UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934

Release No. 85530 / April 5, 2019 

ADMINISTRATIVE PROCEEDING

File No. 3-17212

In the Matter of 

LOGITECH INTERNATIONAL, S.A., 

MICHAEL DOKTORCZYK, and 

SHERRALYN BOLLES, CPA,

Respondents. 

ORDER APPROVING APPLICATION OF 

FUND ADMINISTRATOR FOR 

PAYMENT OF FEES AND EXPENSES

AND APPROVAL OF FUTURE FEES 

AND EXPENSES

On April 19, 2016, the Securities and Exchange Commission (the “Commission”) 

issued an Order Instituting Cease-and-Desist Proceedings Pursuant to Section 21C of the 

Securities Exchange Act of 1934, Making Findings, and Imposing Cease-and-Desist Orders 

and Penalties (the “Order”)1against Logitech International, S.A. (“Logitech”), Michael 

Doktorczyk (“Doktorczyk”), and Sherralyn Bolles, CPA (“Bolles”) (collectively, the 

“Respondents”). In the Order, the Commission found Logitech responsible for recurring 

instances of improper accounting between 2008 and 2013 related to a product write-down, 

warranty liabilities, and revenue recognition. The Commission further found Doktorczyk and 

Bolles, both former officers of Logitech, responsible for the improper accounting for warranty 

liabilities, which occurred during their employment. The Commission ordered Logitech, 

Doktorczyk, and Bolles to pay civil money penalties of $7,500,000.00, $50,000.00, and 

$25,000.00, respectively. The Order provides that the Commission can distribute the civil 

money penalties if, in its discretion, it orders the establishment of a Fair Fund, pursuant to 

Section 308(a) of the Sarbanes-Oxley Act of 2002 (“Sarbanes-Oxley Act”). The Respondents 

have since paid in full and the Commission holds more than $7.7 million, comprised of the 

civil money penalties paid by the Respondents, civil money penalties and disgorgement 

collected in a related action, and accrued interest.2 

On February 27, 2018, the Commission issued an Order establishing a Fair Fund (the 

“Fair Fund”), pursuant to Section 308(a) of the Sarbanes-Oxley Act of 2002 (the “Fair Fund 

Order”), so that the civil money penalties collected from the Respondents can be distributed 

for the benefit of the injured investors.3

 

1 Exchange Act Rel. No. 77644 (Apr. 19, 2016). 

2

Final judgments have been entered against the defendants in the related civil action, SEC v. Bardman, 16-cv2023 (N.D. Cal.), and on December 18, 2018, the United States District Court for the Northern District of 

California ordered that the $224,000 in disgorgement and civil penalties collected from the defendants be 

included in the distribution in the captioned administrative proceeding.

3 Order Establishing Fair Fund, Exchange Act Rel. No. 82783 (Feb. 27, 2018).
2

On March 30, 2018, the Commission issued an order appointing Garden City Group, 

LLC (“GCG”) as the Fund Administrator of the Fair Fund4and setting the administrator’s 

bond at $7.575 million.

5

 

On September 6, 2018, the Commission published a Notice of Proposed Plan of 

Distribution and Opportunity for Comment (“Notice”)6pursuant to Rule 1103 of the 

Commission’s Rules on Fair Fund and Disgorgement Plans (“Rules”).7 The Commission 

received no comments and on October 26, 2018, the Commission approved a plan of 

distribution (the “Plan”).

8

 

The Plan contemplates the payment of taxes, fees, and expenses of a distribution will 

be paid from the Fair Fund.9 In accordance with Rule 1105(d) of the Rules, 17 C.F.R. 

§ 201.1105(d), the Fund Administrator has submitted to the Commission staff invoices for 

services rendered from April 4, 2018 through December 31, 2018, totaling $35,570.47. The 

Commission staff has reviewed the Fund Administrator’s invoices, confirmed that the services 

have been provided, and finds the fees and expenses of $35,570.47 to be reasonable. The 

Commission staff has requested that the Commission authorize the Office of Financial 

Management (“OFM”) to pay the Fund Administrator’s current fees and expenses of 

$35,570.47 from the Fair Fund. 

Additionally, to expedite and streamline the process for future payments, the 

Commission staff has requested that the Commission authorize OFM, at the direction of the 

Assistant Director of the Office of Distributions, to pay the Fund Administrator’s future fees 

and expenses, so long as the total amount paid to the Fund Administrator, including the 

invoice to be paid, does not exceed the total amount of approved cost proposal submitted by 

the Fund Administrator.

Accordingly, it is hereby ORDERED, pursuant to Rule 1105(d) of the Commission’s 

Rules, 17 C.F.R. § 201.1105(d), that OFM pay the Fund Administrator’s current fees and 

expenses of $35,570.47 from the Fair Fund. Further, OFM is authorized to pay, at the 

direction of the Assistant Director of the Office of Distributions, any future fees and expenses 

of the Fund Administrator from the Fair Fund, so long as the total amount paid to the Fund 

Administrator, including the invoice to be paid, does not exceed the total amount of the 

approved cost proposal submitted by the Fund Administrator. 

By the Commission. 

Vanessa A. Countryman

Acting Secretary 

 

4 On June 18, 2018, Epiq Class Action and Claims Solutions, Inc. (“Epiq”) acquired GCG and GCG has been 

rebranded as Epiq. 

5

See Order Appointing Fund Administrator and Setting Administrator Bond Amount, Exchange Act Rel. No. 

82972 (Mar. 30, 2018).

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

7

17 C.F.R. § 201.1103. 

8 Order Approving Corrected Plan of Distribution, Exchange Act Rel. No. 84493 (Oct. 26, 2018).

9

Plan, https://www.sec.gov/litigation/admin/2018/34-84493-dp.pdf , at ¶ 8.