SEC v. Gabriel Rebeiz, No. 3:25-cv-00124, Southern District of California (Jan. 21, 2025) — Complaint

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STEPHEN T. KAM (Cal. Bar No. 327576)
Email:  [email protected]
SARA D. KALIN (Cal. Bar No. 212156)
Email:  [email protected]

Attorneys for Plaintiff
Securities and Exchange Commission

Joseph G. Sansone, Chief (Market Abuse Unit)
New York Regional Office
100 Pearl Street, Suite 20-100
New York, New York 10004-2616

Douglas M. Miller, Regional Trial Counsel
444 S. Flower Street, Suite 900
Los Angeles, California 90071
Telephone: (323) 965-3998
Facsimile: (213) 443-1904
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,

vs.
GABRIEL REBEIZ,
Defendant.
    Case    No.

COMPLAINT

Jury Trial Demanded

Plaintiff Securities and Exchange Commission (“SEC”) alleges:
SUMMARY
1. This case involves insider trading by Defendant Gabriel Rebeiz
(“Rebeiz” or “Defendant”) in the securities of Resonant Inc. (“Resonant”).  Rebeiz, a
technology consultant who served on Resonant’s Technical Advisory Committee (the
“TAC”), traded on material non-public information in advance of a February 14,
2022 public announcement (the “Announcement”) that a subsidiary of Murata
'25CV0124KSCBAS

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Manufacturing Ltd. (“Murata”) would acquire Resonant (the “Acquisition”).
2. Specifically, due to his role on the TAC, Rebeiz had access to
proprietary information relating to the quality of Resonant’s technology, which led
him to encourage management to sell the company.  In addition, a few weeks before
the Announcement, he spoke with a senior Resonant executive (“Resonant
Executive”), who made a statement to Rebeiz suggesting that there was an impending
acquisition.  The day after Rebeiz received this material non-public information, he
began purchasing Resonant shares.
3. As a result of the Announcement in February 2022, Resonant’s stock
price rose 257%, resulting in $360,673 in illegal trading profits for Rebeiz.
4. By engaging in the conduct alleged in this complaint, Defendant violated
Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”), 15 U.S.C. §
78j(b), and Rule 10b-5 promulgated under the Exchange Act, 17 C.F.R. § 240.10b-5.
The SEC seeks a permanent injunction, disgorgement of all ill-gotten gains, a civil
penalty, and an officer and director bar against Rebeiz.
JURISDICTION AND VENUE
5. The Court has jurisdiction over this action pursuant to Sections 21(d)(1),
21(d)(3)(A), 21A and 27(a) of the Exchange Act, 15 U.S.C. §§ 78u(d), 78u-1 & 78aa.
6. Defendant, directly or indirectly, made use of the means or
instrumentalities of interstate commerce, of the mails, or of the facilities of a national
securities exchange in connection with the transactions, acts, practices, and courses of
business alleged in this complaint.
7. Venue is proper in this district pursuant to Section 27(a) of the Exchange
Act, 15 U.S.C. § 78aa(a), because certain of the transactions, acts, practices, and
courses of conduct constituting violations of the federal securities laws occurred
within this district.  In addition, venue is proper in this district because Rebeiz resides
in this district.

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THE DEFENDANT
8. Gabriel Rebeiz, age 60, resides in La Jolla, California.  Rebeiz is an
electrical engineering professor at the University of California, San Diego, and has
been a consultant to several public companies that produce radio frequency filters.
He also co-founded Extreme Waves, LLC, a private entity in the radio frequency
industry.
RELEVANT ENTITIES AND INDIVIDUALS
9. Resonant Inc. was a Delaware company headquartered in Goleta,
California, until March 25, 2022, when it was acquired by a Murata subsidiary.
Resonant was founded in 2012, and designed radio frequency filters used by mobile
handset and wireless devices.  In 2014, it became an SEC-reporting company quoted
on the NASDAQ Stock Market under the symbol “RESN,” and had shares registered
pursuant to Section 12(b) of the Exchange Act.
10. Murata Manufacturing Co. Ltd., a Japanese company with its
principal place of business in Kyoto, Japan, is a global leader in radio frequency
modules and filters.  Murata’s shares trade on the Tokyo Stock Exchange and the
Singapore Exchange.  Murata is not an SEC-reporting company.  Its shares and
ADRs trade on OTC Markets Group.
11. Resonant Executive was a senior executive at Resonant from
approximately 2019-2022.
THE ALLEGATIONS
A. Rebeiz’s Role at Resonant
12. Resonant’s business involves designing and helping customers design
radio frequency filters for mobile and wireless devices.
13. In early 2021, Resonant formed the TAC with the goal of having outside
persons assess its technology and provide feedback.
14. Rebeiz is an electrical engineer in the field of radio frequency filters who
joined the TAC on or about February 9, 2021.

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15. As part of joining the committee, Rebeiz signed an offer letter agreeing
that he would not exploit the company’s nonpublic information for his own benefit
(the “Offer Letter”).
16. By signing the Offer Letter, Rebeiz understood that he was considered
an insider who was not allowed to trade on inside information.
B. Rebeiz Learns Proprietary Information About Resonant Technology
17. Prior to joining the TAC, Rebeiz did not know the quality of Resonant’s
technology.
18. Upon attending his first TAC meeting in March 2021, where he had
access to technical data that was not available to the public, Rebeiz learned
confidential and proprietary information regarding Resonant’s technology.
19. Following this March 2021 meeting, Rebeiz told Resonant executives
that he was impressed with the technology and encouraged Resonant executives to
sell the company to Murata or another large competitor based on the quality of
Resonant’s technology and its stage of development.
20. During an October 2021 TAC meeting, Rebeiz learned updated
proprietary information about Resonant’s technology, including its performance in
certain tests, and its positive performance compared to the technology of competitor
companies.  After the meeting, Rebeiz reiterated to Resonant executives that
Resonant’s technology was mature and encouraged them to sell the company to a
larger company.
C. Resonant’s Merger Discussions
21. Between October 2021 and February 2022, Resonant began seriously
exploring the idea of selling itself to another company.
22. Resonant Executive was involved in this process, but Rebeiz was not.
D. Rebeiz’s Receipt of Material Non-Public Information and Trading in
Advance of the Announcement
23. On January 19, 2022, the TAC met for the last time.  During the

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meeting, Resonant executives told members of the committee that the company no
longer needed input from the TAC on its current technology.
24. At the meeting, Rebeiz told Resonant executives that Murata should buy
Resonant.
25. About two hours after the meeting, Rebeiz called Resonant Executive for
the first time in a month.  During their call, Rebeiz repeated his opinion that Resonant
should sell itself.
26. In response, Resonant Executive indicated to Rebeiz that “something is
going to happen,” suggesting that Resonant was, in fact, on the verge of selling itself.
27. On January 20, 2022 – the day after the last TAC meeting and his
discussion with Resonant Executive – Rebeiz purchased 60,000 shares of Resonant
stock at $1.42 per share, worth $85,200, in breach of the duty he owed Resonant as a
member of the TAC and in breach of the Offer Letter he signed.
28. Prior to purchasing Resonant stock on January 20, 2022, Rebeiz had not
purchased or sold any security since July 2020.  He had not even accessed his
brokerage account since September 2021.
29. The next day, Rebeiz purchased an additional 30,000 shares at $1.30 per
share worth $39,000, in breach of the duty he owed Resonant as a member of the
TAC and in breach of the Offer Letter he signed.
30. On February 4, 2022, Rebeiz purchased another 30,000 shares at an
average price of $1.40 per share, worth $41,927, in breach of the duty he owed
Resonant as a member of the TAC and in breach of the Offer Letter he signed.
31. In total, Rebeiz purchased 120,000 shares for $166,127.
32. On February 14, 2022, Resonant announced that it was being acquired
by a subsidiary of Murata.
33. After the Announcement, Resonant’s stock price closed at $4.39 per
share – a 257% increase resulting in Rebeiz generating trading profits of $360,673.

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E. Rebeiz Acted With Scienter
34. Rebeiz acted with scienter when he traded Resonant securities on the
basis of material non-public information.
35. Rebeiz knew or was reckless in not knowing that he was subject to the
terms of the Offer Letter, which prohibited him from exploiting Resonant’s
confidential information for his own benefit.
36. Rebeiz knew or was reckless in not knowing that he owed a duty to
Resonant.
37. Rebeiz knew or was reckless in not knowing that the information he
received in his role on the TAC regarding Resonant’s technological capabilities,
product maturity, that the TAC would no longer be assessing Resonant’s current
technology, and Resonant Executive’s response to his comment about Resonant
selling itself was material non-public information.
38. Rebeiz knew or was reckless in not knowing that he breached his duty to
Resonant by purchasing Resonant shares while aware of and on the basis of this
material non-public information.
FIRST 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
39. The SEC realleges and incorporates by reference paragraphs 1 through
38 above.
40. By engaging in the conduct described above, Defendant Rebeiz, directly
or indirectly, in connection with the purchase or sale of a security, by the use of
means or instrumentalities of interstate commerce, of the mails, or of the facilities of
a national securities exchange: (a) employed devices, schemes, or artifices to defraud;
(b) 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; or (c) engaged in acts, practices, or

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courses of business which operated or would operate as a fraud or deceit upon other
persons.
41. By engaging in the conduct described above, Defendant Rebeiz violated,
and unless restrained and enjoined will continue to violate, Section 10(b) of the
Exchange Act, 15 U.S.C. § 78j(b), and Rules 10b-5 thereunder, 17 C.F.R. § 240.10b-
5.
PRAYER FOR RELIEF
WHEREFORE, the SEC respectfully requests that the Court:
I.
Issue findings of fact and conclusions of law that Defendant committed the
alleged violations.
II.
Issue a judgment, in a form consistent with Rule 65(d) of the Federal Rules of
Civil Procedure permanently enjoining Defendant Rebeiz and his officers, agents,
servants, employees and attorneys, and those persons in active concert or
participation with any of them, who receive actual notice of the judgment by personal
service or otherwise, and each of them, 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.
III.
Order Defendant Rebeiz to disgorge all funds received from his illegal conduct,
together with prejudgment interest thereon pursuant to Exchange Act Sections
21(d)(5) and 21(d)(7), 15 U.S.C. §§ 78u(d)(5), 78u(d)(7).
IV.
Order Defendant Rebeiz to pay a civil penalty under Section 21A of the
Exchange Act, 15 U.S.C. § 78u-1.
V.
Enter an order against Defendant Rebeiz pursuant to Section 21(d)(2) of the
Exchange Act, 15 U.S.C. § 78u(d)(2), prohibiting him from acting as an officer or

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director of any issuer that has a class of securities registered pursuant to Section 12 of
the Exchange Act, 15 U.S.C. § 78l, or that is required to file reports pursuant to
Section 15(d) of the Exchange Act, 78 U.S.C. § 78o(d).
VI.
Retain jurisdiction of this action in accordance with the principles of equity and
the Federal Rules of Civil Procedure in order to implement and carry out the terms of
all orders and decrees that may be entered, or to entertain any suitable application or
motion for additional relief within the jurisdiction of this Court.
VII.
Grant such other and further relief as this Court may determine to be just and
necessary.

Dated:  January 21, 2025
  /s/ Stephen Kam
Stephen Kam
Sara D. Kalin
Attorneys for Plaintiff
Securities and Exchange Commission

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INTELLECTUAL
San Diego
Securities and Exchange Commission
Stephen Kam and Sara D. Kalin
Securities and Exchange Commission, 444 S. Flower St.,
Ste. 900, Los Angeles, CA 90071, Tel:  323-965-3998
Gabriel Rebeiz
Jason L. Liang
Liang Ly LLP, 601 S. Figueroa St., Ste. 1950, Los Angeles,
CA 90071, Tel:  213-262-8000
✖
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15 U.S.C. § 78j(b), 17 C.F.R. § 240.10b-5
Complain alleges violations of federal securities laws.
✖
✖
Jan 21, 2025/s/ Stephen Kam
'25CV0124KSCBAS

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STEPHEN T. KAM (Cal. Bar No. 327576) 
Email:  [email protected] 
SARA D. KALIN (Cal. Bar No. 212156) 
Email:  [email protected] 
 
Attorneys for Plaintiff 
Securities and Exchange Commission  
 
Joseph G. Sansone, Chief (Market Abuse Unit) 
New York Regional Office 
100 Pearl Street, Suite 20-100 
New York, New York 10004-2616 
 
Douglas M. Miller, Regional Trial Counsel 
444 S. Flower Street, Suite 900 
Los Angeles, California 90071 
Telephone: (323) 965-3998 
Facsimile: (213) 443-1904 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF CALIFORNIA 

SECURITIES AND EXCHANGE 
COMMISSION, 

Plaintiff, 
 

vs. 

GABRIEL REBEIZ, 

Defendant. 

 Case No. 
 
 
COMPLAINT 
 
 
Jury Trial Demanded 

 
Plaintiff Securities and Exchange Commission (“SEC”) alleges: 

SUMMARY 

1. This case involves insider trading by Defendant Gabriel Rebeiz 

(“Rebeiz” or “Defendant”) in the securities of Resonant Inc. (“Resonant”).  Rebeiz, a 

technology consultant who served on Resonant’s Technical Advisory Committee (the 

“TAC”), traded on material non-public information in advance of a February 14, 

2022 public announcement (the “Announcement”) that a subsidiary of Murata 

'25CV0124 KSCBAS

Case 3:25-cv-00124-BAS-KSC     Document 1     Filed 01/21/25     PageID.1     Page 1 of 8



 

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Manufacturing Ltd. (“Murata”) would acquire Resonant (the “Acquisition”).   

2. Specifically, due to his role on the TAC, Rebeiz had access to 

proprietary information relating to the quality of Resonant’s technology, which led 

him to encourage management to sell the company.  In addition, a few weeks before 

the Announcement, he spoke with a senior Resonant executive (“Resonant 

Executive”), who made a statement to Rebeiz suggesting that there was an impending 

acquisition.  The day after Rebeiz received this material non-public information, he 

began purchasing Resonant shares. 

3. As a result of the Announcement in February 2022, Resonant’s stock 

price rose 257%, resulting in $360,673 in illegal trading profits for Rebeiz. 

4. By engaging in the conduct alleged in this complaint, Defendant violated 

Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”), 15 U.S.C. § 

78j(b), and Rule 10b-5 promulgated under the Exchange Act, 17 C.F.R. § 240.10b-5.  

The SEC seeks a permanent injunction, disgorgement of all ill-gotten gains, a civil 

penalty, and an officer and director bar against Rebeiz. 

JURISDICTION AND VENUE 

5. The Court has jurisdiction over this action pursuant to Sections 21(d)(1), 

21(d)(3)(A), 21A and 27(a) of the Exchange Act, 15 U.S.C. §§ 78u(d), 78u-1 & 78aa. 

6. Defendant, directly or indirectly, made use of the means or 

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

securities exchange in connection with the transactions, acts, practices, and courses of 

business alleged in this complaint.  

7. Venue is proper in this district pursuant to Section 27(a) of the Exchange 

Act, 15 U.S.C. § 78aa(a), because certain of the transactions, acts, practices, and 

courses of conduct constituting violations of the federal securities laws occurred 

within this district.  In addition, venue is proper in this district because Rebeiz resides 

in this district. 

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THE DEFENDANT 

8. Gabriel Rebeiz, age 60, resides in La Jolla, California.  Rebeiz is an 

electrical engineering professor at the University of California, San Diego, and has 

been a consultant to several public companies that produce radio frequency filters.  

He also co-founded Extreme Waves, LLC, a private entity in the radio frequency 

industry. 

RELEVANT ENTITIES AND INDIVIDUALS 

9. Resonant Inc. was a Delaware company headquartered in Goleta, 

California, until March 25, 2022, when it was acquired by a Murata subsidiary.  

Resonant was founded in 2012, and designed radio frequency filters used by mobile 

handset and wireless devices.  In 2014, it became an SEC-reporting company quoted 

on the NASDAQ Stock Market under the symbol “RESN,” and had shares registered 

pursuant to Section 12(b) of the Exchange Act.  

10. Murata Manufacturing Co. Ltd., a Japanese company with its 

principal place of business in Kyoto, Japan, is a global leader in radio frequency 

modules and filters.  Murata’s shares trade on the Tokyo Stock Exchange and the 

Singapore Exchange.  Murata is not an SEC-reporting company.  Its shares and 

ADRs trade on OTC Markets Group.     

11. Resonant Executive was a senior executive at Resonant from 

approximately 2019-2022.   

THE ALLEGATIONS 

A. Rebeiz’s Role at Resonant 

12. Resonant’s business involves designing and helping customers design 

radio frequency filters for mobile and wireless devices. 

13. In early 2021, Resonant formed the TAC with the goal of having outside 

persons assess its technology and provide feedback.   

14. Rebeiz is an electrical engineer in the field of radio frequency filters who 

joined the TAC on or about February 9, 2021.   

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15. As part of joining the committee, Rebeiz signed an offer letter agreeing 

that he would not exploit the company’s nonpublic information for his own benefit 

(the “Offer Letter”).   

16. By signing the Offer Letter, Rebeiz understood that he was considered 

an insider who was not allowed to trade on inside information.   

B. Rebeiz Learns Proprietary Information About Resonant Technology  

17. Prior to joining the TAC, Rebeiz did not know the quality of Resonant’s 

technology.   

18. Upon attending his first TAC meeting in March 2021, where he had 

access to technical data that was not available to the public, Rebeiz learned 

confidential and proprietary information regarding Resonant’s technology.   

19. Following this March 2021 meeting, Rebeiz told Resonant executives 

that he was impressed with the technology and encouraged Resonant executives to 

sell the company to Murata or another large competitor based on the quality of 

Resonant’s technology and its stage of development.   

20. During an October 2021 TAC meeting, Rebeiz learned updated 

proprietary information about Resonant’s technology, including its performance in 

certain tests, and its positive performance compared to the technology of competitor 

companies.  After the meeting, Rebeiz reiterated to Resonant executives that 

Resonant’s technology was mature and encouraged them to sell the company to a 

larger company.    

C. Resonant’s Merger Discussions  

21. Between October 2021 and February 2022, Resonant began seriously 

exploring the idea of selling itself to another company.   

22. Resonant Executive was involved in this process, but Rebeiz was not. 

D. Rebeiz’s Receipt of Material Non-Public Information and Trading in 

Advance of the Announcement 

23. On January 19, 2022, the TAC met for the last time.  During the 

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meeting, Resonant executives told members of the committee that the company no 

longer needed input from the TAC on its current technology. 

24. At the meeting, Rebeiz told Resonant executives that Murata should buy 

Resonant.   

25. About two hours after the meeting, Rebeiz called Resonant Executive for 

the first time in a month.  During their call, Rebeiz repeated his opinion that Resonant 

should sell itself.   

26. In response, Resonant Executive indicated to Rebeiz that “something is 

going to happen,” suggesting that Resonant was, in fact, on the verge of selling itself.  

27. On January 20, 2022 – the day after the last TAC meeting and his 

discussion with Resonant Executive – Rebeiz purchased 60,000 shares of Resonant 

stock at $1.42 per share, worth $85,200, in breach of the duty he owed Resonant as a 

member of the TAC and in breach of the Offer Letter he signed. 

28. Prior to purchasing Resonant stock on January 20, 2022, Rebeiz had not 

purchased or sold any security since July 2020.  He had not even accessed his 

brokerage account since September 2021.   

29. The next day, Rebeiz purchased an additional 30,000 shares at $1.30 per 

share worth $39,000, in breach of the duty he owed Resonant as a member of the 

TAC and in breach of the Offer Letter he signed.   

30. On February 4, 2022, Rebeiz purchased another 30,000 shares at an 

average price of $1.40 per share, worth $41,927, in breach of the duty he owed 

Resonant as a member of the TAC and in breach of the Offer Letter he signed. 

31. In total, Rebeiz purchased 120,000 shares for $166,127.  

32. On February 14, 2022, Resonant announced that it was being acquired 

by a subsidiary of Murata.   

33. After the Announcement, Resonant’s stock price closed at $4.39 per 

share – a 257% increase resulting in Rebeiz generating trading profits of $360,673. 

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E. Rebeiz Acted With Scienter  

34. Rebeiz acted with scienter when he traded Resonant securities on the 

basis of material non-public information. 

35. Rebeiz knew or was reckless in not knowing that he was subject to the 

terms of the Offer Letter, which prohibited him from exploiting Resonant’s 

confidential information for his own benefit.   

36. Rebeiz knew or was reckless in not knowing that he owed a duty to 

Resonant.   

37. Rebeiz knew or was reckless in not knowing that the information he 

received in his role on the TAC regarding Resonant’s technological capabilities, 

product maturity, that the TAC would no longer be assessing Resonant’s current 

technology, and Resonant Executive’s response to his comment about Resonant 

selling itself was material non-public information. 

38. Rebeiz knew or was reckless in not knowing that he breached his duty to 

Resonant by purchasing Resonant shares while aware of and on the basis of this 

material non-public information. 

FIRST 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 

39. The SEC realleges and incorporates by reference paragraphs 1 through 

38 above. 

40. By engaging in the conduct described above, Defendant Rebeiz, directly 

or indirectly, in connection with the purchase or sale of a security, by the use of 

means or instrumentalities of interstate commerce, of the mails, or of the facilities of 

a national securities exchange: (a) employed devices, schemes, or artifices to defraud; 

(b) 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; or (c) engaged in acts, practices, or 

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courses of business which operated or would operate as a fraud or deceit upon other 

persons. 

41. By engaging in the conduct described above, Defendant Rebeiz violated, 

and unless restrained and enjoined will continue to violate, Section 10(b) of the 

Exchange Act, 15 U.S.C. § 78j(b), and Rules 10b-5 thereunder, 17 C.F.R. § 240.10b-

5. 

PRAYER FOR RELIEF 

WHEREFORE, the SEC respectfully requests that the Court: 

I. 

Issue findings of fact and conclusions of law that Defendant committed the 

alleged violations. 

II. 

Issue a judgment, in a form consistent with Rule 65(d) of the Federal Rules of 

Civil Procedure permanently enjoining Defendant Rebeiz and his officers, agents, 

servants, employees and attorneys, and those persons in active concert or 

participation with any of them, who receive actual notice of the judgment by personal 

service or otherwise, and each of them, 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. 

III. 

Order Defendant Rebeiz to disgorge all funds received from his illegal conduct, 

together with prejudgment interest thereon pursuant to Exchange Act Sections 

21(d)(5) and 21(d)(7), 15 U.S.C. §§ 78u(d)(5), 78u(d)(7).  

IV. 

Order Defendant Rebeiz to pay a civil penalty under Section 21A of the 

Exchange Act, 15 U.S.C. § 78u-1.  

V. 

Enter an order against Defendant Rebeiz pursuant to Section 21(d)(2) of the 

Exchange Act, 15 U.S.C. § 78u(d)(2), prohibiting him from acting as an officer or 

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director of any issuer that has a class of securities registered pursuant to Section 12 of 

the Exchange Act, 15 U.S.C. § 78l, or that is required to file reports pursuant to 

Section 15(d) of the Exchange Act, 78 U.S.C. § 78o(d). 

VI. 

Retain jurisdiction of this action in accordance with the principles of equity and 

the Federal Rules of Civil Procedure in order to implement and carry out the terms of 

all orders and decrees that may be entered, or to entertain any suitable application or 

motion for additional relief within the jurisdiction of this Court. 

VII. 

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

necessary. 

 

Dated:  January 21, 2025  

  /s/ Stephen Kam  
Stephen Kam 
Sara D. Kalin 
Attorneys for Plaintiff 
Securities and Exchange Commission 
 

 
 

Case 3:25-cv-00124-BAS-KSC     Document 1     Filed 01/21/25     PageID.8     Page 8 of 8



JS 44   (Rev. 03/24) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as 
provided by local rules of court.  This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the 
purpose of initiating the civil docket sheet.    (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF 
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

II.  BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff 
and One Box for Defendant) (For Diversity Cases Only)

1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4

of Business In This State

2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6 6
Foreign Country

IV.  NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury  - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC 
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))
140 Negotiable Instrument Liability 367 Health Care/ 400 State Reapportionment
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust

& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking
151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce
152 Recovery of Defaulted Liability 368 Asbestos Personal 835 Patent - Abbreviated 460 Deportation

Student Loans 340 Marine Injury Product New Drug Application 470 Racketeer Influenced and
(Excludes Veterans) 345 Marine Product Liability 840 Trademark Corrupt Organizations

153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR 880 Defend Trade Secrets 480 Consumer Credit
of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards Act of 2016 (15 USC 1681 or 1692)

160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending Act 485 Telephone Consumer
190 Other Contract Product Liability 380 Other Personal 720 Labor/Management SOCIAL SECURITY Protection Act
195 Contract Product Liability 360 Other Personal Property Damage Relations 861 HIA (1395ff) 490 Cable/Sat TV
196 Franchise Injury 385 Property Damage 740 Railway Labor Act 862 Black Lung (923) 850 Securities/Commodities/

362 Personal Injury - Product Liability 751 Family and Medical 863 DIWC/DIWW (405(g)) Exchange
Medical Malpractice Leave Act 864 SSID Title XVI 890 Other Statutory Actions

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation 865 RSI (405(g)) 891 Agricultural Acts
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 893 Environmental Matters
220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act FEDERAL TAX SUITS 895 Freedom of Information
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 870 Taxes (U.S. Plaintiff Act
240 Torts to Land 443 Housing/ Sentence or Defendant) 896 Arbitration
245 Tort Product Liability Accommodations 530 General 871 IRS—Third Party 899 Administrative Procedure
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION Act/Review or Appeal of

Employment Other: 462 Naturalization Application Agency Decision
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration 950 Constitutionality of

Other 550 Civil Rights Actions State Statutes
448 Education 555 Prison Condition

560 Civil Detainee -
Conditions of 
Confinement

V.  ORIGIN (Place an “X” in One Box Only)
1 Original

Proceeding 
2 Removed from

State Court
3 Remanded from

Appellate Court 
4 Reinstated or

Reopened
5 Transferred from

Another District
(specify)

6 Multidistrict
Litigation - 
Transfer

8  Multidistrict
Litigation -
Direct File

VI.  CAUSE OF ACTION
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

Brief description of cause:

VII.  REQUESTED IN
COMPLAINT:

CHECK IF THIS IS A CLASS ACTION
UNDER RULE 23, F.R.Cv.P. 

DEMAND $ CHECK YES only if demanded in complaint:
JURY DEMAND: Yes No

VIII.  RELATED CASE(S) 
          IF ANY (See instructions):

JUDGE DOCKET NUMBER

DATE SIGNATURE OF ATTORNEY OF RECORD

FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

26 USC 7609

INTELLECTUAL

San Diego

Securities and Exchange Commission

Stephen Kam and Sara D. Kalin 
Securities and Exchange Commission, 444 S. Flower St., 
Ste. 900, Los Angeles, CA 90071, Tel: 323-965-3998

Gabriel Rebeiz

Jason L. Liang 
Liang Ly LLP, 601 S. Figueroa St., Ste. 1950, Los Angeles, 
CA 90071, Tel: 213-262-8000

✖

✖

15 U.S.C. § 78j(b), 17 C.F.R. § 240.10b-5

Complain alleges violations of federal securities laws.

✖

✖

Jan 21, 2025 /s/ Stephen Kam

'25CV0124 KSCBAS

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2



JS 44 Reverse (Rev. 03/24)

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as 
required by law, except as provided by local rules of court.  This form, approved by the Judicial Conference of the United States in September 1974, is 
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet.  Consequently, a civil cover sheet is submitted to the Clerk of 
Court for each civil complaint filed.  The attorney filing a case should complete the form as follows: 

I.(a) Plaintiffs-Defendants.  Enter names (last, first, middle initial) of plaintiff and defendant.  If the plaintiff or defendant is a government agency, use   
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then 
the official, giving both name and title.

   (b) County of Residence.  For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the 
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land 
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.) 

   (c) Attorneys.  Enter the firm name, address, telephone number, and attorney of record.  If there are several attorneys, list them on an attachment, noting  
in this section "(see attachment)". 

II.   Jurisdiction.  The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings.  Place an "X" 
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below. 
United States plaintiff.  (1) Jurisdiction based on 28 U.S.C. 1345 and 1348.  Suits by agencies and officers of the United States are included here. 
United States defendant.  (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box. 
Federal question.  (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment 
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes 
precedence, and box 1 or 2 should be marked. 
Diversity of citizenship.  (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states.  When Box 4 is checked, the  
citizenship of the different parties must be checked.  (See Section III below; NOTE: federal question actions take precedence over diversity  
cases.) 

III.   Residence (citizenship) of Principal Parties.  This section of the JS 44 is to be completed if diversity of citizenship was indicated above.  Mark this 
section for each principal party. 

IV. Nature of Suit.  Place an "X" in the appropriate box.  If there are multiple nature of suit codes associated with the case, pick the nature of suit code  
that is most applicable.  Click here for: Nature of Suit Code Descriptions. 

V.  Origin.  Place an "X" in one of the seven boxes. 
Original Proceedings.  (1) Cases which originate in the United States district courts. 
Removed from State Court.  (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.   
Remanded from Appellate Court.  (3) Check this box for cases remanded to the district court for further action.  Use the date of remand as the filing 
date. 
Reinstated or Reopened.  (4) Check this box for cases reinstated or reopened in the district court.  Use the reopening date as the filing date. 
Transferred from Another District.  (5) For cases transferred under Title 28 U.S.C. Section 1404(a).  Do not use this for within district transfers or
multidistrict litigation transfers. 
Multidistrict Litigation – Transfer.  (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. 
Section 1407. 
Multidistrict Litigation – Direct File.  (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.  
PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7.  Origin Code 7 was used for historical records and is no longer relevant due to  
changes in statute. 

VI.  Cause of Action.  Report the civil statute directly related to the cause of action and give a brief description of the cause.  Do not cite jurisdictional  
statutes unless diversity.  Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service. 

VII.  Requested in Complaint.  Class Action.  Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P. 
Demand.  In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction. 
Jury Demand.  Check the appropriate box to indicate whether or not a jury is being demanded. 

VIII.   Related Cases.   This section of the JS 44 is used to reference related cases, if any.  If there are related cases, insert the docket  
numbers and the corresponding judge names for such cases. 

Date and Attorney Signature.  Date and sign the civil cover sheet. 

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