UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934 

Release No. 90347 / November 5, 2020

ADMINISTRATIVE PROCEEDING 

File No. 3-17212

In the Matter of

Logitech International, S.A.

Michael Doktorczyk and

Sherralyn Bolles, CPA,

Respondents.

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ORDER DIRECTING 

DISBURSEMENT OF FAIR FUND

On September 6, 2018, the Secretary, pursuant to delegated authority, published a Notice 

of Proposed Plan of Distribution and Opportunity for Comment (“Notice”),1pursuant to Rule 

1103 of the Commission’s Rules on Fair Fund and Disgorgement Plans (“Commission’s 

Rules”).2 The Notice advised interested persons that they could obtain a copy of the Proposed 

Plan of Distribution (“Proposed Plan”) from the Commission’s public website or by submitting a 

written request to Catherine E. Pappas, Senior Adviser, United States Securities and Exchange 

Commission, One Penn Center, 1617 JFK Blvd., Ste. 520, Philadelphia, PA 19103. The Notice 

also advised that all persons desiring to comment on the Proposed Plan could submit their 

comments, in writing, within 30 days of the Notice. The Commission received no comments on 

the Proposed Plan during the comment period. On October 26, 2018, the Secretary, pursuant to 

 

1

 Exchange Act Rel. No. 84044 (Sept. 6, 2018).

2

 17 C.F.R. § 201.1103.
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delegated authority, issued an order approving the Proposed Plan,3and posted the Plan of 

Distribution (the “Plan”). 

The Plan provides for the distribution of the Fair Fund,4plus accumulated interest, less 

taxes, fees, and expenses (the “Net Fair Fund”), to the harmed investors according to the 

methodology set forth in the Plan. 

In accordance with the Plan, the Fund Administrator has submitted a Payee List in a 

Commission-approved format, along with a reasonable assurance letter as to its completeness 

and accuracy. The Commission staff has reviewed the Payee List5and reasonable assurance 

letter and requests, pursuant to Rule 1101(b)(6) of the Commission’s Rules, 17 C.F.R. § 

201.1101(b)(6), that the Commission authorize the transfer of $2,892,751.29 from the Fair Fund 

to the Fair Fund’s escrow account at The Huntington National Bank for distribution by the Fund 

Administrator to the Eligible Claimants in accordance with the Plan. In accordance with the 

Plan, the Claim Deadline has passed and all timely submitted claims have been processed by the 

Fund Administrator. All investors whose claims have been determined ineligible, in whole or in 

part, have been notified and provided the opportunity to cure.

 

3

 See Exchange Act Rel. No. 84493 (Oct. 26, 2018).

4 The Fair Fund includes the $7.575 million in civil money penalties paid by the Respondents, as well as an 

additional $224,000 collected in a related district court proceeding against two former officers of Logitech. See SEC 

v. Bardman, et al., 16-cv-2023 (N.D. Cal.), Dkt. No. 97.

5 Capitalized terms not defined herein are defined in the Plan. 
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Accordingly, it is hereby ORDERED, that Commission staff shall transfer $2,892,751.29

from the Fair Fund to the Fair Fund’s escrow account at The Huntington National Bank, and the 

Fund Administrator shall distribute such monies to the Eligible Claimants in accordance with the 

Plan.

By the Commission.

Vanessa A. Countryman

Secretary