Stuart Alderoty
@s_alderoty
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Chief Legal Officer @Ripple. Over 35 years of legal experience with expertise in regulatory affairs and complex litigation.
Miami
Joined July 2016
A huge win today – as a matter of law - XRP is not a security. Also a matter of law - sales on exchanges are not securities. Sales by executives are not securities. Other XRP distributions – to developers, to charities, to employees are not securities.
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Over 18 months and 6 court orders later, we finally have the Hinman docs (internal SEC emails and drafts of his infamous 2018 speech). While they remain confidential for now (at the SEC’s insistence), I can say that it was well worth the fight to get them.
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Today marks Gensler’s last full day. Starting tomorrow, ‘Gary who?’ will be the only appropriate response if someone mentions his name. Onward.
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1/ It’s been 5 years since Bill Hinman gave his infamous speech – and through the SEC’s lawsuit against @Ripple (and 7 court orders), we can finally share what happened behind the scenes through the now public emails / drafts of the speech.
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If I I had told you four years ago that I’d be standing at the Inaugural Crypto Ball in D.C. with Snoop Dogg, would you have believed me? Yeah, me neither.
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As expected, the SEC’s appeal brief is a rehash of already failed arguments –and likely to be abandoned by the next administration. We’ll respond formally in due time. For now, know this: the SEC’s lawsuit is just noise. A new era of pro-innovation regulation is coming, and.
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Victory has a thousand fathers, but make no mistake. The courage of Brad and Chris, and the resilience and expertise of Ripple Team Legal (most of whom are nameless and never sought the Twitter spotlight) paved the way. Ripple provided the blueprint to defeat Gary Gensler’s.
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The SEC made a serious mistake going after Brad & Chris personally – and now, they’ve capitulated, dismissing all charges against our executives. This is not a settlement. This is a surrender by the SEC.
#XRPCommunity #SECGov v. #Ripple #XRP BREAKING: CASE DISMISSED AGAINST BRAD GARLINGHOUSE AND CHRIS LARSEN
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Welcome to O̵f̵f̵i̵c̵e̵ After Hours with me! Let’s clear up this confusion about securities, investment contracts and digital assets.
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Couldn’t have said it better than @bgarlinghouse. This Administration understands our industry and the law. So refreshing.
Still riding high from all the Inauguration events in DC this weekend!. From the Crypto Ball, to the VP dinner, to the POTUS dinner, to sitting in the Capitol yesterday - there’s palpable excitement for all the good that’s possible leveraging crypto and blockchain… here in the
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…and to top it off, the beef bourguignon was really good.
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On January 20, Gensler’s war on crypto ends at the SEC. We asked the SEC to agree to postpone the filing of their opening brief in their appeal of our victory (current deadline Jan 15) – and they refused. What a waste of time and taxpayer dollars! . Nevertheless, we are confident.
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So much positive news today! Hard to pick my favorite, but this one (from the Fact Sheet accompanying the Executive Order) strikes a chord - doesn't it?
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I’ve always felt good about our legal arguments, and I feel even better now. I always felt bad about the SEC’s tactics, and I feel even worse about them now.
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Before the SEC sued Ripple, Chris and Brad (3 yrs ago today) they offered us the following settlement: the SEC would announce to the market that XRP is a security and the market would be given a short window to “come into compliance.” We said no because: (1) XRP is not a.
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A final judgment. The Court rejects the SEC’s suggestion that Ripple acted recklessly and she reminds the SEC that this case did not involve any allegations of fraud or intentional wrongdoing, and no one suffered any financial harm. She rejects the SEC’s absurd demand for $2B in.
The SEC asked for $2B, and the Court reduced their demand by ~94% recognizing that they had overplayed their hand. We respect the Court’s decision and have clarity to continue growing our company. This is a victory for Ripple, the industry and the rule of law. The SEC’s.
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The SEC has lost 4 of its last 5 cases in the Supreme Court, thanks to the few that had the courage and resources to fight back against the SEC’s bullying and clinging to stretch legal positions that were not faithful to the law.
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Thank you, Acting Chairman Uyeda, for saying it: The SEC's war on crypto created "confusion about what is legal” and “an environment hostile to innovation and conducive to fraud." Looking forward to working with the Crypto Task Force to undo the prior administration's damage.
🇺🇸 BREAKING: The SEC has launched a new crypto task force, led by Commissioner Peirce, aimed at establishing a clear regulatory framework for the cryptocurrency industry.
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The Court’s July 13 ruling was, and remains, the law of the land. XRP is not a security.
#XRPCommunity #SECGov v. #Ripple #XRP BREAKING: Judge Torres has DENIED the SEC’s Motion to File an Interlocutory Appeal.
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It's outrageous that in today's Senate hearing, Mr. Gensler again misstates the law (and the Howey test), suggesting that tokens, standing alone, are investment contracts. Is the SEC really going to continue to be allowed to peddle these falsehoods?.
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Turns out, the only ‘efforts of others’ that truly moved crypto markets—by causing massive and prolonged artificial suppression—were those of the SEC.
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Crypto lawyer PSA: Chair Gensler has again proclaimed that every cryptocurrency, except BTC, is an unregistered security. He now must recuse himself from voting on any enforcement case that raises that issue since he has prejudged the outcome. Antoniu v. SEC (8th Cir. 1989).
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This is our final submission where we ask the court to grant judgment in our favor. After two long years, Ripple is proud of the defense we’ve mounted on behalf of the entire crypto industry. We have always played it straight with the Court. Can’t say the same for our adversary.
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XRP holders have always said that the SEC’s lawsuit is a direct attack on them. Now it's official. The Court’s ruling permits John Deaton to share his “meaningful perspective” to help the Court “reach a proper decision.” Yet another important (and positive) development.
🚨BREAKING: Judge Torres grants amici status to @JohnEDeaton1 and Movants, and Denies Motion to Intervene in @Ripple v. @SECGov . ADDED to our Document Library:.✅Text of the Order from Judge Torres 👇.
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Today’s order makes it clear there’s a serious question whether the SEC ever provided Ripple with fair notice that its distributions of XRP - since 2013 - would ever be prohibited under the securities law.
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The conclusion of these now public 2012 memos is clear: XRP “do not constitute securities.” 1/2.
#XRPCommunity #XRP #SECGov v. #Ripple #XRP BREAKING: BELOW ARE THE TWO LEGAL MEMOS THAT HAVE NOW BEEN UNSEALED.
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As we hit the beginning of the end with the SEC lawsuit, I couldn’t have asked for a better team to be part of. Thankful everyday for my equally inimitable colleagues at @Ripple!.
Learned a few new fun facts about our inimitable @s_alderoty here myself! ( example: the man has put out BOTH literal and figurative fires 🔥).
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I call it ‘Not a Security.’ Opening bid: $5 million. Serious inquiries only.
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As crypto enters its renaissance, please don’t hire any lawyer who was involved in suing any crypto company or project, or those who cheered the SEC suing a particular company, CEO, or founder. Want a list? My DMs are open.
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Over 40 million Americans own crypto. Most of those are between the ages of 18-34 and are demographically and racially diverse. That’s a lot of votes. Gary Gensler is a political liability.
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Could not agree more with @katiebiber. Pathetic “statement” coming from the SEC today. Take the loss. You earned it.
SEC Statement on Ripple has vibes of young campaign hack spinning on bad facts, vs powerful government agency expected to tell the truth. Do better.
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Today, we filed our preliminary legal response to the SEC’s complaint. With it, we start to set the record straight and correct many misconceptions and contradictions within their allegations. 1/5 .
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The SEC lost on all key points—that’s why they appealed. Today, Ripple filed a cross-appeal to ensure nothing’s left on the table, including the argument that there can’t be an "investment contract" without there being essential rights and obligations found in a contract.
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Talking to someone who still doesn’t understand that the token itself is not the security is like explaining to a flat earther that the world is round.
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Thank you to both campaigns for a hard-fought race and for invigorating the democratic process. Congratulations to @realDonaldTrump! You took the time to listen to Ripple's story when we met in SF this summer, and you prioritized crypto as a key policy issue. Now, let’s move.
.@realDonaldTrump, Congratulations!. Some fodder for your first 100-day checklist to get things moving:.- Fire Gensler. Day 1, no delays. - In his place, appoint Giancarlo, Brooks, or Gallagher – they’d be massive upgrades in rebuilding the rule of law (and reputation) at the.
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Just released photo of SEC’s misguided case following two years of Ripple’s relentless defense.
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(1) The SEC's decision to appeal is disappointing, but not surprising. This just prolongs what's already a complete embarrassment for the agency. The Court already rejected the SEC’s suggestion that Ripple acted recklessly, and there were no allegations of fraud and, of course,.
#XRPCommunity #SECGov v. #Ripple #XRP BREAKING: The @SECGov has filed a Notice of Appeal of Judge Torres’s Ruling.
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Ripple exposed the SEC’s lawless tactics early on. As the court said in our case: ‘The SEC is adopting its litigation positions to further its desired goal, not out of a faithful allegiance to the law.’ The question isn’t whether the SEC under Gensler is rogue—it is. The
Here’s the worst part: the SEC regularly loses case after case in federal court because they contort their rules in illegal & unconstitutional ways. They’re worse at following the law than the defendants they go after, which undermines public confidence in the rule of law itself.
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As many of you have seen, the SEC filed an amended complaint today. The only legal claim remains: did certain distributions of XRP constitute an investment contract? Disappointing the SEC needed to try to “fix” their complaint after waiting years to bring it in the first place. .
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Huge congrats to @iampaulgrewal and @coinbase for their win today. In Gensler’s final days, his anti-crypto crusade is imploding, and a federal appeals court has laid bare what the industry has said for years: his selective enforcement of securities laws was a (not so) covert
We just won our petition for a writ of mandamus at the Third Circuit. Rebuking @SECGov for its order denying our rulemaking petition, the Court held that the "SEC’s order was conclusory and insufficiently reasoned, and thus arbitrary and capricious, we grant Coinbase’s petition.
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Per *its own rules*, w/in 4 days the SEC should disclose the incident's nature and scope, and the impact on the market along with a description of its processes for assessing, identifying, and preventing such cybersecurity threats.
The @SECGov twitter account was compromised, and an unauthorized tweet was posted. The SEC has not approved the listing and trading of spot bitcoin exchange-traded products.
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Guess not. .
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On this 4th anniversary of the SEC’s lawless lawsuit against Ripple, Brad, & Chris, we urge the incoming administration to cleanse the lingering stain of Hinman from the agency. There’s much more to do to repair the damage, but let’s start by restoring trust.
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The SEC admits that FTX customer assets were used to bail out BlockFi. Were those customer assets funneled to the SEC to make payments on the $100 million SEC/BlockFi settlement? Did the SEC bother to conduct any due diligence on the source of those funds?
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My hot take - after two years of litigation, the SEC is unable to identify any contract for investment (that’s what the statute requires); and cannot satisfy a single prong of the Supreme Court’s Howey test. Everything else is just noise.
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Missed all the excitement yesterday on the Gensler hearing. I am in London, spending time with our team focused on growing our business. Can't tell you how inept the SEC looks from this side of the pond.
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Some SEC lawyers are still playing old games, earning yet another admonishment from a federal judge today—this time in the Kraken case. This conduct must end swiftly or risk undermining the efforts of SEC Crypto 2.0.
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So the SEC finally admits that 1/ "crypto asset security" is a made up term and 2/ to prove a "crypto asset security" is an investment contract, the SEC needs evidence of a bundle of "contracts, expectations, and understandings"? . Think it's time for @SECgov to admit it has
"The SEC regrets any confusion it may have invited" by falsely and repeatedly stating that tokens themselves are securities. This is the remarkable representation in Footnote 6 of @SECGov's Amended Complaint against Binance. I hope @s_alderoty is getting some good sleep tonight.
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Gary Gensler's institutional damage to the @SECGov runs deep. His legacy of undermining American innovation, and failing to uphold the law is shameful. With 18 states suing to hold him accountable, I look forward to him soon becoming an unfortunate footnote in SEC history.
The SEC overstepped its authorization from Congress and is attempting to classify cryptocurrencies as investment contracts – like stocks or bonds – that are subject to the SEC’s regulation. Read about our lawsuit:
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Maybe we can now start a rational conversation about crypto regulation in this country.
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Every litigator will tell you it’s always the defendant - never the plaintiff - asking to delay proceedings. Why would any plaintiff, let alone one with unlimited resources, play the delay card? 👀.
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The fact that Ripple had the foresight to seek legal advice from a prominent firm in 2012 – in the absence of clear case law and 5 years before the SEC even started talking about digital assets – should be applauded. 2/2.
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Reminder: The SEC complaint only "alleges." Nothing has been determined. That's what Courts are for. That's it. That's the tweet.
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The SEC bragging about record fines collected is like a professor boasting about their highest-ever class failure rate and the most cheating scandals. It’s not a measure of success—it’s an indictment of oversight gone terribly wrong, driven by perverse incentives.
We announced that the SEC filed 583 total enforcement actions in fiscal year 2024 while obtaining orders for $8.2 billion in financial remedies, the highest amount in SEC history. For more:
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A must watch. For hours Mr. Gensler smugly evaded question after question (even laughing about how rich he is) until Rep. Torres took him out with a command of the law and a touch of South Bronx street sense. Gensler didn’t know what hit him until it was too late.
I cross-examined @SECGov Chair Gary Gensler about the term 'investment contract', which is key to determining his authority over crypto. Gensler struggled to answer basic questions like whether an investment contract requires a contract. His evasions are deafening and damning.
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The SEC does not have the “right” to appeal just yet which is why they are asking permission to file an “interlocutory” appeal. Ripple will file its response with the Court next week. Stay tuned.
#XRPCommunity #SECGov v. #Ripple #XRP BREAKING: SEC Files Letter outlining its basis for filing a Motion for Leave to File an Interlocutory Appeal regarding “Programmatic” offers and sales to XRP buyers over trading platforms and Ripple’s “Other Distributions.”.
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My absolute gratitude to the teams that have been working tirelessly on this matter for over the years. The Judge’s decision affirms so much of what this industry is fighting for, and shows that the SEC does not have unbounded jurisdiction over crypto.
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Interesting to see the reactions to Trump’s appointments. Where was the outrage when Biden appointed a Goldman Sachs 'hundred millionaire' non-lawyer and pretend crypto academic with no peer-reviewed work and questionable connections, to lead the SEC and dismantle an industry?.
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Can I get a fact check on aisle 2, please? Rep Sherman, the US has not (in fact, no country has) determined XRP to be a security. When elected officials don’t understand that the mere filing of a case by the SEC doesn’t determine anything…it’s more than concerning.
US Rep. Brad Sherman urges SEC to ‘go after’ crypto exchanges that had traded in XRP.
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No surprises here — once again it’s been made clear. The Court’s ruling that “XRP is not a security” is NOT being appealed. That decision stands as the law of the land. Stay tuned for Ripple’s Form C to be filed next week.
#XRPCommunity #SECGov v. #Ripple #XRP The @SECGov has filed the Civil Appeal Pre-Argument Statement (Form C) with attachments.
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Swung by @SCOTUS in between meetings in DC. While the industry waits for legislative clarity from Congress, we should always be able to count on checks and balances.
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Today, Ripple filed a Form C - listing the issues we plan to raise on our cross appeal. A few things to keep in mind as we move forward:. The case is not about whether XRP, in and of itself, is a security. XRP is uniquely situated as having clarity (alongside BTC) in not being.
#XRPCommunity #SECGov v. #Ripple #XRP @Ripple has filed the Civil Appeal Pre-Argument Statement (Form C). The relevant pages are below.
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A securities agency only has jurisdiction over securities. No security, no role for the SEC. Pretending to have jurisdiction when there is none, is simply a political power play. It helps no one; it hurts everyone.
An important topic has come up about protecting retail. The SEC created this mess by proclaiming it was the cop on the crypto beat when it had no legal jurisdiction Where’s that gotten us? Consumers left holding the bag in bankruptcy court while the SEC holds press conferences.
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A troubling pattern emerges:.- Court finds the SEC demonstrated “hypocrisy” by making inconsistent arguments to the Court and not acting out of a “faithful allegiance to the law.” SEC v Ripple, 7/12/22.- Court agrees that the SEC defaulted on its duty to respond in good faith to.
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It's my Dad’s birthday today. 93. A son of immigrants. Proud Brooklyn native. Dropped out of high school to join the Army as the Korean war was breaking out. A retired Teamster who still believes in fairness. Every time we speak he asks: “Did you win your case yet?”.
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The SEC is getting battered in the court. In our case it's been proven wrong, been called hypocritical, lacking faithful allegiance to the law, fined for discovery abuses and now another distinguished court saying it’s "arbitrary and capricious" - that’s a really big deal.
BREAKING: An appeals court has ordered the SEC to review its rejection of Grayscale's bitcoin ETF bid, potentially opening the door to an approval. @ledesmalyllah reports.
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In yesterday’s testimony, Gensler kept talking about “crypto asset securities.” That’s a made-up term, found nowhere in the law, by a deeply flawed unelected bureaucrat. He also implied that all crypto executives were criminals. If you own crypto and have had enough - VOTE.
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The @SEC is raging. Ripple defended itself - “agreeing to nothing.” The court gave clarity that XRP is not a security. There are no “victims” to compensate. And worst of all for the @SEC, Ripple is thriving. But at least @SEC seems to have abandoned its absurd demand for $2B.
#XRPCommunity #SECGov v. #Ripple #XRP @SECGov has responded to @Ripple’s letter regarding the TerraForm Labs Consent Judgment.
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Suddenly now saying that you haven’t prejudged every crypto (with the possible exception of BTC) as a security, after being called out for publicly prejudging every crypto as a security doesn’t unring the bell. Words have consequences, even for unelected senior bureaucrats.
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Our opposition to the SEC’s request for $2B in penalties for legacy institutional sales is now public. In a case that had no allegations (or findings) of recklessness or fraud, and in which Ripple won on significant issues, the SEC’s ask is just more evidence of its ongoing.
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@DavidSacks Double-click on that! Now let’s dismiss these baseless cases with no fraud, no victims—just a political agenda to cripple the US crypto industry. They’re a massive waste of gov’t time and resources.
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The only thing the Court found constitutes an investment contract is past direct XRP sales to institutional clients. There will be further court proceedings only on these institutional sales per the Court’s order.
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Ripple’s reply brief is public. You can view it here👇.
#XRPCommunity #SECGov v. #Ripple #XRP BREAKING: .Ripple has filed its Redacted Reply to the SEC's Opposition to Ripple's Motion for Summary Judgment.
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Yesterday’s opinion from the Court on Ripple and the SEC’s proposed expert opinions – if you didn’t read all 57 pages, here’s the TLDR… 1/4.
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Instead of standing down and pausing crypto litigation with new leadership just weeks away, Gensler's SEC filed an 81-page brief in the Binance case yesterday, recycling the same failed arguments—including the absurd (and unsupported) claim that crypto has no inherent value.
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The SEC is making it up as it goes. Using “strategic ambiguity” and enforcement—or the threat of it— to advance its own jurisdiction rather than collaborate with other regulators, policymakers and market participants. When will the tactics stop?.
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Today Ripple filed our answer to the SEC's amended complaint. Notably w/ full transparency to the SEC: XRP was listed on 200+ exchanges, billions of $ in XRP were bought/sold monthly, many market makers had daily XRP txns, & 3rd party products (not developed by Ripple) used XRP.
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Another court, this time in the Kraken case, confirms there's no such thing as a “crypto asset security.” Bad news for the SEC, whose entire regulation-by-enforcement strategy hinges on that failed premise.
6/ The SEC unqualifiedly lost on this “tokens are securities” theory, and will not be permitted to rely on it going forward. Instead, it will need to prove, for every alleged transaction on Kraken, that the Howey Test factors are satisfied. They aren’t, and we look forward to.
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The law requires SEC employees, like all federal employees, to act (and appear to act) impartially. The law asks: Would a reasonable person, knowing the facts, question the employee’s impartiality. You now know the facts. 5 CFR 2635.101(b)(14).
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To be clear: The SEC’s tag along complaint against SBF seeks to recover funds for FTX’s sophisticated equity investors, not the consumers who have been left holding the bag in bankruptcy court.
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Today a Federal Court sanctioned the SEC for abusing its unique status to present evidence that was false, mischaracterized, and/or misleading. If anyone thinks this conduct by this agency under this leadership is limited to this case, I have a bridge in Brooklyn to sell.
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The Binance resolution of anti-money laundering (etc.) violations is a necessary step to bring the crypto industry into compliance with these important laws and safeguards. Big banks all went through some version of this years ago.
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Gary Gensler attempting to justify his four-year-long political crusade to destroy crypto by claiming he just continued what Jay Clayton started is like burning down the house and saying, ‘Jay lit the match—I just added the gasoline.’
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The allegations in these suits are just that – unproved. The SEC – despite what Chair Gensler pretends - does not have a magic regulatory wand that it can just wave and say tokens are securities. Looking forward to how the Courts and Congress will take this.
If it wasn’t already clear, it should be now – Chair Gensler’s laughable “pro-innovation” stance (as he said today), is exactly the opposite. What this also tells me is that the SEC is throwing lawsuits at the wall and hoping they distract from the agency’s FTX debacle.
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The triumvirate of Atkins, Peirce, and Uyeda at the SEC will not only bring common sense back to the agency, but true investor protection as well.
An outstanding choice – Paul Atkins at the helm of the SEC will bring common sense back to the agency. Along with Hester Peirce and Mark Uyeda, it’s time to swiftly and definitively end the prohibition era on crypto, restoring freedom of choice, economic growth, and innovation.
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Ripple's case is over, but the 'fair notice' defense is still alive for others. The SEC cites the 2017 DAO report as industry notice that 'crypto asset securities' are subject to US securities laws. Seven years later, the SEC apologizes to a federal judge—surely a person of at
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Another loss this week for the SEC – the streak continues. The 2d Circuit in SEC v Govil held that the SEC can’t ask for a crippling disgorgement award w/o first proving that “investors” suffered actual financial harm. In other words, no harm, no foul.
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We oppose the SEC’s request for an interlocutory appeal. There is no extraordinary circumstance here that would justify departing from the rule requiring all issues as to all parties to be resolved before an appeal.
#XRPCommunity #SECGov v. #Ripple #XRP BREAKING: Ripple files it’s opposition to the SEC’s anticipated motion for leave to file an interlocutory appeal.
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It’s easy to play armchair lawyer on Twitter, but convincing a judge to side with you is no small feat. Crypto doesn’t need more convoluted legal theories and structures that make lawyers rich and confuse judges. Let’s simplify: Tokens and transactions in them aren’t securities.
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While Mr. Gensler is making bad Halloween jokes on X, his agency is being shamed for ignoring the law that requires agency rules to be reviewed by Congress. Seems the SEC has become the lawless Wild West Gensler loves to talk about so much.
Securities and Exchange Commission—Applicability of the Congressional Review Act to Staff Accounting Bulletin No. 121
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Memo to: Department of Government Efficiency @DOGE . Subject: Inquiry into Wasted Tax Dollars. Could you please provide an estimate of how much taxpayer money has been wasted on these?. Thank you
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The SEC is losing in court; being criticized by Judges for shady behavior; being rebuked by the Gov’t’s internal auditor; hiding info about meetings with a felon; becoming irrelevant on the international stage. Gensler - admitting no fault - has become the insulate Col. Jessep.
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Who else would hire him? He’s politically toxic, he’s a serial loser in the courts, his staff has been caught lying to judges, his agency’s Twitter account was hacked in the most embarrassing way, and his sponsor at MIT quit because of close Epstein ties. Did I miss anything?.
SEC Chair Gary Gensler said Wednesday he "absolutely" plans to stay on as Wall Street's top regulator should President Joe Biden win a second term in November. "I love this job," Gensler said in an interview from his office at the SEC's headquarters in Washington. -@declanharty.
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The term 'crypto asset security' is nowhere to be found in any statute—it's a fabricated term with no legal basis. The SEC needs to stop trying to deceive judges by using it.
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@DegenerateNews @realDonaldTrump @Ripple @Unchained_pod Wow, unnamed sources? Here’s a named source: me. The rumors published by this 3rd-tier crypto rag are pure fiction. Completely made up. Wonder who’s behind this? 🤔.
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The 2nd Cir. will either affirm Judge Torres or expand her ruling. The best the SEC can hope for (and it’s a remote hope) is a remand. But during the SEC's failed 'interlocutory' appeal, Judge Torres made it clear that ‘Howey’ and all of Ripple’s defenses, including Fair Notice,
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Some reflections as we approach the one year anniversary of Judge Torres’ Summary Judgment decision in the SEC v Ripple lawsuit. First and foremost – it was a watershed moment to find as a matter of law, a token – in this case, XRP – in and of itself, is not a security. This.
A huge win today – as a matter of law - XRP is not a security. Also a matter of law - sales on exchanges are not securities. Sales by executives are not securities. Other XRP distributions – to developers, to charities, to employees are not securities.
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Update: The SEC has lost 5 of its last 6 cases in the Supreme Court. SEC v Cochran (4/14/23).
The SEC has lost 4 of its last 5 cases in the Supreme Court, thanks to the few that had the courage and resources to fight back against the SEC’s bullying and clinging to stretch legal positions that were not faithful to the law.
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