1 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF OHIO

WESTERN DIVISION

COMMODITY FUTURES TRADING 

COMMISSION,

Plaintiff,

v. 

JARED J. DAVIS, 

Defendant.

Case No. 3:19-cv-2140 

COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF AND FOR 

CIVIL MONETARY PENALTIES 

Plaintiff, Commodity Futures Trading Commission (“CFTC” or “Commission”), by 

its attorneys, alleges as follows: 

I. SUMMARY

1. From at least July 2012 through at least June 2016 (the “Relevant Period”), 

Jared J. Davis (“Davis” or “Defendant”), operating through multiple private entities and 

using various trade names, fraudulently solicited and accepted at least $10 million from 

customers in the United States and elsewhere to trade off-exchange binary options on 

commodities, foreign currencies, individual stocks, and stock indices. 

2. Davis created, operated, and controlled a number of domestic and foreign 

business entities and internet websites to facilitate his binary options scheme. This binary 

options enterprise, referred to hereinafter as the “Enterprise,” was at all times primarily 

managed by Davis. 

Case: 3:19-cv-02140 Doc #: 1 Filed: 09/17/19 1 of 18. PageID #: 1
2 

3. Davis, directly or indirectly through the Enterprise, solicited prospective 

customers to trade off-exchange binary options through internet marketing campaigns, 

through one or more of the Enterprise’s websites, and through e-mail and telephone 

communications. 

4. Davis, directly or indirectly through the Enterprise, defrauded customers by 

making misrepresentations and omissions of material facts to attract and to retain customers

to enter into off-exchange binary options, including but not limited to, misrepresenting and 

failing to disclose that Davis effectively took the opposing position on each trade and 

therefore made money when customers lost money on trades. 

5. By virtue of this conduct, and as more fully set forth below, Davis has 

engaged, is engaging, and/or is about to engage in acts and practices in violation of Section 

4c(b) of the Commodity Exchange Act (the “Act”), 7 U.S.C. 6c(b) (2012), and Commission 

Regulation (“Regulation”) 32.4, 17 C.F.R. § 32.4 (2019). 

6. Accordingly, pursuant to Section 6c of the Act, 7 U.S.C. § 13a-1 (2012), the 

CFTC brings this action to enjoin Defendant’s unlawful acts and practices, to compel his 

compliance with the Act and Regulations thereunder, and to enjoin him from engaging in any 

commodity related activity, as set forth below. In addition, the CFTC seeks civil monetary 

penalties for each violation of the Act, and remedial ancillary relief, including, but not 

limited to, trading and registration bans, restitution, disgorgement, rescission, pre- and postjudgment interest, and such other relief as the Court may deem necessary and appropriate. 

Case: 3:19-cv-02140 Doc #: 1 Filed: 09/17/19 2 of 18. PageID #: 2
3 

7. Unless restrained and enjoined by this Court, Davis is likely to continue to 

engage in the acts and practices alleged in this Complaint, or in similar acts and practices, as 

described more fully below. 

II. JURISDICTION AND VENUE

8. This Court possesses jurisdiction over this action pursuant to 28 U.S.C. 

§ 1331 (2012) (codifying federal question jurisdiction) and 28 U.S.C. § 1345 (2012) 

(providing that U.S. district courts have original jurisdiction over civil actions commenced by 

the United States or by any agency expressly authorized to sue by act of Congress). In 

addition, Section 6c of the Act, 7 U.S.C. § 13a-1 (2012), provides that U.S. district courts 

possess jurisdiction to hear actions brought by the CFTC for injunctive relief or to enforce 

compliance with the Act whenever it shall appear that such person has engaged, is engaging, 

or is about to engage in any act or practice constituting a violation of any provision of the Act 

or any rule, regulation, or order thereunder. 

9. Venue properly lies in this District pursuant to Section 6c(e) of the Act, 

7 U.S.C. § 13a-1(e) (2012), because Davis transacted business in and committed acts and 

practices in violation of the Act and Regulations within this District, among other places. 

III. PARTIES

10. Plaintiff Commodity Futures Trading Commission is an independent 

federal regulatory agency charged by Congress with the administration and enforcement of 

the Act and the Regulations promulgated thereunder. The CFTC maintains its principal 

office at 1155 21st Street N.W., Washington, D.C. 20581. 

Case: 3:19-cv-02140 Doc #: 1 Filed: 09/17/19 3 of 18. PageID #: 3
4 

11. Defendant Jared J. Davis is last known to be a resident of Sandusky, Ohio. 

Davis directly or indirectly owned various businesses and internet websites that offered 

binary options trading to customers, and Davis served as the primary manager of the overall 

Enterprise. Davis has never been registered with the CFTC in any capacity. 

IV. STATUTORY BACKGROUND

A. Commission Jurisdiction Regarding Off-Exchange Options Trading 

12. Through Section 4c(b) of the Act, 7 U.S.C § 6c(b) (2012), Congress has given 

the CFTC jurisdiction and plenary rulemaking authority over all commodity option 

transactions.

13. Binary options are “options,” as defined by Section 1a(36) of the Act, 

7 U.S.C. § 1a(36) (2012), and binary options on commodity futures and “commodities,” as 

defined by Section 1a(9) or (19) of the Act, 7 U.S.C. § 1a(9), (19) (2012), are commodity 

option transactions pursuant to Section 4c(b) of the Act, 7 U.S.C § 6c(b) (2012), and 

Regulation 32.2, 17 C.F.R. § 32.2 (2019).

14. 7 U.S.C. § 6c(b) makes it unlawful for any person to offer to enter into, enter 

into, or confirm the execution of any transaction involving any commodity regulated under 

the Act which is of the character of, or is commonly known as, inter alia, an “option,” “bid,” 

“offer,” “put,” or “call,” contrary to any rule, regulation, or order of the CFTC prohibiting 

any such transaction or allowing any such transaction under such terms and conditions as the 

CFTC shall prescribe. 

15. Section 2(c)(2)(B)(i)(I) and (II), 7 U.S.C. § 2(c)(2)(B)(i)(I), (II) (2012), 

provides in relevant part that the Act applies to, and the CFTC shall have jurisdiction over, an 

Case: 3:19-cv-02140 Doc #: 1 Filed: 09/17/19 4 of 18. PageID #: 4
5 

agreement, contract or transaction in foreign currency (“forex”) that is an option and is 

offered to, or entered into with, a person that is not an eligible contract participant (“ECP”), 

unless the counterparty, or the person offering to be the counterparty, of the person is one of 

the enumerated exceptions not applicable here. 

16. An ECP is defined by 7 U.S.C. § 1a(18)(A)(xi), in relevant part, as an 

individual who has amounts invested on a discretionary basis, the aggregate of which is in 

excess of $10,000,000, or $5,000,000 and who enters into the agreement, contract or 

transaction to manage the risk associated with an asset owned or a liability incurred, or 

reasonably likely to be owned or incurred, by the individual. 

B. Prohibition Against Fraud 

17. The Act and Regulations contain numerous anti-fraud provisions applicable to 

various categories of entities or transactions. Regulation 32.4, 17 C.F.R. § 32.4 (2019), 

promulgated under 7 U.S.C. § 6c(b), provides that: 

In or in connection with an offer to enter into, the entry into, or the 

confirmation of the execution of, any commodity option transaction, it shall 

be unlawful for any person, directly or indirectly: 

(a) To cheat or defraud or attempt to cheat or defraud any person; 

(b) To make or cause to be made to any other person any false report or 

statement thereof or cause to be entered for any person any false record 

thereof; or 

(c) To deceive or attempt to deceive any other person by any means 

whatsoever.

C. Controlling Person Liability

18. Section 13(b) of the Act, 7 U.S.C. § 13c(b) (2012), provides in relevant part 

that any person who, directly or indirectly, controls any person who has violated any 

provision of the Act or any of the rules, regulations, or orders issued pursuant to the Act may 

Case: 3:19-cv-02140 Doc #: 1 Filed: 09/17/19 5 of 18. PageID #: 5
6 

be held liable for such violation in any action brought by the Commission, if such person did 

not act in good faith or knowingly induced, directly or indirectly, the act or acts constituting 

the violation. 

V. FACTS

A. Binary Options Generally 

19. A binary option is a type of options contract in which the payout depends 

entirely on the outcome of a discrete event—usually a “yes/no” proposition. The “yes/no” 

proposition typically relates to whether the price of a particular asset (e.g., a commodity, a 

foreign currency, or an individual stock) will rise above or fall below a specified amount on a 

specified date and time. For example, the “yes/no” proposition might be whether the price of 

silver will be higher than $15.26 per ounce at 11:17 am on a particular day, or if the 

exchange rate between the U.S. Dollar and the Euro will be above $1.18 at 2:15 pm on a 

given day. 

20. Once the option holder acquires a binary option through payment of a 

premium, there is typically no further decision for the investor to make regarding the exercise 

of the binary option because binary option contracts expire automatically. 

21. Unlike other types of options, a binary option does not give the holder the 

right to purchase or sell the underlying asset—instead, it is “cash settled.” When the binary 

option expires, the option holder typically receives a pre-determined amount of money if he 

or she made a correct prediction. If the investor made an incorrect prediction, he or she gets 

nothing and loses the premium paid. 

Case: 3:19-cv-02140 Doc #: 1 Filed: 09/17/19 6 of 18. PageID #: 6
7 

B. The Unregistered Binary Options Industry

22. The unregistered binary options industry is often comprised of three main 

components, sometimes referred to as “trading platforms,” “brands,” and “affiliate 

marketers.”

1. Trading Platforms 

23. Trading platforms offer services for a fee that brands (discussed below) 

purchase or license and use to accept orders and execute binary option trades with customers. 

Trading platforms may offer software related to (a) trade entry and execution services; 

(b) customer account and client relationship management services; (c) access to investment 

products (i.e., various binary option contracts); and (d) back-office information technology 

support. 

24. Some platforms, including ones used by Davis including SpotOption and 

Hello Binary, offer their brand customers access to software protocols, sometimes referred to 

as “risk management.” “Risk management” protocols, applied at the platform level to 

investor accounts, allow a brand operator like Davis to manipulate the trading software to 

distort binary options prices and payouts, thereby determining whether customers lose or 

make money trading binary options. 

25. For example, a brand operator may request that a platform manipulate the 

starting prices of a trade and increase the chances of an investment loss for customers with a 

history of trading success. Similarly, a brand operator may request that a platform increase 

the chances of an investment win for discouraged customers in order to induce them to keep 

trading and/or to deposit additional funds into their binary options trading account. 

Case: 3:19-cv-02140 Doc #: 1 Filed: 09/17/19 7 of 18. PageID #: 7
8 

2. Brands

26. Brands, also known in the unregistered binary options industry as “private 

labels,” “white labels,” or “brokers,” may be established with a relatively modest investment 

and typically operate under a trade name while contracting with a platform for trading, 

customer account, back-office systems, and services. 

27. Generally, brand operators, such as Davis, possess custody of customer funds 

and are the counterparty to each customer’s binary options transaction. Brands make money 

by being the counterparty to losing customer trades and retaining the premiums paid by 

losing customers. In other words, binary option brands have an interest in having their 

customers lose money through binary options trading. 

28. In order for brands to maintain their fraudulent binary options scheme and 

cover their expenses, they need to ensure that they have an active customer base losing 

money to the brands via losing trades, and that there is a constant stream of new customers to 

replace those who have either lost all of their investment or who have closed their account. 

3. Affiliate Marketers 

29. Affiliate marketers are independent entities who produce and disseminate 

marketing and promotional materials on internet websites and via email solicitations touting 

exaggerated profits that can be obtained through binary options trading. 

30. Affiliate marketers either work directly with brands or they use brand 

intermediaries to direct prospective customers and customers from their marketing 

campaigns to the brand website. Affiliate marketers, including those hired by Davis, 

Case: 3:19-cv-02140 Doc #: 1 Filed: 09/17/19 8 of 18. PageID #: 8
9 

frequently employ materially false or misleading statements to induce prospective customers 

to open an account and trade binary options through a specific brand.

C. Davis’s Binary Options Business

31. During the Relevant Period, Davis, directly or indirectly through the 

Enterprise, using various trade names and websites, solicited customers for the fraudulent 

offer and sale of binary options through internet marketing campaigns, one or more of the 

Enterprise’s websites, and call centers located in Sandusky, Ohio, and later located in Costa 

Rica and Sint Maarten. 

32. During or before July 2012, Davis established his first binary options brand, 

Option Mint (www.optionmint.com) by forming various shell companies with foreign bank 

accounts, among other things. 

33. Over the next few years, Davis established three additional brands—Option 

King (www.optionking.com), Option Queen (www.optionqueen.com), and Option Prince 

(www.optionprince.com)—by forming additional shell companies with foreign bank 

accounts, among other things. 

34. Throughout the Relevant Period, Davis, directly or indirectly through the 

Enterprise, solicited customers located throughout the United States and around the world to 

trade binary option contracts, including binary option contracts based on commodities and 

foreign currencies, through internet websites, e-mails, and telephone communications. 

35. During the Relevant Period, the Enterprise accepted at least $10 million from 

customers for the purpose of trading binary options, of which Davis obtained a portion 

thereof. The Enterprise instructed customers to fund their trading accounts either with wire 

Case: 3:19-cv-02140 Doc #: 1 Filed: 09/17/19 9 of 18. PageID #: 9
10 

transfers to bank accounts that Davis controlled or through credit card or PayPal charges to 

accounts that Davis also controlled. 

36. During the Relevant Period, Davis, directly or indirectly through the 

Enterprise, offered or entered into binary option trades that were agreements, contracts, or 

transactions in foreign currency, to or with persons who were not ECPs, and Davis was not 

an enumerated counterparty as defined by Section 2(c)(2)(B)(i)(II)(aa)-(ff), 7 U.S.C. 

§ 2(c)(2)(B)(i)(II)(aa)-(ff) (2012). 

D. Davis’ Fraud in Connection with Off-Exchange Binary Options 

37. During the Relevant Period, Davis, directly or indirectly through the 

Enterprise, engaged in an off-exchange binary options trading scam and falsely claimed in 

his solicitations that customers would generate significant profits through binary options 

trading, with winning trades offering a payout of up to 85%. 

38. Davis, directly or indirectly through the Enterprise, defrauded customers by 

making misrepresentations of material facts to attract and retain customers to enter into 

illegal, off-exchange binary options transactions, including by misrepresenting that:

a. Customer funds were maintained in individual trading accounts, when in 

reality the funds were commingled with the general funds of the Enterprise; 

b. Enterprise employees were “brokers” or “market analysts” who possessed 

specialized knowledge and financial expertise necessary to recommend 

profitable binary options trades, when in reality Davis and his employees had 

no relevant experience or qualifications; 

Case: 3:19-cv-02140 Doc #: 1 Filed: 09/17/19 10 of 18. PageID #: 10
11 

c. Customers could make “risk free” or “guaranteed” binary options trades if 

they deposited more money, when in reality customers were often placed in 

losing trades; and

d. Customers could withdraw money from their binary options accounts at any 

time, when in reality customers were often not permitted to withdraw funds 

even after complying with Enterprise requests for additional burdensome 

paperwork and/or funds. 

39. Davis, directly or indirectly through the Enterprise, defrauded customers by 

making omissions of material facts to attract and retain customers to enter into off-exchange 

binary options transactions, including by failing to disclose that:

a. Davis did not connect customers to a legitimate binary options exchange that 

matched customers who chose different binary option outcomes; 

b. Davis effectively took the opposite position on each trade and thus made 

money for the Enterprise and himself every time a customer lost money; 

c. Davis could and oftentimes did instruct, and directed Enterprise employees to 

instruct, the trading platforms to manipulate internal software settings via

“risk management” protocols to make it more likely for certain customers to 

win or lose; and 

d. Enterprise employees, at the direction of Davis, provided fictitious trading 

results to customers in an effort to induce them to deposit additional funds and 

“burned” certain customer accounts through excessive trading. 

Case: 3:19-cv-02140 Doc #: 1 Filed: 09/17/19 11 of 18. PageID #: 11
12 

40. Davis, directly or indirectly through the Enterprise, communicated with 

SpotOption to use “risk management” as a way of increasing individual customer losses. For 

example:

a. On or about June 2, 2014, an employee for Davis wrote an email to “Risk 

Management <risk@spotoption.com>,” that referred to “optionmint 16312,” a 

specific OptionMint customer. Defendant wrote: “He is burying us. Please 

do something with him.” 

b. On or about February 19, 2014, an employee for Defendant wrote an email to 

“Risk Management <risk@spotoption>,” stating “[p]lease look at user #15747 

. . . He’s taking out positions for random amounts and is killing us.” The 

employee copied Davis to this email using Defendant’s 

“jared@davisinvestment.com” account.

c. On or about February 25, 2014, an employee for Davis wrote an email to 

“Risk Management <risk@spotoption.com>,” stating “[p]lease adjust risk for 

following trader. He is crushing us.” The employee copied Davis to this 

email using Defendant’s “jared@davisinvestment.com” account.

d. On or about April 9, 2014, an employee for Davis wrote an email to “Risk 

Management <risk@spotoption.com>,” stating “[c]an you please adjust risk 

for the below OptionMint user. He is crushing us with this straddle strategy.” 

The employee copied Davis to this email using Defendant’s 

“jared@davisinvestment.com” account. 

Case: 3:19-cv-02140 Doc #: 1 Filed: 09/17/19 12 of 18. PageID #: 12
13 

e. On or about April 10, 2014, an employee for Davis wrote an email to “Risk 

Management <risk@spotoption.com>,” as a follow up to his April 9, 2014 

email. The employee asked, “[h]as this risk been changed yet. This was sent 

yesterday but no reply yet.” The employee copied Davis. A SpotOption 

employee replied the same day, copying Davis and stating “[t]hank you for 

contacting us. We had changed the status risk for the guy below. It should be 

more aggressive and reducing his profits in the soon [sic] future.” 

f. On or about April 21, 2014, an employee for Davis wrote an email to “Risk 

Management <risk@spotoption.com>,” stating “[t]his user is still crushing us 

even though the risk was adjusted 6 days ago. Can you please take another 

look immediately and fix this ASAP.” The employee copied Davis to this 

email. A SpotOption employee responded, copying Davis, and writing that 

the customer “lost 621$ in the last 6 days . . . Eventually, we believe the 

changes will do the work.” 

g. On or about November 4, 2014, an employee for Davis wrote an email to 

“Risk Management <risk@spotoption.com>,” stating “[p]lease adjust risk for 

OptionMint user: [xxxxx]@gmail.com. Large trade amounts and at a 76% 

win rate.” The employee copied Defendant to this email using Davis’s 

“jared@davisinvestment.com” account. 

41. Davis, directly or indirectly through the Enterprise, also defrauded customers 

who requested withdrawals from their accounts by falsely representing that their accounts 

had been reassigned to other brokers, that they had not made enough trades to withdraw their 

Case: 3:19-cv-02140 Doc #: 1 Filed: 09/17/19 13 of 18. PageID #: 13
14 

money, and/or that their money was tied up in pending trades which they eventually lost. 

Further, Davis falsely induced certain customers to send additional funds to cover purported 

fees and taxes in order to return their funds. 

42. Ultimately, although Davis occasionally allowed customers to withdraw small 

amounts from their accounts, the majority of customers were unable to obtain any funds back 

from Davis or the Enterprise despite repeated demands. 

VI. VIOLATIONS OF THE COMMODITY EXCHANGE ACT AND 

REGULATIONS

COUNT ONE

Commodity Options Fraud 

Violations of Section 4c(b) of the Act and Regulation 32.4 

43. The allegations set forth in the preceding paragraphs are re-alleged and 

incorporated herein by reference.

44. During the Relevant Period, Davis, in or in connection with an offer to enter 

into, the entry into, or the confirmation of the execution of, any commodity option 

transaction, directly or indirectly: (a) cheated or defrauded, or attempted to cheat or defraud, 

customers and prospective customers; (b) made or caused to be made to customers and 

prospective customers false reports or statements; and (c) deceived or attempted to deceive 

customers and prospective customers, in violation of Section 4c(b) of the Act, 7 U.S.C. 

§ 6c(b) (2012), and Regulation 32.4, 17 C.F.R. § 32.4 (2019).

45. During the Relevant Period, Davis was a controlling person of the Enterprise 

and, through the conduct set forth in paragraphs 19-42, failed to act in good faith, or 

knowingly induced, directly or indirectly, the acts constituting the violations. Accordingly, 

Case: 3:19-cv-02140 Doc #: 1 Filed: 09/17/19 14 of 18. PageID #: 14
15 

Davis is liable for each and every violation of the Act committed by employees or agents of 

the Enterprise pursuant to Section 13(b) of the Act, 7 U.S.C. § 13c(b) (2012). 

46. Each act by Davis or by any employee or agent of the Enterprise in violation 

of 7 U.S.C. § 6c(b) and 17 C.F.R. § 32.4, including but not limited to those specifically 

alleged herein, is alleged as a separate and distinct violation of 7 U.S.C. § 6c(b) and 17 

C.F.R. § 32.4. 

VII. RELIEF REQUESTED

WHEREFORE, the CFTC respectfully requests that this Court, as authorized by 

Section 6c of the Act, 7 U.S.C. § 13a-1 (2012), and pursuant to its own equitable powers, 

enter:

A. An order finding that Defendant violated Section 4c(b) of the Act, 7 U.S.C. 

§ 6c(b) (2012), and Regulation 32.4, 17 C.F.R. § 32.4 (2019); 

B. An order of permanent injunction enjoining Defendant, and his affiliates, 

agents, servants, employees, successors, assigns, attorneys, and all persons in active concert 

with him, who receive actual notice of such order by personal service or otherwise, from 

engaging in the conduct described above, in violation of 7 U.S.C. § 6c(b) and 17 

C.F.R. § 32.4;

C. An order of permanent injunction prohibiting Defendant, and any of his 

agents, servants, employees, successors, assigns, attorneys, and all persons in active concert 

with Defendant, from directly or indirectly:

(1) Trading on or subject to the rules of any registered entity (as that term is 

defined in Section 1a(40) of the Act, 7 U.S.C. § 1a(40) (2012)); 

Case: 3:19-cv-02140 Doc #: 1 Filed: 09/17/19 15 of 18. PageID #: 15
16 

(2) Entering into any transactions involving “commodity interests” (as that term is 

defined in Regulation 1.3, 17 C.F.R. § 1.3 (2019)), for accounts held in the 

name of Defendant or for accounts in which Defendant has a direct or indirect 

interest; 

(3) Having any commodity interests traded on Defendant’s behalf;

(4) Controlling or directing the trading for, or on behalf of, any other person or 

entity, whether by power of attorney or otherwise, in any account involving 

commodity interests; 

(5) Soliciting, receiving, or accepting any funds from any person for the purpose 

of purchasing or selling any commodity interests;

(6) Applying for registration or claiming exemption from registration with the 

CFTC in any capacity, and engaging in any activity requiring such registration 

or exemption from registration with the CFTC, except as provided for in 

Regulation 4.14(a)(9), 17 C.F.R. § 4.14(a)(9) (2019); and

(7) Acting as a principal (as that term is defined in Regulation 3.1(a), 17 

C.F.R. § 3.1(a) (2019)), agent, or any other officer or employee of any person 

registered, exempted from registration, or required to be registered with the 

CFTC except as provided for in 17 C.F.R. § 4.14(a)(9); 

D. An order directing Defendant, as well as any third-party transferee and/or 

successors thereof, to disgorge, pursuant to such procedure as the Court may order, all 

benefits received including, but not limited to, salaries, commissions, loans, fees, revenues, 

and trading profits derived, directly or indirectly, from acts or practices which constitute 

Case: 3:19-cv-02140 Doc #: 1 Filed: 09/17/19 16 of 18. PageID #: 16
17 

violations of the Act and Regulations as described herein, including pre-judgment and postjudgment interest; 

E. An order requiring Defendant, as well as any successors thereof, to make full 

restitution to every person who has sustained losses proximately caused by the violations 

described herein, including pre-judgment and post-judgment interest; 

F. An order directing Defendant, as well as any successors thereof, to rescind, 

pursuant to such procedures as the Court may order, all contracts and agreements, whether 

implied or express, entered into between, with, or among Defendant, and any customer 

whose funds were received by Defendant as a result of the acts and practices that constituted

violations of the Act and Regulations, as described herein;

G. An order directing Defendant, as well as any successors thereof, to pay a civil 

monetary penalty assessed by the Court, in an amount not to exceed the penalty described by 

Section 6c(d)(1) of the Act, 7 U.S.C. § 13a-1(d)(1) (2012), as adjusted for inflation pursuant 

to the Federal Civil Penalties Inflation Adjustment Improvements Act of 2015, Pub. L. 114-

74, tit. VII, § 701, 129 Stat. 584, 599-600, see Regulation 143.8, 17 C.F.R. § 143.8 (2019), 

for each violation of the Act and Regulations, as described herein; 

H. An order requiring Defendant to pay costs and fees as permitted by 28 

U.S.C. §§ 1920 and 2413(a)(2) (2012); and 

///

///

///

Case: 3:19-cv-02140 Doc #: 1 Filed: 09/17/19 17 of 18. PageID #: 17
18 

I. Such other and further relief as the Court may deem necessary and appropriate 

under the circumstances.

Dated: September 17, 2019 Respectfully submitted, 

COMMODITY FUTURES TRADING 

COMMISSION 

/s/ Peter M. Haas 

PETER M. HAAS 

DANIELLE KARST 

JASON GIZZARELLI 

Attorneys for Plaintiff 

COMMODITY FUTURES TRADING 

COMMISSION 

1155 21st Street, N.W.

Washington, D.C. 20581 

Telephone: (202) 418-5000 

Fax: (202) 418-5523 

phaas@cftc.gov 

dkarst@cftc.gov 

jgizzarelli@cftc.gov 

Case: 3:19-cv-02140 Doc #: 1 Filed: 09/17/19 18 of 18. PageID #: 18