UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

INVESTMENT ADVISERS ACT OF 1940

Release No. 5574 / September 8, 2020

INVESTMENT COMPANY ACT OF 1940

Release No. 34004 / September 8, 2020

ADMINISTRATIVE PROCEEDING

File No. 3-19965

In the Matter of

Alexander S. Gould,

Respondent.

ORDER INSTITUTING ADMINISTRATIVE 

AND CEASE-AND-DESIST PROCEEDINGS, 

PURSUANT TO SECTIONS 203(f) AND 

203(k) OF THE INVESTMENT ADVISERS 

ACT OF 1940, AND SECTION

9(b) OF THE INVESTMENT COMPANY

ACT OF 1940, MAKING FINDINGS, AND 

IMPOSING REMEDIAL SANCTIONS AND 

A CEASE-AND-DESIST ORDER 

I.

The Securities and Exchange Commission (“Commission”) deems it appropriate and in the 

public interest that public administrative and cease-and-desist proceedings be, and hereby are, 

instituted pursuant to Sections 203(f) and 203(k) of the Investment Advisers Act of 1940 

(“Advisers Act”), and Section 9(b) of the Investment Company Act of 1940 (“Investment 

Company Act”) against Alexander S. Gould (“Gould” or “Respondent”). 

II.

In anticipation of the institution of these proceedings, Respondent has submitted an Offer 

of Settlement (the “Offer”) which the Commission has determined to accept. Solely for the 

purpose of these proceedings and any other proceedings brought by or on behalf of the 

Commission, or to which the Commission is a party, and without admitting or denying the findings 

herein, except as to the Commission’s jurisdiction over him and the subject matter of these 

proceedings, which are admitted, and except as provided herein in Section V, Respondent consents 

to the entry of this Order Instituting Administrative and Cease-and-Desist Proceedings Pursuant to 

Sections 203(f) and 203(k) of the Investment Advisers Act of 1940, and Section 9(b) of the 

Investment Company Act of 1940, Making Findings, and Imposing Remedial Sanctions and a 

Cease-and-Desist Order (“Order”), as set forth below. 
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III.

On the basis of this Order and Respondent’s Offer, the Commission finds that:

Summary

Alexander S. Gould, a Silicon Valley venture capitalist, misappropriated more than half a 

million dollars from Goulden Boy LLC (“Goulden Boy” or the “Fund”), a private venture capital 

fund he founded and advised. In 2018, Gould used Goulden Boy’s assets to pay for various 

personal expenses, including his debt to another fund that he had previously managed, and his 

mortgage, credit card debt and travel expenses. All told, Gould misappropriated $537,460 from the 

Fund that he never repaid. This was more than half of the total capital invested in the Fund.

Respondent

1. Alexander S. Gould, age 49, resides in Menlo Park, California. He is the founder of 

venture capital fund Goulden Boy and a university economics lecturer. He has founded and cofounded other venture capital funds. He has been on the boards of directors of several private, 

early-stage companies. Gould controlled and managed Goulden Boy, acted as its investment 

adviser, and was entitled to a one-time management fee of 1.5% of the total amount of the Fund. 

Gould is not associated with any entity registered with the Commission.

Other Relevant Entity

2. Goulden Boy LLC is a private venture capital fund formed in December 2017 by 

Gould, with its principal place of business in Menlo Park, California. From February to July 2018, 

investors invested capital in Goulden Boy for the purpose of purchasing interests in private, earlystage technology and media companies. 
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Gould Misappropriated Fund Assets

3. From 2013 to 2017, Gould was a managing member of a venture capital fund based 

in Menlo Park, CA (“Fund A”). Fund A made investments in a number of early stage technology 

and media start-up companies. 

4. In December 2017, Gould signed a separation agreement with Fund A. He resigned 

from his position at Fund A, and promised to pay $798,339 to reimburse it for money that he had 

spent on personal and other unauthorized expenses, plus an additional $100,000. He also agreed to 

purchase, either personally or through an entity, all of Fund A and its general partner’s interests in 

six of its portfolio companies.

5. Also in December 2017, Gould formed Goulden Boy. Gould was the sole

managing member of Goulden Boy, and controlled its bank account. From February 2018 to July 

2018, seven investors (“Investors A-G”) invested a total of $874,960 in Goulden Boy, for the 

purpose of buying interests in private, early-stage companies. Gould did not personally invest in 

the Fund during this time period. According to Goulden Boy’s Operating Agreement, Gould was 

entitled to a one-time management fee of 1.5% of the total amount of the Fund. 

6. From February 2018 to July 2018, Gould used Goulden Boy’s assets to make 

payments to Fund A. At the time of the payments, Gould had discussed with his former partner at 

Fund A that the money Goulden Boy sent to Fund A should be used to purchase interests in the six

portfolio companies. But on July 25, 2018, following more negotiations, Gould signed a contract 

in which he agreed that all of the money that Goulden Boy had sent to Fund A would be applied to 

pay his personal debt to Fund A. Gould sent a total of $891,000 from Goulden Boy to Fund A.

7. From February 2018 to December 2018, on multiple occasions, Gould also spent 

Goulden Boy’s money on other personal expenses. For example, he spent the money on his 

mortgage payment, business class travel, payments on a credit card and a personal line of credit, 

and payments to individuals, and withdrew cash. Gould sent a total of at least $358,000 from 

Goulden Boy to himself.

8. Gould caused Goulden Boy to invest in only two companies. The total amount of 

these investments was $337,500. The Fund never purchased any of Fund A’s interests in the six 

portfolio companies.

9. Between April and October of 2018, Gould obtained three loans, totaling $810,000,

to pay back some of the money that he had misappropriated from Goulden Boy. However, a net 

amount of $537,460 of the Goulden Boy investors’ money was not paid back to the Fund. This 

amount was about 40 times the management fee that Gould could have been entitled to, had he not 

misappropriated most of the Fund’s assets.

10. In late 2019, Gould purchased the ownership interests of one of the investors, and 

became an investor in Goulden Boy. By buying these interests, Gould shared in some of the 
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Fund’s loss, and the amount by which he was enriched by his misappropriation was reduced by 

$61,426.81.

Violations

11. As a result of the conduct described above, Gould willfully violated Section 206(1) 

of the Advisers Act, which makes it unlawful for any investment adviser, directly or indirectly, to 

employ any device, scheme, or artifice to defraud any client or prospective client, and Section 

206(2) of the Advisers Act, which makes it unlawful for any investment adviser, directly or 

indirectly, to engage in any transaction, practice, or course of business which operates as a fraud or 

deceit upon any client or prospective client.

IV.

In view of the foregoing, the Commission deems it appropriate and in the public interest to 

impose the sanctions agreed to in Respondent Gould’s Offer.

Accordingly, pursuant to Sections 203(f) and 203(k) of the Advisers Act and Section 9(b) 

of the Investment Company Act, it is hereby ORDERED that:

A. Gould cease and desist from committing or causing any violations and any future 

violations of Sections 206(1) and 206(2) of the Advisers Act. 

B. Gould be, and hereby is:

barred from association with any broker, dealer, investment adviser, 

municipal securities dealer, municipal advisor, transfer agent, or nationally 

recognized statistical rating organization, and

prohibited from serving or acting as an employee, officer, director, member 

of an advisory board, investment adviser or depositor of, or principal 

underwriter for, a registered investment company or affiliated person of such 

investment adviser, depositor, or principal underwriter,

with the right to apply for reentry after five (5) years to the appropriate self-regulatory organization, 

or if there is none, to the Commission.

C. Any reapplication for association by the Respondent will be subject to the 

applicable laws and regulations governing the reentry process, and reentry may be conditioned 

upon a number of factors, including, but not limited to, compliance with the Commission’s order 

and payment of any or all of the following: (a) any disgorgement or civil penalties ordered by a 

Court against the Respondent in any action brought by the Commission; (b) any disgorgement 

amounts ordered against the Respondent for which the Commission waived payment; (c) any 

arbitration award related to the conduct that served as the basis for the Commission order; (d) any 

self-regulatory organization arbitration award to a customer, whether or not related to the conduct 
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that served as the basis for the Commission order; and (e) any restitution order by a self-regulatory 

organization, whether or not related to the conduct that served as the basis for the Commission 

order.

D. Respondent shall, within 10 days of the entry of this Order, pay disgorgement of 

$476,033.19 and prejudgment interest of $50,137.33 to the Securities and Exchange Commission. 

If timely payment is not made, additional interest shall accrue pursuant to SEC Rule of Practice 

600.

E. Respondent shall, within 10 days of the entry of this Order, pay a civil money 

penalty in the amount of $200,000 to the Securities and Exchange Commission. If timely payment 

is not made, additional interest shall accrue pursuant to 31 U.S.C. §3717. Payment must be made 

in one of the following ways: 

(1) Respondent may transmit payment electronically to the Commission, which 

will provide detailed ACH transfer/Fedwire instructions upon request;

(2) Respondent may make direct payment from a bank account via Pay.gov 

through the SEC website at http://www.sec.gov/about/offices/ofm.htm; or 

(3) Respondent may pay by certified check, bank cashier’s check, or United 

States postal money order, made payable to the Securities and Exchange 

Commission and hand-delivered or mailed to: 

Enterprise Services Center

Accounts Receivable Branch

HQ Bldg., Room 181, AMZ-341

6500 South MacArthur Boulevard

Oklahoma City, OK 73169

Payments by check or money order must be accompanied by a cover letter identifying 

Alexander Gould as a Respondent in these proceedings, and the file number of these proceedings; 

a copy of the cover letter and check or money order must be sent to Monique Winkler, Division of 

Enforcement, Securities and Exchange Commission, San Francisco Regional Office, 44 

Montgomery St., Ste 2800, San Francisco, CA 94104. 

F. Pursuant to Section 308(a) of the Sarbanes-Oxley Act of 2002, a Fair Fund is created 

for the disgorgement, prejudgment interest and penalties referenced in paragraph D above. 

Amounts ordered to be paid as civil money penalties pursuant to this Order shall be treated as 

penalties paid to the government for all purposes, including all tax purposes. To preserve the 

deterrent effect of the civil penalty, Respondent agrees that in any Related Investor Action, he shall 

not argue that he is entitled to, nor shall he benefit by, offset or reduction of any award of 

compensatory damages by the amount of any part of Respondent’s payment of a civil penalty in 

this action ("Penalty Offset"). If the court in any Related Investor Action grants such a Penalty 

Offset, Respondent agrees that he shall, within 30 days after entry of a final order granting the 
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Penalty Offset, notify the Commission's counsel in this action and pay the amount of the Penalty 

Offset to the Securities and Exchange Commission. Such a payment shall not be deemed an 

additional civil penalty and shall not be deemed to change the amount of the civil penalty imposed 

in this proceeding. For purposes of this paragraph, a "Related Investor Action" means a private 

damages action brought against Respondent by or on behalf of one or more investors based on 

substantially the same facts as alleged in the Order instituted by the Commission in this 

proceeding.

V.

It is further Ordered that, solely for purposes of exceptions to discharge set forth in Section 

523 of the Bankruptcy Code, 11 U.S.C. §523, the findings in this Order are true and admitted by 

Respondent, and further, any debt for disgorgement, prejudgment interest, civil penalty or other 

amounts due by Respondent under this Order or any other judgment, order, consent order, decree

or settlement agreement entered in connection with this proceeding, is a debt for the violation by 

Respondent of the federal securities laws or any regulation or order issued under such laws, as set 

forth in Section 523(a)(19) of the Bankruptcy Code, 11 U.S.C. §523(a)(19).

By the Commission.

Vanessa A. Countryman

Secretary