MEMORANDUM ORDER
PATRICK E. HIGGINBOTHAM, District Judge.
This is an action by plaintiff OKC Corp. ("OKC") against the Securities and Exchange Commission and various commissioners, officers, and employees of the Commission (collectively "the SEC"). To simplify presentation of the issues, the court subdivided the litigation into two phases. In the first phase, the court granted partial dismissal and partial summary judgment in favor of the SEC. The court...
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