Filed 04/06/26 in TXSD
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Case 4:26-cv-02721
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Filed 04/06/26 in TXSD
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IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
SECURITIES AND EXCHANGE COMMISSION,
Plaintiff,
v.
AARON VERDUGO,
VERDUGO ENTERPRIZES, LLC
D/B/A BDAASWORX, AND
BDAAS INC.,
Defendants.
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Case No.: 4:26-cv-2721
JURY TRIAL DEMANDED
COMPLAINT
Plaintiff Securities and Exchange Commission (the “Commission” or “Plaintiff”) files this
Complaint against Aaron Verdugo (“Verdugo”), Verdugo Enterprizes, LLC d/b/a BDaaSWorx
(“BDaaSWorx”), and BDaaS Inc. (“BDaaS”) (collectively “Defendants”) and alleges as follows:
I.
SUMMARY
1.
From approximately August 2022 through January 2024 (the “Relevant Period”),
Verdugo raised approximately $6.67 million from approximately 200 investors in an unregistered
securities offering made primarily through two entities that he wholly owned, BDaasWorx and
BDaaS (together, “BDX”), based on materially false and misleading statements.
2.
The Defendants offered and sold to investors the opportunity to purchase
computer chipset units, along with the management services provided by BDX to install, manage,
and maintain the units, which were purportedly going to be deployed in BDX’s current
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infrastructure (the “BDX Power Program”). BDX claimed to operate a data center where it housed
and maintained the chipset units it purported to have contracted for use by third parties who
required high volume data computation and/or storage services (“big data as a service” or “BDaaS
services”). The Defendants promised to maintain and manage the chipset units and secure
customers to utilize the chipset units, which would ultimately generate profits for the investors.
3.
Defendants made numerous materially false and misleading statements to
investors about fundamental aspects of BDX and the BDX Power Program. Defendants claimed
BDX had established customer relationships with several large Fortune 500 technology
companies, among others, and further claimed it was already providing BDaaS services to them.
Investors were promised monthly returns purportedly generated from the payments BDX received
from these purported existing customers. Investors were further promised a quick return of their
full investment and a “satisfaction guarantee,” whereby investors could receive a full refund of
their investment amount, less any returns that they had received during the investment period, if
they were not satisfied with their investment for any reason.
4.
In reality, BDX did not have any customer contracts, provide any BDaaS services
to any customers, or have any source of revenue. By early 2023, just months after the Defendants
started raising investor funds, they had ceased paying monthly returns to nearly all investors, and
the Defendants failed to honor the satisfaction guarantee refunds to all but four investors, which
were paid using other investors’ funds. Meanwhile, Verdugo directed BDX staff to make
additional misstatements regarding BDX’s failure to pay monthly returns.
5.
Unbeknownst to investors, Verdugo also misappropriated at least $6.1 million of
investor funds, using approximately $591,000 to pay investors and approximately $5.5 million
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to pay unauthorized expenses, of which approximately $4,684,000 was used to pay unauthorized
operational expenses and approximately $854,000 was used to pay unauthorized compensation.
Except for the $591,000 in investor funds paid to investors as returns or refunds, the remaining
investors never received any monthly returns or refunds, which resulted in substantial losses to
investors based on their investments.
6.
By committing the acts alleged in this Complaint, Defendants violated Sections
5(a), 5(c), and 17(a)(2) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77e(a) and
(c) and 77q(a)(2)] and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”)
[15 U.S.C. § 78j(b)] and Rule 10b-5(b) thereunder [17 C.F.R. § 240.10b-5(b)].
7.
The Commission brings this action against the Defendants seeking: (a) injunctive
relief; (b) disgorgement of ill-gotten gains; (c) pre-judgment interest on those ill-gotten gains; (d)
a civil penalty against Verdugo; and (e) all other equitable and ancillary relief to which the Court
determines that the Commission is entitled.
II.
JURISDICTION AND VENUE
8.
The Court has jurisdiction over this action under Sections 20(b), 20(d) and 22(a)
of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d) and 77v(a)] and Sections 21(d), 21(e), and 27
of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), and 78aa]. Defendants, directly and indirectly,
made use of means or instrumentalities of interstate commerce, or of the mails, or the facilities of
a national securities exchange, in connection with the acts, omissions, transactions, practices,
and/or courses of business alleged herein.
9.
Venue in this district is proper under Section 22 of the Securities Act [15 U.S.C. §
77v] and Section 27 of the Exchange Act [15 U.S.C. § 78aa] because a substantial part of the
events giving rise to the claims occurred within the district, including but not limited to
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Defendants’ sales of securities, misrepresentations, acts, practices, transactions, and courses of
business. Further, Verdugo resides in Humble, Texas, which is located in this district.
10.
Defendants engaged in the acts, omissions, transactions, practices, and/or courses
of business described in this Complaint in connection with the offer, purchase, and/or sale of
investment contracts through the BDX Power Program, which are securities under Section 2(a)(1)
of the Securities Act and Section 3(a)(10) of the Exchange Act.
III.
DEFENDANTS
11.
Aaron Verdugo resides in Humble Texas. At all relevant times, Verdugo has
been the founder, principal officer, and sole member of BDaaSWorx and the control person of
BDaaS.
12.
Verdugo Enterprizes, LLC d/b/a BDaaSWorx is an Arizona limited liability
company with its principal place of business in Tempe, Arizona. Verdugo is the founder, sole
member and principal officer of BDaaSWorx. Verdugo formed and operated several companies
under the name “BDaaSWorx” or “BDaaS,” but corporate formalities were not observed between
the various entities, and these entities appear to have been used somewhat interchangeably during
the Relevant Period with general references to “BDaaSWorx,” “BdaaS,” “BDX,” and the “BDX
Power Program” in marketing materials, including written sales presentations and BDX’s
website. As such, representations and other information provided to investors about the offering
were made by BDaaSWorx and BDaaS interchangeably at various times throughout the Relevant
Period. BDaaSWorx and BDaaS are collectively referred to as “BDX” throughout this
Complaint.
13.
BDaaS Inc. is a Wyoming corporation with its principal place of business in
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Sheridan, Wyoming. Verdugo is the control person of BDaaS.
IV.
STATEMENT OF FACTS
A.
Background.
14.
In August 2022, Verdugo launched the BDX Power Program which offered
investors in multiple states the opportunity to purchase computer chipset units, along with
management services provided by BDX to install, manage and maintain the units. BDX claimed
to operate a data center in Houston, Texas where it housed and maintained computer hardware
(i.e., chipset units). The Defendants claimed that BDX had contracts for use of the chipset units
housed at its data center with third parties who required high volume data computation and/or
storage services. The Defendants claimed that they had established customer relationships with
Fortune 500 technology companies, among others, and further claimed that chipsets purchased
through the BDX Power Program would purportedly be installed to power BDX’s existing
infrastructure and support BDX’s existing customers. In exchange for their investment, investors
were promised monthly payments purportedly generated from the payments BDX received from
its existing customers.
B.
Sale of the BDX Power Program Securities
15.
Depending on when investors participated in the BDX Power Program, investors
made a one-time payment between approximately $8,300 and $12,300, which, according to the
Defendants, BDX would purportedly use to purchase, install, and program the chipset unit. More
than half of the investors in the BDX Power Program purchased more than one chipset unit or
made multiple investments with BDX. Most investors sent their money via wire transfer to
BDX’s bank accounts, which were owned and controlled by Verdugo. Investor funds were
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pooled and commingled in these accounts and subsequently used by Verdugo to make payments
to investors and for various unauthorized expenses.
16.
The Defendants utilized a sales team to promote the BDX Power Program, which
were internally referred to as “Authorized Dealers.” Several of the Authorized Dealers were
investors themselves in the BDX Power Program. Verdugo recruited an individual to lead the sales
and marketing efforts of the Authorized Dealers, and to help facilitate communications with
investors. This individual was responsible for overseeing the sales process and preparing
marketing materials and other offering documents based upon information provided to him by
Verdugo, all of which were provided to Verdugo for his review and approval before distributing
to potential investors. Once approved, these marketing materials were provided to the Authorized
Dealers who then distributed them to potential investors on BDX’s public website and by email,
text, phone, and social media platforms. Verdugo occasionally attended in-person and video
meetings with potential investors where he would describe the BDX Power Program and BDX’s
infrastructure and technology.
17.
When an investor agreed to invest in the BDX Power Program, they entered into a
Services Agreement with BDX in which BDX agreed to provide ongoing services to investors as
a part of the investment. Specifically, BDX agreed to install, manage, and maintain the investors’
chipset units, including programming and configuring the units to provide data processing and
storage services for BDX’s customers. Investors were to receive a pro rata share of the profits
generated from the deployment of their respective chipset unit(s) to power BDX’s infrastructure.
Investors were fully reliant on the Defendants to operate the data center, manage and maintain the
chipset units, and generate the promised returns. As noted in BDX’s written sales presentations
and on its website, the BDX Power Program promised investors “passive income,” that they could
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make money while they slept, and that their participation in the program required zero hours from
them.
C.
The BDX Power Program was an Unregistered Securities Offering
18.
The BDX Power Program was a securities offering because investments in the
program constituted investment contracts under the federal securities laws. Investors invested
money by wiring funds to BDX bank accounts, where the money was pooled with other investors’
funds. After sending their money to the Defendants, the investors had no decision-making
authority regarding how BDX would use their funds and they had no control over the success of
their investments. Instead, investors collectively relied on the efforts and expertise of the
Defendants to generate sufficient revenues to pay the monthly returns and to uphold their
obligations under the satisfaction guarantee, which is discussed in more detail below.
19.
Investors expected their profits solely from the efforts of the Defendants and were
entirely passive. Investors had no control over, or insight into, what was done with their money
after they sent it to BDX. The investors had to rely on the Defendants for the success or
profitability of the purported investment because they did not have the requisite knowledge to
manage or maintain the chipset units or to operate the data center, all of which BDX claimed to
engage in to generate its revenue. Investors were not given any information or access that would
have allowed them to participate in the operation of the data center.
20.
During the Relevant Period, the Defendants raised at least $6.67 million from
approximately 200 investors in multiple states through the offer and sale of investment contracts
related to the BDX Power Program. The Defendants used in-person events, BDX’s public
website, email, text, phone, and social media platforms to solicit investors, many of whom did
not have preexisting, substantive relationships with the Defendants or the Authorized Dealers.
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The BDX Power Program offering was not registered with the Commission. Further,
the Defendants did not attempt to verify that investors were accredited investors and, in fact, accepted
investments from unaccredited investors.
D.
Misrepresentations Regarding the BDX Power Program
i.
Statements Regarding BDX’s Existing Customer Relationships
22.
During the Relevant Period, the Defendants made numerous false and misleading
statements to investors regarding BDX’s existing relationships with data services customers. For
example, in offering materials provided to investors, including written sales presentations, the
Defendants included a false and misleading statement that BDX provided services to several
Fortune 500 companies, among others. The Defendants made similar false and misleading
statements touting BDX’s established customer relationships with several Fortune 500 companies
on its website, and during in-person sales presentations to investors. The corporate logos for the
Fortune 500 companies were prominently featured in the BDX offering materials.
23.
These statements were false and misleading because, while the Defendants did
undertake some effort to set up its business operations, such as renting office space, purchasing
computer equipment and hardware, and securing bookkeeping software, BDX did not provide
BDaaS services to any customers, let alone Fortune 500 companies, during the Relevant Period.
ii.
24.
Statements Regarding BDX’s Investment Returns and Satisfaction Guarantee
The Defendants also made false and misleading statements regarding BDX’s
successful track record and the returns investors could expect to receive from investing in the BDX
Power Program. Included in written sales presentations provided to investors, investors were
promised “incredible earnings” with most investors recouping their full investment within
approximately four to nine months. In other written sales presentations provided to investors, the
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Defendants promised investors “100% Success” with all investors earning returns within 90 days
after investing in the BDX Power Program. Similar claims were repeated on BDX’s public
website. Investors were further promised “passive income” and the ability to “make money while
[they] sleep” as the chipset earned income from the BDaaS services. Investors were told to expect
monthly returns between $480 - $2,000 per chipset for the life of the unit, which would typically
continue for 7-10 years.
25.
While BDX acknowledged to investors that the expected rate of return was not
guaranteed, the Defendants promised a satisfaction guarantee to provide another type of investor
protection for the BDX Power Program. This satisfaction guarantee was presented to investors in
the Services Agreement, in written sales presentations, and on BDX’s website. Investors were told
they could receive a full refund of their investment amount, less any returns they had received
during the investment period if they were not satisfied with the investment for any reason.
Investors could elect to exercise their satisfaction guarantee after an initial 12-month term, which
was later extended to a 24-month term.
26.
In reality, BDX’s offering materials misrepresented the performance and potential
returns of the BDX Power Program, while understating the risks of the investment. At the time
the Defendants were making such representations to investors, the BDX Power Program had just
launched and did not have any operating history. Further, the expected monthly returns promised
to investors were arbitrary, because BDX did not have any customer contracts or other source of
revenue. In fact, by early 2023, the Defendants had ceased paying returns to nearly all investors.
The satisfaction guarantee was also misleading because BDX was not generating any revenues
and had no source of funds – aside from funds from investors – that could be used to provide a
full refund if an investor elected to receive one. Despite many demands, the Defendants failed to
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provide refunds to all but four investors. Ultimately those that did receive a refund or return only
did so after the Defendants received money from new investors.
E.
Defendants’ Use of Investor Funds
27.
In offering materials provided to investors, including written sales presentations and the
Services Agreement, the Defendants represented to investors their funds would be allocated to
purchase the chipset units and the installation and programming of the units by BDX. As part of the
BDX Power Program offering, the Defendants provided each investor with an invoice reflecting the
purported allocations of their investment funds. These invoices were false.
28.
The Services Agreement provided that BDX would withhold a 20% service fee on
all earnings withdrawals made by investors from their account. It was this service fee, not investor
funds, that was meant to cover BDX’s ongoing operational expenses for the data centers used to
store the chipset units, along with the labor required to service, maintain, and manage the chipset
units. However, BDX did not have any customer contracts to generate earnings and the majority
of investors never received any earnings withdrawals from BDX from which the Defendants could
withhold the service fee.
29.
When investors contacted BDX regarding missed or lower than expected
payments, the Defendants made additional misstatements regarding the payment delays,
including blaming programming errors, BDX not receiving customer payments because of
changes in business practices by vendors, an internal “audit” to improve BDX’s process, and the
creation of a waiting list for refunds. In reality, BDX did not have any customer contracts and
was not generating any revenue to pay the monthly returns or to meet its refund obligations. By
the end of the Relevant Period, BDX stopped responding to investor inquiries and complaints and
investors stopped receiving any information regarding their investment in the BDX Power
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Program.
30.
After receiving investor funds sent to the BDX bank accounts he controlled,
Verdugo misappropriated investor funds to make payments to investors, and for unauthorized
expenses. Bank records indicate Verdugo misappropriated at least $6.1 million of investor funds,
of which he made approximately $591,000 in payments to investors as returns and refunds. In
addition, out of the misappropriated investor funds, Verdugo made payments for unauthorized
expenses totaling approximately $5.5 million, of which approximately $4,684,000 was used to
pay unauthorized operational expenses and approximately $854,000 was used to pay
unauthorized compensation, including paying for a luxury vehicle, transferring funds to his
spouse, and making credit card payments for personal expenditures.
V.
CLAIMS FOR RELIEF
FIRST CLAIM FOR RELIEF
Violations of Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and
Rule 10b-5(b) thereunder [17 C.F.R. § 240.10b-5(b)]
Against all Defendants
31.
Plaintiff re-alleges and incorporates paragraphs 1-30 of this Complaint by
reference as if set forth verbatim in this Claim.
32.
By engaging in the acts and conduct alleged herein, Defendants, directly or
indirectly, in connection with the purchase or sale of a security, by the use of any means or
instrumentality of interstate commerce, or of the mails or of any facility of any national securities
exchange, knowingly or with severe recklessness, made an untrue statement of material fact or
omitted to state a material fact necessary in order to make the statements made, in light of the
circumstances under which they were made, not misleading.
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33.
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By reason of the foregoing, Defendants violated, and unless restrained and
enjoined will continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and
Rule 10b-5(b) thereunder [17 C.F.R. §§ 240.10b-5(b)].
SECOND CLAIM FOR RELIEF
Violations of Section 17(a)(2) of the Securities Act [15 U.S.C. §77q(a)(2)]
Against all Defendants
34.
Plaintiff re-alleges and incorporates paragraphs 1-30 of this Complaint by reference
as if set forth verbatim in this Claim.
35.
By engaging in the acts and conduct alleged herein, Defendants, directly or
indirectly, in the offer or sale of securities, by the use of any means or instruments of transportation
or communication in interstate commerce or by the use of the mails, have knowingly, with severe
recklessness, or negligently, obtained money or property by means of an untrue statement of a
material fact or an omission to state a material fact necessary in order to make the statements made,
in light of the circumstances under which they were made, not misleading.
36.
By reason of the foregoing, Defendants have violated, and unless restrained and
enjoined will continue to violate, Section 17(a)(2) of the Securities Act [15 U.S.C. § 77q(a)(2)].
THIRD CLAIM FOR RELIEF
Violations of Sections 5(a) and 5(c) of the Securities Act
[15 U.S.C. §§ 773(a) and 77e(c)]
Against all Defendants
37.
Plaintiff re-alleges and incorporates paragraphs 1-30 of this Complaint by
reference as if set forth verbatim in this Claim.
38.
By engaging in the acts and conduct alleged herein, Defendants, directly or
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indirectly:
a. made use of the means or instruments of transportation or communication in
interstate commerce or of the mails to sell, through the use or medium of any
prospectus or otherwise, securities as to which no registration statement was
in effect;
b. for the purpose of sale or delivery after sale, carried or caused to be carried
through the mails or in interstate commerce, by means or instruments of
transportation, securities as to which no registration statement was in effect;
and/or
c. made use of means or instruments of transportation or communication in
interstate commerce or of the mails to offer to sell, through the use or medium
of any prospectus or otherwise, securities as to which no registration statement
had been filed.
39.
There were no applicable exemptions from registration.
40.
By engaging in the conduct described above, Defendants have violated, and
unless restrained and enjoined will continue to violate, Sections 5(a) and 5(c) of the Securities
Act [15 U.S.C. §§ 77e(a) and (c)].
VI.
JURY DEMAND
41.
The SEC demands a trial by jury on all issues that may be so tried.
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VII.
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that the Court enter a Final
Judgment:
A.
Permanently restraining and enjoining Defendants from violating Sections 5(a),
5(c), and 17(a)(2) of the Securities Act [15 U.S.C. §§ 77e(a) and (c) and 77q(a)(2)] and Section
10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5(b) thereunder [17 C.F.R. §
240.10b-5(b)];
B.
Restraining and enjoining Defendant Verdugo, for a period of five years, 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.
Ordering Defendants to disgorge, on a joint-and-several basis, all ill-gotten gains
they received as a result of the conduct alleged herein, together with prejudgment interest on
those amounts, pursuant to Sections 21(d)(3), 21(d)(5) and 21(d)(7) of the Exchange Act [15
U.S.C. §§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)];
D.
Ordering Defendant Verdugo to pay a civil 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
E.
Granting such other and further relief as this Court may determine to be just and
necessary.
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Respectfully submitted,
/s/ Matthew J. Gulde
Illinois Bar No. 6272325
Securities and Exchange Commission
Burnett Plaza, Suite 1900
801 Cherry Street, Unit 18
Fort Worth, TX 76102
Telephone: (817) 978-3821
Facsimile: (817) 978-4927
guldem@sec.gov
Attorney for Plaintiff
Securities and Exchange Commission
15
JS 44 (Rev. 03/24)
Case 4:26-cv-02721
Document
1-1 Filed
04/06/26 in TXSD
CIVIL COVER
SHEET
Page 1 of 1
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS
DEFENDANTS
AARON VERDUGO, VERDUGO ENTERPRIZES, LLC,
D/B/A BDAASWORX, AND BDAAS INC.
County of Residence of First Listed Defendant
Harris
SECURITIES AND EXCHANGE COMMISSION
(b) County of Residence of First Listed Plaintiff
(EXCEPT IN U.S. PLAINTIFF CASES)
NOTE:
(c) Attorneys (Firm Name, Address, and Telephone Number)
Matthew J. Gulde
801 Cherry St., Suite 1900, Fort Worth, TX 76102
(817) 978-3821
II. BASIS OF JURISDICTION (Place an “X” in One Box Only)
✖
1
U.S. Government
Plaintiff
3
Federal Question
(U.S. Government Not a Party)
2
U.S. Government
Defendant
4
Diversity
(Indicate Citizenship of Parties in Item III)
(IN U.S. PLAINTIFF CASES ONLY)
IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
Attorneys (If Known)
Alan Baskin, Esq., Weiss Brown
6263 N. Scottsdale Road, Suite 340, Scottsdale, AZ 85250
III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only)
PTF
Citizen of This State
1
2
2
Incorporated and Principal Place
of Business In Another State
5
5
Citizen or Subject of a
Foreign Country
3
3
Foreign Nation
6
6
Click here for: Nature of Suit Code Descriptions.
TORTS
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excludes Veterans)
153 Recovery of Overpayment
of Veteran’s Benefits
160 Stockholders’ Suits
190 Other Contract
195 Contract Product Liability
196 Franchise
REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property
PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
Slander
330 Federal Employers’
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury Medical Malpractice
CIVIL RIGHTS
440 Other Civil Rights
441 Voting
442 Employment
443 Housing/
Accommodations
445 Amer. w/Disabilities Employment
446 Amer. w/Disabilities Other
448 Education
and One Box for Defendant)
PTF
DEF
Incorporated or Principal Place
4
4
of Business In This State
Citizen of Another State
IV. NATURE OF SUIT (Place an “X” in One Box Only)
CONTRACT
DEF
1
PERSONAL INJURY
365 Personal Injury Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
370 Other Fraud
371 Truth in Lending
380 Other Personal
Property Damage
385 Property Damage
Product Liability
PRISONER PETITIONS
Habeas Corpus:
463 Alien Detainee
510 Motions to Vacate
Sentence
530 General
535 Death Penalty
Other:
540 Mandamus & Other
550 Civil Rights
555 Prison Condition
560 Civil Detainee Conditions of
Confinement
FORFEITURE/PENALTY
BANKRUPTCY
OTHER STATUTES
625 Drug Related Seizure
of Property 21 USC 881
690 Other
422 Appeal 28 USC 158
423 Withdrawal
28 USC 157
INTELLECTUAL
PROPERTY RIGHTS
375 False Claims Act
376 Qui Tam (31 USC
3729(a))
400 State Reapportionment
410 Antitrust
430 Banks and Banking
450 Commerce
460 Deportation
470 Racketeer Influenced and
Corrupt Organizations
480 Consumer Credit
(15 USC 1681 or 1692)
485 Telephone Consumer
Protection Act
490 Cable/Sat TV
850 Securities/Commodities/
Exchange
890 Other Statutory Actions
891 Agricultural Acts
893 Environmental Matters
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Act
896 Arbitration
899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
950 Constitutionality of
State Statutes
LABOR
710 Fair Labor Standards
Act
720 Labor/Management
Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Employee Retirement
Income Security Act
IMMIGRATION
462 Naturalization Application
465 Other Immigration
Actions
820 Copyrights
830 Patent
835 Patent - Abbreviated
New Drug Application
840 Trademark
880 Defend Trade Secrets
Act of 2016
SOCIAL SECURITY
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
✖
FEDERAL TAX SUITS
870 Taxes (U.S. Plaintiff
or Defendant)
871 IRS—Third Party
26 USC 7609
V. ORIGIN (Place an “X” in One Box Only)
✖
1 Original
Proceeding
2 Removed from
State Court
3
Remanded from
Appellate Court
4 Reinstated or
Reopened
5 Transferred from
Another District
(specify)
6 Multidistrict
Litigation Transfer
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
8 Multidistrict
Litigation Direct File
Sections 5(a), 5(c), & 17(a)(2) of the Securities Act & Section 10(b) of the Securities Exchange Act & Rule 10b-5 thereunder
VI. CAUSE OF ACTION Brief description of cause:
Securities Fraud
VII. REQUESTED IN
COMPLAINT:
VIII. RELATED CASE(S)
IF ANY
CHECK IF THIS IS A CLASS ACTION
UNDER RULE 23, F.R.Cv.P.
(See instructions):
CHECK YES only if demanded in complaint:
DEMAND $
JURY DEMAND:
JUDGE
DATE
SIGNATURE OF ATTORNEY OF RECORD
April 6, 2026
s/Matthew J. Gulde
DOCKET NUMBER
FOR OFFICE USE ONLY
RECEIPT #
AMOUNT
APPLYING IFP
JUDGE
MAG. JUDGE
✖
Yes
No
This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.