UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934

Release No. 84044 / September 6, 2018

ADMINISTRATIVE PROCEEDING

File No. 3-17212

In the Matter of 

LOGITECH INTERNATIONAL, S.A., 

MICHAEL DOKTORCZYK, and 

SHERRALYN BOLLES, CPA,

Respondents. 

NOTICE OF PROPOSED PLAN OF 

DISTRIBUTION AND 

OPPORTUNITY TO COMMENT

Notice is hereby given, pursuant to Rule 1103 of the United States Securities and

Exchange Commission’s (“Commission”) Rules on Fair Fund and Disgorgement Plans,

17 C.F.R. § 201.1103, that the Division of Enforcement has submitted to the Commission a 

proposed plan of distribution (the “Plan”) for the distribution of monies paid by Logitech 

International, S.A. (“Logitech”), Michael Doktorczyk (“Doktorczyk”), and Sherralyn Bolles, 

CPA (“Bolles”) (collectively, the “Respondents”) in settlement of the above-captioned 

administrative proceeding.

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. By Order dated February 27, 2018,

2

the Commission created a Fair Fund pursuant to Section 308(a) of the Sarbanes-Oxley Act of 

2002, as amended, for the monies ordered (the “Fair Fund”). The Respondents have paid the 

money ordered in full. 

 

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

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

By Order dated March 30, 2018, the Commission appointed Garden City Group, LLC as 

the Fund Administrator of the Fair Fund.

3

OPPORTUNITY FOR COMMENT

Pursuant to this Notice, all interested persons are advised that they may obtain a copy of 

the Plan from the Commission’s public website at http://www.sec.gov/litigation/fairfundlist.htm. 

Interested persons may also obtain a written copy of the Plan by submitting a written request to 

Catherine E. Pappas, Esq., United States Securities and Exchange Commission, One Penn 

Center, 1617 JFK Blvd., Ste. 520, Philadelphia, PA 19103. All persons who desire to comment 

on the Plan may submit their comments, in writing, no later than thirty (30) days from the date of 

this Notice:

1. to the Office of the Secretary, United States Securities and Exchange 

Commission, 100 F Street, NE, Washington, DC 20549-1090;

2. by using the Commission’s Internet comment form 

(http://www.sec.gov/litigation/admin.shtml); or 

3. by sending an e-mail to rule-comments@sec.gov.

Comments submitted should include “Administrative Proceeding File No. 3-17212” in the 

subject line. Comments received will be publicly available. Persons should submit only 

information that they wish to make publicly available.

THE PLAN

The Fair Fund holds more than $7.575 million, comprised of the civil money penalties 

paid by the Respondents and accrued interest. The Plan proposes to distribute the funds 

currently in the Fair Fund, less taxes, fees, and expenses, to investors who purchased shares of 

Logitech common stock on the Nasdaq Global Select Market at inflated prices during the period 

from May 28, 2011 through July 27, 2011, inclusive, and who suffered losses in the value of 

their investment subsequent to disclosures by the Respondents.

For the Commission, by its Secretary, pursuant to delegated authority

Brent J. Fields

Secretary

 

3 Order Appointing Fund Administrator and Setting Administrator Bond Amount, Exchange Act Rel. No. 82972 

(Mar. 30, 2018).