The $3.5MM, imo, falls under disgorgement. These are dollars
ACT received that were illegal. The penalties sometimes can be
as much as the disgorgement. Hopefully it won't be any worse
than the $3.5MM..
SEC relief sought,
II.
Disgorgement
Issue an Order directing Lefkowitz, Compass Capital, Unico, Peacock, Traveller, and Advanced Cell to disgorge, with prejudgment interest, all profits that they received as a result of the acts and/or courses of conduct alleged in this Complaint.
III.
Penalties
Issue an Order directing Lefkowitz, Compass Capital, Lopez, Unico, Peacock, Traveller, and Advanced Cell to pay civil money penalties pursuant to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d) of the Exchange Act [15 U.S.C. § 78u(d)].
