compames. Johnson concealed his illicit trading
using an online brokerage account held inthe name
his wife, Dalila Lopez (the "Lopez account"), that Johnson did not disclose toNasdaq in violation
Nasdaq policy. Johnson frequently placed the orders for his illegal tradesfrom his office computer at Nasdaq's offices in New York.
Johnson took advantage
both favorable and unfavorable information that wasentrusted to him in confidence
Nasdaq and its listed company clients, shorting stocks
several occasions and establishing long positions in other instances, altogether reaping illegalprofits in excess of$755,000.
Johnson's trading violated the antifraud provisions
Securities Exchange Act
U.S.c. § 78j(b)] and Rule
[17 C.F.R.§ 240.1
thereunder. The Commission requests that this Court permanently enjoin Johnsonfrom violating the aforesaid statutory provision and rule, order disgorgement ofillegal tradingprofits with prejudgment interest thereon, and impose civil penalties. In addition, as to ReliefDefendant Lopez, the Commission seeks disgorgement
all proceeds from the alleged insidertrading that are in her possession, custody,
control, plus prejudgment interest thereon.
JURISDICTION AND VENUE
This Court has jurisdiction over this action pursuant to Sections
Exchange Act [15 U.S.C.
78u(d) and (e), 78u-l, and 78aa].
Venue is proper in this district pursuant to Section 27
the Exchange Act [15
§ 78aa] because certain acts and transactions constituting the violations occurred in thisdistrict. Many
Johnson's illegal trades were placed online from his work computer, located inNasdaq's Manhattan