UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
(West Palm Beach Division)
SECURITIES AND EXCHANGE COMMISSION,
Plaintiff, :
: CASE NO.
v. :
: COMPLAINT FOR
JEFFREY D. CHANDLER : INJUNCTIVE AND
: OTHER RELIEF
RANDALL JORDAN :
Defendants.
Plaintiff Securities and Exchange Commission ("SEC" or "Commission") alleges as
follows:
INTRODUCTION
1. The Commission brings this action to enjoin Jeffrey D. Chandler ("Chandler") and
Randall Jordan ("Jordan") (collectively, "Defendants") from continuing to violate the
federal securities laws in connection with a fraudulent offering of securities of eComprar
Network, Inc. ("eComprar"), a now defunct company that purportedly operated a
television home shopping network in Latin America. From approximately February 2000
to July 2000, Defendants disseminated false and misleading information to investors
concerning, among other things, eComprar's operations, expected financial results, and
use of proceeds. As part of their scheme, Defendants raised $5 million and used a
substantial portion of the proceeds to maintain a lavish lifestyle for themselves and to
settle prior legal disputes. As a result, Defendants violated Sections 5(a), 5(c) and 17(a)
of the Securities Act of 1933 ("Securities Act") and Section 10(b) of the Securities
Exchange Act of 1934 ("Exchange Act") and Rule 10b-5 thereunder.
DEFENDANTS
2. Defendant Chandler, age 36, resides in Stuart, Florida and was, at all relevant times,
the president and majority shareholder of eComprar. Chandler directed and supervised
the activities of eComprar.
3. Defendant Jordan, age 47, resides in Jupiter, Florida and was, at all relevant times, the
executive vice-president, director, and a shareholder of eComprar. During the relevant
time period, Jordan also directed and supervised the activities of eComprar.
SNIPPETS:
SOUTHERN DISTRICT OF FLORIDA
Plaintiff Securities and Exchange Commission alleges as follows:
From approximately February 2000 to July 2000, Defendants disseminated false and misleading
As a result, Defendants violated Sections 5, 5and 17of the Securities Act of 1933 and Section
Defendant Chandler, age 36, resides in Stuart, Florida and was, at all relevant times, the
Defendant Jordan, age 47, resides in Jupiter, Florida and was, at all relevant times, the
Defendants, directly or indirectly, have made use of the means and instrumentalities of
eComprar, a defunct Florida corporation formerly located in West Palm Beach, Florida,
Jordan joined eComprar shortly after its formation, and both Chandler and Jordan prepared a
From February to July 2000, Chandler and Jordan engaged in a fraudulent common stock offering
In private and group meetings, Jordan and Chandler gave investors the PPM and other offering
The PPM failed to disclose, however, that there was a pending civil lawsuit against Chandler
Chandler and Jordan knew, or recklessly disregarded, that these representations and omissions
The PPM misrepresented that eComprar would begin broadcasting its programming in the
Beginning in 1999, Chandler and Jordan submitted documents to Banc of America Securities, LLP
Chandler and Jordan also gave investors copies of internal materials prepared by Banc of
By reason of the foregoing, Defendants, directly or indirectly, have violated, and unless
The SEC realleges and repeats its allegations set forth at paragraphs 1 through 19 of this
Issue an Order directing Defendants Chandler and Jordan to disgorge all profits or proceeds
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