. From 2015 to the present, investor funds totaling approximately $1.3 million were 

transferred from one or more of the Four Entities to Harriton.  During this same timeframe, 

investor funds totaling approximately $1.5 million were withdrawn from bank accounts in the 

name of 127 Holdings and Advance Entertainment, which accounts are controlled by Meli.  

Investor funds also have been used from 127 Holdings and Advance Entertainment to make 

payments for what appear to be personal expenses, including, from 2015 to the present: at least 

$5 million in payments for jewelry and other retail purchases, private school and camp tuition, 

automobiles, private club memberships and expenses, wine, restaurants, driving services 

(including limousines), travel expenses and hotels, and payments to casinos; and at least an 

additional $1.8 million in payments made to architecture, design, or construction firms.  Investor 

funds also have been transferred between and among the Four Entities, all of which are entities 

Meli or Harriton control.  These payments were not disclosed to investors and were used for 

purposes inconsistent with representations made to investors by the Defendants. 

5. From 2015 to the present, investor funds also have been transferred from one or 

more of the Four Entities to: Jessica Ingber Meli (Joseph Meli’s spouse) and personal credit card 

accounts in the name of Jessica Ingber Meli, totaling more than $710,000; Anna Meli (Joseph 

Meli’s mother), totaling at least $405,000; 127 Partners, LLC (“127 Partners”), an entity 

controlled by Meli, totaling at least $307,000; 127 Iconic Holdings, LLC (“127 Iconic 

Holdings”), an entity controlled by Meli, totaling at least $489,000; Nineteen Two Productions, 

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LLC (“Nineteen Two Productions”), an entity controlled by Meli, totaling at least $260,000; 

MXCU Holdings, LLC (“MXCU Holdings”), an entity controlled by Harriton, totaling at least 

$325,000; and Mash Transactions, LLC (“Mash Transactions”), an entity controlled by Harriton, 

totaling more than $70,000 (collectively, the “Relief Defendants”).  In addition, in or around 

October 2015, a property was purchased in East Hampton, New York for approximately $3 

million in cash in the name of Jessica Ingber Meli.  The purchase was funded by investor funds 

transferred from a bank account in the name of Advance Entertainment, which account is 

controlled by Joseph Meli.  The Relief Defendants have no legitimate interest in, or right to, the 

funds they received, which represent proceeds of the fraudulent scheme. 

6. As a result of the conduct alleged herein, the Defendants violated, and unless 

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

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

1934 (“Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 340.10b-5].   

7. The Commission seeks emergency preliminary relief, including a temporary 

restraining order against further violations of the federal securities laws and an emergency asset 

freeze to preserve assets necessary to satisfy any eventual judgment against the Defendants.  The 

Commission also requests an immediate accounting, expedited discovery, a repatriation order, an 

order prohibiting the Defendants from continuing to accept or deposit additional investor funds, 

and an order prohibiting the alteration or destruction of relevant documents. 

8. The Commission also seeks a permanent injunction against the Defendants, 

enjoining them from engaging in the transactions, acts, practices, and courses of business alleged 

in this Complaint, disgorgement of all ill-gotten gains from the unlawful conduct set forth in this 

Complaint, together with prejudgment interest, civil penalties pursuant to Section 20(d) of the 

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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 such other relief as the Court may deem appropriate. 

9. The Commission also seeks an order requiring all Relief Defendants to disgorge, 

with prejudgment interest, all ill-gotten gains obtained from any of the Defendants. 

10. The Commission further seeks appointment of a receiver over Defendants and 

Relief Defendants pursuant to Federal Rule of Civil Procedure 66. 

JURISDICTION AND VENUE 

11. This Court has jurisdiction over this action pursuant to Section 22(a) of the 

Securities Act [15 U.S.C. § 77v(a)] and Sections 21(d), 21(e), and 27 of the Exchange Act [15 

U.S.C. §§ 78u(d), 78u(e), and 78aa]. 

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].  Certain of the acts, 

practices, transactions and courses of business alleged in this Complaint, including 

communications with investors and prospective investors, occurred within the Southern District 

of New York, and were effected, directly or indirectly, by making use of means or 

instrumentalities of transportation or communication in interstate commerce, or the mails.  In 

addition, Meli and Harriton reside in the district. 

DEFENDANTS 

13. Joseph Meli, age 42, lives in New York, New York.  He and Harriton are the 

direct or indirect owners of Advance Entertainment II.  Meli owns 100% of Advance 

Entertainment which, in turn, owns an 80% interest in Advance Entertainment II.  Meli also 

controls 127 Holdings, 127 Partners, 127 Iconic Holdings, and Nineteen Two Productions.  Meli, 

with Harriton, manages 875 Holdings, which Harriton controls.   

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14. Matthew Harriton, age 52, lives in New York, New York.  He and Meli are the 

direct or indirect owners of Advance Entertainment II, and Harriton, with Meli, manages 875 

Holdings.  Harriton owns an 80% interest (through two intermediary LLCs) in 875 Holdings.  

Harriton directly owns a 20% interest in Advance Entertainment II.  Harriton also controls Mash 

Transactions and MXCU Holdings. 

15. 875 Holdings, LLC is a Delaware limited liability company organized in 2015 

with a principal place of business in Stamford, Connecticut.  Meli and Harriton together manage 

875 Holdings, which Harriton controls.  Meli and Harriton are the named signers for an 875 

Holdings bank account that received investor funds and was used to make payments as part of 

the ticket investment scheme. 

16. 127 Holdings, LLC is a Delaware limited liability company controlled by Meli 

and organized in 2009 with a principal place of business at what appears to be Meli’s residence 

in New York, New York.  Meli is the sole named account signer for a 127 Holdings bank 

account that received investor funds and was used to make payments as part of the ticket 

investment scheme. 

17. Advance Entertainment, LLC is a Delaware limited liability company controlled 

by Meli and organized in 2011 with a principal place of business in New York, New York at 

what appears to be Meli’s residence.  Meli is a named signer for one or more Advance 

Entertainment bank accounts that received investor funds and were used to make payments as 

part of the ticket investment scheme. 

18. Advance Entertainment II, LLC is a Delaware limited liability company 

organized in 2016 with a principal place of business in New Canaan, Connecticut.  Harriton 

manages Advance Entertainment II, and Meli and Harriton directly or indirectly own Advance 

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7 
 

Entertainment II.  Harriton is the sole named signer for Advance Entertainment II bank accounts 

that received investor funds and were used to make payments as part of the ticket investment 

scheme. 

RELIEF DEFENDANTS 

19. Jessica Ingber Meli is the spouse of and lives at the same address as Joseph Meli 

in New York, New York.  From January 2015 to January 2017, she and personal credit card 

accounts in her name received more than $710,000 of investor funds from the ticket investment 

scheme through transfers and payments from 127 Holdings.  Additionally, in or around October 

2015, a property was purchased in East Hampton, New York for approximately $3 million in 

cash in the name of Jessica Ingber Meli.  The purchase of the property was funded by investor 

funds from the ticket investment scheme transferred from a bank account in the name of 

Advance Entertainment. 

20. Anna Meli is the mother of Joseph Meli and maintains an address in the same 

building as Joseph Meli in New York, New York.  From January 2015 to January 2017, she 

received at least $405,000 of investor funds from the ticket investment scheme through transfers 

and payments from Advance Entertainment and 127 Holdings. 

21. 127 Partners, LLC is a Delaware limited liability company controlled by Meli and 

organized in 2009 with a principal place of business at what appears to be Meli’s residence in 

New York, New York.  From January 2015 to January 2017, a 127 Partners bank account 

received at least $307,000 of investor funds from the ticket investment scheme through transfers 

and payments from 127 Holdings. 

22. 127 Iconic Holdings, LLC is a Delaware limited liability company controlled by 

Meli and organized in 2013 with a principal place of business at what appears to be Meli’s 

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residence in New York, New York.  From January 2015 to January 2017, a 127 Iconic Holdings 

bank account received at least $489,000 of investor funds from the ticket investment scheme 

through transfers and payments from 127 Holdings. 

23. Nineteen Two Productions, LLC is a New York limited liability company 

organized in 2015 with a principal place of business at what appears to be Joseph Meli’s 

residence in New York, New York.  Joseph Meli and another individual were the named signers 

for a bank account in the name of Nineteen Two Productions that is now closed.  From January 

2015 to January 2017, this Nineteen Two Productions bank account received at least $260,000 of 

investor funds from the ticket investment scheme through transfers and payments from Advance 

Entertainment and 127 Holdings. 

24. MXCU Holdings, LLC is a Delaware limited liability company managed and 

controlled by Harriton and organized in 2013 with a principal place of business in New York, 

New York.  Harriton is the sole named signer for a bank account in the name of MXCU 

Holdings, and Harriton is identified as MXCU Holdings’ manager in the account opening 

documents.  From January 2015 to January 2017, this MXCU Holdings bank account received at 

least $325,000 of investor funds from the ticket investment scheme through transfers and 

payments from Advance Entertainment. 

25. Mash Transactions, LLC is a Delaware limited liability company controlled by 

Harriton and organized in 2011 with a principal place of business in New York, New 

York.  Mash Transactions indirectly owns 875 Holdings (through another intermediate 

entity).  Harriton is the sole authorized signer on a bank account in the name of Mash 

Transactions, and Harriton is identified as an officer, member, and 100% beneficial owner in the 

account opening documents.  From January 2015 to January 2017, this Mash Transactions bank 

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account received more than $70,000 of investor funds from the ticket investment scheme through 

transfers and payments from 127 Holdings and 875 Holdings. 

FACTS 

26. From January 2015 to January 2017, Meli and Harriton offered and sold a total of 

more than $97 million of interests in the Four Entities (Advance Entertainment, Advance 

Entertainment II, 875 Holdings and 127 Holdings), all of which purportedly engaged in bulk 

ticket purchases and resales.  Investors frequently invested in more than one entity at various 

times and may not have clearly distinguished among the entities, which made similar 

representations about their businesses.  

875 Holdings 

27. 875 Holdings was organized in or around July 2015.  The next month, 875 

Holdings filed a Form D with the SEC stating that the company was making a private offering of 

equities in an unspecified business with no revenue, and had sold $1,050,000 to date.  In 

February 2016, 875 Holdings filed an amended Form D stating that 25 persons had invested in 

the offering, with a total amount sold of $3.4 million. 

28. From in or around July 2015 through January 2017, 875 Holdings received a total 

of at least $7.1 million from investors.  In soliciting the investments, Meli and Harriton 

represented that investor money would be pooled and used to buy a participation interest in 

profits from the resale of tickets for high profile events.  Investors were further told that 875 

Holdings was a diversified fund whose purpose was to purchase tickets to various shows, and 

that the fund would have discretion as to which shows or events to purchase tickets for.  Funds 

raised from investors into 875 Holdings were spent or transferred contrary to representations 

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made to investors, including for the purpose of repaying other investors and making transfers to 

Harriton and Mash Transactions, an entity controlled by Harriton. 

Advance Entertainment 

29.  From January 2015 to January 2017, Advance Entertainment, which was formed 

in 2011, received more than $64 million from investors.  Funds raised from investors into 

Advance Entertainment were spent or transferred contrary to representations made to investors, 

including for the purpose of repaying other investors, withdrawals, paying for personal and legal 

expenses, funding the purchase of a property in the Hamptons in the name of Jessica Ingber 

Meli, and making transfers to Harriton and several Relief Defendants. 

30. In December 2015, Meli signed a “Funding Agreement” on behalf of Advance 

Entertainment with an investor.  In the Funding Agreement, Advance Entertainment falsely 

represented that it had a signed agreement with the producer of the Broadway musical Hamilton 

to purchase 35,000 tickets to the musical and that the investor’s money would be used to pay part 

of the cost of obtaining the tickets.  The Funding Agreement provided that within eight months, 

the investor would receive, from the proceeds of the resale of Hamilton tickets, the return of its 

principal, along with “an amount sufficient to generate a 10% annualized return” on the 

investment, and that the investor would also receive 50% of any further proceeds less Advance 

Entertainment’s reasonable expenses incurred in reselling the tickets.  Similar representations 

were made to other investors and potential investors.  Some investors were provided with a 

signed “Letter Agreement” between Advance Entertainment (signed by Meli) and the producer 

of Hamilton purporting to show that Advance Entertainment had an agreement to purchase 

35,000 tickets to Hamilton on Broadway for a total of $7 million.  On some occasions, Harriton 

provided this signed “Letter Agreement” with the producer of Hamilton to investors or 

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prospective investors.  Meli and Harriton sometimes referred to the “Letter Agreement” with the 

Hamilton producer as a “vault agreement.”  The representations in the Funding Agreement were 

false, and the “Letter Agreement” with the Hamilton producer was fraudulent.  Neither Advance 

Entertainment nor any of Meli or Harriton’s other entities had any legitimate agreement with the 

Hamilton producer to purchase tickets to the musical, and no purchase of 35,000 tickets to the 

musical was made with investor money. 

31. In January 2017, Meli signed another “Funding Agreement” on behalf of Advance 

Entertainment with an investor.  In the Funding Agreement, Advance Entertainment falsely 

represented that it had entered into an agreement with the theater company associated with Harry 

Potter and the Cursed Child to purchase 250,000 tickets for a total of $62.5 million to an 

upcoming Broadway run of the play, and that the investor’s money would be used to pay part of 

the cost of obtaining the tickets.  The Funding Agreement provided that the investor would 

receive, from the proceeds of the resale of tickets to Harry Potter and the Cursed Child, the 

return of its principal, followed by a pro rata share of certain profits.  Meli provided the investor 

with a signed “Letter Agreement” (which he referred to as a “vault agreement”) between 

Advance Entertainment and the theater company purporting to show that Advance Entertainment 

had an agreement to purchase 250,000 tickets to Harry Potter and the Cursed Child on 

Broadway for a total of $62.5 million.  The representations in the Funding Agreement were false, 

and the “Letter Agreement” with the theater company was fraudulent.  Neither Advance 

Entertainment nor any of Meli or Harriton’s other entities had any agreement with the theater 

company to purchase tickets to the Harry Potter play on Broadway, and no purchase of 250,000 

tickets to the play was made with investor money. 

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32. In or around January 2017, Meli solicited and obtained an investment with 

Advance Entertainment to be used for the purchase of block tickets to Metallica concerts.  Meli 

and Advance Entertainment falsely represented that the investment would be used to purchase 

tickets to an upcoming Metallica concert tour, and that the investor would receive certain profits 

from the resale of the Metallica tickets.  In fact, the investment was used in a manner not 

consistent with these representations, including to repay earlier investors and to transfer money 

for legal expenses. 

33. In or around January 2017, Meli solicited and obtained an investment with 

Advance Entertainment to be used for the purchase of block tickets to Nine Inch Nails concerts.  

Meli and Advance Entertainment falsely represented that the investment would be used to 

purchase tickets to Nine Inch Nails concerts, and that the investor would receive certain profits 

from the resale of the Nine Inch Nails tickets.  In fact, the investment was used in a manner not 

consistent with these representations, including to repay an earlier investor and to transfer money 

for legal expenses. 

Advance Entertainment II   

34. Advance Entertainment II was organized in or around February 2016. The next 

month, Advance Entertainment II filed a Form D with the SEC stating that the company was 

making a private offering of equities in an unspecified business with no revenue, and had made 

sales totaling $10,220,000 to date.  Advance Entertainment II filed a second Form D in August 

2016 for another offering of $13,000,000. 

35. From February 2016 to January 2017, Advance Entertainment II received at least 

$17.5 million of investor funds.  In soliciting investments for Advance Entertainment II, Meli 

and Harriton each represented to investors that money invested with the company would be 

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pooled to buy a participation interest in profits from the resale of tickets to high profile events, 

including the Broadway musical Hamilton (which Meli and Harriton sometimes referred to as 

“Event I”), Adele concerts (which Meli and Harriton sometimes referred to as “Event II”), and a 

concert festival known as Desert Trip (which Meli and Harriton sometimes referred to as “Event 

III”).  Investors typically received a “Profit Participation Purchase Agreement” which confirmed 

that they were “acquiring a participation interest in a portion of the proceeds derived by the 

Company from the re-sale of tickets it intends to acquire for a specific Event.”  The agreement 

typically included a “participation schedule” stating that within nine months from the 

investment, the investor would receive a 10% “preference percentage,” or return on investment, 

and a “remainder percentage” of 50%, meaning 50% of any additional profits from the ticket 

resales.  Funds raised from investors into Advance Entertainment II were spent or transferred 

contrary to representations made to investors, including for the purpose of repaying other 

investors and making transfers to Harriton. 

127 Holdings 

36. 127 Holdings was organized in or around 2009.  From January 2015 to January 

2017, 127 Holdings received more than $8 million of investor funds.  Funds raised from 

investors into 127 Holdings were spent or transferred contrary to representations made to 

investors, including for the purpose of repaying other investors, withdrawals, paying for personal 

and legal expenses, and making transfers to several Relief Defendants. 

37. According to an individual who invested $500,000 in 127 Holdings in or around 

June 2015, and who later invested additional funds in Advance Entertainment, Meli made 

substantially the same representations to the investor concerning 127 Holdings as he made 

concerning Advance Entertainment.  In particular, Meli represented that an agreement was in 

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place with the producer of Hamilton to purchase tickets to the musical in bulk, that the investor’s 

money would be used to pay part of the cost of obtaining these tickets from the Hamilton 

producer, and that the investor would receive a return on his investment from the resale of tickets 

obtained from the Hamilton producer.  Those representations were false.  None of Meli or 

Harriton’s entities had any legitimate agreement with the Hamilton producer to purchase tickets 

to the musical in bulk, and no bulk purchase of tickets from the Hamilton producer was made 

with investor money. 

Defendants Use Investor Funds to Pay Obligations to Prior Investors 

38. From January 2015 to January 2017, Meli and Harriton caused the Four Entities 

to receive funds totaling more than $97 million from investors.  During that same period, Meli 

and Harriton caused the Four Entities to spend less than 14% of that amount (approximately 

$13.4 million) to make payments to third parties that appear to have any connection with ticket 

sales or live event production. 

39. The largest category of payments the Four Entities made was to individuals and 

entities that appear to have made earlier investments in the Four Entities, providing purported 

returns on their investments.  From January 2015 to January 2017, the Four Entities received less 

than $6.5 million from third parties with any apparent connection to the ticket sales or live event 

industries, yet they paid out over $59 million to investors.  A significant portion of these 

payments to earlier investors came directly from the funds of later investors. 

40. Defendants did not pool the more than $97 million received from investors to buy 

bulk tickets to high profile events for resale at a profit to be distributed to investors.  Instead, 

Defendants operated a Ponzi scheme, making payments to prior investors from new investor 

funds.  Defendants did not tell investors that, contrary to their representations and contrary to the 

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terms of the written agreements with investors signed by Meli and Harriton, a significant portion 

of the invested funds would be used for purposes other than purchasing tickets for resale. 

Investor A 

41. Between January and August 2016, Investor A invested a total $1.85 million with 

Meli and Harriton; specifically, he made separate investments in 875 Holdings, Advance 

Entertainment and Advance Entertainment II.  Investor A first met Meli and Harriton in 

December 2015 or January 2016.  Investor A met both Meli and Harriton in person, and he also 

spoke with each of them on the phone.  Investor A learned from Meli and Harriton that they were 

in the business of purchasing tickets in bulk and reselling them on the secondary market.  Meli 

and Harriton represented to Investor A that his money would be pooled with other investors’ 

funds and used solely for the purchases of tickets associated with events or shows. 

42. Between January and August 2016, Investor A invested $1.85 million with Meli 

and Harriton in four tranches.  First, on or about January 11, 2016, Investor A invested $500,000 

into 875 Holdings.  Meli and Harriton told Investor A that 875 Holdings was a diversified fund 

whose purpose was to purchase tickets for various shows, and that 875 Holdings would have 

discretion as to which shows or events to purchase tickets for.  Next, in January and February 

2016, Investor A invested a total of $350,000 (consisting of $250,000 on or about January 22, 

2016, and $100,000 on or about February 12, 2016) into Advance Entertainment to be used for 

an investment into a ticket purchase for the Broadway musical Hamilton.  Third, on or about 

March 3, 2016, Investor A invested $700,000 into Advance Entertainment II.  His understanding 

based on communications with Meli and Harriton was that $200,000 of that investment would be 

used to fund further purchases of Hamilton tickets, and that $500,000 of that investment would 

be used to fund tickets to Adele concerts.  Finally, on or about August 23, 2016, Investor A 

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invested an additional $300,000 into Advance Entertainment II to be used to fund the bulk 

purchase and resale tickets to Desert Trip, a concert festival featuring The Rolling Stones, Bob 

Dylan, Paul McCartney and other high profile musicians. 

43. At or around the times of each of his investments, Investor A signed investment 

contracts with the entities into which he was investing his funds. 

44. Investor A’s funds were deposited into several different bank accounts controlled 

by one or more of the Defendants and then spent or transferred contrary to the representations 

made to him by Meli and Harriton, and not consistent with the purported investment into event 

ticket purchases and resales.  Payments and transfers included, by way of example: 

a. Investor A’s initial investment of $500,000 into 875 Holdings was used, in whole 

or in part, to fund a payment to another investor, rather than for ticket purchases 

and resales.  On or about January 11, 2016, the $500,000 investment was 

deposited into an 875 Holdings account at Signature Bank ending in ‘1199.  On or 

about January 12, 2016, all, or at least a significant portion of this investment, 

along with other available account funds totaling $650,000, was transferred to an 

Advance Entertainment account at Merrill Lynch ending in ‘3098.  On or about 

January 14, 2016, Advance Entertainment used $1.2 million from the Merrill 

Lynch ‘3098 account to pay another investor.  This payment was funded in part 

by the transfer from 875 Holdings, including Investor A’s funds. 

b. On or about January 22, 2016, Investor A’s $250,000 investment into Advance 

Entertainment was deposited into an Advance Entertainment account at Merrill 

Lynch ending in ‘3098.  On or about January 26, 2016, all, or at least a significant 

portion of this investment, along with other available account funds totaling 

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$600,000, was used to pay another investor out of the Advance Entertainment 

account. 

c. On or about March 3, 2016, Investor A’s $700,000 investment was deposited into 

an Advance Entertainment II account at Signature Bank ending in ‘2528.  On the 

same day, $500,000 was transferred from the Advance Entertainment II account 

to Advance Entertainment, and another $200,000 was transferred from the 

Advance Entertainment II account to Harriton’s father. 

Investor B 

45.   On or about December 16, 2015, Investor B signed a Funding Agreement to 

invest $1.25 million into Advance Entertainment to fund a portion of a pooled investment to 

purchase and resell 35,000 tickets to the Hamilton musical.  The Funding Agreement referenced 

an underlying letter agreement dated in October 2015 between Advance Entertainment and the 

Hamilton producer for the purchase of 35,000 tickets.  In reality, neither Advance Entertainment 

nor any of Meli or Harriton’s other entities had any legitimate agreement with the Hamilton 

producer to purchase tickets to the musical, and no purchase of 35,000 tickets to the musical was 

made with investor money.  Advance Entertainment received Investor B’s $1.25 million on or 

about December 28, 2015, deposited in Advance Entertainment’s Merrill Lynch account ending 

in ‘3098.  After the deposit of this $1.25 million of investor funds, the daily balance of the 

Advance Entertainment account was approximately $1.94 million.  The following day, Advance 

Entertainment disbursed $1.5 million from this account to a third party who has no involvement 

in ticket sales or live event production, for Hamilton or any other event. 

Investor C 

46. Between approximately June and October 2015, another individual and his 

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affiliated business (collectively, “Investor C”) invested $6 million into Advance Entertainment 

and 127 Holdings.  Similar to Investor B, all or a significant portion of Investor C’s funds were 

invested for the bulk purchase of Hamilton tickets based on false representations from Meli, who 

claimed that an agreement was in place with the producer of Hamilton to purchase $7 million 

worth of tickets for resale.  Investor C’s funds were deposited into company bank accounts 

controlled by Meli and then spent or transferred contrary to representations made to Investor C, 

including to fund the purchase of a property in East Hampton, New York in the name of Jessica 

Ingber Meli. 

Investor D 

47. On or about January 12, 2017, Investor D invested $2 million into Advance 

Entertainment for the purchase of block tickets to Metallica concerts.  Meli and Advance 

Entertainment falsely represented that the investment would be used to purchase tickets to an 

upcoming Metallica concert tour, and that Investor D would receive certain profits from the 

resale of the Metallica tickets.  In fact, the investment was used in a manner not consistent with 

these representations.  By January 26, 2017, all or the vast majority of Investor D’s $2 million 

investment had been used for purposes inconsistent with Meli and Advance Entertainment’s 

representations, including to repay earlier investors and to pay for legal expenses. 

Investor E 

48. In January 2017, Investor E invested a total of $7.86 million into Advance 

Entertainment (paid through five payments to an Advance Entertainment account at Merrill 

Lynch ending in ‘3098 from on or about January 18, 2017 to on or about January 24, 2017).  

Investor E entered into a Funding Agreement with Advance Entertainment, signed by Meli, 

which falsely represented that Advance Entertainment had entered into an agreement with the 

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theater company associated with Harry Potter and the Cursed Child to purchase 250,000 tickets 

for a total of $62.5 million to an upcoming Broadway run of the play, and that the investor’s 

money would be used to pay part of the cost of obtaining the tickets, with the principal and 

certain profits from the ticket sales to be returned to the investor.  Meli provided Investor E with 

a “Letter Agreement” (which he referred to as a “vault agreement”) between Advance 

Entertainment and the theater company purporting to show that Advance Entertainment had 

secured an agreement to purchase 250,000 tickets.  The representations in the Funding 

Agreement were false, and the “Letter Agreement” that Meli provided to the investor was 

fraudulent.  Advance Entertainment did not have any agreement with the theater company to 

purchase tickets to the Harry Potter play, and no purchase of 250,000 tickets was made with 

investor money.  Instead, by January 26, 2017, just two days after Investor E’s last payment was 

sent to Advance Entertainment, all or the vast majority of Investor E’s $7.86 million investment 

had been used for purposes inconsistent with Meli and Advance Entertainment’s representations, 

including to repay earlier investors and to pay for legal expenses. 

Investor F 

49. On or about January 25, 2017, Investor F invested $500,000 into Advance 

Entertainment for the purchase of block tickets to Nine Inch Nails concerts.  Meli and Advance 

Entertainment falsely represented that the investment would be used to purchase tickets to Nine 

Inch Nails concerts, and that Investor F would receive certain profits from the resale of the Nine 

Inch Nails tickets.  In fact, the investment was used in a manner not consistent with these 

representations.  On or about January 26, 2017, one day after Investor F’s investment, all or the 

vast majority of the $500,000 investment was used for purposes inconsistent with Meli and 

Advance Entertainment’s representations, including to repay Investor B and for legal expenses. 

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50. On or about January 26, 2017, Investor B received a wire transfer of $1,250,000 

as a purported return of principal and/or a return on an earlier investment.  The funds for this 

transfer appear to have come from deposits during January 2017 by other investors, including 

Investors D, E, and F. 

Defendants Use Investor Funds for Other Undisclosed Purposes 

51. In addition to using new investor funds to make payments owed to existing 

investors, from January 2015 to January 2017, at least $5 million of investor funds was used 

from 127 Holdings and Advance Entertainment to pay for jewelry and other retail purchases, 

private school and camp tuition, automobiles, private club memberships and expenses, wine, 

restaurants, driving services (including limousines), travel expenses and hotels, and payments to 

casinos; and at least an additional $1.8 million in payments were made to architecture, design, or 

construction firms.  These payments were not disclosed to investors and were used for purposes 

inconsistent with representations made to investors by the Defendants. 

52. From January 2015 to January 2017, investor funds totaling approximately $1.3 

million were transferred from one or more of the Four Entities to Harriton.  These payments 

were not disclosed to investors and were used for purposes inconsistent with representations 

made to investors by the Defendants. 

53. From January 2015 to January 2017, an additional approximately $1.5 million of 

investor funds were withdrawn from bank accounts in the name of 127 Holdings and Advance 

Entertainment, which accounts are controlled by Meli.  These withdrawals were not disclosed to 

investors and were used for purposes inconsistent with representations made to investors by the 

Defendants. 

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54. On or about January 26, 2017, investor funds totaling $685,000 were transferred 

from bank accounts in the name of 127 Holdings and Advance Entertainment, which accounts 

are both controlled by Meli, to pay for legal services.  The funds for these payments appear to 

have come from deposits earlier in January 2017 by investors, including Investors D, E, and F.  

These payments were not disclosed to investors and were used for purposes inconsistent with 

representations made to investors by the Defendants. 

55. As a supposed benefit of investing in their ticket resale enterprise, Meli and 

Harriton offered certain investors complimentary, premium tickets for their personal use to live 

performances, including the Hamilton musical and Adele concerts.  On multiple occasions, after 

receiving a request from an investor for tickets for personal use to a particular performance and 

date, Harriton used investor funds from one or more of the Four Entities’ bank accounts to 

purchase several premium tickets on the secondary market, often paying in excess of $1,000 per 

ticket, well above face value, and sometimes paying significantly more than $1,000 per ticket.  

Harriton personally placed these ticket orders and arranged for payment of the tickets from 

investor funds.  The tickets were then provided to the requesting investor at no cost to the 

investor.  This supposed benefit was offered at least in part for the purpose of duping investors 

into believing that Meli and Harriton were actually engaged in a large-scale ticket reselling 

enterprise.  The use of funds from certain investors to purchase tickets for other investors’ 

personal use was not disclosed and was inconsistent with representations made to investors by 

the Defendants. 

Meli’s Recorded Statements to a Cooperating Witness 

56. In or around December 2016, an individual agreed to cooperate with law 

enforcement authorities, including the Federal Bureau of Investigation, as a cooperating witness 

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in an undercover criminal investigation.  On multiple instances in December 2016 and January 

2017, the cooperating witness (the “CW”) consensually recorded conversations with Meli, 

unbeknownst to Meli.  In one such recorded conversation in December 2016, Meli stated to the 

CW, among other things: “All I’ve been doing all along is the shell game.  You know how it 

works, right?  You take money from one guy to pay off the other guy.”  In a separate recorded 

conversation in December 2016, referring to the source of funds used to repay a particular 

investor, Meli stated to the CW: “Everything is fungible.  I’ve been moving things around and 

playing the shell game to keep that prick at bay by giving him little payments.  But I’ve been 

taking it from other people.”  Meli also stated to the CW in a December 2016 recorded 

conversation: “The Advance Entertainment account might as well be my personal account.” 

Relief Defendants 

57. From January 2015 to January 2017, relief defendant Jessica Ingber Meli or her 

personal credit card accounts received payments totaling more than $710,000 from 127 

Holdings.  Additionally, in or around October 2015, a property was purchased in the name of 

Jessica Ingber Meli in East Hampton, New York for approximately $3 million in cash funded by 

investor funds invested in Advance Entertainment.  There is no indication that Jessica Ingber 

Meli provided services in exchange for these payments to her or her credit card accounts, or for 

the funds used to purchase the East Hampton property in her name.  These payments were not 

disclosed to investors and were used for purposes inconsistent with representations made to 

investors by the Defendants.  Jessica Ingber Meli has no legitimate interest in, or right to, the 

funds she and her personal credit card accounts received or which were used to purchase a 

property in her name and which funds represented proceeds of the fraudulent scheme. 

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58. From January 2015 to January 2017, relief defendant Anna Meli received 

payments totaling at least $405,000 from 127 Holdings and Advance Entertainment.  There is no 

indication that Anna Meli provided services in exchange for these payments to her.  These 

payments were not disclosed to investors and were used for purposes inconsistent with 

representations made to investors by the Defendants.  Anna Meli has no legitimate interest in, or 

right to, the funds she received and which funds represented proceeds of the fraudulent scheme. 

59. From January 2015 to January 2017, relief defendant 127 Partners, an entity 

controlled by Meli, received payments totaling at least $307,000 from 127 Holdings.  There is no 

indication that 127 Partners provided services in exchange for these payments.  The payments to 

it were not disclosed to investors and were used for purposes inconsistent with representations 

made to investors by the Defendants.  127 Partners has no legitimate interest in, or right to, the 

funds it received and which funds represented proceeds of the fraudulent scheme. 

60. From January 2015 to January 2017, relief defendant 127 Iconic Holdings, an 

entity controlled by Meli, received payments totaling at least $489,000 from 127 Holdings.  

There is no indication that 127 Iconic Holdings provided services in exchange for these 

payments.  The payments to it were not disclosed to investors and were used for purposes 

inconsistent with representations made to investors by the Defendants.  127 Iconic Holdings has 

no legitimate interest in, or right to, the funds it received and which funds represented proceeds 

of the fraudulent scheme. 

61. From January 2015 to January 2017, relief defendant Nineteen Two Productions, 

an entity controlled by Meli, received payments totaling at least $260,000 from Advance 

Entertainment and 127 Holdings.  There is no indication that Nineteen Two Productions 

provided services in exchange for these payments.  The payments to it were not disclosed to 

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investors and were used for purposes inconsistent with representations made to investors by the 

Defendants.  Nineteen Two Productions has no legitimate interest in, or right to, the funds it 

received and which funds represented proceeds of the fraudulent scheme. 

62. From January 2015 to January 2017, relief defendant MXCU Holdings, an entity 

controlled by Harriton, received payments totaling at least $325,000 from Advance 

Entertainment.  There is no indication that MXCU Holdings provided services in exchange for 

these payments.  The payments to it were not disclosed to investors and were used for purposes 

inconsistent with representations made to investors by the Defendants.  MXCU Holdings has no 

legitimate interest in, or right to, the funds it received and which funds represented proceeds of 

the fraudulent scheme. 

63. From January 2015 to January 2017, relief defendant Mash Transactions, an 

entity controlled by Harriton, received payments totaling more than $70,000 from 127 Holdings 

and 875 Holdings.  There is no indication that Mash Transactions provided services in exchange 

for these payments.  The payments to it were not disclosed to investors and were used for 

purposes inconsistent with representations made to investors by the Defendants.  Mash 

Transactions has no legitimate interest in, or right to, the funds it received and which funds 

represented proceeds of the fraudulent scheme. 

FIRST CLAIM FOR RELIEF 
FRAUD IN THE OFFER OR SALE OF SECURITIES 

(Violations of Section 17(a)(1), (2) and (3) of the Securities Act) 
 

64. Paragraphs 1 through 63 are re-alleged and incorporated by reference. 

65. By reason of the conduct described above, defendants Joseph Meli, Matthew 

Harriton, 875 Holdings, LLC, 127 Holdings, LLC, Advance Entertainment, LLC, and Advance 

Entertainment II, LLC, in connection with the offer or sale of securities, by the use of the means 

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or instrumentalities of interstate commerce or of the mails, directly or indirectly, acting with the 

requisite degree of knowledge or state of mind (i) employed devices, schemes, or artifices to 

defraud; (ii) obtained money or property by means of untrue statements of a material fact or 

omitted to state a material fact necessary in order to make the statements made, in the light of the 

circumstances under which they were made, not misleading; and (iii) engaged in transactions, 

practices, or courses of business which operated or would operate as a fraud or deceit upon any 

persons, including purchasers or sellers of the securities.   

66. By reason of the conduct described above, Defendants violated Securities Act 

Section 17(a) [15 U.S.C. § 77q(a)]. 

SECOND CLAIM FOR RELIEF 
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES  

(Violations of Section 10(b) of the Exchange Act and Rule 10b-5(a), (b) and (c) thereunder) 
 

67. Paragraphs 1 through 63 are re-alleged and incorporated by reference. 

68. By reason of the conduct described above, defendants Joseph Meli, Matthew 

Harriton, 875 Holdings, LLC, 127 Holdings, LLC, Advance Entertainment, LLC, and Advance 

Entertainment II, LLC, directly or indirectly, in connection with the purchase or sale of 

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

of any facility of any national securities exchange, intentionally, knowingly or recklessly, (i) 

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

or omitted to state a material fact necessary in order to make the statements made, in the light of 

the circumstances under which they were made, not misleading; and (iii) engaged in acts, 

practices, or courses of business which operated or would operate as a fraud or deceit upon any 

persons, including purchasers or sellers of the securities. 

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69. By reason of the conduct described above, Defendants violated Exchange Act 

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

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that this Court: 

 A. Temporarily, preliminarily, and permanently restrain and enjoin Joseph Meli, 

Matthew Harriton, 875 Holdings, LLC, 127 Holdings, LLC, Advance Entertainment, LLC, and 

Advance Entertainment II, LLC, their officers, agents, servants, employees and attorneys, and 

those persons in active concert or participation with them who receive actual notice of the 

injunction by personal service or otherwise, and each of them, from violating Section 17(a) of 

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

and Rule 10b-5 thereunder [17 C.F.R. 240.10b-5]; 

 B. Enter a temporary restraining order, preliminary injunction, order freezing assets, 

order requiring an accounting of assets and liabilities, order requiring repatriation of assets, order 

prohibiting the accepting or depositing of additional investor funds, order allowing expedited 

discovery, order prohibiting the alteration or destruction of relevant documents, and order for 

other equitable relief in the form submitted with the Commission’s motion for such relief, as to 

Joseph Meli, Matthew Harriton, 875 Holdings, LLC, 127 Holdings, LLC, Advance 

Entertainment, LLC, and Advance Entertainment II, LLC; 

 C. Order Joseph Meli, Matthew Harriton, 875 Holdings, LLC, 127 Holdings, LLC, 

Advance Entertainment, LLC, and Advance Entertainment II, LLC,  to disgorge, with 

prejudgment interest, all ill-gotten gains obtained by reason of the unlawful conduct alleged in 

this Complaint; 

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 D. Order Relief Defendant Jessica Ingber Meli to disgorge, with prejudgment 

interest, all ill-gotten gains obtained by her from any of the Defendants including, but not limited 

to, payments to her, her personal credit card accounts, and funds used to purchase a property in 

her name totaling more than $3,710,000, which were transferred from 127 Holdings and 

Advance Entertainment; 

 E. Order Relief Defendant Anna Meli to disgorge, with prejudgment interest, all ill-

gotten gains obtained by her from any of the Defendants including, but not limited to, payments 

to her totaling at least $405,000 from 127 Holdings and Advance Entertainment; 

 F. Order Relief Defendant 127 Partners, LLC to disgorge, with prejudgment interest, 

all ill-gotten gains obtained by it from any of the Defendants including, but not limited to, 

payments to it totaling at least $307,000 from 127 Holdings; 

 G. Order Relief Defendant 127 Iconic Holdings, LLC to disgorge, with prejudgment 

interest, all ill-gotten gains obtained by it from any of the Defendants including, but not limited 

to, payments to it totaling at least $489,000 from 127 Holdings; 

 H. Order Relief Defendant Nineteen Two Productions, LLC to disgorge, with 

prejudgment interest, all ill-gotten gains obtained by it from any of the Defendants including, but 

not limited to, payments to it totaling at least $260,000 from Advance Entertainment and 127 

Holdings; 

 I. Order Relief Defendant MXCU Holdings, LLC to disgorge, with prejudgment 

interest, all ill-gotten gains obtained by it from any of the Defendants including, but not limited 

to, payments to it totaling at least $325,000 from Advance Entertainment; 

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 J. Order Relief Defendant Mash Transactions, LLC to disgorge, with prejudgment 

interest, all ill-gotten gains obtained by it from any of the Defendants including, but not limited 

to, payments to it totaling more than $70,000 from 127 Holdings and 875 Holdings; 

 K. Order Joseph Meli, Matthew Harriton, 875 Holdings, LLC, 127 Holdings, LLC, 

Advance Entertainment, LLC, and Advance Entertainment II, LLC, to pay civil monetary 

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)];  

 L. Appoint a receiver over Defendants and Relief Defendants pursuant to Federal 

Rule of Civil Procedure 66; 

M. Retain jurisdiction over this action to implement and carry out the terms of all 

orders and decrees that may be entered; and 

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

JURY DEMAND 

The Commission hereby demands a trial by jury on all claims so triable. 

Dated: March 7, 2017    On behalf of the Commission, 
 Boston, MA 
       

//s// Dahlia Rin     
      Alicia M. Reed (NY Bar # 4913596) 

Dahlia Rin* (MA Bar # 674137) 
Rebecca Israel** (NY Bar # 4783304) 
Martin F. Healey* (MA Bar # 227550) 
U.S. Securities and Exchange Commission 
Boston Regional Office 
33 Arch Street, 24th Floor 
Boston, MA  02110 
(617) 573-8807 (Rin) 
[email protected] 
 
*Admitted Pro Hac Vice 
**Not admitted in the S.D.N.Y. 

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CERTIFICATE OF SERVICE 

 I certify that on March 7, 2017, I caused a copy of the foregoing document to be filed 
through the ECF system and, accordingly, the document will be sent electronically to all 
registered participants as identified on the Notice of Electronic Filing (“NEF”).   

//s// Dahlia Rin      
Dahlia Rin 

 

 

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