JURISDICTION AND VENUE
This Court has jurisdiction under Sections 21(d), 21(e), and 27 of the ExchangeAct [15 U.S.C. §§ 78u(d), 78u(e) and 78aa]. Noble, Jackson, and Ruehlen, directly or indirectly,made use of the means or instrumentalities of interstate commerce, including electronic mail, of the mails, or of the facilities of a national securities exchange in connection with the transactions,acts, practices, and courses of business alleged in this Complaint.7.
Venue is appropriate in this Court under Section 27 of the Exchange Act [15U.S.C. § 78aa] or 28 U.S.C. § 1391(d) because, among other reasons, certain acts or transactionsconstituting the violations by Defendants occurred in this district.
DEFENDANTS AND OTHER ENTITIES
Jackson was Noble’s CFO from September 2000 to about October 2005, andActing CFO from about March 2006 to about November 2006. Jackson became COO in March2005, became the President and COO in February 2006, became a Director in July 2006, and became CEO in late October 2006. When Jackson resigned in September 2007, he wasPresident, CEO, and Chairman of the Board.9.
As CFO and Acting CFO, Jackson was responsible for Noble’s compliance withthe FCPA. He received regular reports of payments made to government officials, and hereviewed and approved such payments, including those for TIPs and TIP extensions. As CFOand Acting CFO, Jackson supervised Noble’s internal audit, finance, and accounting functions.The head of internal audit reported directly to Jackson, and Jackson received both drafts and finalversions of audit reports. Jackson was responsible for the accuracy of Noble’s books, includingthe accurate recording of payments to government officials.
Case 4:12-cv-00563 Document 95 Filed in TXSD on 01/25/13 Page 3 of 58