MEMORANDUM OPINION
MATSCH, District Judge.
This is a civil enforcement proceeding brought by the Securities and Exchange Commission (SEC) pursuant to § 20(b) of the Securities Act of 1933, 15 U.S.C. § 77t(b), and § 21(e) of the Securities Exchange Act of 1934, 15 U.S.C. § 78u(e) for injunctive and ancillary equitable relief upon claims of violations of the substantive provisions of those statutes in connection with a public offering of...
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