UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
SECURITIES AND EXCHANGE
COMMISSION, :
: Civil Action
Plaintiff, : 02-CV
:
v. :
: COMPLAINT
G. CHRISTOPHER SCOGGIN, :
Defendant.
Plaintiff Securities and Exchange Commission (the "Commission") alleges:
NATURE OF THE ACTION
1. G. Christopher Scoggin ("Scoggin"), a former licensed stockbroker, violated the
antifraud and anti-touting provisions of the Securities Exchange Act of 1934 ("Exchange
Act") and the Securities Act of 1933 (the "Securities Act") by making repeated false
representations that his stock picks appearing in his newsletter, "Stock Talk," and on his
website, "Stocktalknews.com," were the result of "independent and diligent analysis." In
fact, Scoggin's stock picks were derived solely from his undisclosed financial and other
employment-related obligations to the issuers he touted, rather than from any independent
analysis. In addition, Scoggin failed to disclose the source of his compensation that, in
fact, derived from the very issuers he touted. As a result, Scoggin purposefully misled
investors. Moreover, on two occasions, Scoggin advised his readers to buy two different
stocks he was "independently" analyzing, only to begin selling his own positions in those
stocks days later.
2. By knowingly or recklessly engaging in fraudulent conduct, defendant directly or
indirectly violated the antifraud provisions of the federal securities laws, specifically,
Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)], and Rule 10b-5 thereunder [17
C.F.R. § 240.10b-5].
3. Defendant also violated Section 17(b) of the Securities Act [15 U.S.C. § 77q(b)] when
he touted stocks on his websites without fully disclosing he had received or expected to
receive compensation for doing so, and the amount thereof.
SNIPPETS:
UNITED STATES DISTRICT COURT
Plaintiff Securities and Exchange Commission alleges:
G. Christopher Scoggin, a former licensed stockbroker, violated the antifraud and
In addition, Scoggin failed to disclose the source of his compensation that, in fact, derived
Moreover, on two occasions, Scoggin advised his readers to buy two different stocks he was
By knowingly or recklessly engaging in fraudulent conduct, defendant directly or indirectly
Defendant also violated Section 17of the Securities Act when he touted stocks on his websites
Defendant, G. Christopher Scoggin, at all relevant times was a resident of Katy, Texas and is
Scoggin held senior shareholder relations positions at two NASDAQ-listed public companies
In conjunction with his consulting firm, Scoggin started an investment newsletter called
The newsletters in question all followed the same general format: the newsletter contained
While Scoggin did in some cases disclose his ownership interest in, or relationship with, the
Further, despite the fact that Aqua Vie paid the entire cost of producing the newsletter and
In exchange for his services, Alliance gave Scoggin the opportunity to purchase 100,000
Scoggin engaged in a similar deception regarding his promotion of Carnegie International.
While Scoggin did state his firm held 2,000,000 shares of restricted Carnegie stock and that
Scoggin disclosed that he had purchased 133,000 shares of Carnegie on the open market with
EINI was a Los Angeles-based company that purportedly used the internet to match actors with
Scoggin and EINI entered into an oral agreement whereby EINI would compensate Scoggin for his
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