UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934

Release No. 84493 / October 26, 2018

ADMINISTRATIVE PROCEEDING

File No. 3-17212

In the Matter of 

LOGITECH INTERNATIONAL, S.A., 

MICHAEL DOKTORCZYK, and 

SHERRALYN BOLLES, CPA,

Respondents. 

ORDER APPROVING CORRECTED 

PLAN OF DISTRIBUTION

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, 

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

2002, as amended, for distribution of the monies ordered (the “Fair Fund”).

2

 The Respondents 

have paid the money ordered in full.

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

the Fund Administrator for the Fair Fund.

3

 

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

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

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

(Mar. 30, 2018). 
2

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

Distribution and Opportunity for Comment (“Notice”),

4

pursuant to Rule 1103 of the 

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

5

 The Notice advised all 

interested persons that they may obtain a copy of the proposed plan of distribution (“Distribution 

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

by submitting a written request to Catherine E. Pappas, Senior Advisor, 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 Distribution Plan 

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

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 email to 

rule-comments@sec.gov. The Commission received no negative comments on the Distribution 

Plan during the comment period.

The Distribution Plan provides for distribution of the Fair Fund, plus any interest earned, 

less taxes, fees, and expenses, to the investors harmed by the conduct described in the Order

pursuant to the methodology described in the Plan. 

The Division of Enforcement now requests that the Commission approve the Corrected

Distribution Plan.6 

Accordingly, it is hereby ORDERED, pursuant to Rule 1104 of the Rules,

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that the 

Corrected Distribution Plan is approved.

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

Brent J. Fields

Secretary 

 

4

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

5

 17 C.F.R. § 201.1103.

6 The Distribution Plan has been corrected to include in footnote 2 the possibility that the Fair Fund will receive 

additional funds from a related federal district court action, SEC v. Bardman, 16-cv-2023 (N.D. Cal.).

7

 17 C.F.R. § 201.1104.