2026-03-31 sec-litreleases judgment 175 KB 9,529 chars

SEC v. Brent David Willis, No. 1:22-cv-02744, District of Colorado (Mar. 31, 2026) — Judgment

raw: SEC v. BRENT DAVID WILLIS

SEC v. BRENT DAVID WILLIS, No. 1:22-cv-02744 (Mar. 31, 2026)

Caption
Securities and Exchange Commission v. Brent David Willis

Enriched metadata

Scheme
insider-trading (95%)
Court
District of Colorado
Case No.
1:22-cv-02744
Outcome
settled
Civil penalty
$175,000
Classified insider-trading(confidence 95%). EDGAR detection: forms 4/3/5/144· recall 81% / precision 19%. detection rule →
Statutes
15 U.S.C. § 77q(a)15 U.S.C. § 78m(a)15 U.S.C. § 78l15 U.S.C. § 78o(d)15 U.S.C. § 77t(d)28 U.S.C. § 196128 U.S.C. § 300111 U.S.C. §52311 U.S.C. §523(a)17 C.F.R. § 243.100Sections 17(a)(2) and 17(a)(3) of the Securities ActSections 17(a)(2) and 17(a)(3) of the Securities ActSections 17(a)(2) and 17(a)(3) of the Securities ActSection 20(d) of the Securities Act
Parties
Securities and Exchange CommissionBrent David Willis
Keywords
finalordered adjudgedadjudged decreedfurther orderedentry finalcommissionshallbrent daviddavid willisgpg-tpo documentdocument usdcusdc coloradofurthersecuritiesordered

Extracted insights

Dollar amounts 3
  • $175K $175,000 $100K–$1M
  • $50K $50,000 $10K–$100K
  • $25K $25,000 $10K–$100K
Entities 3
  • person brent david willis
  • agency civil penalty of $175,000.00 to the securities and exchange commission
  • agency Securities and Exchange Commission
Triples 13
  • Securities and Exchange Commission filed Complaint
  • Brent David Willis consented to Court's jurisdiction
  • Brent David Willis consented to entry of Final Judgment
  • Brent David Willis is restrained from violating Sections 17(a)(2) and 17(a)(3) of the Securities Act of 1933
  • Brent David Willis is restrained from aiding and abetting violation of Section 13(a) of the Exchange Act and Regulation FD
  • Brent David Willis is enjoined from acting as officer or director of any issuer for 5 years
  • Brent David Willis shall pay civil penalty of $175,000.00 to the Securities and Exchange Commission
  • Brent David Willis shall transmit photocopies of evidence of payment to Commission's counsel
  • Brent David Willis relinquishes all legal and equitable right, title, and interest in such funds
  • Securities and Exchange Commission shall send funds paid to the United States Treasury
  • Securities and Exchange Commission may enforce Court's judgment for penalties
  • Brent David Willis shall pay post-judgment interest on any amounts due after 30 days
  • Brent David Willis shall comply with undertakings and agreements set forth in the Consent
Text layers
Extracted body text (9,529c)
1 

UNITED STATES DISTRICT COURT 
DISTRICT OF COLORADO 

SECURITIES AND EXCHANGE COMMISSION, 

Plaintiff, 
C.A. No. 22-cv-07244-GPG-TPO

v. 

BRENT DAVID WILLIS, 

Defendant. 

FINAL JUDGMENT AS TO DEFENDANT BRENT DAVID WILLIS 

The Securities and Exchange Commission having filed a Complaint and Defendant Brent 

David Willis (“Defendant”) having entered a general appearance; consented to the Court’s 

jurisdiction over Defendant and the subject matter of this action; consented to entry of this Final 

Judgment without admitting or denying the allegations of the Complaint (except as to 

jurisdiction and except as otherwise provided herein in paragraph [VI]); waived findings of fact 

and conclusions of law; and waived any right to appeal from this Final Judgment: 

I. 

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Defendant is 

permanently restrained and enjoined from violating Sections 17(a)(2) and 17(a)(3) of the 

Securities Act of 1933 (the “Securities Act”) [15 U.S.C. § 77q(a)(2), (3)] in the offer or sale of 

any security by the use of any means or instruments of transportation or communication in 

interstate commerce or by use of the mails, directly or indirectly: 

(2) to obtain money or property by means of any untrue statement of a material fact

or any omission of a material fact necessary in order to make the statements

Case No. 1:22-cv-02744-GPG-TPO     Document 104     filed 03/25/26     USDC Colorado 
pg 1 of 6



2 

made, in light of the circumstances under which they were made, not misleading; 

or 

(3) to engage in any transaction, practice, or course of business which operates or

would operate as a fraud or deceit upon the purchaser.

by, directly or indirectly, making any false or misleading statement, or disseminating any false or 

misleading documents, materials, or information, concerning matters relating to a decision by an 

investor or prospective investor to buy or sell securities of any company. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Final Judgment by personal service or otherwise:  (a) Defendant’s 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendant or with anyone described in (a). 

II. 

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant 

is permanently restrained and enjoined from aiding and abetting any violation of Section 13(a) of 

the Exchange Act [15 U.S.C. § 78m(a)] and Regulation FD [17 C.F.R. § 243.100, et seq.] 

thereunder by knowingly or recklessly providing substantial assistance to an issuer that privately 

discloses material nonpublic information to certain persons outside the issuer without 

simultaneously disclosing such information to the public. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Final Judgment by personal service or otherwise:  (a) Defendant’s 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

Case No. 1:22-cv-02744-GPG-TPO     Document 104     filed 03/25/26     USDC Colorado 
pg 2 of 6



3 

participation with Defendant or with anyone described in (a). 

III. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that pursuant to the 

Court’s inherent authority to fashion appropriate equitable relief in this matter, and Section 

21(d)(5) of the Exchange Act [15 U.S. Code § 78u] for the benefit of investors, Defendant is 

enjoined for a period of 5 years from the date of this Final Judgment from acting as an officer or 

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 [15 U.S.C. § 78o(d)]. 

IV. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant shall pay a 

civil penalty in the amount of $175,000.00 to the Securities and Exchange Commission pursuant 

to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)].  Defendant shall pay the penalty due 

of $175,000.00 in 4 installments to the Commission according to the following schedule: (1) 

$25,000.00 within 30 days of entry of this Final Judgment; (2) $50,000.00 within 90 days of 

entry of this Final Judgment; (3) $50,000.00 within 180 days of entry of this Final Judgment; and 

(4) $50,000.00 within one year of entry of this Final Judgment.  Payments shall be deemed made

on the date they are received by the Commission and shall be applied first to post judgment 

interest, which accrues pursuant to 28 U.S.C. § 1961 on any unpaid amounts due after 30 days of 

the entry of Final Judgment. Prior to making the final payment set forth herein, Defendant shall 

contact the staff of the Commission for the amount due for the final payment. 

If Defendant fails to make any payment by the date agreed and/or in the amount agreed 

according to the schedule set forth above, all outstanding payments under this Final Judgment, 

Case No. 1:22-cv-02744-GPG-TPO     Document 104     filed 03/25/26     USDC Colorado 
pg 3 of 6



4 

including post-judgment interest, minus any payments made, shall become due and payable 

immediately at the discretion of the staff of the Commission without further application to the 

Court. 

Defendant may transmit payment electronically to the Commission, which will provide 

detailed ACH transfer/Fedwire instructions upon request.   Payment may also be made directly 

from a bank account via Pay.gov through the SEC website at 

http://www.sec.gov/about/offices/ofm.htm.  Defendant may also pay by certified check, bank 

cashier’s check, or United States postal money order payable to the Securities and Exchange 

Commission, which shall be delivered or mailed to  

Enterprise Services Center 
Accounts Receivable Branch 
6500 South MacArthur Boulevard 
Oklahoma City, OK 73169 

 and shall be accompanied by a letter identifying the case title, civil action number, and name of 

this Court; Brent David Willis’s name as a defendant in this action; and specifying that payment 

is made pursuant to this Final Judgment.   

Defendant shall simultaneously transmit photocopies of evidence of payment and case 

identifying information to the Commission’s counsel in this action.  By making this payment, 

Defendant relinquishes all legal and equitable right, title, and interest in such funds and no part 

of the funds shall be returned to Defendant.  The Commission shall send the funds paid pursuant 

to this Final Judgment to the United States Treasury.  

The Commission may enforce the Court’s judgment for penalties by the use of all 

collection procedures authorized by law, including the Federal Debt Collection Procedures Act, 

28 U.S.C. § 3001 et seq., and moving for civil contempt for the violation of any Court orders 

issued in this action.  Defendant shall pay post-judgment interest on any amounts due after 30 

Case No. 1:22-cv-02744-GPG-TPO     Document 104     filed 03/25/26     USDC Colorado 
pg 4 of 6



5 

days of the entry of this Final Judgment pursuant to 28 USC § 1961.  

V. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Consent is 

incorporated herein with the same force and effect as if fully set forth herein, and that Defendant 

shall comply with all of the undertakings and agreements set forth therein. 

VI. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, solely for purposes of 

exceptions to discharge set forth in Section 523 of the Bankruptcy Code, 11 U.S.C. §523, the 

allegations in the complaint are true and admitted by Defendant, and further, any debt for 

disgorgement, prejudgment interest, civil penalty or other amounts due by Defendant under this 

Final Judgment or any other judgment, order, consent order, decree or settlement agreement 

entered in connection with this proceeding, is a debt for the violation by Defendant of the federal 

securities laws or any regulation or order issued under such laws, as set forth in Section 

523(a)(19) of the Bankruptcy Code, 11 U.S.C. §523(a)(19). 

VII. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that except as 

otherwise stated in this Final Judgment and the Consent of Defendant dated [March 25, 2026] 

(the “Consent”), which is incorporated herein with the same force and effect as if fully set forth 

herein, the Court hereby dismisses with prejudice all other claims and relief sought in this action 

based on the conduct alleged in the Complaint through the date of this Final Judgment.   

VIII. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that this Court shall 

retain jurisdiction of this matter for the purposes of enforcing the terms of this Final Judgment. 

Case No. 1:22-cv-02744-GPG-TPO     Document 104     filed 03/25/26     USDC Colorado 
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6 

Dated:  ______________, _____ 

____________________________________ 
Gordon P. Gallagher
UNITED STATES DISTRICT JUDGE 

March 25th 2026

______________ _________________________ _____________ ____________________________________ __
ordon P. Gaaaaaaaaaaaaallllllllllllllllllllllllllllagagagagagagagagagagagagaggheheheheheheheheheheheheherrrr

Case No. 1:22-cv-02744-GPG-TPO     Document 104     filed 03/25/26     USDC Colorado 
pg 6 of 6
OCR text (9,529c · textlayer · 95% conf)
1 

UNITED STATES DISTRICT COURT 
DISTRICT OF COLORADO 

SECURITIES AND EXCHANGE COMMISSION, 

Plaintiff, 
C.A. No. 22-cv-07244-GPG-TPO

v. 

BRENT DAVID WILLIS, 

Defendant. 

FINAL JUDGMENT AS TO DEFENDANT BRENT DAVID WILLIS 

The Securities and Exchange Commission having filed a Complaint and Defendant Brent 

David Willis (“Defendant”) having entered a general appearance; consented to the Court’s 

jurisdiction over Defendant and the subject matter of this action; consented to entry of this Final 

Judgment without admitting or denying the allegations of the Complaint (except as to 

jurisdiction and except as otherwise provided herein in paragraph [VI]); waived findings of fact 

and conclusions of law; and waived any right to appeal from this Final Judgment: 

I. 

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Defendant is 

permanently restrained and enjoined from violating Sections 17(a)(2) and 17(a)(3) of the 

Securities Act of 1933 (the “Securities Act”) [15 U.S.C. § 77q(a)(2), (3)] in the offer or sale of 

any security by the use of any means or instruments of transportation or communication in 

interstate commerce or by use of the mails, directly or indirectly: 

(2) to obtain money or property by means of any untrue statement of a material fact

or any omission of a material fact necessary in order to make the statements

Case No. 1:22-cv-02744-GPG-TPO     Document 104     filed 03/25/26     USDC Colorado 
pg 1 of 6



2 

made, in light of the circumstances under which they were made, not misleading; 

or 

(3) to engage in any transaction, practice, or course of business which operates or

would operate as a fraud or deceit upon the purchaser.

by, directly or indirectly, making any false or misleading statement, or disseminating any false or 

misleading documents, materials, or information, concerning matters relating to a decision by an 

investor or prospective investor to buy or sell securities of any company. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Final Judgment by personal service or otherwise:  (a) Defendant’s 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendant or with anyone described in (a). 

II. 

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant 

is permanently restrained and enjoined from aiding and abetting any violation of Section 13(a) of 

the Exchange Act [15 U.S.C. § 78m(a)] and Regulation FD [17 C.F.R. § 243.100, et seq.] 

thereunder by knowingly or recklessly providing substantial assistance to an issuer that privately 

discloses material nonpublic information to certain persons outside the issuer without 

simultaneously disclosing such information to the public. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Final Judgment by personal service or otherwise:  (a) Defendant’s 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

Case No. 1:22-cv-02744-GPG-TPO     Document 104     filed 03/25/26     USDC Colorado 
pg 2 of 6



3 

participation with Defendant or with anyone described in (a). 

III. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that pursuant to the 

Court’s inherent authority to fashion appropriate equitable relief in this matter, and Section 

21(d)(5) of the Exchange Act [15 U.S. Code § 78u] for the benefit of investors, Defendant is 

enjoined for a period of 5 years from the date of this Final Judgment from acting as an officer or 

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 [15 U.S.C. § 78o(d)]. 

IV. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant shall pay a 

civil penalty in the amount of $175,000.00 to the Securities and Exchange Commission pursuant 

to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)].  Defendant shall pay the penalty due 

of $175,000.00 in 4 installments to the Commission according to the following schedule: (1) 

$25,000.00 within 30 days of entry of this Final Judgment; (2) $50,000.00 within 90 days of 

entry of this Final Judgment; (3) $50,000.00 within 180 days of entry of this Final Judgment; and 

(4) $50,000.00 within one year of entry of this Final Judgment.  Payments shall be deemed made

on the date they are received by the Commission and shall be applied first to post judgment 

interest, which accrues pursuant to 28 U.S.C. § 1961 on any unpaid amounts due after 30 days of 

the entry of Final Judgment. Prior to making the final payment set forth herein, Defendant shall 

contact the staff of the Commission for the amount due for the final payment. 

If Defendant fails to make any payment by the date agreed and/or in the amount agreed 

according to the schedule set forth above, all outstanding payments under this Final Judgment, 

Case No. 1:22-cv-02744-GPG-TPO     Document 104     filed 03/25/26     USDC Colorado 
pg 3 of 6



4 

including post-judgment interest, minus any payments made, shall become due and payable 

immediately at the discretion of the staff of the Commission without further application to the 

Court. 

Defendant may transmit payment electronically to the Commission, which will provide 

detailed ACH transfer/Fedwire instructions upon request.   Payment may also be made directly 

from a bank account via Pay.gov through the SEC website at 

http://www.sec.gov/about/offices/ofm.htm.  Defendant may also pay by certified check, bank 

cashier’s check, or United States postal money order payable to the Securities and Exchange 

Commission, which shall be delivered or mailed to  

Enterprise Services Center 
Accounts Receivable Branch 
6500 South MacArthur Boulevard 
Oklahoma City, OK 73169 

 and shall be accompanied by a letter identifying the case title, civil action number, and name of 

this Court; Brent David Willis’s name as a defendant in this action; and specifying that payment 

is made pursuant to this Final Judgment.   

Defendant shall simultaneously transmit photocopies of evidence of payment and case 

identifying information to the Commission’s counsel in this action.  By making this payment, 

Defendant relinquishes all legal and equitable right, title, and interest in such funds and no part 

of the funds shall be returned to Defendant.  The Commission shall send the funds paid pursuant 

to this Final Judgment to the United States Treasury.  

The Commission may enforce the Court’s judgment for penalties by the use of all 

collection procedures authorized by law, including the Federal Debt Collection Procedures Act, 

28 U.S.C. § 3001 et seq., and moving for civil contempt for the violation of any Court orders 

issued in this action.  Defendant shall pay post-judgment interest on any amounts due after 30 

Case No. 1:22-cv-02744-GPG-TPO     Document 104     filed 03/25/26     USDC Colorado 
pg 4 of 6



5 

days of the entry of this Final Judgment pursuant to 28 USC § 1961.  

V. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Consent is 

incorporated herein with the same force and effect as if fully set forth herein, and that Defendant 

shall comply with all of the undertakings and agreements set forth therein. 

VI. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, solely for purposes of 

exceptions to discharge set forth in Section 523 of the Bankruptcy Code, 11 U.S.C. §523, the 

allegations in the complaint are true and admitted by Defendant, and further, any debt for 

disgorgement, prejudgment interest, civil penalty or other amounts due by Defendant under this 

Final Judgment or any other judgment, order, consent order, decree or settlement agreement 

entered in connection with this proceeding, is a debt for the violation by Defendant of the federal 

securities laws or any regulation or order issued under such laws, as set forth in Section 

523(a)(19) of the Bankruptcy Code, 11 U.S.C. §523(a)(19). 

VII. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that except as 

otherwise stated in this Final Judgment and the Consent of Defendant dated [March 25, 2026] 

(the “Consent”), which is incorporated herein with the same force and effect as if fully set forth 

herein, the Court hereby dismisses with prejudice all other claims and relief sought in this action 

based on the conduct alleged in the Complaint through the date of this Final Judgment.   

VIII. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that this Court shall 

retain jurisdiction of this matter for the purposes of enforcing the terms of this Final Judgment. 

Case No. 1:22-cv-02744-GPG-TPO     Document 104     filed 03/25/26     USDC Colorado 
pg 5 of 6



6 

Dated:  ______________, _____ 

____________________________________ 
Gordon P. Gallagher
UNITED STATES DISTRICT JUDGE 

March 25th 2026

______________ _________________________ _____________ ____________________________________ __
ordon P. Gaaaaaaaaaaaaallllllllllllllllllllllllllllagagagagagagagagagagagagaggheheheheheheheheheheheheherrrr

Case No. 1:22-cv-02744-GPG-TPO     Document 104     filed 03/25/26     USDC Colorado 
pg 6 of 6