7. Certain of the insider trading was conducted through brokerage accountsheld in the names of Tatiana Vorobieva, Vorobiev’s wife, and Anjali Walter, Koval’swife, and portions of the proceeds from the illicit trading were received by Vorobieva andWalter. Accordingly, Vorobieva and Walter are named as relief defendants in this action.8. Each of the Defendants violated Section 10(b) of the Securities ExchangeAct of 1934 (“Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5 [17 C.F.R. § 240.10b-5] thereunder and Section 14(e) of the Exchange Act [15 U.S.C. § 78n(e)] and Rule 14e-3[17 C.F.R. § 240.14e-3] thereunder. The Commission requests that the Court enjoin eachDefendant from violating the foregoing securities laws, order each Defendant to disgorgetheir unlawful profits with prejudgment interest, impose civil monetary penalties on eachDefendant and order such other relief as the Court may deem appropriate.9. Unless temporarily restrained and preliminarily enjoined, the Defendantswill continue to violate the federal securities laws and attempt to hide and dissipate assetsand monies generated by the illegal trading.
JURISDICTION AND VENUE
10. This Court has jurisdiction of this action pursuant to Sections 21(d), 21(e),21A, and 27 of the Exchange Act [15 U.S.C. §§ 78u(d)(1), 78u(e), 78u-1, and 78aa]. TheDefendants, directly or indirectly, singly or in concert with others, made use of the meansor instruments of transportation and communication of interstate commerce, or of themails, or the facilities of a national securities exchange in connection with thetransactions, acts, practices, and courses of business alleged in this Complaint.3