SEC v. EAMMA SAFI; and ZHI GE a/k/a JOSH GE, No. 1:25-cv-10516, District of Massachusetts (Mar. 14, 2025) — Complaint

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

SECURITIES AND EXCHANGE
COMMISSION,

                        Plaintiff,

            v.

EAMMA SAFI and ZHI GE a/k/a JOSH GE,

                        Defendants.

     Civil Action No. 25-cv-

     JURY TRIAL DEMANDED

COMPLAINT
 Plaintiff United States Securities and Exchange Commission (“the Commission”) alleges
as follows against Defendants Eamma Safi (“Safi”) and Zhi Ge a/k/a Josh Ge (“Ge”):
SUMMARY OF THE ACTION
1. From in or about 2017 through in or about 2024, Safi and Ge willfully
participated in an international insider trading scheme that netted them millions in illicit profits
from trading in advance of market-moving announcements. The scheme (the “Tipping Scheme”)
involved tips that originated from persons known to Safi or his close associates.
2. In the Tipping Scheme, Safi directly or indirectly obtained from insiders
(including one or more sources at publicly traded companies) material nonpublic information
about impending corporate transactions or other confidential information that could move the
market, such as earnings announcements. Safi then tipped Ge as well as another individual
(“Trader A”) recruited by Ge, and all three traded profitably on the tips of inside information.
Safi and/or Ge demanded and received kickbacks of trading profits from Trader A in exchange
for such information.
3. Using the illegal tips, Safi and Ge – along with Trader A – generated millions in

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illicit profits trading the securities of numerous companies, both through their individual trading
accounts and through brokerage accounts in the names of other people and entities that were
controlled by Safi, Ge, and/or Trader A.
4. Safi and Ge knew or were reckless in not knowing they were trading while aware
of and on the basis of material nonpublic information obtained from insiders at public companies
and/or other sources owing a similar duty to maintain the confidentiality of such information.
5. By knowingly or recklessly engaging in the conduct described in this Complaint,
Defendants Safi and Ge violated, and unless restrained and enjoined will continue to violate,
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. § 240.10b-5].
NATURE OF PROCEEDING AND RELIEF SOUGHT
6. The Commission brings this action under Section 21(d) of the Exchange Act [15
U.S.C. § 78u(d)]. The Commission seeks permanent injunctions against the Defendants, to
enjoin them from engaging in the transactions, acts, practices, and courses of business alleged in
this Complaint; disgorgement of profits realized from the unlawful trading set forth herein, along
with prejudgment interest; and civil monetary penalties pursuant to Section 21A of the Exchange
Act [15 U.S.C. § 78u-1], and for such other relief as the Court may deem just and appropriate.
JURISDICTION AND VENUE
7. This Court has jurisdiction over this action under Sections 21(d), 21(e), 21A, and
27 of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), 78u-1, and 78aa]. Certain of the acts,
practices, transactions, and courses of business constituting the violations made use of a means
or instrumentality of interstate commerce, or of the mails, and/or of the facilities of national
securities exchanges.

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8. Venue in this District is proper under Section 27 of the Exchange Act [15 U.S.C.
§ 78aa], because certain of the acts, practices, transactions, and courses of business constituting
the violations alleged in this Complaint occurred in the District of Massachusetts. Among other
things, certain of the options trades executed by Safi, Ge, and/or Trader A in connection with this
scheme, including in Medidata Solutions, Inc. and Cytokinetics, Inc., were conducted through
the BOX Options Exchange (BOX), located in Boston, Massachusetts.
THE DEFENDANTS
9. Safi, age 37, has resided in the United Arab Emirates and is a German citizen.
Safi is the owner of Emallates.com FZE, and purportedly works in the information technology
industry.
10. Ge, age 34, is a Singapore citizen. Ge is the owner of Belleby Holdings Pte Ltd.,
which purportedly manages restaurants and real estate.
OTHER RELEVANT INDIVIDUALS
11. Trader A is a U.S.-based securities trader who obtained material nonpublic
information from Safi and/or Ge, and, as described in greater detail herein, traded on that inside
information.
12. Safi’s Associate resides in France, previously worked in investment banking, and
owned and operated a Paris restaurant in which Safi shared partial ownership (the “Paris
restaurant”).
13. Insider 1 resides in France and at times relevant to this Complaint worked in the
M&A group of Atos S.E. (“Atos”) and then Worldline S.A. (“Worldline”), publicly traded
companies based in France which previously were affiliated. Insider 1 was an investor in the
Paris restaurant and previously worked with Safi’s Associate at a large investment bank.

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TYPES OF SECURITIES TRADED
14. In connection with the Tipping Scheme, Safi and Ge, along with Trader A and
other tippees, established “long” positions in companies that were targeted for acquisition by
purchasing shares of common stock, call options (a type of security that is typically purchased if
the buyer believes the company’s stock price will increase),
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 American depositary receipts,
and/or contracts-for-difference.
15. An American depositary receipt (“ADR”) is a certificate issued by a U.S. bank
that represents a specified number of shares of a foreign company traded on a foreign exchange
and held by the bank overseas. ADRs are priced and traded in U.S. dollars on U.S. stock
exchanges comparable to shares of stock in domestic companies. ADRs allow investors to
functionally trade foreign equities on U.S. exchanges.
16. A contract-for-difference (“CFD”) is an agreement between two parties to
exchange the difference in value of an underlying stock between the time the contract is opened
and the time at which it is closed. If the share price of the underlying stock increases, the seller
pays the difference to the buyer; however, if the share price declines, the buyer must pay the
seller. A CFD related to a U.S.-listed company thus mirrors the movement and pricing of the
underlying stock on a dollar-for-dollar basis. A CFD provider ordinarily hedges its exposure
against a CFD buyer’s long position by purchasing (directly or indirectly) a corresponding
number of shares of the underlying U.S. company on a U.S. exchange through domestic
brokerage firms.

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 A buyer who purchases a call option for a stock has the opportunity, but not the obligation, to buy that stock for a
specific price known as the “strike price” for a predetermined period ending on the “expiration date.”

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FACTUAL ALLEGATIONS
17. Beginning in or about mid-2017, Trader A began receiving tips of material
nonpublic information from Safi and/or Ge regarding public companies. Safi and/or Ge provided
specific information, obtained directly or indirectly from corporate insiders and/or investment
bankers, about upcoming announcements, including about earnings releases, acquisition offers,
and/or other market-moving events expected to impact the share price of a publicly traded
company. Safi and/or Ge further provided guidance about exactly when to buy securities of a
given company, and, on occasion, directed Trader A to exit his investment if an anticipated
announcement was no longer going to take place as expected.
18.  In furtherance of the Tipping Scheme, Safi directly or indirectly leaked material
nonpublic information to journalists and news outlets, so that Safi and other scheme participants
could profitably trade around the market reaction to the publication of such information, rather
than waiting to potentially profit from a corporate press release. Trader A understood from Safi
that he had connections with persons writing articles about upcoming deals; on one or more
occasions Safi previewed for Trader A that news related to a deal was coming out and later
identified which news agency would publish it.
19. As described below, Safi and/or Ge provided material nonpublic information
about U.S.-based public companies, as well as foreign public companies traded on foreign
exchanges with ADRs that traded on U.S. exchanges.
A. Safi and Ge Recruit Trader A and Provide “Sample” Insider Trading Tip
20. Safi and Ge have known each other since at least 2016.
21. By at least November 2016, Safi began recruiting Ge into the Tipping Scheme,
and, to that end, invited Ge to visit Safi and Safi’s Associate in Paris.

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22. On November 17, 2016, Safi messaged Ge (via Facebook Messenger) that
“[Safi’s Associate] wants to see you this Friday,” adding that “Plan would be lunch and in the
evening drinks.” When Ge made remarks about the short notice for this trip to Paris, given the
need for flight and hotel arrangements, Safi noted “We are doing business.” After messaging
further about Ge’s travel plans, Safi wrote to Ge: “Friday you will be welcomed to our world of
business.”
23. On or about November 19, 2016, Ge messaged Safi, asking “When do I meet
[Safi’s Associate] today,” then adding “Can’t wait to get started.” After some more back and
forth, with Safi indicating he needed to check the time of the meeting, Safi wrote: “So you will
be 5:30 at the restaurant.”  Later that day, Ge sent a message to Safi confirming his arrival: “I’m
at [name of the Paris Restaurant] already.”
24. Also in November 2016, after the meeting at the Paris restaurant, Safi and Ge
exchanged messages about recruiting more investors into the Tipping Scheme. Ge remarked to
Safi that “this shit is easier than I thought... Everyone knows what’s up lol ... I thought peeps
are gonna be more apprehensive.”
25. Safi and Ge began using code words to communicate about the Tipping Scheme.
For example, “socks” and “shoes” were code for disposable (or “burner”) cell phones and SIM
cards, while “greens” was code for money, and “games” and/or “races” were code words for
forthcoming corporate announcements which were not yet public.
26. On November 21, 2016, Ge told Safi that Ge was recruiting his mother’s friend
into the Tipping Scheme, and they began discussing getting new “shoes” and “socks,” i.e.,
obtaining burner phones and new SIM cards to mask communications related to the scheme.
Safi told Ge: “[N]ew socks and shoes is a must bro.” In messaging Ge about the need for both
“socks” and “shoes,” Safi warned Ge that not changing burner cell phones and SIM cards was

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the “major mistake people do.” After being reminded by Safi to frequently change “shoes” and
“socks,” Ge messaged Safi: “[I]’ll change after every game, okay?”
27. On November 24, 2016, Safi and Ge continued to message about recruiting
investors, and Safi alerted Ge that a “race” was on the way, meaning that he was in possession of
nonpublic information about an upcoming corporate deal. Safi touted to Ge how much money
they would make, telling Ge: “Millions are like 12 to 15 months away worst case... hundreds of
K [meaning, thousands] ... Just [a] few months.” Ge replied to Safi: “[L]et’s do it.”
28. In or about December 2016, Safi traveled to Hong Kong and to Singapore so that
he and Ge could recruit traders into the Tipping Scheme and provided some potential traders
with a “sample” tip about an upcoming deal in a non-U.S. company.
29. On January 8, 2017, Ge exchanged several messages with Safi and advised Safi
that Ge was planning a trip to Los Angeles to “network ... and exp[a]nd our business,” meaning
the Tipping Scheme.
30. In or around February 2017, Ge met Trader A at a social event in California and
they struck up a friendship.
31. On March 10, 2017, Ge sent Safi an electronic message explaining that he had
become close to Trader A.
32. Shortly thereafter, Ge shared what he described as a “free sample” tip with Trader
A regarding a potential acquisition of Kindred Healthcare, Inc. (“Kindred”), which at that time
was a U.S. company headquartered in Louisville, Kentucky. Kindred shares traded on the New
York Stock Exchange under the ticker symbol KND.
33. Based on Ge’s tip, Trader A purchased Kindred call options, but lost money on
his investment because the call options that he purchased had too high of a “strike price.”
Although the price of Kindred stock rose in response to the announcement of the acquisition, the

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stock price never reached the options’ strike price and thus expired worthless. Nevertheless,
Trader A expressed interest in the Tipping Scheme.
34. On or about June 17, 2017, Ge informed Trader A that he would arrange for
Trader A to meet “his partners” and “dine at their restaurant” in Paris.
35. On June 23, 2017, Ge messaged Safi to ask if he was in Paris because Trader A
wished to visit and “he’s down for racing.”
36. Over the next several days, Ge corresponded separately with Trader A and Safi
about the arrangements for the meeting.
37. On or about June 29, 2017, Safi and Trader A met as planned at the Paris
restaurant. Safi’s Associate also attended. After dining together, Safi asked Trader A to discuss
trading with him. As part of this discussion, Safi referenced having various sources of
confidential information. Trader A agreed to join Safi’s trading group and to share 50% of his
trading profits.
38. On June 29, 2017, Ge messaged Trader A inquiring about the outcome of his
meeting with Safi. Trader A responded the next day, stating that the meeting was great and
thanking Ge for making the introduction. As part of this same message thread that day, Trader A
asked Ge what the percentage is for “you guys” and Ge responded “50.  I told you
haha...Promoters take 50% profit off the door sales;” Trader A responded, “...it works.”  Ge
cautioned Trader A that “if he [meaning, Safi] told you something else there [meaning, in Paris]
... [t]hat one would be the next one and it’ll be charged.”  Trader A responded: “Got it.”
39. After Trader A joined the group, Safi encouraged him to “find insiders,” such as
on Wall Street in New York City, and to refer other traders with resources to Safi. Ge likewise
sought to recruit additional traders and insiders, once telling an associate that he “was looking for
investment bankers in big banks working in M&A specifically.”

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B. Safi, Ge, and Trader A Establish Secret Communication Protocols
40. When Ge and Trader A first exchanged electronic communications, they used
Facebook Messenger to send messages back and forth. But before tipping Trader A about
Kindred (the “free sample” tip), Ge asked Trader A to download Signal to communicate. Signal
is a secure messaging application that uses end-to-end encryption, which allows communications
to remain private as between senders and recipients. Ge introduced Trader A to Signal, and
Trader A understood that its purpose was to keep communications confidential.
41. After Trader A met Safi in Paris in June 2017 and agreed to participate in the
Tipping Scheme, Safi provided further instructions to Trader A about how to communicate to
ensure that any communications would remain private. Safi explained that all electronic
messaging about the group’s trading should take place through disappearing messages on
Telegram, a cloud-based application that stores user data in encrypted form and permits users to
set messages or photographs to disappear within a period as short as minutes or seconds. Safi
told Trader A to obtain a “burner” (or, disposable) phone, use it to activate Telegram, and then
extract the SIM card from the burner phone and throw it in the trash.
42. Safi also provided instructions to Trader A about how to communicate in code
about their trading on material nonpublic information: all communications regarding public
issuers would be disguised as conversations about women and/or girlfriends, and the issuers
would be given female code names with a first letter that corresponded to the first letter of the
company. For example, “Kindred” was coded as “Kelly” in the chats.
43. As with Ge, Safi used code words with Trader A in communications about trading
on material nonpublic information. In addition to “shoes,” “socks,” “greens,” and “races,” Safi,
Ge, and Trader A also used the term “sniper” to refer to inside information that they considered
especially strong and reliable, and thus likely to generate substantial trading profits.

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44. After they began trading together, Safi also directed Trader A to delete any
message threads that mentioned his name. Trader A complied with this directive.
C. Safi and Ge Require Kickbacks from Trader A in Exchange for Tips
45. After an initial grace period in which Trader A received tips and accumulated
trading profits, Safi addressed with Trader A the need for Trader A to make a payment, with Safi
explaining he would “pass on the gift,” meaning Safi needed to pay his sources for the inside
information tipped to Trader A.
46.  In or about August 2018, Safi specifically instructed Trader A to pay Safi
100,000 Euros as partial payment for their trading activity since June 2017. When Trader A
expressed concern to Safi over the size of the withdrawal, Safi directed Trader A that if he was
questioned by bank personnel, Trader A should lie and tell them that he needed the money for an
art deal or for gambling.
47. In or about September 2018, Safi instructed Trader A to meet him in Vienna,
Austria to make the payment.  Trader A traveled from the Czech Republic to Vienna and met
Safi at a café, giving him the money in a plastic bag.
48. In March 2020, Safi requested another payment from Trader A – this time for
$300,000. Ge also began communicating with Trader A to tell him to make the payment. Ge
directed Trader A to wire the funds to a bank in Hong Kong in the name of an associate of Safi
and Ge, so that the funds were not traceable to Safi or Ge. As a cover story for the payment, Ge
told Trader A to say it was a payment to an antique watch dealer that only accepted cash.
49. On or about April 1, 2020, Trader A made the $300,000 payment as directed by
Safi and Ge. Around this same time, Ge sent a DHL box containing a toy to Trader A’s home to
make it look like Trader A had in fact ordered something from overseas.

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D. Safi, Ge, and Trader A, on Multiple Occasions, Trade Together on Material
Nonpublic Information from Insider 1
50. Safi, Ge, and Trader A generated substantial profits purchasing the securities of
companies (including U.S.-traded companies) that were being targeted for acquisition, and/or for
which Safi and Ge had other confidential information that was likely to cause the stock price to
move, in advance of such information being disclosed to the public. This coordinated pattern of
insider trading specifically included, on information and belief, trading on material nonpublic
information obtained from Insider 1, who had timely, advance knowledge of the information in
the Atos and Worldline corporate announcements addressed below, while owing a duty to keep
such information confidential.
December 2017 Atos Offer to Acquire Gemalto
51. For example, in or about November 2017, Safi directly or indirectly tipped
material nonpublic information to Ge and Trader A in advance of the December 11, 2017
announcement by Atos that it had made an all-cash offer to acquire Gemalto, N.V. (“Gemalto”).
Gemalto was a cybersecurity company headquartered in the Netherlands that traded on the
Amsterdam Stock Exchange, with ADRs that traded over-the-counter in the United States under
the ticker symbol GTOMY. By November 1, 2017 (or earlier), Insider 1 had knowledge of the
contemplated Atos-Gemalto transaction.
52. In tipping Trader A, Safi described the material nonpublic information regarding
the still-secret plan for Atos to make an all-cash offer to acquire Gemalto as a “sniper” deal,
meaning that Safi had a high level of confidence the information was accurate and the expected
announcement would result in substantial trading profits for Safi, Ge, and Trader A.
53. On or about November 24, 2017, Safi began purchasing shares of Gemalto.

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54. On or about November 28, 2017, Trader A began purchasing U.S.-traded ADRs
of Gemalto, and then expanded his trading in Gemalto to include shares and foreign options
between November 29, 2017 and December 8, 2017.
55. On December 8, 2017 (a Friday), Trader A messaged a family member to whom
he had been passing along tips from Safi: “[L]ast chance to buy GTOMY before it takes off.”
56. On Monday, December 11, 2017, Atos announced a bid to acquire Gemalto, and
the price of Gemalto shares increased by 35%.
57. The same day, Trader A removed Safi as a “friend” on Facebook to conceal their
association.
58. As a result of his trading Gemalto securities based on inside information, Safi
realized approximately $225,000 in illicit trading profits from trading in equities.
59. As a result of his trading Gemalto securities based on inside information, Trader
A generated approximately $130,000 in illicit trading profits, comprised of approximately
$15,000 from trading Gemalto ADRs and $115,000 from trading in Gemalto shares and options.
Trader A also generated approximately $400,000 in illicit profits trading in Gemalto and
GTOMY through his spouse’s trading accounts, which he controlled.
60. On December 26, 2017, Ge sent a Facebook Messenger communication to Trader
A, saying: “Hope you’re good and hope you’re satisfied with the gift from [Safi] and I! ͧͨͩͪ”
Trader A responded: “[H]ey yeah bro, Merry Christmas... [M]ore to say but I won’t say it here
... but thank you, thank you, thank you.”
July 2018 Atos Offer to Acquire Syntel
61. Safi also directly or indirectly tipped material nonpublic information to Trader A
in advance of the July 22, 2018 announcement that Atos had agreed to acquire Syntel, Inc.
(“Syntel”), a U.S.-based IT services company traded on NASDAQ under the ticker symbol

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“SYNT.” Insider 1 had access to material nonpublic information concerning the transaction,
including, without limitation, in January, June, and July 2018.
62. On or about June 4, 2018, Trader A began buying Syntel call options through an
account in the name of his spouse.
63. On or about June 29, 2018, Trader began buying Syntel call options in his own
account(s) and purchased additional Syntel securities in or about early July 2018.
64. As a result of his trading Syntel securities based on inside information, Trader A
generated approximately $200,000 in illicit trading profits from trading in Syntel shares and
options. Trader A also generated approximately $210,000 in illicit profits trading in Syntel
shares and options through his spouse’s trading accounts, which he controlled.
October 2018 Atos Negative Earnings Announcement
65. In or about October 2018, Safi again directly or indirectly tipped Trader A with
material nonpublic information concerning the French company Atos – this time, that Atos
would soon announce lower-than-expected revenue growth and a reduced profit forecast for the
year.
66. In tipping Trader A, Safi described the negative earnings announcement from
Atos and told Trader A that it was a “sniper” – meaning that the nonpublic information about
Atos was highly likely to be accurate and Trader A could trade with confidence on the tip.
67. On October 22, 2018, Trader A used foreign accounts held in his spouse’s name
to purchase CFDs and options, anticipating that Atos’s stock price would decline.
68. On October 23, 2018, Atos issued negative earnings guidance. In the wake of the
announcement, the company’s stock price declined 22% by the end of the trading day.

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69. In total, Trader A realized approximately $110,000 in illicit profits from trading
around the Atos negative news, which was comprised of approximately $16,000 in CFD trading
profits and $94,000 in options trading profits in his spouse’s account.
January 2019 Atos Spinoff of Worldline Shares
70. In or about December 2018, Atos began discussions with Worldline to distribute
approximately half of Atos’s 50% ownership stake in Worldline to Atos shareholders through a
share distribution.
71. On or about December 12, 2018, Safi began buying Atos call options, and Trader
A began buying U.S.-traded Atos ADRs in an account in his mother’s name.
72. On December 13, 2018, Insider 1 received official notice that he was considered
an insider on the potential Atos/Worldline transaction.
73. On December 17, 2018, Trader A began purchasing Atos call options through an
account in his spouse’s name.
74. On January 9, 2019, Ge communicated with Trader A, advising Trader A that Ge
would write to Trader A “on other,” meaning Signal or Telegram.
75. On or about January 9, 2019, Ge began buying Atos call options, and on the
following day, January 10, 2019, Trader A bought Atos CFDs through an account in his spouse’s
name.
76. On January 14, 2019, Safi purchased Atos call options.  On the same day, Ge
added to his own options position in Atos and messaged another scheme participant, ordering
him to contact Ge as soon as possible and noting that “the business we are doing is very serious.”
This individual began purchasing call options in Atos on or about that same day.
77. On January 28, 2019, Trader A purchased U.S.-traded Atos ADRs (ticker symbol
AEXAY).

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78. Two days later, on January 30, 2019, Atos announced a plan to distribute a
portion of the share capital of Worldline to Atos investors, and that pursuant to this plan, “Atos’
shareholders [we]re expected to receive 2 Worldline shares for 5 Atos shares held.” Following
the announcement, the price of Atos shares closed about 5% higher than the prior trading day.
79. Also on January 30, 2019, Ge again messaged with the other scheme participant
referenced in paragraph 76 above, telling him not to make any independent moves (“[I]’ll
instruct you what to do”) and the next day ordered him to “start transferring the profits on my
share to your bank.” On February 1, 2019, Ge messaged this individual again to check on the
status of the profit transfer, stating: “I gotta collect from you asap gotta pay some peeps.”
80. As a result of his illicit trading of Atos securities based on inside information, Ge
generated approximately $240,000 in trading profits.
81. As a result of his illicit trading of Atos securities based on inside information,
Trader A generated approximately $40,000 in trading profits in accounts in his own name and in
his spouse’s name.
82. Safi did not generate profits from his above-described options trading in advance
of this announcement because those options positions were closed before January 30, 2019.
February 2020 Worldline Offer to Acquire Ingenico
83. In or about October 2019, Safi directly or indirectly tipped material nonpublic
information to Trader A in advance of the February 3, 2020 announcement that Worldline had
agreed to acquire French rival Ingenico Group SA (“Ingenico”), which traded on the Paris Stock
Exchange, with ADRs that traded over-the-counter in the United States under the ticker symbol
INGIY. Insider 1 had knowledge of the transaction by at least mid-October 2019.

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84. On or about October 14, 2019, Trader A began buying U.S-traded Ingenico ADRs
in his account and Ingenico options through his spouse’s trading accounts, which he controlled,
and continued to trade Ingenico securities for several months.
85. As a result of his trading Ingenico securities based on inside information, Trader
A generated approximately $120,000 in illicit trading profits comprised of approximately
$40,000 from trading Ingenico ADRs and $80,000 from trading Ingenico shares. Trader A also
generated approximately $460,000 in illicit profits trading in Ingenico through his spouse’s
trading accounts, which he controlled.
E. Safi, Ge, and Trader A Trade on Material Nonpublic Information from
Other Inside Source(s)
86. In addition to the above-described Atos and Worldline corporate announcements,
Safi and/or Ge traded on and/or covertly tipped material nonpublic information to Trader A in
advance of other corporate news and announcements, including but not limited to acquisition
offers for Medidata Solutions, Inc. (“Medidata”), Tiffany & Co. (“Tiffany”), and Wright Medical
Group N.V. (“Wright Medical”).
April 2019 Dassault Acquisition of Medidata Solutions
87. On November 22, 2018, Paris-based Dassault Systèmes SE (“Dassault”) entered
into a confidentiality agreement with Medidata related to a potential acquisition transaction. At
that time, Medidata was a technology company headquartered in New York and shares of
Medidata traded on NASDAQ (ticker symbol MDSO).
88. On February 15, 2019, after numerous board meetings, Dassault confirmed to
Medidata via a telephone call that it was interested in acquiring Medidata.

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89. On February 19, 2019, Trader A began buying shares of Medidata via accounts in
his name, his wife’s name, and the name of an entity held in his wife’s name. Then, two days
later, Trader A purchased shares of Medidata in his parents’ account.
90. In early April 2019, Ge reached out to his cousin to ask for money, telling him
that Ge was short on cash and that the “play” was happening soon.
91. On April 21, 2019, Bloomberg News published an article about a possible
purchase of Medidata by Dassault, and Medidata’s stock price increased by approximately 14%.
92. On or about May 1, 2019, Ge began buying Medidata call options. The following
week, Ge messaged another trader and instructed him to “get ready”; the trader then began
purchasing Medidata as Ge directed.
93. On May 14, 2019, Ge sent a message to Trader A asking how things were going.
Trader A responded that he was stressed but hoped “Maria” (code for Medidata) would “help
take a little stress off next week.”
94. On June 12, 2019, Dassault formally announced that it had made an offer for
Medidata at a 17% premium over the share price before the acquisition rumors began in mid-
April 2019. Medidata’s share price did not change significantly upon this announcement.
95. In total, Trader A generated approximately $110,000 in profits from illicit trading
in Medidata, including options trading in his own account and options and equity trading in his
wife’s account. Certain of these options trades were conducted on the BOX. Ge generated
approximately $40,000 in illicit profits from trading in Medidata options.
October 2019 LVMH Offer to Acquire Tiffany
96. On October 15, 2019, luxury goods conglomerate Louis Vuitton Moët Hennessy
(LVMH), headquartered in Paris, France, approached U.S. jewelry company Tiffany,

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headquartered in New York, New York and traded on the New York Stock Exchange under
ticker symbol TIF, with an unsolicited offer to acquire the company for $120 per share.
97. Trader A was in Ibiza in October 2019 when he was contacted via Telegram by
Safi, who urged him to look up TIF.
98. On or about October 22, 2019, Ge tried to call Trader A, but Trader A missed the
call. When Trader A reached out to Ge after missing the call, Ge wrote: “Let’s talk on other”
(meaning, on Signal or Telegram).
99. On or about October 24, 2019, Trader A sent a message to a friend saying:
“URGENT.  Buy Tiffany Co. symbol is TIF.  Load the fuckin’ truck up.”
100. On or about October 24, 2019, Ge, Safi, and Trader A began buying TIF.
101. On or about October 27, 2019 (a Sunday), news of the LVMH offer leaked to the
press and both Tiffany and LVMH subsequently confirmed that preliminary discussions had
taken place between the two companies regarding a possible transaction. On Monday, October
28, 2019, Tiffany’s stock price closed at around $129 per share, an increase of approximately
32% from the closing price on Friday, October 25, 2019.
102. In total, Trader A generated approximately $2,260,000 in illicit profits from
equity and options trading in Tiffany in his own account, and an additional $1,280,000 from
equity and options trading Tiffany in his wife’s accounts. Ge generated approximately
$1,660,000 in illicit profits from trading Tiffany CFDs and options. Safi generated
approximately $3,090,000 in illicit profits from trading in Tiffany options.
November 2019 Acquisition by Stryker of Wright Medical Group
103. Safi also tipped material nonpublic information to Trader A ahead of news that
medical technology company Stryker, headquartered in Kalamazoo, Michigan, would acquire

19
Wright Medical, a medical device company based at the time in Amsterdam, Netherlands, with
shares publicly traded on NASDAQ (ticker symbol WMGI).
104. On or about November 1, 2019, Safi, Ge, and Trader A all began buying Wright
Medical securities, including buying by Trader A in his wife’s account. The same day, Trader A
sent a message to his sibling, saying: “I loaded you up today on Wright Medical. $1m position.
It is up another 10% now in after-hours trading ♩♪♫♬♭♮♩♪♫♬♭♮♩♪♫♬♭♮♩♪♫♬♭♮♩♪♫♬♭♮/News out after market close
that Wright Medical is exploring a sale. Lucky timing on my bet ͧͨͩͪ.”
105. On November 1, 2019, post-market close, Bloomberg News published an
unconfirmed report regarding Wright Medical’s exploration of a potential sale.
106. On November 4, 2019, pre-market open, Stryker announced a definitive
agreement to acquire all of the issued and outstanding shares of Wright Medical for $30.75 per
share. Upon news of the acquisition, Wright Medical’s stock price increased $7.03 or 32%,
closing that day at $29.04 per share.
107. On or about the same day, Ge messaged Trader A “Yo bro” and Trader A
responded “yo yo yo, it’s Christmas time (:” and Ge replied “Yeah bro.”
108. In total, Trader A generated approximately $1,070,000 in illicit profits from
trading in Wright Medical, and his wife’s accounts generated approximately $150,000. Ge
generated approximately $1,100,000 and Safi generated approximately $565,000 in illicit profits
from trading in Wright Medical.
Late 2023/Early 2024: Trading Around Potential Novartis Acquisition of Cytokinetics
109. On or before September 25, 2023, the Swiss pharmaceutical company Novartis
AG (“Novartis”) expressed interest in acquiring Cytokinetics, Inc. (“Cytokinetics”), a San
Francisco-based biopharmaceutical company traded on NASDAQ (ticker symbol CYTK).

20
110. On or about September 29, 2023, Ge began buying Cytokinetics call options, and,
by October 5, 2023, Safi had also begun trading Cytokinetics call options.
111. On or about October 12, 2023, Ge and Safi exchanged messages via Telegram
about one of Ge’s recruits (the “Recruit”), with Safi stating: “Cytk | Tell him upside from here
120% | At leak 40% | We wanna exit at leak ... | And revisit the deal with options.”  On or about
the same day, the Recruit purchased Cytokinetics shares.
112. On the morning of October 31, 2023, Bloomberg News published an article
regarding takeover interest in Cytokinetics, and by the end of the day, the share price for CYTK
had increased by 9% from the prior day’s close.
113. On or about October 31, 2023, Safi and Ge sold nearly all of their Cytokinetics
call options for a profit, after the Bloomberg article was published.
114. On or about December 28, 2023, as part of continued merger discussions between
the companies, Novartis sent Cytokinetics a non-binding offer letter.
115. On or about January 6, 2024 (a Friday), Ge dispatched a Telegram message to the
Recruit, conveying material nonpublic information from Safi about the nature and timing of
anticipated Cytokinetics news: “Monday pre market | Tell him a strategic sell process | Has very
firm timelines ... And owners of Cytk are not amateurs is [Safi names investment firm].”  The
Recruit messaged Ge later that same day, asking “Hi bro guess nothing to do tonight? | Still on
track for Mon?” Ge responded by relaying additional information from Safi: “Bro tell [Recruit]|
We waiting if nova | Gies [sic] higher with bid | Because if leak comes | And we know that lets
say nova wins at 124 | And leak take it to 140 | We sell | Or if it takes it to 120 | We well [sic] the
short leg of the 125 call | Calls.”

21
116. On January 8, 2024, the Wall Street Journal reported that Novartis was in talks to
acquire Cytokinetics, and Cytokinetics shares increased by 15%, but two days later, the Journal
reported that Novartis was backing away from the Cytokinetics deal.
117. Safi and Ge made at least approximately $275,000 from trading Cytokinetics
securities based on material nonpublic information in or about January 2024.
118. Both Safi and Ge purchased Cytokinetics call options over the BOX Options
Exchange.
February 2024 Novartis Acquisition of MorphoSys
119. In December 2023, Novartis began exploring the possibility of acquiring
MorphoSys AG (“MorphoSys”), a German biotechnology company traded on the Frankfurt
Stock Exchange with ADRs traded on NASDAQ.
120. By January 3, 2024, Novartis had sent MorphoSys a non-binding acquisition
proposal, and, on January 15, 2024, Novartis sent MorphoSys a binding acquisition proposal to
purchase 100% of its stock for a 121% premium over its January 12, 2024 closing price.
121. On or about the following day, January 16, 2024, Ge and two of his associates
began buying MorphoSys call options and continued to do so over the course of the next two
days. A third associate of Ge began buying NASDAQ-traded MorphoSys ADRs on January 30,
2024.
122. On February 5, 2024, Novartis announced the acquisition of MorphoSys, and
MorphoSys’s stock price rose by approximately 50% over the next two days.
123. In total, Ge made approximately $3.8 million in illicit profits from trading in
MorphoSys options in advance of the Novartis acquisition announcement.

22
CLAIM FOR RELIEF
Violations of Section 10(b) of the Exchange Act and Rule 10b-5 Thereunder

124. The Commission re-alleges and incorporates by reference Paragraphs 1 through
123 above as if they were fully set forth herein.
125. Safi and Ge traded, and/or tipped other individuals to trade, securities while
aware, and on the basis, of material nonpublic information. Safi and Ge knew or recklessly
disregarded that such information was material and nonpublic. Safi and Ge also knew, recklessly
disregarded, should have known, or consciously avoided knowing that such material nonpublic
information had been conveyed and/or obtained in breach of a duty or obligation arising from a
similar relationship of trust or confidence.
126. By engaging in the conduct described above, Safi and Ge, directly or indirectly, in
connection with the purchase or sale of securities, by the use of means or instrumentalities of
interstate commerce, or of the mails, with scienter:
(a) employed devices, schemes, or artifices to defraud;

(b) made untrue statements of material fact or omitted to state material facts
necessary in order to make the statements made, in the light of the circumstances
under which they were made, not misleading; and

(c) engaged in acts, practices, or courses of business which operated or would operate
as a fraud or deceit upon other persons, including purchasers and sellers of
securities.

127. By reason of the actions alleged herein, Safi and Ge violated and, unless
restrained and enjoined, will continue to violate 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].

23
PRAYER FOR RELIEF
 WHEREFORE, the Commission respectfully requests that this Court enter a judgment:

I.
 Finding that Defendants Safi and Ge each violated 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];
II.
Permanently restraining and enjoining Defendants from violating 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] by
committing or engaging in specified actions or activities relevant to insider trading;
III.
Ordering each Defendant to disgorge, with prejudgment interest, all ill-gotten gains or
unjust enrichment derived from all actions alleged herein;
IV.
Ordering Defendants to pay civil monetary penalties pursuant to Section 21A of the
Exchange Act [15 U.S.C. § 78u-l];
V.
Retaining jurisdiction over this action to implement and carry out the terms of all orders
and decrees that may be entered; and
VI.
Granting such other and further relief as this Court may determine to be just and
appropriate.

Dated:  March 4, 2025

24
B
y:
Rua M. Kelly (Mass. Bar No. 643351)
Michael D. Foster (Ill. Bar No. 6257063)
U.S. Securities and Exchange Commission
Boston Regional Office
33 Arch Street, 24
th
 Floor
Boston, MA  02110
Kelly direct: (617)-573-8941
Email:  [email protected]
R
ua M. Kelly

UNITED STATES DISTRICT COURT  
DISTRICT OF MASSACHUSETTS 

 
 
SECURITIES AND EXCHANGE  
COMMISSION, 
 
  Plaintiff, 
 
 v. 
 
EAMMA SAFI and ZHI GE a/k/a JOSH GE, 
 
  Defendants.  

 
 
 
 
     Civil Action No. 25-cv- 
 
 
     JURY TRIAL DEMANDED 

 
      
 
     
 

  
 

COMPLAINT 

 Plaintiff United States Securities and Exchange Commission (“the Commission”) alleges 

as follows against Defendants Eamma Safi (“Safi”) and Zhi Ge a/k/a Josh Ge (“Ge”): 

SUMMARY OF THE ACTION 

1. From in or about 2017 through in or about 2024, Safi and Ge willfully 

participated in an international insider trading scheme that netted them millions in illicit profits 

from trading in advance of market-moving announcements. The scheme (the “Tipping Scheme”) 

involved tips that originated from persons known to Safi or his close associates.  

2. In the Tipping Scheme, Safi directly or indirectly obtained from insiders 

(including one or more sources at publicly traded companies) material nonpublic information 

about impending corporate transactions or other confidential information that could move the 

market, such as earnings announcements. Safi then tipped Ge as well as another individual 

(“Trader A”) recruited by Ge, and all three traded profitably on the tips of inside information. 

Safi and/or Ge demanded and received kickbacks of trading profits from Trader A in exchange 

for such information. 

3. Using the illegal tips, Safi and Ge – along with Trader A – generated millions in 

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illicit profits trading the securities of numerous companies, both through their individual trading 

accounts and through brokerage accounts in the names of other people and entities that were 

controlled by Safi, Ge, and/or Trader A.  

4. Safi and Ge knew or were reckless in not knowing they were trading while aware 

of and on the basis of material nonpublic information obtained from insiders at public companies 

and/or other sources owing a similar duty to maintain the confidentiality of such information.  

5. By knowingly or recklessly engaging in the conduct described in this Complaint, 

Defendants Safi and Ge violated, and unless restrained and enjoined will continue to violate, 

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. § 240.10b-5]. 

NATURE OF PROCEEDING AND RELIEF SOUGHT 

6. The Commission brings this action under Section 21(d) of the Exchange Act [15 

U.S.C. § 78u(d)]. The Commission seeks permanent injunctions against the Defendants, to 

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

this Complaint; disgorgement of profits realized from the unlawful trading set forth herein, along 

with prejudgment interest; and civil monetary penalties pursuant to Section 21A of the Exchange 

Act [15 U.S.C. § 78u-1], and for such other relief as the Court may deem just and appropriate. 

JURISDICTION AND VENUE 

7. This Court has jurisdiction over this action under Sections 21(d), 21(e), 21A, and 

27 of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), 78u-1, and 78aa]. Certain of the acts, 

practices, transactions, and courses of business constituting the violations made use of a means 

or instrumentality of interstate commerce, or of the mails, and/or of the facilities of national 

securities exchanges. 

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8. Venue in this District is proper under Section 27 of the Exchange Act [15 U.S.C. 

§ 78aa], because certain of the acts, practices, transactions, and courses of business constituting 

the violations alleged in this Complaint occurred in the District of Massachusetts. Among other 

things, certain of the options trades executed by Safi, Ge, and/or Trader A in connection with this 

scheme, including in Medidata Solutions, Inc. and Cytokinetics, Inc., were conducted through 

the BOX Options Exchange (BOX), located in Boston, Massachusetts. 

THE DEFENDANTS 

9. Safi, age 37, has resided in the United Arab Emirates and is a German citizen.  

Safi is the owner of Emallates.com FZE, and purportedly works in the information technology 

industry.   

10. Ge, age 34, is a Singapore citizen. Ge is the owner of Belleby Holdings Pte Ltd., 

which purportedly manages restaurants and real estate. 

OTHER RELEVANT INDIVIDUALS 

11. Trader A is a U.S.-based securities trader who obtained material nonpublic 

information from Safi and/or Ge, and, as described in greater detail herein, traded on that inside 

information. 

12. Safi’s Associate resides in France, previously worked in investment banking, and 

owned and operated a Paris restaurant in which Safi shared partial ownership (the “Paris 

restaurant”). 

13. Insider 1 resides in France and at times relevant to this Complaint worked in the 

M&A group of Atos S.E. (“Atos”) and then Worldline S.A. (“Worldline”), publicly traded 

companies based in France which previously were affiliated. Insider 1 was an investor in the 

Paris restaurant and previously worked with Safi’s Associate at a large investment bank. 

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TYPES OF SECURITIES TRADED 

14. In connection with the Tipping Scheme, Safi and Ge, along with Trader A and 

other tippees, established “long” positions in companies that were targeted for acquisition by 

purchasing shares of common stock, call options (a type of security that is typically purchased if 

the buyer believes the company’s stock price will increase),1 American depositary receipts, 

and/or contracts-for-difference.   

15. An American depositary receipt (“ADR”) is a certificate issued by a U.S. bank 

that represents a specified number of shares of a foreign company traded on a foreign exchange 

and held by the bank overseas. ADRs are priced and traded in U.S. dollars on U.S. stock 

exchanges comparable to shares of stock in domestic companies. ADRs allow investors to 

functionally trade foreign equities on U.S. exchanges. 

16. A contract-for-difference (“CFD”) is an agreement between two parties to 

exchange the difference in value of an underlying stock between the time the contract is opened 

and the time at which it is closed. If the share price of the underlying stock increases, the seller 

pays the difference to the buyer; however, if the share price declines, the buyer must pay the 

seller. A CFD related to a U.S.-listed company thus mirrors the movement and pricing of the 

underlying stock on a dollar-for-dollar basis. A CFD provider ordinarily hedges its exposure 

against a CFD buyer’s long position by purchasing (directly or indirectly) a corresponding 

number of shares of the underlying U.S. company on a U.S. exchange through domestic 

brokerage firms. 

  

 
1 A buyer who purchases a call option for a stock has the opportunity, but not the obligation, to buy that stock for a 
specific price known as the “strike price” for a predetermined period ending on the “expiration date.” 

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FACTUAL ALLEGATIONS 

17. Beginning in or about mid-2017, Trader A began receiving tips of material 

nonpublic information from Safi and/or Ge regarding public companies. Safi and/or Ge provided 

specific information, obtained directly or indirectly from corporate insiders and/or investment 

bankers, about upcoming announcements, including about earnings releases, acquisition offers, 

and/or other market-moving events expected to impact the share price of a publicly traded 

company. Safi and/or Ge further provided guidance about exactly when to buy securities of a 

given company, and, on occasion, directed Trader A to exit his investment if an anticipated 

announcement was no longer going to take place as expected. 

18.  In furtherance of the Tipping Scheme, Safi directly or indirectly leaked material 

nonpublic information to journalists and news outlets, so that Safi and other scheme participants 

could profitably trade around the market reaction to the publication of such information, rather 

than waiting to potentially profit from a corporate press release. Trader A understood from Safi 

that he had connections with persons writing articles about upcoming deals; on one or more 

occasions Safi previewed for Trader A that news related to a deal was coming out and later 

identified which news agency would publish it. 

19. As described below, Safi and/or Ge provided material nonpublic information 

about U.S.-based public companies, as well as foreign public companies traded on foreign 

exchanges with ADRs that traded on U.S. exchanges. 

A. Safi and Ge Recruit Trader A and Provide “Sample” Insider Trading Tip 

20. Safi and Ge have known each other since at least 2016.   

21. By at least November 2016, Safi began recruiting Ge into the Tipping Scheme, 

and, to that end, invited Ge to visit Safi and Safi’s Associate in Paris.  

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6 

22. On November 17, 2016, Safi messaged Ge (via Facebook Messenger) that 

“[Safi’s Associate] wants to see you this Friday,” adding that “Plan would be lunch and in the 

evening drinks.” When Ge made remarks about the short notice for this trip to Paris, given the 

need for flight and hotel arrangements, Safi noted “We are doing business.” After messaging 

further about Ge’s travel plans, Safi wrote to Ge: “Friday you will be welcomed to our world of 

business.”  

23. On or about November 19, 2016, Ge messaged Safi, asking “When do I meet 

[Safi’s Associate] today,” then adding “Can’t wait to get started.” After some more back and 

forth, with Safi indicating he needed to check the time of the meeting, Safi wrote: “So you will 

be 5:30 at the restaurant.”  Later that day, Ge sent a message to Safi confirming his arrival: “I’m 

at [name of the Paris Restaurant] already.” 

24. Also in November 2016, after the meeting at the Paris restaurant, Safi and Ge 

exchanged messages about recruiting more investors into the Tipping Scheme. Ge remarked to 

Safi that “this shit is easier than I thought… Everyone knows what’s up lol … I thought peeps 

are gonna be more apprehensive.” 

25. Safi and Ge began using code words to communicate about the Tipping Scheme.  

For example, “socks” and “shoes” were code for disposable (or “burner”) cell phones and SIM 

cards, while “greens” was code for money, and “games” and/or “races” were code words for 

forthcoming corporate announcements which were not yet public.   

26. On November 21, 2016, Ge told Safi that Ge was recruiting his mother’s friend 

into the Tipping Scheme, and they began discussing getting new “shoes” and “socks,” i.e., 

obtaining burner phones and new SIM cards to mask communications related to the scheme.  

Safi told Ge: “[N]ew socks and shoes is a must bro.” In messaging Ge about the need for both 

“socks” and “shoes,” Safi warned Ge that not changing burner cell phones and SIM cards was 

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7 

the “major mistake people do.” After being reminded by Safi to frequently change “shoes” and 

“socks,” Ge messaged Safi: “[I]’ll change after every game, okay?” 

27. On November 24, 2016, Safi and Ge continued to message about recruiting 

investors, and Safi alerted Ge that a “race” was on the way, meaning that he was in possession of 

nonpublic information about an upcoming corporate deal. Safi touted to Ge how much money 

they would make, telling Ge: “Millions are like 12 to 15 months away worst case… hundreds of 

K [meaning, thousands] … Just [a] few months.” Ge replied to Safi: “[L]et’s do it.” 

28. In or about December 2016, Safi traveled to Hong Kong and to Singapore so that 

he and Ge could recruit traders into the Tipping Scheme and provided some potential traders 

with a “sample” tip about an upcoming deal in a non-U.S. company.   

29. On January 8, 2017, Ge exchanged several messages with Safi and advised Safi 

that Ge was planning a trip to Los Angeles to “network … and exp[a]nd our business,” meaning 

the Tipping Scheme. 

30. In or around February 2017, Ge met Trader A at a social event in California and 

they struck up a friendship.   

31. On March 10, 2017, Ge sent Safi an electronic message explaining that he had 

become close to Trader A.   

32. Shortly thereafter, Ge shared what he described as a “free sample” tip with Trader 

A regarding a potential acquisition of Kindred Healthcare, Inc. (“Kindred”), which at that time 

was a U.S. company headquartered in Louisville, Kentucky. Kindred shares traded on the New 

York Stock Exchange under the ticker symbol KND.   

33. Based on Ge’s tip, Trader A purchased Kindred call options, but lost money on 

his investment because the call options that he purchased had too high of a “strike price.” 

Although the price of Kindred stock rose in response to the announcement of the acquisition, the 

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8 

stock price never reached the options’ strike price and thus expired worthless. Nevertheless, 

Trader A expressed interest in the Tipping Scheme. 

34. On or about June 17, 2017, Ge informed Trader A that he would arrange for 

Trader A to meet “his partners” and “dine at their restaurant” in Paris.  

35. On June 23, 2017, Ge messaged Safi to ask if he was in Paris because Trader A 

wished to visit and “he’s down for racing.” 

36. Over the next several days, Ge corresponded separately with Trader A and Safi 

about the arrangements for the meeting. 

37. On or about June 29, 2017, Safi and Trader A met as planned at the Paris 

restaurant. Safi’s Associate also attended. After dining together, Safi asked Trader A to discuss 

trading with him. As part of this discussion, Safi referenced having various sources of 

confidential information. Trader A agreed to join Safi’s trading group and to share 50% of his 

trading profits. 

38. On June 29, 2017, Ge messaged Trader A inquiring about the outcome of his 

meeting with Safi. Trader A responded the next day, stating that the meeting was great and 

thanking Ge for making the introduction. As part of this same message thread that day, Trader A 

asked Ge what the percentage is for “you guys” and Ge responded “50.  I told you 

haha…Promoters take 50% profit off the door sales;” Trader A responded, “…it works.”  Ge 

cautioned Trader A that “if he [meaning, Safi] told you something else there [meaning, in Paris] 

… [t]hat one would be the next one and it’ll be charged.”  Trader A responded: “Got it.”    

39. After Trader A joined the group, Safi encouraged him to “find insiders,” such as 

on Wall Street in New York City, and to refer other traders with resources to Safi. Ge likewise 

sought to recruit additional traders and insiders, once telling an associate that he “was looking for 

investment bankers in big banks working in M&A specifically.”  

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9 

B. Safi, Ge, and Trader A Establish Secret Communication Protocols 

40. When Ge and Trader A first exchanged electronic communications, they used 

Facebook Messenger to send messages back and forth. But before tipping Trader A about 

Kindred (the “free sample” tip), Ge asked Trader A to download Signal to communicate. Signal 

is a secure messaging application that uses end-to-end encryption, which allows communications 

to remain private as between senders and recipients. Ge introduced Trader A to Signal, and 

Trader A understood that its purpose was to keep communications confidential. 

41. After Trader A met Safi in Paris in June 2017 and agreed to participate in the 

Tipping Scheme, Safi provided further instructions to Trader A about how to communicate to 

ensure that any communications would remain private. Safi explained that all electronic 

messaging about the group’s trading should take place through disappearing messages on 

Telegram, a cloud-based application that stores user data in encrypted form and permits users to 

set messages or photographs to disappear within a period as short as minutes or seconds. Safi 

told Trader A to obtain a “burner” (or, disposable) phone, use it to activate Telegram, and then 

extract the SIM card from the burner phone and throw it in the trash.  

42. Safi also provided instructions to Trader A about how to communicate in code 

about their trading on material nonpublic information: all communications regarding public 

issuers would be disguised as conversations about women and/or girlfriends, and the issuers 

would be given female code names with a first letter that corresponded to the first letter of the 

company. For example, “Kindred” was coded as “Kelly” in the chats. 

43. As with Ge, Safi used code words with Trader A in communications about trading 

on material nonpublic information. In addition to “shoes,” “socks,” “greens,” and “races,” Safi, 

Ge, and Trader A also used the term “sniper” to refer to inside information that they considered 

especially strong and reliable, and thus likely to generate substantial trading profits.   

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10 

44. After they began trading together, Safi also directed Trader A to delete any 

message threads that mentioned his name. Trader A complied with this directive. 

C. Safi and Ge Require Kickbacks from Trader A in Exchange for Tips 

45. After an initial grace period in which Trader A received tips and accumulated 

trading profits, Safi addressed with Trader A the need for Trader A to make a payment, with Safi 

explaining he would “pass on the gift,” meaning Safi needed to pay his sources for the inside 

information tipped to Trader A.   

46.  In or about August 2018, Safi specifically instructed Trader A to pay Safi 

100,000 Euros as partial payment for their trading activity since June 2017. When Trader A 

expressed concern to Safi over the size of the withdrawal, Safi directed Trader A that if he was 

questioned by bank personnel, Trader A should lie and tell them that he needed the money for an 

art deal or for gambling. 

47. In or about September 2018, Safi instructed Trader A to meet him in Vienna, 

Austria to make the payment.  Trader A traveled from the Czech Republic to Vienna and met 

Safi at a café, giving him the money in a plastic bag.  

48. In March 2020, Safi requested another payment from Trader A – this time for 

$300,000. Ge also began communicating with Trader A to tell him to make the payment. Ge 

directed Trader A to wire the funds to a bank in Hong Kong in the name of an associate of Safi 

and Ge, so that the funds were not traceable to Safi or Ge. As a cover story for the payment, Ge 

told Trader A to say it was a payment to an antique watch dealer that only accepted cash. 

49. On or about April 1, 2020, Trader A made the $300,000 payment as directed by 

Safi and Ge. Around this same time, Ge sent a DHL box containing a toy to Trader A’s home to 

make it look like Trader A had in fact ordered something from overseas. 

 

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11 

D. Safi, Ge, and Trader A, on Multiple Occasions, Trade Together on Material 
Nonpublic Information from Insider 1 

50. Safi, Ge, and Trader A generated substantial profits purchasing the securities of 

companies (including U.S.-traded companies) that were being targeted for acquisition, and/or for 

which Safi and Ge had other confidential information that was likely to cause the stock price to 

move, in advance of such information being disclosed to the public. This coordinated pattern of 

insider trading specifically included, on information and belief, trading on material nonpublic 

information obtained from Insider 1, who had timely, advance knowledge of the information in 

the Atos and Worldline corporate announcements addressed below, while owing a duty to keep 

such information confidential. 

December 2017 Atos Offer to Acquire Gemalto 

51. For example, in or about November 2017, Safi directly or indirectly tipped 

material nonpublic information to Ge and Trader A in advance of the December 11, 2017 

announcement by Atos that it had made an all-cash offer to acquire Gemalto, N.V. (“Gemalto”).  

Gemalto was a cybersecurity company headquartered in the Netherlands that traded on the 

Amsterdam Stock Exchange, with ADRs that traded over-the-counter in the United States under 

the ticker symbol GTOMY. By November 1, 2017 (or earlier), Insider 1 had knowledge of the 

contemplated Atos-Gemalto transaction. 

52. In tipping Trader A, Safi described the material nonpublic information regarding 

the still-secret plan for Atos to make an all-cash offer to acquire Gemalto as a “sniper” deal, 

meaning that Safi had a high level of confidence the information was accurate and the expected 

announcement would result in substantial trading profits for Safi, Ge, and Trader A. 

53. On or about November 24, 2017, Safi began purchasing shares of Gemalto.   

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54. On or about November 28, 2017, Trader A began purchasing U.S.-traded ADRs 

of Gemalto, and then expanded his trading in Gemalto to include shares and foreign options 

between November 29, 2017 and December 8, 2017. 

55. On December 8, 2017 (a Friday), Trader A messaged a family member to whom 

he had been passing along tips from Safi: “[L]ast chance to buy GTOMY before it takes off.” 

56. On Monday, December 11, 2017, Atos announced a bid to acquire Gemalto, and 

the price of Gemalto shares increased by 35%. 

57. The same day, Trader A removed Safi as a “friend” on Facebook to conceal their 

association. 

58. As a result of his trading Gemalto securities based on inside information, Safi 

realized approximately $225,000 in illicit trading profits from trading in equities. 

59. As a result of his trading Gemalto securities based on inside information, Trader 

A generated approximately $130,000 in illicit trading profits, comprised of approximately 

$15,000 from trading Gemalto ADRs and $115,000 from trading in Gemalto shares and options. 

Trader A also generated approximately $400,000 in illicit profits trading in Gemalto and 

GTOMY through his spouse’s trading accounts, which he controlled. 

60. On December 26, 2017, Ge sent a Facebook Messenger communication to Trader 

A, saying: “Hope you’re good and hope you’re satisfied with the gift from [Safi] and I! ” 

Trader A responded: “[H]ey yeah bro, Merry Christmas… [M]ore to say but I won’t say it here 

… but thank you, thank you, thank you.” 

July 2018 Atos Offer to Acquire Syntel 

61. Safi also directly or indirectly tipped material nonpublic information to Trader A 

in advance of the July 22, 2018 announcement that Atos had agreed to acquire Syntel, Inc. 

(“Syntel”), a U.S.-based IT services company traded on NASDAQ under the ticker symbol 

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“SYNT.” Insider 1 had access to material nonpublic information concerning the transaction, 

including, without limitation, in January, June, and July 2018. 

62. On or about June 4, 2018, Trader A began buying Syntel call options through an 

account in the name of his spouse. 

63. On or about June 29, 2018, Trader began buying Syntel call options in his own 

account(s) and purchased additional Syntel securities in or about early July 2018. 

64. As a result of his trading Syntel securities based on inside information, Trader A 

generated approximately $200,000 in illicit trading profits from trading in Syntel shares and 

options. Trader A also generated approximately $210,000 in illicit profits trading in Syntel 

shares and options through his spouse’s trading accounts, which he controlled. 

October 2018 Atos Negative Earnings Announcement 

65. In or about October 2018, Safi again directly or indirectly tipped Trader A with 

material nonpublic information concerning the French company Atos – this time, that Atos 

would soon announce lower-than-expected revenue growth and a reduced profit forecast for the 

year.   

66. In tipping Trader A, Safi described the negative earnings announcement from 

Atos and told Trader A that it was a “sniper” – meaning that the nonpublic information about 

Atos was highly likely to be accurate and Trader A could trade with confidence on the tip.   

67. On October 22, 2018, Trader A used foreign accounts held in his spouse’s name 

to purchase CFDs and options, anticipating that Atos’s stock price would decline.   

68. On October 23, 2018, Atos issued negative earnings guidance. In the wake of the 

announcement, the company’s stock price declined 22% by the end of the trading day. 

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69. In total, Trader A realized approximately $110,000 in illicit profits from trading 

around the Atos negative news, which was comprised of approximately $16,000 in CFD trading 

profits and $94,000 in options trading profits in his spouse’s account. 

January 2019 Atos Spinoff of Worldline Shares 

70. In or about December 2018, Atos began discussions with Worldline to distribute 

approximately half of Atos’s 50% ownership stake in Worldline to Atos shareholders through a 

share distribution. 

71. On or about December 12, 2018, Safi began buying Atos call options, and Trader 

A began buying U.S.-traded Atos ADRs in an account in his mother’s name. 

72. On December 13, 2018, Insider 1 received official notice that he was considered 

an insider on the potential Atos/Worldline transaction.   

73. On December 17, 2018, Trader A began purchasing Atos call options through an 

account in his spouse’s name. 

74. On January 9, 2019, Ge communicated with Trader A, advising Trader A that Ge 

would write to Trader A “on other,” meaning Signal or Telegram.   

75. On or about January 9, 2019, Ge began buying Atos call options, and on the 

following day, January 10, 2019, Trader A bought Atos CFDs through an account in his spouse’s 

name. 

76. On January 14, 2019, Safi purchased Atos call options.  On the same day, Ge 

added to his own options position in Atos and messaged another scheme participant, ordering 

him to contact Ge as soon as possible and noting that “the business we are doing is very serious.” 

This individual began purchasing call options in Atos on or about that same day. 

77. On January 28, 2019, Trader A purchased U.S.-traded Atos ADRs (ticker symbol 

AEXAY). 

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78. Two days later, on January 30, 2019, Atos announced a plan to distribute a 

portion of the share capital of Worldline to Atos investors, and that pursuant to this plan, “Atos’ 

shareholders [we]re expected to receive 2 Worldline shares for 5 Atos shares held.” Following 

the announcement, the price of Atos shares closed about 5% higher than the prior trading day.   

79. Also on January 30, 2019, Ge again messaged with the other scheme participant 

referenced in paragraph 76 above, telling him not to make any independent moves (“[I]’ll 

instruct you what to do”) and the next day ordered him to “start transferring the profits on my 

share to your bank.” On February 1, 2019, Ge messaged this individual again to check on the 

status of the profit transfer, stating: “I gotta collect from you asap gotta pay some peeps.” 

80. As a result of his illicit trading of Atos securities based on inside information, Ge 

generated approximately $240,000 in trading profits. 

81. As a result of his illicit trading of Atos securities based on inside information, 

Trader A generated approximately $40,000 in trading profits in accounts in his own name and in 

his spouse’s name. 

82. Safi did not generate profits from his above-described options trading in advance 

of this announcement because those options positions were closed before January 30, 2019. 

February 2020 Worldline Offer to Acquire Ingenico 

83. In or about October 2019, Safi directly or indirectly tipped material nonpublic 

information to Trader A in advance of the February 3, 2020 announcement that Worldline had 

agreed to acquire French rival Ingenico Group SA (“Ingenico”), which traded on the Paris Stock 

Exchange, with ADRs that traded over-the-counter in the United States under the ticker symbol 

INGIY. Insider 1 had knowledge of the transaction by at least mid-October 2019. 

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84. On or about October 14, 2019, Trader A began buying U.S-traded Ingenico ADRs 

in his account and Ingenico options through his spouse’s trading accounts, which he controlled, 

and continued to trade Ingenico securities for several months.   

85. As a result of his trading Ingenico securities based on inside information, Trader 

A generated approximately $120,000 in illicit trading profits comprised of approximately 

$40,000 from trading Ingenico ADRs and $80,000 from trading Ingenico shares. Trader A also 

generated approximately $460,000 in illicit profits trading in Ingenico through his spouse’s 

trading accounts, which he controlled. 

E. Safi, Ge, and Trader A Trade on Material Nonpublic Information from 
Other Inside Source(s) 

86. In addition to the above-described Atos and Worldline corporate announcements, 

Safi and/or Ge traded on and/or covertly tipped material nonpublic information to Trader A in 

advance of other corporate news and announcements, including but not limited to acquisition 

offers for Medidata Solutions, Inc. (“Medidata”), Tiffany & Co. (“Tiffany”), and Wright Medical 

Group N.V. (“Wright Medical”). 

April 2019 Dassault Acquisition of Medidata Solutions 

87. On November 22, 2018, Paris-based Dassault Systèmes SE (“Dassault”) entered 

into a confidentiality agreement with Medidata related to a potential acquisition transaction. At 

that time, Medidata was a technology company headquartered in New York and shares of 

Medidata traded on NASDAQ (ticker symbol MDSO). 

88. On February 15, 2019, after numerous board meetings, Dassault confirmed to 

Medidata via a telephone call that it was interested in acquiring Medidata.   

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89. On February 19, 2019, Trader A began buying shares of Medidata via accounts in 

his name, his wife’s name, and the name of an entity held in his wife’s name. Then, two days 

later, Trader A purchased shares of Medidata in his parents’ account. 

90. In early April 2019, Ge reached out to his cousin to ask for money, telling him 

that Ge was short on cash and that the “play” was happening soon.   

91. On April 21, 2019, Bloomberg News published an article about a possible 

purchase of Medidata by Dassault, and Medidata’s stock price increased by approximately 14%. 

92. On or about May 1, 2019, Ge began buying Medidata call options. The following 

week, Ge messaged another trader and instructed him to “get ready”; the trader then began 

purchasing Medidata as Ge directed. 

93. On May 14, 2019, Ge sent a message to Trader A asking how things were going.  

Trader A responded that he was stressed but hoped “Maria” (code for Medidata) would “help 

take a little stress off next week.” 

94. On June 12, 2019, Dassault formally announced that it had made an offer for 

Medidata at a 17% premium over the share price before the acquisition rumors began in mid-

April 2019. Medidata’s share price did not change significantly upon this announcement. 

95. In total, Trader A generated approximately $110,000 in profits from illicit trading 

in Medidata, including options trading in his own account and options and equity trading in his 

wife’s account. Certain of these options trades were conducted on the BOX. Ge generated 

approximately $40,000 in illicit profits from trading in Medidata options. 

October 2019 LVMH Offer to Acquire Tiffany 

96. On October 15, 2019, luxury goods conglomerate Louis Vuitton Moët Hennessy 

(LVMH), headquartered in Paris, France, approached U.S. jewelry company Tiffany, 

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headquartered in New York, New York and traded on the New York Stock Exchange under 

ticker symbol TIF, with an unsolicited offer to acquire the company for $120 per share.   

97. Trader A was in Ibiza in October 2019 when he was contacted via Telegram by 

Safi, who urged him to look up TIF.   

98. On or about October 22, 2019, Ge tried to call Trader A, but Trader A missed the 

call. When Trader A reached out to Ge after missing the call, Ge wrote: “Let’s talk on other” 

(meaning, on Signal or Telegram).   

99. On or about October 24, 2019, Trader A sent a message to a friend saying: 

“URGENT.  Buy Tiffany Co. symbol is TIF.  Load the fuckin’ truck up.” 

100. On or about October 24, 2019, Ge, Safi, and Trader A began buying TIF. 

101. On or about October 27, 2019 (a Sunday), news of the LVMH offer leaked to the 

press and both Tiffany and LVMH subsequently confirmed that preliminary discussions had 

taken place between the two companies regarding a possible transaction. On Monday, October 

28, 2019, Tiffany’s stock price closed at around $129 per share, an increase of approximately 

32% from the closing price on Friday, October 25, 2019. 

102. In total, Trader A generated approximately $2,260,000 in illicit profits from 

equity and options trading in Tiffany in his own account, and an additional $1,280,000 from 

equity and options trading Tiffany in his wife’s accounts. Ge generated approximately 

$1,660,000 in illicit profits from trading Tiffany CFDs and options. Safi generated 

approximately $3,090,000 in illicit profits from trading in Tiffany options. 

November 2019 Acquisition by Stryker of Wright Medical Group 

103. Safi also tipped material nonpublic information to Trader A ahead of news that 

medical technology company Stryker, headquartered in Kalamazoo, Michigan, would acquire 

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Wright Medical, a medical device company based at the time in Amsterdam, Netherlands, with 

shares publicly traded on NASDAQ (ticker symbol WMGI). 

104. On or about November 1, 2019, Safi, Ge, and Trader A all began buying Wright 

Medical securities, including buying by Trader A in his wife’s account. The same day, Trader A 

sent a message to his sibling, saying: “I loaded you up today on Wright Medical. $1m position.  

It is up another 10% now in after-hours trading /News out after market close 

that Wright Medical is exploring a sale. Lucky timing on my bet .”   

105. On November 1, 2019, post-market close, Bloomberg News published an 

unconfirmed report regarding Wright Medical’s exploration of a potential sale. 

106. On November 4, 2019, pre-market open, Stryker announced a definitive 

agreement to acquire all of the issued and outstanding shares of Wright Medical for $30.75 per 

share. Upon news of the acquisition, Wright Medical’s stock price increased $7.03 or 32%, 

closing that day at $29.04 per share. 

107. On or about the same day, Ge messaged Trader A “Yo bro” and Trader A 

responded “yo yo yo, it’s Christmas time (:” and Ge replied “Yeah bro.” 

108. In total, Trader A generated approximately $1,070,000 in illicit profits from 

trading in Wright Medical, and his wife’s accounts generated approximately $150,000. Ge 

generated approximately $1,100,000 and Safi generated approximately $565,000 in illicit profits 

from trading in Wright Medical. 

Late 2023/Early 2024: Trading Around Potential Novartis Acquisition of Cytokinetics  

109. On or before September 25, 2023, the Swiss pharmaceutical company Novartis 

AG (“Novartis”) expressed interest in acquiring Cytokinetics, Inc. (“Cytokinetics”), a San 

Francisco-based biopharmaceutical company traded on NASDAQ (ticker symbol CYTK).   

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110. On or about September 29, 2023, Ge began buying Cytokinetics call options, and, 

by October 5, 2023, Safi had also begun trading Cytokinetics call options. 

111. On or about October 12, 2023, Ge and Safi exchanged messages via Telegram 

about one of Ge’s recruits (the “Recruit”), with Safi stating: “Cytk | Tell him upside from here 

120% | At leak 40% | We wanna exit at leak … | And revisit the deal with options.”  On or about 

the same day, the Recruit purchased Cytokinetics shares.   

112. On the morning of October 31, 2023, Bloomberg News published an article 

regarding takeover interest in Cytokinetics, and by the end of the day, the share price for CYTK 

had increased by 9% from the prior day’s close.   

113. On or about October 31, 2023, Safi and Ge sold nearly all of their Cytokinetics 

call options for a profit, after the Bloomberg article was published. 

114. On or about December 28, 2023, as part of continued merger discussions between 

the companies, Novartis sent Cytokinetics a non-binding offer letter. 

115. On or about January 6, 2024 (a Friday), Ge dispatched a Telegram message to the 

Recruit, conveying material nonpublic information from Safi about the nature and timing of 

anticipated Cytokinetics news: “Monday pre market | Tell him a strategic sell process | Has very 

firm timelines … And owners of Cytk are not amateurs is [Safi names investment firm].”  The 

Recruit messaged Ge later that same day, asking “Hi bro guess nothing to do tonight? | Still on 

track for Mon?” Ge responded by relaying additional information from Safi: “Bro tell [Recruit]| 

We waiting if nova | Gies [sic] higher with bid | Because if leak comes | And we know that lets 

say nova wins at 124 | And leak take it to 140 | We sell | Or if it takes it to 120 | We well [sic] the 

short leg of the 125 call | Calls.”   

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116. On January 8, 2024, the Wall Street Journal reported that Novartis was in talks to 

acquire Cytokinetics, and Cytokinetics shares increased by 15%, but two days later, the Journal 

reported that Novartis was backing away from the Cytokinetics deal. 

117. Safi and Ge made at least approximately $275,000 from trading Cytokinetics 

securities based on material nonpublic information in or about January 2024. 

118. Both Safi and Ge purchased Cytokinetics call options over the BOX Options 

Exchange. 

February 2024 Novartis Acquisition of MorphoSys 

119. In December 2023, Novartis began exploring the possibility of acquiring 

MorphoSys AG (“MorphoSys”), a German biotechnology company traded on the Frankfurt 

Stock Exchange with ADRs traded on NASDAQ.   

120. By January 3, 2024, Novartis had sent MorphoSys a non-binding acquisition 

proposal, and, on January 15, 2024, Novartis sent MorphoSys a binding acquisition proposal to 

purchase 100% of its stock for a 121% premium over its January 12, 2024 closing price.  

121. On or about the following day, January 16, 2024, Ge and two of his associates 

began buying MorphoSys call options and continued to do so over the course of the next two 

days. A third associate of Ge began buying NASDAQ-traded MorphoSys ADRs on January 30, 

2024. 

122. On February 5, 2024, Novartis announced the acquisition of MorphoSys, and 

MorphoSys’s stock price rose by approximately 50% over the next two days.  

123. In total, Ge made approximately $3.8 million in illicit profits from trading in 

MorphoSys options in advance of the Novartis acquisition announcement.   

  

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CLAIM FOR RELIEF 

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

124. The Commission re-alleges and incorporates by reference Paragraphs 1 through 

123 above as if they were fully set forth herein. 

125. Safi and Ge traded, and/or tipped other individuals to trade, securities while 

aware, and on the basis, of material nonpublic information. Safi and Ge knew or recklessly 

disregarded that such information was material and nonpublic. Safi and Ge also knew, recklessly 

disregarded, should have known, or consciously avoided knowing that such material nonpublic 

information had been conveyed and/or obtained in breach of a duty or obligation arising from a 

similar relationship of trust or confidence. 

126. By engaging in the conduct described above, Safi and Ge, directly or indirectly, in 

connection with the purchase or sale of securities, by the use of means or instrumentalities of 

interstate commerce, or of the mails, with scienter: 

(a) employed devices, schemes, or artifices to defraud; 
 

(b) made untrue statements of material fact or omitted to state material facts 
necessary in order to make the statements made, in the light of the circumstances 
under which they were made, not misleading; and 
 

(c) engaged in acts, practices, or courses of business which operated or would operate 
as a fraud or deceit upon other persons, including purchasers and sellers of 
securities.  

 
127. By reason of the actions alleged herein, Safi and Ge violated and, unless 

restrained and enjoined, will continue to violate 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].   

  

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PRAYER FOR RELIEF 

 WHEREFORE, the Commission respectfully requests that this Court enter a judgment: 
 

I. 

 Finding that Defendants Safi and Ge each violated 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]; 

II.  

Permanently restraining and enjoining Defendants from violating 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] by 

committing or engaging in specified actions or activities relevant to insider trading; 

III. 

Ordering each Defendant to disgorge, with prejudgment interest, all ill-gotten gains or 

unjust enrichment derived from all actions alleged herein; 

IV. 

Ordering Defendants to pay civil monetary penalties pursuant to Section 21A of the 

Exchange Act [15 U.S.C. § 78u-l]; 

V. 

Retaining jurisdiction over this action to implement and carry out the terms of all orders 

and decrees that may be entered; and  

VI. 

Granting such other and further relief as this Court may determine to be just and 

appropriate. 

 
Dated:  March 4, 2025  

  

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By: 
Rua M. Kelly (Mass. Bar No. 643351) 
Michael D. Foster (Ill. Bar No. 6257063) 
U.S. Securities and Exchange Commission 
Boston Regional Office 
33 Arch Street, 24th Floor 
Boston, MA  02110 
Kelly direct: (617)-573-8941 
Email:  [email protected] 

Rua M. Kelly

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