SEC v. NORMAN V. MEIER, No. 1:24-cv-12602, District of Massachusetts (Oct. 11, 2024) — Complaint

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

UNITED STATES SECURITIES AND
EXCHANGE COMMISSION,

                        Plaintiff,

            v.

NORMAN V. MEIER,

                        Defendant,

and

TREUHAND, INC., NORMAN MEIER
INTERNATIONAL, INC. a/k/a NMI, INC.,
WINDECO CORPORATION, TEXXON OIL
CORP., AND INTERNATIONAL FINANCIAL
SERVICES, INC. a/k/a IFS, INC. a/k/a IFS, INC.
d/b/a IRM, INC.,

                        Relief Defendants.

     Civil Action No. 24-12602

     JURY TRIAL DEMANDED

COMPLAINT

 Plaintiff, United States Securities and Exchange Commission (“SEC” or “Commission”)
alleges as follows against Defendant Norman V. Meier (“Meier”) and Relief Defendants
Treuhand, Inc. (“Treuhand”), Norman Meier International, Inc. a/k/a NMI, Inc. (“NMI”),
Windeco Corporation (“Windeco”), Texxon Oil Corp. (“Texxon”), and International Financial
Services, Inc. a/k/a IFS, Inc. a/k/a IFS, Inc. d/b/a IRM, Inc. (“IFS”).
SUMMARY
1. Massachusetts resident Norman Meier orchestrated a years-long international
securities fraud.  From at least June 2015 to December 2023, Meier defrauded over 180
investors, mostly European, out of at least $7.9 million.  Meier engaged teams of cold callers in
Eastern Europe who used fake names to sell fake investments.  Meier’s scheme involved

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soliciting investments in companies that he created for purposes of defrauding investors.  Meier’s
scheme also involved soliciting investments in well-known public companies to which Meier and
his teams of cold callers had no real connection.
2. Meier’s victims wired funds to bank accounts in the United States that Meier
controlled.  Rather than investing funds as promised, Meier misappropriated the money for his
own use and to pay his overseas sales network to lure additional investors.  Meier and his sales
teams deceived investors into believing that the investors’ money was being sent to a financial
institution in the United States for investment in the United States.  Many of Meier’s victims
were German speaking.  Meier named one of his companies “Treuhand,” a German word akin to
“trust” or “escrow,” such that investors believed they were sending funds to a trust or escrow
account.  In reality, the Treuhand bank account was one of several that Meier used to steal
investor money and pay his sales network.
3. Meier also defrauded investors in the United States.  In 2015, Meier solicited
investments from an individual in California while Meier was living in California.  Meier
convinced the California investor to invest in three entities, including relief defendant Windeco.
The California investor wired a total of $12,500 to an account that Meier controlled.  Meier
failed to invest the money as he had promised, and instead misappropriated the investor’s money
for his own purposes.  Meier solicited investments from two other investors in California, also in
or around 2015.
VIOLATIONS
4. By virtue of the conduct alleged herein, Meier violated Sections 17(a)(1),
17(a)(2), and 17(a)(3) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77q(a)(1),
(2), and (3)], and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15
U.S.C. §78j(b)] and Rules 10b-5(a), (b), and (c) thereunder [17 C.F.R. §§240.10b-5(a), (b), and

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(c)].
NATURE OF THE PROCEEDING AND RELIEF SOUGHT
5. The Commission brings this action pursuant to the authority conferred upon it by
Section 20(b) of the Securities Act [15 U.S.C. §77t(b)] and Section 21(d)(1) of the Exchange Act
[15 U.S.C. §78u(d)(1)].
6. The Commission seeks a final judgment: (a) permanently enjoining Meier from
violating the federal securities laws by engaging in transactions, acts, practices, and courses of
business of the type alleged in this Complaint; (b) permanently enjoining Meier from, directly or
indirectly, including but not limited to, through any entity owned or controlled by him,
participating in the issuance, purchase, offer, or sale of any security, provided, however, that
such injunction shall not prevent him from purchasing or selling securities for his own personal
account; (c) barring Meier from acting as an officer or director of any public company, pursuant
to Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)] and Section 21(d)(2) of the Exchange
Act [15 U.S.C. § 78u(d)(2)]; (d) ordering Meier to disgorge any ill-gotten gains with
prejudgment interest thereon, pursuant to Sections 21(d)(5) and 21(d)(7) of the Exchange Act [15
U.S.C. §78u(d)(5) and (7)]; (e) ordering Treuhand, NMI, Windeco, Texxon, and IFS to disgorge
all unjust enrichment and/or ill-gotten gains, with prejudgment interest thereon; (f) ordering
Meier to pay a civil money penalty pursuant to Section 20(d) of the Securities Act [15 U.S.C.
§77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C. §78u(d)(3)]; and (g) ordering such
other and further relief the Court may deem just and proper.
DEFENDANT
7. Norman V. Meier (“Meier”), age 49, is a resident of Wakefield, Massachusetts.
Meier has held a U.S. passport since at least December 2014.  Meier is a native of Switzerland.
His first language is Swiss German (dialect of the German-speaking area of Switzerland).  Meier

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is the sole executive officer of relief defendants Treuhand, Inc. and Norman Meier International,
Inc. (also known as NMI, Inc.).
RELIEF DEFENDANTS
8. Treuhand, Inc. (“Treuhand”) incorporated in Massachusetts in December 2020,
listing Meier as an officer, and purports to have a principal place of business in Boston,
Massachusetts.  Treuhand has maintained bank accounts in the United States, including accounts
opened in Massachusetts.  Meier is the sole signatory on Treuhand’s bank accounts.
9. Norman Meier International, Inc., a/k/a NMI, Inc. (“NMI”) incorporated in
Massachusetts in June 2022, listing Meier as an officer, and purports to have a principal place of
business in Saugus, Massachusetts.  Meier is the sole signatory to one or more NMI bank
accounts.
10. Windeco Corporation (“Windeco”) incorporated in Nevada in 2013 and
purports to have a principal place of business in Las Vegas, Nevada.  Windeco has maintained
bank accounts in the United States.  Meier is the sole signatory to one or more Windeco bank
accounts.
11.  Texxon Oil Corp. (“Texxon”) incorporated in Nevada in August 2014 and
purports to have a principal place of business in Dallas, Texas.  Texxon has maintained bank
accounts in the United States.  On four occasions between August 2014 and January 2018, an
associate of Meier filed with the Commission Form D Notices of Exempt Offering of Securities
for Texxon pursuant to Rule 506(b) of Regulation D under Section 4(a)(2) of the Securities Act.
Meier is the sole signatory to one or more Texxon bank accounts.
12. International Financial Services (“IFS”) is an unincorporated entity and
purported financial services firm located in New York, New York.  Meier created and
maintained websites using a variation of “IFS,” including “ifs-global.com,” to deceive investors

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into believing that they were dealing with a legitimate Wall Street firm.  In March of 2022,
Germany’s Federal Financial Supervisory Authority (BaFin) issued a notice ordering IFS to
cease initiating unsolicited contact with former customers of a German based advisory firm.  IFS
has maintained at least one bank account in the United States.  Meier is the sole signatory to one
or more IFS bank accounts.  IFS and International Financial Services were names Meier ascribed
to his private equity selling network.
JURISDICTION AND VENUE
13. This Court has jurisdiction over this action pursuant to Sections 20(d)(1) and
22(a) of the Securities Act [15 U.S.C. §§77t(d)(1) and 77v(a)] and Sections 21(d), 21(e), and 27
of the Exchange Act [15 U.S.C. §§78u(d), 78u(e), 78aa].  Venue lies in this district pursuant to
Section 22(a) of the Securities Act [15 U.S.C. §77v(a)] and Section 27 of the Exchange Act [15
U.S.C. §78aa].  A substantial portion of the acts, practices, transactions and courses of business
alleged in this Complaint occurred within the District of Massachusetts.  Meier resides in this
district and controlled one or more bank accounts in this district where he received proceeds
from his scheme.  Meier used Treuhand and NMI, both businesses that he incorporated in
Massachusetts, to further his fraud.
14. In connection with the transactions, acts, practices, and courses of business
alleged in this Complaint, Defendant, directly or indirectly, singly or in concert with others,
made use of the means or instrumentalities of transportation or communication in interstate
commerce, or the mails.

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DEFENDANT’S ACTS IN VIOLATION OF THE FEDERAL SECURITIES LAWS
Meier’s Method of Investor Solicitation
15. In 2014, Meier published a book titled Create Wealth with Private Equity and
Public Companies – A Guide for Entrepreneurs and Investors.  Meier wrote of his dream “to
become a millionaire no matter what it took.”
16. Meier maintained among his corporate records various lists of his goals for the
years 2020 through 2023, which included to become a millionaire and to have “several homes
and real estate all over the world.”  In 2020, Meier aimed to create income streams from a
“Private Equity Organization” in Europe and to have $100,000 in monthly income from his
“Private Equity Business.”  Meier also listed a goal to be CEO of a public company.
17. Meier maintained a website called normanmeier.com.  On his website, Meier
described himself as being born and raised in Switzerland.  He claimed to have advanced degrees
from a university in Switzerland.  Meier claimed that he had been CEO of a publicly listed
company.  Meier described himself in a 2013 blog posting as having a huge client base in Europe
and North America and “a network all over the world.”
18. On his website, Meier described himself as an expert in raising investor funds
through private equity, which Meier described as raising money from investors in companies not
yet listed on a stock exchange.  Through normanmeier.com, Meier offered a training course
called “Private Equity Broker Training” for individuals to learn how to secure investors for
private equity investments.  Meier offered a “job opportunity” that first required “learn[ing] the
basics and go[ing] through our training program.”  In the program, a “trainee” would be expected
to “make phone calls to potential investors,” “generate at least 5 new leads per day,” and “learn
how to close a deal on the phone.”  After completing the training, “the trainee will receive a

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permanent job as a Private Equity Broker and will raise money every month for the sales
organization while earning commissions.”
19. Meier’s book Create Wealth includes a how-to guide for soliciting investors
through cold calling.  Meier gives suggestions on “general statements that help to convince
investors”, including:
 “If this train leaves, it is hard to get back on later.  And there is
not another one coming that is going where you want to go.”
 “If you sleep on it, you won’t be smarter tomorrow.  If you
knew what I know about his deal, you wouldn’t hesitate one
second.”
 “How much time do you need to think about it?  2 weeks?  So
are you going to think about it for 2 hours for the next 14 days?
So a total of 28 hours?  I don’t think so. That would be
ridiculous, right?  So how much real thinking time do you
really need?  One hour?  So let me help you right now.  If you
still need time, then I will call you tomorrow morning?”
 “I am sorry if I am putting too much pressure on you right now.
But you need to understand that you can buy a car and wait a
couple of weeks before you actually get it.  But when it comes
to stocks, one day or even one hour can make a difference
whether you make 100% return or only 1%.  That’s why I urge
you to act now.”
20. In Create Wealth, Meier described a hypothetical sales pitch for a cold call to a
potential investor:
Hi, I am calling from XYZ Company.  We would like to
introduce ourselves and our company to you.  We are a
company specializing in ABC investments and we help
companies go public.  We would like to send you some
general information about our company by email so that
you can see whether his could be of interest to you or not.
We are currently working on deal ABC that will go public
in 6 months and it is a very interesting investment
opportunity because we can currently offer the shares at
$0.50 and we expect the company to be value at $2.00
when it is listed . . . .

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21. Meier writes in his book that he was a stockbroker “in Europe and North
America” and that he “can teach you everything about getting international investors and how to
approach different markets.”  Meier’s book provides guidance on how to structure a sales team to
solicit investors by phone.  Meier describes paying salespeople an hourly wage and a
commission for cold calling and securing investors.
22. In describing the creation of a sales team, Meier writes in Create Wealth:
Based on the clients that you will target you could set up a
call center in a foreign country.  At one point we have only
targeted investors in the German speaking part of Europe
(Germany, Austria, and Switzerland) because the financial
potential was much better at the time than in America.

In Europe, a lot of people speak several languages.  We
have had a marketing team of women who call up clients in
Germany from an Eastern European country because the
costs of running an operation in those countries are much
cheaper.

Meier’s Commission Filings for Private Securities Offerings
23. Under Section 5 of the Securities Act, a company may not offer or sell securities
unless the offering has been registered with the Commission or an exemption from registration is
available.  Offerings that are exempted by Section 4(a)(2) of the Securities Act or its safe harbor
under the Commission rule “Regulation D” are referred to as private placements.  Companies
issuing securities in reliance on a Regulation D exemption are required to file with the
Commission a document called a Form D, which is available online to the public and contains
brief information about the company, its management and promoters, and the offering of
securities.
24. Meier signed a December 14, 2020 Form D filing with the Commission
concerning a private placement offering of securities of Discovery Gold, Inc. (“Discovery

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Gold”).  Meier is identified in the Form D as a director of Discovery Gold.  Discovery Gold
purported to be a Wyoming corporation with a principal place of business in New York, NY.
25. Meier signed a July 21, 2021 Form D filing with the Commission concerning a
private placement offering of securities of New Energy Systems, Inc. (“New Energy Systems”).
Meier is identified in the Form D as a director of New Energy Systems.  New Energy Systems
purported to be a Wyoming corporation with a principal place of business in New York, NY.
Overview of Meier’s Scheme
26. Meier began misappropriating money from investors as early as 2015.  In 2015, a
California resident met Meier while Meier was living in Carlsbad, California.  Meier convinced
the California resident to invest in three entities, including Windeco.  The California resident
sent two wires for purposes of investment, totaling $12,500, to an account that Meier controlled.
Meier, however, failed to invest the money as he had promised and instead misappropriated the
investor’s money for his own personal purposes.  Meier solicited investments from two other
investors in California, also in or around 2015.  Meier solicited the two additional California
investors to invest in Windeco and Texxon.  None of the California investors have received any
proceeds from their purported investments.
27. Between January 2017 and December 2023, U.S. bank accounts controlled by
Meier received approximately $7.9 million in proceeds from individuals in Europe.  The bank
accounts received the proceeds by wire and the wire instructions often specified the investment
purpose.  For instance, $301,748 arrived with wire instructions including the German word
“aktien” which translates to “stock” or “shares.”  Another $471,781 arrived with a notation for
“Discovery” or “Discovery Gold.”  A total of $247,767 arrived with a notation for “New Energy
Systems.”  A total of $523,572 arrived with a notation for “Barrick” or “Barrick Gold,” which is
a reference to a publicly traded mining company based in Canada.  Of the $7.9 million, Treuhand

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received $5,689,603, Windeco received $582,290, Texxon received $978,151, and IFS received
$690,328.  The Investor Proceeds arrived from bank accounts in Germany, Austria, and
Switzerland.
28. Meier did not direct the Investor Proceeds to investment purposes.  Instead, he
absconded with the investor proceeds for his own personal purposes including payments to
further his scheme.  Meier’s use of investor proceeds for his own purposes involved transferring
investor proceeds to his personal bank accounts or to NMI bank accounts, including accounts in
the United States.
29. Among Meier’s diversion of Investor Proceeds, Meier wired portions of the
proceeds to other individuals in Serbia and other overseas locations, who were not investors.
Those overseas payments were commissions or finder’s fees for securing victims of Meier’s
investment scheme.
30. Meier maintained a list of members of his “private equity teams and people”
which included individuals who received payments from accounts controlled by Meier.
31. Meier also maintained written goals for IFS, or “International Financial Services,”
which was the name that Meier ascribed to his private equity selling network.  Meier’s business
goals for “IFS/Private Equity” in 2020 included “Build a system to generate daily leads of
potential investors.”  His goals for 2022 included “IFS Private Equity Europe (Serbia).”  His
goals for 2023 included an “IFS USA: Hire people and start operations.”
32. In March 2020, Meier received an email from an individual representing a call
center in Ukraine.  Meier spoke with the Ukrainian call center representative and then sent an
email to her saying “I am very interested in working with you.”  He wrote that “we are mainly
dealing with German speaking clients.  Therefore, it would make most sense to start with a small
team of about 5 people who speak German very well and ideally without an accent.”

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33. Meier continued in his email to the Ukrainian call center representative:
The first call to a potential investor is a cold call.  A marketing
person calls up people in Germany and asks them if they are
interested in receiving our info material by email.  This potential
investor should be open and willing to listen and should have the
ability to invest at least $10,000.

The second call, which is a follow up sales call, can be done by our
sales team.  They will try to close the deal and get the person to
invest into the shares that we offer.

We typically sell shares of new companies that are not yet listed on
a stock exchange but plan to go public soon.

34. Meier also wrote to the Ukrainian call center representative that he would send
two projects to start: Windeco Gold Corporation and Global Energy Group, Inc.
35. Meier maintained a to do list for May 2020 which included “3 Fake news
websites”, including “Global Energy.”
36. In October 2021, Meier wrote to a graphic designer in Argentina to request
creation of IFS-branded factsheets “with a quick summary for each company and a STRONG
BUY recommendation.”  Meier requested factsheets for, among others, Discovery Gold and
Global Energy Group.
37. In his goals for 2022, Meier listed “peace of mind, legal businesses.”  He also
sought to “legally save.”  For 2023, Meier included under the category of “Business changes” his
goal of “only legal deals” and “IPO deal with real projects.”
38. Meier’s goals for 2022 and 2023 also included to “move money to other country,”
and “move $100,000 to Switzerland for additional safety from government, etc.”
39. In October 2019, Meier wrote of a goal to have one office “with sales people
where I work from every day,” but perhaps with a different name than IFS “due to negative
links, etc.”

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Examples of the Scheme
Investor 1
40. An investor, referred to herein as “Investor 1” is a German citizen and resident of
Germany.  Investor 1 is over 85 years old and is retired.  Investor 1 is a veteran of the German
Air Force.
41. In or about April 2023, Investor 1 was contacted by phone by a person identifying
himself as Martin Richter.  Richter claimed to work for a company called International Portfolio
Management in New York City.  In reality, “Martin Richter” was either Meier or someone acting
at Meier’s direction or in concert with him.
42. Investor 1 found Richter to be very convincing and honest sounding.  Richter
convinced Investor 1 to invest in a private offering of shares of Databricks, Inc.  Databricks is a
Delaware corporation with a principal place of business in San Francisco, California.  Richter
claimed that Databricks had an upcoming initial public offering and would be listed on the
NASDAQ exchange in the United States before the end of 2023.
43. Meier emailed himself a link to Databricks’ website on February 24, 2023.
44. On or about April 3, 2023, Individual 1 received an email from info@ipm-
invest.com (the “IPM Email Address”).  The email bore a signature block for Sabine Huber,
Administration and Investor Relations, IPM – International Portfolio Management, One World
Trade Center, 285 Fulton Street, Suite 2800, New York, NY 10007.
45. The April 3, 2023 email from Huber to Investor 1 also listed IPM’s website
www.ipm-invest.com (the “IPM Website”).  Meier was the registered owner of IPM’s Website.
The website was hosted by GoDaddy, Inc., but Meier registered his ownership through Domains
by Proxy.  This provided a layer of anonymity because Domains by Proxy was listed as the
contact for ownership of the website, rather than Meier.

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46. Huber’s April 3, 2023 email told Investor 1 that he would “receive the Databricks
documents from us.”
1
  The email represented that Databricks was planning for an initial public
offering (IPO) in the summer of 2023.  The email contained a written overview of Databricks, its
history, its products and operations, and a planned initial public offering for 2023.
47. On July 18, 2023, Meier received an email from an individual who attached a
written description of Databricks substantively identical to the description in the April 3, 2023
email from IPM to Investor 1.  The individual asked if Meier could arrange for a graphic
designer to create a Databricks brochure and “it would be useful to design editable brochures so
that changes to them can be made right away.”
48. The IPM Email Address sent Investor 1 a Databricks “Share Subscription
Agreement.”  A subscription agreement is an agreement containing the terms of an investment in
a private offering of securities.  Investor 1 completed the Share Subscription Agreement and
returned it by email to IPM on April 28, 2023.
49. The Share Subscription Agreement purported to concern a private placement of
Databricks common stock with an offering commencing on August 1, 2020 and terminating on
April 1, 2021.  Databricks did not make an offering with those dates.  The Subscription
Agreement was a fake.
50. The cover page of the Subscription Agreement contained logos for Databricks and
IPM, which made it falsely appear that IPM was an underwriter or agent of Databricks for
purposes of the offering.
51. The Subscription Agreement was written in German.  It provided, among other
things, that the “purchaser” (i.e., Investor 1) agreed to purchase Databricks shares at a specified

1
 This email and certain other communications and records cited herein were written in German and have been
translated for purposes of this Complaint.

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price and to deliver to Databricks’ agents (i.e., IPM) a signed subscription agreement and an
authorized U.S. Bank Check or wire transfer to a specified bank account.  The specified bank
account was a bank in Peabody, Massachusetts in the name of Treuhand.  The Share
Subscription Agreement provided that any disputes would be governed by U.S. law and that
jurisdiction would be in California.
52. The Subscription Agreement further provided that Databricks would notify the
purchaser if it had accepted the purchaser’s subscription, in which case it would deliver a share
certificate.  IPM then led Investor 1 to believe that he had in fact made an investment in
Databricks and that his shares were being held in an IPM account in the United States.
53. IPM also convinced Investor 1 to invest in the German issuer Rheinmetall AG.
IPM told Investor 1 that there would be a tax advantage to purchasing the Rheinmetall shares in
the United States rather than Germany.  Investor 1 agreed to invest in Rheinmettall.  At IPM’s
direction, Investor 1 also completed an IRS Form W-8BEN, Certificate of Foreign Status of
Beneficial Owner for United States Tax Withholding and Reporting.  Form W-8BEN is a form
for foreign persons who receive income from U.S. sources.
54. On April 28, 2023, Investor 1 informed IPM that Investor 1 would invest in
Databricks.  On May 2, 2023, Investor 1 informed IPM that Investor 1 would invest in
Rheinmettall, and Investor 1 placed an additional Rheinmettall order on May 11, 2023.
55. On April 28, 2023, an IPM representative emailed Investor 1 login information
for an investment account.  The address for the purported online account was
onlinedepot.systems.  Meier was the registered owner of the onlinedepot.systems website.  The
website was hosted by GoDaddy, Inc., but Meier maintained anonymity by registering his
ownership through Domains by Proxy.

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56. In Germany, “depot” is a term used to describe a brokerage account.  Meier
maintained among his corporate files an Excel document titled “online depot systems.”  That file
identified an investor (different than Investor 1) with a purported holding of Databricks shares.
The file also identified several investors who sent money to Treuhand accounts controlled by
Meier, as well as to Windeco.
57. On May 3, 2023, Investor 1 wired $35,696 to a Treuhand account in the United
States for which Meier is the sole signatory.  On May 25, 2023, Investor 1 wired an additional
$112,375 to the Treuhand account.  Investor 1’s wires were for purposes of investment in
Databricks and Rheinmettall.
58. Investor 1 understood Treuhand to be a German word akin to “escrow” in
English.  He understood that he was wiring funds to some form of an escrow account for
purposes of investment.  In reality, Treuhand was a corporation that Meier controlled and
operated for the purpose of deceiving investors.
59. In August 2023, Investor 1 was contacted by an individual identifying himself as
Mr. Jung of IPM.  Jung stated that Richter was ill and that Jung would be taking over Investor
1’s account.  In reality, “Jung” was either Meier or someone acting at Meier’s direction or in
concert with him.  Jung stated that IPM was being taken over by another company and that
Investor 1 should relocate shares from IPM in the United States to an account in Germany.  Jung
said, however, that this would require a transfer fee to cover IPM’s commission and the U.S. tax
on the gains in Rheinmettall shares.  At Jung’s direction, Investor 1 sent the transfer fee to an
account in Switzerland.
60. Investor 1 has tried to reach the IPM representatives but at some point they
disappeared.  They no longer replied to Investor 1’s emails or phone calls, and the IPM website
disappeared.

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61. Meier absconded with Investor 1’s money after it arrived in Treuhand’s account.
None of Investor 1’s money intended for investment in Databricks was invested in Databricks or
in any other security.  None of Investor 1’s money intended for investment in Rheinmettall was
invested in Rheinmettal or any other security.
Investor 2
62. An investor, referred to herein as “Investor 2” is a German citizen and resident of
Germany.
63. On February 24, 2022, the German carmaker Volkswagen AG announced a
possible IPO of shares of its Porsche brand.  The IPO ultimately took place in September 2022
and Porsche shares became publicly traded on the Frankfurt Stock Exchange.
64. In the summer of 2022, an individual identifying himself as Tobias Moser
contacted Investor 2.  In reality, “Moser” was either Meier or someone acting at Meier’s
direction or in concert with him.  Moser introduced Investor 2 to an individual calling himself
Steven Weiss.  Investor 2 understood Weiss to work on Wall Street in New York.  Weiss
represented that he could sell Investor 2 shares of Porsche which would become more valuable
following its upcoming IPO.  Investor 2 transferred $500,000 to the United States to invest in
Porsche shares.  After Porsche went public, Investor 2 was unable to contact Moser or Weiss.
65. In March or April of 2023, Moser contacted Investor 2 and said he was now
working for IPM.  Moser told Investor 2 that Weiss had committed fraud but that IPM could
recover the $500,000 Porsche investment.  Moser told Investor 2 that Investor 2 would have to
convert the Porsche stock into Rheinmettall stock.  Moser told Investor 2 that this would require
a transfer fee of $120,000.
66. Investor 2 understood that the Porsche shares had been purchased in the United
States, and that the conversion of shares into Rheinmettall shares and payment of a transfer fee

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would be required for the return of Investor 2’s money.  On June 15, 2023, “Sabine Huber” of
IPM emailed the U.S. tax form W-8BEN to Investor 2 in connection with the purported trade of
Porsche shares for Rheinmettall shares.
67. Investor 2 also received emails from purported IPM representatives, which
included information indicating that IPM was located at One World Trade Center in New York
and listing the ipm-invest.com website owned by Meier.
68. As directed by IPM, Investor 2 directed the purported transfer fee to three
different banks.  One portion went to a Treuhand account in the United States controlled by
Meier.  A second portion went to a different account in the United States.  A third portion went
to one or more accounts in Europe.
69. After sending payment for the purported transfer fee, Investor 2 communicated
with IPM regarding delays in receiving the return of her investment proceeds.  IPM stopped
communicating altogether in November 2023.
Investor 3
70. On March 20, 2023, a Treuhand account located in the United States and
controlled by Meier received $109,223 by wire from an individual (“Investor 3”) in Switzerland.
The wire instructions identified the purpose of the wire as relating to shares of Barrick Gold
Corporation.  Barrick Gold is a company with shares of stock publicly traded on the New York
Stock Exchange.
71. After arriving in Treuhand’s account, no portion of Investor 3’s funds were used
to purchase Barrick Gold shares.  Three days after the receipt of Investor 3’s funds, Meier wrote
a check from the Treuhand account to his own personal account for $25,000.  On March 27,
2023, Meier wrote a check from his personal account for a $7,585 payment related to installation

18
of an in-ground pool at Meier’s home in Massachusetts.  Meier’s written goals for 2022 included
“get a pool for $80,000.”
Investor 4
72. On September 8, 2022, a Treuhand account in the United States and controlled by
Meier received a wire of $33,972 from an individual in Switzerland (“Investor 4”).  The purpose
of the wire was designated as an investment in Discovery Gold, one of the companies for which
Meier signed a Form D related to a private offering.  No portion of Investor 4’s proceeds were
invested in Discovery Gold shares or any other security.  Also on September 8, 2022, Meier
transferred $16,500 to a bank account in his name.
73. On September 27, 2022, Investor 4 wired $76,577.26 to the Treuhand account for
the purpose of investment in New Energy Systems, another of the companies for which Meier
signed a Form D related to a private offering.  No portion of Investor 4’s proceeds were invested
in New Energy Systems or any other security.
Investor 5
74. Investor 5 is over 65 years old and a resident of Germany.  In 2019, Investor 5
was solicited to invest in a company called Canadian Minerals or Canadian Mineral Research
(“Canadian Minerals”).  Investor 5 understood the Canadian Minerals investment to be high-risk
and that it might not ever generate returns.  Then, in 2021, Investor 5 was contacted by an
organization called Global Financial Services and told that Canadian Minerals was being
acquired by Barrick Gold and that Investor 5 could obtain Barrick Gold shares, and that Investor
5 should buy more shares of Canadian Minerals.  Investor 5 was persuaded by the Global
Financial Services representatives and bought more Canadian Minerals shares.  One caller from
Global Financial Services identified himself as Antonio Schwarz.

19
75. Barrick Gold has maintained on its website a public warning of investment
schemes involving purported exchange offers with Canadian Minerals.  According to Barrick
Gold’s website:
The individuals behind these schemes use various tactics and
techniques in an attempt to persuade potential investors that the
investment opportunities are legitimate. These include using
falsified documents (such as certificates and agreements) bearing
Barrick’s logo or marks, impersonation of and falsified signatures
from Barrick executives, creating websites that contain content
taken from Barrick’s website and may even have URLs that
contain Barrick’s name, purporting to use email addresses with the
barrick.com domain, and representing falsely that they are acting
on behalf of Barrick.

76. Investor 5 received a letter on Barrick Gold letterhead, dated April 18, 2022 and
purportedly signed by Barrick Gold corporate officers, to “shareholders of Canadian Minerals,
Inc.” purporting to “confirm that Mr. Antonio Schwarz oversees the transaction between Barrick
Gold and Canadian Minerals for the planned take-over.”
77.  Meier maintained an exact copy of the fake April 18, 2022 Barrick Gold letter in
his corporate files.
78. Meier also maintained copies of an email to investors with the subject line
“Canadian Mineral Resources Inc. – Info.”  The email was signed by “Antonio Schwarz, Private
Equity Specialist.”  Meier also emailed in March 2023 with the Argentina-based graphic
designer about creating “share exchange contracts” for “Canadian Minerals to receiving Barrick
G.”
79. Investor 5 was ultimately convinced to send money to Treuhand accounts in the
United States for purported investments in Barrick Gold, Amazon, Porsche, and Tik Tok.
Investor 5 has lost over $300,000 to the scam.  Investor 5 also completed a U.S. tax form W-
8BEN in connection with the purported investments.

20
80. Investor 5 received one or more emails purporting to be from Euro Finance Group
in New York, NY.  The emails contained a signature block including the website
eurofinglobal.com.
81. Investor 5 received one or more emails purporting to be from Antonio Schwarz of
Global Financial Services.  The emails contained a signature block including the website
www.gfs-invest.com.
82. At least one investor (different than Investor 5) received a copy of a passport
purporting to be identification for Antonio Schwarz.  Meier maintained in his records a copy of
the same passport, identical in all respects except for a different first name.
83. Investor 5 also received from Global Financial Services access to a purported
online account system called “E-Account Systems” at e-account.systems.com.  Investor 5’s
purported online account purported to show holdings in Barrick Gold and other securities.  The
purported online account statement included contact information for Global Financial Services
and “EuroFinance” in New York, NY.  EuroFinance purported to have an email address
[email protected].
84. Meier was the registered owner of the websites gfs-invest.com,
e-account.systems.com, ifs-global.com, and eurofinglobal.com.
FIRST CLAIM FOR RELIEF
FRAUD IN THE OFFER OR SALE OF SECURITIES
Violations of Section 17(a) of the Securities Act [15 U.S.C. 77q(a)]
(As to Defendant Meier)
85. The Commission realleges and incorporates by reference paragraphs 1 through 84
as if fully set forth herein.
86. By engaging in the acts and conduct alleged above, Meier directly or indirectly, in
the offer or sale of securities, by use of the means or instruments of transportation or

21
communication in interstate commerce or by use of the mails: (1) employed devices, schemes, or
artifices to defraud; (2) obtained money or property by means of untrue statements of material
fact or by omitting to state material facts necessary in order to make statements made, in the light
of the circumstances under which they were made, not misleading; and (3) engaged in
transactions, practices or courses of business which operated or would operate as a fraud or
deceit upon the purchasers, in violation of Sections 17(a)(1), (2), and (3) of the Securities Act
[15 U.S.C. § 77q(a)(1), (2), and (3)].
SECOND CLAIM FOR RELIEF
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES
Violations of Section 10(b) of the Exchange Act and Rule 10b-5 Thereunder
[15 U.S.C. § 78j(b), 17 C.F.R. § 240.10b-5]
(As to Defendant Meier)
87. The Commission realleges and incorporates by reference paragraphs 1 through 84
as if fully set forth herein.
88. By engaging in the acts and conduct alleged above, Meier, 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, or of a facility of a national securities exchange:
(1) employed devices, schemes, or artifices to defraud; (2) made untrue statements of material
fact or omitted to state material facts necessary in order to make the statements made, in light of
the circumstances under which they were made, not misleading; and (3) engaged in acts,
practices, or courses of business which operated or would operate as a fraud or deceit upon other
persons, including purchases and sellers of securities, in violation of Section 10(b) of the
Exchange Act [15 U.S.C. § 78j(b)] and subsections (a), (b), and (c) of Rule 10b-5 thereunder [17
C.F.R. § 240.10b-5(a), (b), and (c)].

22
THIRD CLAIM FOR RELIEF
Other Equitable Relief, Including Unjust Enrichment and Constructive Trust
(As to Relief Defendants)
89. The Commission realleges and incorporates by reference paragraphs 1 through 84
as if fully set forth herein.
90. Section 21(d)(5) of the Exchange Act states, “In any action or proceeding brought
or instituted by the Commission under any provision of the securities laws, the Commission may
seek, and any Federal court may grant, any equitable relief that may be appropriate or necessary
for the benefit of investors.”
91. Relief Defendants received ill-gotten funds provided by investors for purposes of
investment.  Relief Defendants have no legitimate claim to this property.  In equity and good
conscience, Relief Defendants should not be allowed to retain such funds.
92. As a result, Relief Defendants are liable for unjust enrichment and should each be
required to return their share of ill-gotten gains, in an amount to be determined by the Court.
The Court should also impose a constructive trust on the ill-gotten gains in the possession of
Relief Defendants.
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that the Court:
A. Enter a Final Judgment permanently restraining and enjoining Meier, as well as
his agents, servants, employees, attorneys, and other persons in active concert or participation
with them, from directly or indirectly engaging in the conduct described above, or in conduct of
similar purpose and effect, in violation of:

23
1. Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]; and
2. Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5
thereunder [17 C.F.R. § 240.10b-5].
B. Enter a Final Judgment permanently restraining and enjoining Meier from,
directly or indirectly, including but not limited to, through any entity owned or controlled by
him, participating in the issuance, purchase, offer, or sale of any security, provided, however,
that such injunction shall not prevent him from purchasing or selling securities for his own
personal account.
C. Enter a Final Judgment barring Meier from acting as an officer or director of any
public company, pursuant to Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)] and Section
21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)].
D. Enter a Final Judgment ordering Defendant Meier to disgorge his ill-gotten gains
or unjust enrichment, with prejudgment interest thereon, to effect the remedial purposes of the
federal securities laws.
E. Enter a Final Judgment against Relief Defendants ordering each of them to
disgorge all unjust enrichment and/or ill-gotten gains, with prejudgment interest thereon, to
effect the remedial purposes of the federal securities laws.
F. Enter a Final Judgment ordering Meier to pay civil penalties pursuant to Section
20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d) of the Exchange Act [15
U.S.C. § 78u(d)].
G. Retain jurisdiction over this action to implement and carry out the terms of all
orders and decrees that may be entered.
H. Grant such other and further relief as this Court may deem just and proper.

24
DEMAND FOR JURY TRIAL
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, the Commission demands a
jury trial in this action of all issues so triable under the claims in this Complaint.
Dated: October 11, 2024   Respectfully submitted,

/s Michael C. Moran
Michael C. Moran (Mass. Bar No. 666885)
Kerry Dakin (Mass. Bar No. 640826)
William J. Donahue (Mass. Bar No. 631229)
Colin D. Forbes (N.Y. Bar No. 4664264)
Boston Regional Office
33 Arch Street, 24th Floor
Boston, MA  02110
Phone:  (617) 573-8900
Facsimile:       (617)       573-4590
Moran email:  [email protected]
Moran phone:  (617) 573-8931
Counsel for Plaintiff Securities and Exchange
Commission

UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 

 
 
 
UNITED STATES SECURITIES AND 
EXCHANGE COMMISSION, 
 
  Plaintiff, 
 
 v. 
 
NORMAN V. MEIER, 
 
 
  Defendant,  
 

and 
 
TREUHAND, INC., NORMAN MEIER 
INTERNATIONAL, INC. a/k/a NMI, INC., 
WINDECO CORPORATION, TEXXON OIL 
CORP., AND INTERNATIONAL FINANCIAL 
SERVICES, INC. a/k/a IFS, INC. a/k/a IFS, INC. 
d/b/a IRM, INC., 
 
                        Relief Defendants. 
 

 
 
 
 
 
 
     Civil Action No. 24-12602 
 
     JURY TRIAL DEMANDED 

 
      
 
 
 

COMPLAINT 
 

 Plaintiff, United States Securities and Exchange Commission (“SEC” or “Commission”) 

alleges as follows against Defendant Norman V. Meier (“Meier”) and Relief Defendants 

Treuhand, Inc. (“Treuhand”), Norman Meier International, Inc. a/k/a NMI, Inc. (“NMI”), 

Windeco Corporation (“Windeco”), Texxon Oil Corp. (“Texxon”), and International Financial 

Services, Inc. a/k/a IFS, Inc. a/k/a IFS, Inc. d/b/a IRM, Inc. (“IFS”).   

SUMMARY 

1. Massachusetts resident Norman Meier orchestrated a years-long international 

securities fraud.  From at least June 2015 to December 2023, Meier defrauded over 180 

investors, mostly European, out of at least $7.9 million.  Meier engaged teams of cold callers in 

Eastern Europe who used fake names to sell fake investments.  Meier’s scheme involved 

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soliciting investments in companies that he created for purposes of defrauding investors.  Meier’s 

scheme also involved soliciting investments in well-known public companies to which Meier and 

his teams of cold callers had no real connection.        

2. Meier’s victims wired funds to bank accounts in the United States that Meier 

controlled.  Rather than investing funds as promised, Meier misappropriated the money for his 

own use and to pay his overseas sales network to lure additional investors.  Meier and his sales 

teams deceived investors into believing that the investors’ money was being sent to a financial 

institution in the United States for investment in the United States.  Many of Meier’s victims 

were German speaking.  Meier named one of his companies “Treuhand,” a German word akin to 

“trust” or “escrow,” such that investors believed they were sending funds to a trust or escrow 

account.  In reality, the Treuhand bank account was one of several that Meier used to steal 

investor money and pay his sales network.      

3. Meier also defrauded investors in the United States.  In 2015, Meier solicited 

investments from an individual in California while Meier was living in California.  Meier 

convinced the California investor to invest in three entities, including relief defendant Windeco.  

The California investor wired a total of $12,500 to an account that Meier controlled.  Meier 

failed to invest the money as he had promised, and instead misappropriated the investor’s money 

for his own purposes.  Meier solicited investments from two other investors in California, also in 

or around 2015.           

VIOLATIONS 

4. By virtue of the conduct alleged herein, Meier violated Sections 17(a)(1), 

17(a)(2), and 17(a)(3) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77q(a)(1), 

(2), and (3)], and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 

U.S.C. §78j(b)] and Rules 10b-5(a), (b), and (c) thereunder [17 C.F.R. §§240.10b-5(a), (b), and 

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(c)]. 

NATURE OF THE PROCEEDING AND RELIEF SOUGHT 

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

Section 20(b) of the Securities Act [15 U.S.C. §77t(b)] and Section 21(d)(1) of the Exchange Act 

[15 U.S.C. §78u(d)(1)]. 

6. The Commission seeks a final judgment: (a) permanently enjoining Meier from 

violating the federal securities laws by engaging in transactions, acts, practices, and courses of 

business of the type alleged in this Complaint; (b) permanently enjoining Meier from, directly or 

indirectly, including but not limited to, through any entity owned or controlled by him, 

participating in the issuance, purchase, offer, or sale of any security, provided, however, that 

such injunction shall not prevent him from purchasing or selling securities for his own personal 

account; (c) barring Meier from acting as an officer or director of any public company, pursuant 

to Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)] and Section 21(d)(2) of the Exchange 

Act [15 U.S.C. § 78u(d)(2)]; (d) ordering Meier to disgorge any ill-gotten gains with 

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

U.S.C. §78u(d)(5) and (7)]; (e) ordering Treuhand, NMI, Windeco, Texxon, and IFS to disgorge 

all unjust enrichment and/or ill-gotten gains, with prejudgment interest thereon; (f) ordering 

Meier to pay a civil money penalty pursuant to Section 20(d) of the Securities Act [15 U.S.C. 

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

other and further relief the Court may deem just and proper. 

DEFENDANT 

7. Norman V. Meier (“Meier”), age 49, is a resident of Wakefield, Massachusetts.  

Meier has held a U.S. passport since at least December 2014.  Meier is a native of Switzerland.  

His first language is Swiss German (dialect of the German-speaking area of Switzerland).  Meier 

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is the sole executive officer of relief defendants Treuhand, Inc. and Norman Meier International, 

Inc. (also known as NMI, Inc.).        

RELIEF DEFENDANTS 

8. Treuhand, Inc. (“Treuhand”) incorporated in Massachusetts in December 2020, 

listing Meier as an officer, and purports to have a principal place of business in Boston, 

Massachusetts.  Treuhand has maintained bank accounts in the United States, including accounts 

opened in Massachusetts.  Meier is the sole signatory on Treuhand’s bank accounts.            

9. Norman Meier International, Inc., a/k/a NMI, Inc. (“NMI”) incorporated in 

Massachusetts in June 2022, listing Meier as an officer, and purports to have a principal place of 

business in Saugus, Massachusetts.  Meier is the sole signatory to one or more NMI bank 

accounts.   

10. Windeco Corporation (“Windeco”) incorporated in Nevada in 2013 and 

purports to have a principal place of business in Las Vegas, Nevada.  Windeco has maintained 

bank accounts in the United States.  Meier is the sole signatory to one or more Windeco bank 

accounts. 

11.  Texxon Oil Corp. (“Texxon”) incorporated in Nevada in August 2014 and 

purports to have a principal place of business in Dallas, Texas.  Texxon has maintained bank 

accounts in the United States.  On four occasions between August 2014 and January 2018, an 

associate of Meier filed with the Commission Form D Notices of Exempt Offering of Securities 

for Texxon pursuant to Rule 506(b) of Regulation D under Section 4(a)(2) of the Securities Act.  

Meier is the sole signatory to one or more Texxon bank accounts.  

12. International Financial Services (“IFS”) is an unincorporated entity and 

purported financial services firm located in New York, New York.  Meier created and 

maintained websites using a variation of “IFS,” including “ifs-global.com,” to deceive investors 

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into believing that they were dealing with a legitimate Wall Street firm.  In March of 2022, 

Germany’s Federal Financial Supervisory Authority (BaFin) issued a notice ordering IFS to 

cease initiating unsolicited contact with former customers of a German based advisory firm.  IFS 

has maintained at least one bank account in the United States.  Meier is the sole signatory to one 

or more IFS bank accounts.  IFS and International Financial Services were names Meier ascribed 

to his private equity selling network.   

JURISDICTION AND VENUE 

13. This Court has jurisdiction over this action pursuant to Sections 20(d)(1) and 

22(a) of the Securities Act [15 U.S.C. §§77t(d)(1) and 77v(a)] and Sections 21(d), 21(e), and 27 

of the Exchange Act [15 U.S.C. §§78u(d), 78u(e), 78aa].  Venue lies in this district pursuant to 

Section 22(a) of the Securities Act [15 U.S.C. §77v(a)] and Section 27 of the Exchange Act [15 

U.S.C. §78aa].  A substantial portion of the acts, practices, transactions and courses of business 

alleged in this Complaint occurred within the District of Massachusetts.  Meier resides in this 

district and controlled one or more bank accounts in this district where he received proceeds 

from his scheme.  Meier used Treuhand and NMI, both businesses that he incorporated in 

Massachusetts, to further his fraud.   

14. In connection with the transactions, acts, practices, and courses of business 

alleged in this Complaint, Defendant, directly or indirectly, singly or in concert with others, 

made use of the means or instrumentalities of transportation or communication in interstate 

commerce, or the mails. 

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DEFENDANT’S ACTS IN VIOLATION OF THE FEDERAL SECURITIES LAWS 

Meier’s Method of Investor Solicitation 

15. In 2014, Meier published a book titled Create Wealth with Private Equity and 

Public Companies – A Guide for Entrepreneurs and Investors.  Meier wrote of his dream “to 

become a millionaire no matter what it took.”   

16. Meier maintained among his corporate records various lists of his goals for the 

years 2020 through 2023, which included to become a millionaire and to have “several homes 

and real estate all over the world.”  In 2020, Meier aimed to create income streams from a 

“Private Equity Organization” in Europe and to have $100,000 in monthly income from his 

“Private Equity Business.”  Meier also listed a goal to be CEO of a public company.  

17. Meier maintained a website called normanmeier.com.  On his website, Meier 

described himself as being born and raised in Switzerland.  He claimed to have advanced degrees 

from a university in Switzerland.  Meier claimed that he had been CEO of a publicly listed 

company.  Meier described himself in a 2013 blog posting as having a huge client base in Europe 

and North America and “a network all over the world.” 

18. On his website, Meier described himself as an expert in raising investor funds 

through private equity, which Meier described as raising money from investors in companies not 

yet listed on a stock exchange.  Through normanmeier.com, Meier offered a training course 

called “Private Equity Broker Training” for individuals to learn how to secure investors for 

private equity investments.  Meier offered a “job opportunity” that first required “learn[ing] the 

basics and go[ing] through our training program.”  In the program, a “trainee” would be expected 

to “make phone calls to potential investors,” “generate at least 5 new leads per day,” and “learn 

how to close a deal on the phone.”  After completing the training, “the trainee will receive a 

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 7

permanent job as a Private Equity Broker and will raise money every month for the sales 

organization while earning commissions.”   

19. Meier’s book Create Wealth includes a how-to guide for soliciting investors 

through cold calling.  Meier gives suggestions on “general statements that help to convince 

investors”, including: 

 “If this train leaves, it is hard to get back on later.  And there is 
not another one coming that is going where you want to go.” 

 “If you sleep on it, you won’t be smarter tomorrow.  If you 
knew what I know about his deal, you wouldn’t hesitate one 
second.” 

 “How much time do you need to think about it?  2 weeks?  So 
are you going to think about it for 2 hours for the next 14 days?  
So a total of 28 hours?  I don’t think so. That would be 
ridiculous, right?  So how much real thinking time do you 
really need?  One hour?  So let me help you right now.  If you 
still need time, then I will call you tomorrow morning?” 

 “I am sorry if I am putting too much pressure on you right now.  
But you need to understand that you can buy a car and wait a 
couple of weeks before you actually get it.  But when it comes 
to stocks, one day or even one hour can make a difference 
whether you make 100% return or only 1%.  That’s why I urge 
you to act now.” 

20. In Create Wealth, Meier described a hypothetical sales pitch for a cold call to a 

potential investor: 

Hi, I am calling from XYZ Company.  We would like to 
introduce ourselves and our company to you.  We are a 
company specializing in ABC investments and we help 
companies go public.  We would like to send you some 
general information about our company by email so that 
you can see whether his could be of interest to you or not. 
We are currently working on deal ABC that will go public 
in 6 months and it is a very interesting investment 
opportunity because we can currently offer the shares at 
$0.50 and we expect the company to be value at $2.00 
when it is listed . . . . 

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21. Meier writes in his book that he was a stockbroker “in Europe and North 

America” and that he “can teach you everything about getting international investors and how to 

approach different markets.”  Meier’s book provides guidance on how to structure a sales team to 

solicit investors by phone.  Meier describes paying salespeople an hourly wage and a 

commission for cold calling and securing investors.   

22. In describing the creation of a sales team, Meier writes in Create Wealth: 

Based on the clients that you will target you could set up a 
call center in a foreign country.  At one point we have only 
targeted investors in the German speaking part of Europe 
(Germany, Austria, and Switzerland) because the financial 
potential was much better at the time than in America. 
 
In Europe, a lot of people speak several languages.  We 
have had a marketing team of women who call up clients in 
Germany from an Eastern European country because the 
costs of running an operation in those countries are much 
cheaper. 

 
Meier’s Commission Filings for Private Securities Offerings 

23. Under Section 5 of the Securities Act, a company may not offer or sell securities 

unless the offering has been registered with the Commission or an exemption from registration is 

available.  Offerings that are exempted by Section 4(a)(2) of the Securities Act or its safe harbor 

under the Commission rule “Regulation D” are referred to as private placements.  Companies 

issuing securities in reliance on a Regulation D exemption are required to file with the 

Commission a document called a Form D, which is available online to the public and contains 

brief information about the company, its management and promoters, and the offering of 

securities.   

24. Meier signed a December 14, 2020 Form D filing with the Commission 

concerning a private placement offering of securities of Discovery Gold, Inc. (“Discovery 

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 9

Gold”).  Meier is identified in the Form D as a director of Discovery Gold.  Discovery Gold 

purported to be a Wyoming corporation with a principal place of business in New York, NY. 

25. Meier signed a July 21, 2021 Form D filing with the Commission concerning a 

private placement offering of securities of New Energy Systems, Inc. (“New Energy Systems”).  

Meier is identified in the Form D as a director of New Energy Systems.  New Energy Systems 

purported to be a Wyoming corporation with a principal place of business in New York, NY. 

Overview of Meier’s Scheme 

26. Meier began misappropriating money from investors as early as 2015.  In 2015, a 

California resident met Meier while Meier was living in Carlsbad, California.  Meier convinced 

the California resident to invest in three entities, including Windeco.  The California resident 

sent two wires for purposes of investment, totaling $12,500, to an account that Meier controlled.  

Meier, however, failed to invest the money as he had promised and instead misappropriated the 

investor’s money for his own personal purposes.  Meier solicited investments from two other 

investors in California, also in or around 2015.  Meier solicited the two additional California 

investors to invest in Windeco and Texxon.  None of the California investors have received any 

proceeds from their purported investments.   

27. Between January 2017 and December 2023, U.S. bank accounts controlled by 

Meier received approximately $7.9 million in proceeds from individuals in Europe.  The bank 

accounts received the proceeds by wire and the wire instructions often specified the investment 

purpose.  For instance, $301,748 arrived with wire instructions including the German word 

“aktien” which translates to “stock” or “shares.”  Another $471,781 arrived with a notation for 

“Discovery” or “Discovery Gold.”  A total of $247,767 arrived with a notation for “New Energy 

Systems.”  A total of $523,572 arrived with a notation for “Barrick” or “Barrick Gold,” which is 

a reference to a publicly traded mining company based in Canada.  Of the $7.9 million, Treuhand 

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 10

received $5,689,603, Windeco received $582,290, Texxon received $978,151, and IFS received 

$690,328.  The Investor Proceeds arrived from bank accounts in Germany, Austria, and 

Switzerland.   

28. Meier did not direct the Investor Proceeds to investment purposes.  Instead, he 

absconded with the investor proceeds for his own personal purposes including payments to 

further his scheme.  Meier’s use of investor proceeds for his own purposes involved transferring 

investor proceeds to his personal bank accounts or to NMI bank accounts, including accounts in 

the United States.   

29. Among Meier’s diversion of Investor Proceeds, Meier wired portions of the 

proceeds to other individuals in Serbia and other overseas locations, who were not investors.  

Those overseas payments were commissions or finder’s fees for securing victims of Meier’s 

investment scheme.     

30. Meier maintained a list of members of his “private equity teams and people” 

which included individuals who received payments from accounts controlled by Meier.  

31. Meier also maintained written goals for IFS, or “International Financial Services,” 

which was the name that Meier ascribed to his private equity selling network.  Meier’s business 

goals for “IFS/Private Equity” in 2020 included “Build a system to generate daily leads of 

potential investors.”  His goals for 2022 included “IFS Private Equity Europe (Serbia).”  His 

goals for 2023 included an “IFS USA: Hire people and start operations.”   

32. In March 2020, Meier received an email from an individual representing a call 

center in Ukraine.  Meier spoke with the Ukrainian call center representative and then sent an 

email to her saying “I am very interested in working with you.”  He wrote that “we are mainly 

dealing with German speaking clients.  Therefore, it would make most sense to start with a small 

team of about 5 people who speak German very well and ideally without an accent.”   

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33. Meier continued in his email to the Ukrainian call center representative: 

The first call to a potential investor is a cold call.  A marketing 
person calls up people in Germany and asks them if they are 
interested in receiving our info material by email.  This potential 
investor should be open and willing to listen and should have the 
ability to invest at least $10,000. 
 
The second call, which is a follow up sales call, can be done by our 
sales team.  They will try to close the deal and get the person to 
invest into the shares that we offer.   
 
We typically sell shares of new companies that are not yet listed on 
a stock exchange but plan to go public soon. 
 

34. Meier also wrote to the Ukrainian call center representative that he would send 

two projects to start: Windeco Gold Corporation and Global Energy Group, Inc. 

35. Meier maintained a to do list for May 2020 which included “3 Fake news 

websites”, including “Global Energy.” 

36. In October 2021, Meier wrote to a graphic designer in Argentina to request 

creation of IFS-branded factsheets “with a quick summary for each company and a STRONG 

BUY recommendation.”  Meier requested factsheets for, among others, Discovery Gold and 

Global Energy Group.  

37. In his goals for 2022, Meier listed “peace of mind, legal businesses.”  He also 

sought to “legally save.”  For 2023, Meier included under the category of “Business changes” his 

goal of “only legal deals” and “IPO deal with real projects.”   

38. Meier’s goals for 2022 and 2023 also included to “move money to other country,” 

and “move $100,000 to Switzerland for additional safety from government, etc.”  

39. In October 2019, Meier wrote of a goal to have one office “with sales people 

where I work from every day,” but perhaps with a different name than IFS “due to negative 

links, etc.” 

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Examples of the Scheme 

Investor 1 

40. An investor, referred to herein as “Investor 1” is a German citizen and resident of 

Germany.  Investor 1 is over 85 years old and is retired.  Investor 1 is a veteran of the German 

Air Force.    

41. In or about April 2023, Investor 1 was contacted by phone by a person identifying 

himself as Martin Richter.  Richter claimed to work for a company called International Portfolio 

Management in New York City.  In reality, “Martin Richter” was either Meier or someone acting 

at Meier’s direction or in concert with him.   

42. Investor 1 found Richter to be very convincing and honest sounding.  Richter 

convinced Investor 1 to invest in a private offering of shares of Databricks, Inc.  Databricks is a 

Delaware corporation with a principal place of business in San Francisco, California.  Richter 

claimed that Databricks had an upcoming initial public offering and would be listed on the 

NASDAQ exchange in the United States before the end of 2023.   

43. Meier emailed himself a link to Databricks’ website on February 24, 2023. 

44. On or about April 3, 2023, Individual 1 received an email from info@ipm-

invest.com (the “IPM Email Address”).  The email bore a signature block for Sabine Huber, 

Administration and Investor Relations, IPM – International Portfolio Management, One World 

Trade Center, 285 Fulton Street, Suite 2800, New York, NY 10007.  

45. The April 3, 2023 email from Huber to Investor 1 also listed IPM’s website 

www.ipm-invest.com (the “IPM Website”).  Meier was the registered owner of IPM’s Website.  

The website was hosted by GoDaddy, Inc., but Meier registered his ownership through Domains 

by Proxy.  This provided a layer of anonymity because Domains by Proxy was listed as the 

contact for ownership of the website, rather than Meier.   

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46. Huber’s April 3, 2023 email told Investor 1 that he would “receive the Databricks 

documents from us.”1  The email represented that Databricks was planning for an initial public 

offering (IPO) in the summer of 2023.  The email contained a written overview of Databricks, its 

history, its products and operations, and a planned initial public offering for 2023.   

47. On July 18, 2023, Meier received an email from an individual who attached a 

written description of Databricks substantively identical to the description in the April 3, 2023 

email from IPM to Investor 1.  The individual asked if Meier could arrange for a graphic 

designer to create a Databricks brochure and “it would be useful to design editable brochures so 

that changes to them can be made right away.”      

48. The IPM Email Address sent Investor 1 a Databricks “Share Subscription 

Agreement.”  A subscription agreement is an agreement containing the terms of an investment in 

a private offering of securities.  Investor 1 completed the Share Subscription Agreement and 

returned it by email to IPM on April 28, 2023. 

49. The Share Subscription Agreement purported to concern a private placement of 

Databricks common stock with an offering commencing on August 1, 2020 and terminating on 

April 1, 2021.  Databricks did not make an offering with those dates.  The Subscription 

Agreement was a fake. 

50. The cover page of the Subscription Agreement contained logos for Databricks and 

IPM, which made it falsely appear that IPM was an underwriter or agent of Databricks for 

purposes of the offering.   

51. The Subscription Agreement was written in German.  It provided, among other 

things, that the “purchaser” (i.e., Investor 1) agreed to purchase Databricks shares at a specified 

 
1 This email and certain other communications and records cited herein were written in German and have been 
translated for purposes of this Complaint. 

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price and to deliver to Databricks’ agents (i.e., IPM) a signed subscription agreement and an 

authorized U.S. Bank Check or wire transfer to a specified bank account.  The specified bank 

account was a bank in Peabody, Massachusetts in the name of Treuhand.  The Share 

Subscription Agreement provided that any disputes would be governed by U.S. law and that 

jurisdiction would be in California.   

52. The Subscription Agreement further provided that Databricks would notify the 

purchaser if it had accepted the purchaser’s subscription, in which case it would deliver a share 

certificate.  IPM then led Investor 1 to believe that he had in fact made an investment in 

Databricks and that his shares were being held in an IPM account in the United States.  

53. IPM also convinced Investor 1 to invest in the German issuer Rheinmetall AG.  

IPM told Investor 1 that there would be a tax advantage to purchasing the Rheinmetall shares in 

the United States rather than Germany.  Investor 1 agreed to invest in Rheinmettall.  At IPM’s 

direction, Investor 1 also completed an IRS Form W-8BEN, Certificate of Foreign Status of 

Beneficial Owner for United States Tax Withholding and Reporting.  Form W-8BEN is a form 

for foreign persons who receive income from U.S. sources. 

54. On April 28, 2023, Investor 1 informed IPM that Investor 1 would invest in 

Databricks.  On May 2, 2023, Investor 1 informed IPM that Investor 1 would invest in 

Rheinmettall, and Investor 1 placed an additional Rheinmettall order on May 11, 2023.   

55. On April 28, 2023, an IPM representative emailed Investor 1 login information 

for an investment account.  The address for the purported online account was 

onlinedepot.systems.  Meier was the registered owner of the onlinedepot.systems website.  The 

website was hosted by GoDaddy, Inc., but Meier maintained anonymity by registering his 

ownership through Domains by Proxy.     

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56. In Germany, “depot” is a term used to describe a brokerage account.  Meier 

maintained among his corporate files an Excel document titled “online depot systems.”  That file 

identified an investor (different than Investor 1) with a purported holding of Databricks shares.  

The file also identified several investors who sent money to Treuhand accounts controlled by 

Meier, as well as to Windeco. 

57. On May 3, 2023, Investor 1 wired $35,696 to a Treuhand account in the United 

States for which Meier is the sole signatory.  On May 25, 2023, Investor 1 wired an additional 

$112,375 to the Treuhand account.  Investor 1’s wires were for purposes of investment in 

Databricks and Rheinmettall.     

58. Investor 1 understood Treuhand to be a German word akin to “escrow” in 

English.  He understood that he was wiring funds to some form of an escrow account for 

purposes of investment.  In reality, Treuhand was a corporation that Meier controlled and 

operated for the purpose of deceiving investors.   

59. In August 2023, Investor 1 was contacted by an individual identifying himself as 

Mr. Jung of IPM.  Jung stated that Richter was ill and that Jung would be taking over Investor 

1’s account.  In reality, “Jung” was either Meier or someone acting at Meier’s direction or in 

concert with him.  Jung stated that IPM was being taken over by another company and that 

Investor 1 should relocate shares from IPM in the United States to an account in Germany.  Jung 

said, however, that this would require a transfer fee to cover IPM’s commission and the U.S. tax 

on the gains in Rheinmettall shares.  At Jung’s direction, Investor 1 sent the transfer fee to an 

account in Switzerland.     

60. Investor 1 has tried to reach the IPM representatives but at some point they 

disappeared.  They no longer replied to Investor 1’s emails or phone calls, and the IPM website 

disappeared.   

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61. Meier absconded with Investor 1’s money after it arrived in Treuhand’s account.  

None of Investor 1’s money intended for investment in Databricks was invested in Databricks or 

in any other security.  None of Investor 1’s money intended for investment in Rheinmettall was 

invested in Rheinmettal or any other security. 

Investor 2 

62. An investor, referred to herein as “Investor 2” is a German citizen and resident of 

Germany.       

63. On February 24, 2022, the German carmaker Volkswagen AG announced a 

possible IPO of shares of its Porsche brand.  The IPO ultimately took place in September 2022 

and Porsche shares became publicly traded on the Frankfurt Stock Exchange.    

64. In the summer of 2022, an individual identifying himself as Tobias Moser 

contacted Investor 2.  In reality, “Moser” was either Meier or someone acting at Meier’s 

direction or in concert with him.  Moser introduced Investor 2 to an individual calling himself 

Steven Weiss.  Investor 2 understood Weiss to work on Wall Street in New York.  Weiss 

represented that he could sell Investor 2 shares of Porsche which would become more valuable 

following its upcoming IPO.  Investor 2 transferred $500,000 to the United States to invest in 

Porsche shares.  After Porsche went public, Investor 2 was unable to contact Moser or Weiss. 

65. In March or April of 2023, Moser contacted Investor 2 and said he was now 

working for IPM.  Moser told Investor 2 that Weiss had committed fraud but that IPM could 

recover the $500,000 Porsche investment.  Moser told Investor 2 that Investor 2 would have to 

convert the Porsche stock into Rheinmettall stock.  Moser told Investor 2 that this would require 

a transfer fee of $120,000.   

66. Investor 2 understood that the Porsche shares had been purchased in the United 

States, and that the conversion of shares into Rheinmettall shares and payment of a transfer fee 

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would be required for the return of Investor 2’s money.  On June 15, 2023, “Sabine Huber” of 

IPM emailed the U.S. tax form W-8BEN to Investor 2 in connection with the purported trade of 

Porsche shares for Rheinmettall shares.    

67. Investor 2 also received emails from purported IPM representatives, which 

included information indicating that IPM was located at One World Trade Center in New York 

and listing the ipm-invest.com website owned by Meier.   

68. As directed by IPM, Investor 2 directed the purported transfer fee to three 

different banks.  One portion went to a Treuhand account in the United States controlled by 

Meier.  A second portion went to a different account in the United States.  A third portion went 

to one or more accounts in Europe.   

69. After sending payment for the purported transfer fee, Investor 2 communicated 

with IPM regarding delays in receiving the return of her investment proceeds.  IPM stopped 

communicating altogether in November 2023.   

Investor 3 

70. On March 20, 2023, a Treuhand account located in the United States and 

controlled by Meier received $109,223 by wire from an individual (“Investor 3”) in Switzerland.  

The wire instructions identified the purpose of the wire as relating to shares of Barrick Gold 

Corporation.  Barrick Gold is a company with shares of stock publicly traded on the New York 

Stock Exchange.   

71. After arriving in Treuhand’s account, no portion of Investor 3’s funds were used 

to purchase Barrick Gold shares.  Three days after the receipt of Investor 3’s funds, Meier wrote 

a check from the Treuhand account to his own personal account for $25,000.  On March 27, 

2023, Meier wrote a check from his personal account for a $7,585 payment related to installation 

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of an in-ground pool at Meier’s home in Massachusetts.  Meier’s written goals for 2022 included 

“get a pool for $80,000.” 

Investor 4 

72. On September 8, 2022, a Treuhand account in the United States and controlled by 

Meier received a wire of $33,972 from an individual in Switzerland (“Investor 4”).  The purpose 

of the wire was designated as an investment in Discovery Gold, one of the companies for which 

Meier signed a Form D related to a private offering.  No portion of Investor 4’s proceeds were 

invested in Discovery Gold shares or any other security.  Also on September 8, 2022, Meier 

transferred $16,500 to a bank account in his name.   

73. On September 27, 2022, Investor 4 wired $76,577.26 to the Treuhand account for 

the purpose of investment in New Energy Systems, another of the companies for which Meier 

signed a Form D related to a private offering.  No portion of Investor 4’s proceeds were invested 

in New Energy Systems or any other security.   

Investor 5 

74. Investor 5 is over 65 years old and a resident of Germany.  In 2019, Investor 5 

was solicited to invest in a company called Canadian Minerals or Canadian Mineral Research 

(“Canadian Minerals”).  Investor 5 understood the Canadian Minerals investment to be high-risk 

and that it might not ever generate returns.  Then, in 2021, Investor 5 was contacted by an 

organization called Global Financial Services and told that Canadian Minerals was being 

acquired by Barrick Gold and that Investor 5 could obtain Barrick Gold shares, and that Investor 

5 should buy more shares of Canadian Minerals.  Investor 5 was persuaded by the Global 

Financial Services representatives and bought more Canadian Minerals shares.  One caller from 

Global Financial Services identified himself as Antonio Schwarz.   

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75. Barrick Gold has maintained on its website a public warning of investment 

schemes involving purported exchange offers with Canadian Minerals.  According to Barrick 

Gold’s website: 

The individuals behind these schemes use various tactics and 
techniques in an attempt to persuade potential investors that the 
investment opportunities are legitimate. These include using 
falsified documents (such as certificates and agreements) bearing 
Barrick’s logo or marks, impersonation of and falsified signatures 
from Barrick executives, creating websites that contain content 
taken from Barrick’s website and may even have URLs that 
contain Barrick’s name, purporting to use email addresses with the 
barrick.com domain, and representing falsely that they are acting 
on behalf of Barrick. 

 
76. Investor 5 received a letter on Barrick Gold letterhead, dated April 18, 2022 and 

purportedly signed by Barrick Gold corporate officers, to “shareholders of Canadian Minerals, 

Inc.” purporting to “confirm that Mr. Antonio Schwarz oversees the transaction between Barrick 

Gold and Canadian Minerals for the planned take-over.”  

77.  Meier maintained an exact copy of the fake April 18, 2022 Barrick Gold letter in 

his corporate files. 

78. Meier also maintained copies of an email to investors with the subject line 

“Canadian Mineral Resources Inc. – Info.”  The email was signed by “Antonio Schwarz, Private 

Equity Specialist.”  Meier also emailed in March 2023 with the Argentina-based graphic 

designer about creating “share exchange contracts” for “Canadian Minerals to receiving Barrick 

G.” 

79. Investor 5 was ultimately convinced to send money to Treuhand accounts in the 

United States for purported investments in Barrick Gold, Amazon, Porsche, and Tik Tok.  

Investor 5 has lost over $300,000 to the scam.  Investor 5 also completed a U.S. tax form W-

8BEN in connection with the purported investments. 

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80. Investor 5 received one or more emails purporting to be from Euro Finance Group 

in New York, NY.  The emails contained a signature block including the website 

eurofinglobal.com. 

81. Investor 5 received one or more emails purporting to be from Antonio Schwarz of 

Global Financial Services.  The emails contained a signature block including the website 

www.gfs-invest.com.   

82. At least one investor (different than Investor 5) received a copy of a passport 

purporting to be identification for Antonio Schwarz.  Meier maintained in his records a copy of 

the same passport, identical in all respects except for a different first name. 

83. Investor 5 also received from Global Financial Services access to a purported 

online account system called “E-Account Systems” at e-account.systems.com.  Investor 5’s 

purported online account purported to show holdings in Barrick Gold and other securities.  The 

purported online account statement included contact information for Global Financial Services 

and “EuroFinance” in New York, NY.  EuroFinance purported to have an email address 

[email protected].   

84. Meier was the registered owner of the websites gfs-invest.com,  

e-account.systems.com, ifs-global.com, and eurofinglobal.com. 

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

Violations of Section 17(a) of the Securities Act [15 U.S.C. 77q(a)] 
(As to Defendant Meier) 

85. The Commission realleges and incorporates by reference paragraphs 1 through 84 

as if fully set forth herein. 

86. By engaging in the acts and conduct alleged above, Meier directly or indirectly, in 

the offer or sale of securities, by use of the means or instruments of transportation or 

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 21

communication in interstate commerce or by use of the mails: (1) employed devices, schemes, or 

artifices to defraud; (2) obtained money or property by means of untrue statements of material 

fact or by omitting to state material facts necessary in order to make statements made, in the light 

of the circumstances under which they were made, not misleading; and (3) engaged in 

transactions, practices or courses of business which operated or would operate as a fraud or 

deceit upon the purchasers, in violation of Sections 17(a)(1), (2), and (3) of the Securities Act 

[15 U.S.C. § 77q(a)(1), (2), and (3)]. 

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

Violations of Section 10(b) of the Exchange Act and Rule 10b-5 Thereunder 
[15 U.S.C. § 78j(b), 17 C.F.R. § 240.10b-5] 

(As to Defendant Meier) 

87. The Commission realleges and incorporates by reference paragraphs 1 through 84 

as if fully set forth herein. 

88. By engaging in the acts and conduct alleged above, Meier, 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, or of a facility of a national securities exchange: 

(1) employed devices, schemes, or artifices to defraud; (2) made untrue statements of material 

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

the circumstances under which they were made, not misleading; and (3) engaged in acts, 

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

persons, including purchases and sellers of securities, in violation of Section 10(b) of the 

Exchange Act [15 U.S.C. § 78j(b)] and subsections (a), (b), and (c) of Rule 10b-5 thereunder [17 

C.F.R. § 240.10b-5(a), (b), and (c)]. 

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THIRD CLAIM FOR RELIEF 
Other Equitable Relief, Including Unjust Enrichment and Constructive Trust 

(As to Relief Defendants) 

89. The Commission realleges and incorporates by reference paragraphs 1 through 84 

as if fully set forth herein. 

90. Section 21(d)(5) of the Exchange Act states, “In any action or proceeding brought 

or instituted by the Commission under any provision of the securities laws, the Commission may 

seek, and any Federal court may grant, any equitable relief that may be appropriate or necessary 

for the benefit of investors.” 

91. Relief Defendants received ill-gotten funds provided by investors for purposes of 

investment.  Relief Defendants have no legitimate claim to this property.  In equity and good 

conscience, Relief Defendants should not be allowed to retain such funds.   

92. As a result, Relief Defendants are liable for unjust enrichment and should each be 

required to return their share of ill-gotten gains, in an amount to be determined by the Court.  

The Court should also impose a constructive trust on the ill-gotten gains in the possession of 

Relief Defendants.   

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that the Court: 

A. Enter a Final Judgment permanently restraining and enjoining Meier, as well as 

his agents, servants, employees, attorneys, and other persons in active concert or participation 

with them, from directly or indirectly engaging in the conduct described above, or in conduct of 

similar purpose and effect, in violation of: 

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1. Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]; and 

2. Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5 

thereunder [17 C.F.R. § 240.10b-5]. 

B. Enter a Final Judgment permanently restraining and enjoining Meier from, 

directly or indirectly, including but not limited to, through any entity owned or controlled by 

him, participating in the issuance, purchase, offer, or sale of any security, provided, however, 

that such injunction shall not prevent him from purchasing or selling securities for his own 

personal account. 

C. Enter a Final Judgment barring Meier from acting as an officer or director of any 

public company, pursuant to Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)] and Section 

21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)]. 

D. Enter a Final Judgment ordering Defendant Meier to disgorge his ill-gotten gains 

or unjust enrichment, with prejudgment interest thereon, to effect the remedial purposes of the 

federal securities laws. 

E. Enter a Final Judgment against Relief Defendants ordering each of them to 

disgorge all unjust enrichment and/or ill-gotten gains, with prejudgment interest thereon, to 

effect the remedial purposes of the federal securities laws.    

F. Enter a Final Judgment ordering Meier to pay civil penalties pursuant to Section 

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

U.S.C. § 78u(d)]. 

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

orders and decrees that may be entered. 

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

  

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DEMAND FOR JURY TRIAL 

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, the Commission demands a 

jury trial in this action of all issues so triable under the claims in this Complaint. 

Dated: October 11, 2024   Respectfully submitted, 

  
/s Michael C. Moran      
Michael C. Moran (Mass. Bar No. 666885) 
Kerry Dakin (Mass. Bar No. 640826) 
William J. Donahue (Mass. Bar No. 631229) 
Colin D. Forbes (N.Y. Bar No. 4664264) 
Boston Regional Office 
33 Arch Street, 24th Floor 
Boston, MA  02110 
Phone:  (617) 573-8900 
Facsimile: (617) 573-4590 
Moran email:  [email protected] 
Moran phone:  (617) 573-8931  

Counsel for Plaintiff Securities and Exchange 
Commission 
 
 

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