Case 1:21-cv-01919-JGK Document 38 Filed 07/14/22 Page 1 of 16

Case 1:21-cv-01919-JGK Document 35-1 Filed 07/13/22 Page 1 of 16 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF NEW YORK 

COWvf ODITY FUTURES TRADING 

COMMISSION, 

Plaintiff, 

V. 

JOHN DAVID MCAFEE and 

JIMMY GALE WATSON, JR., 

Defendants. 

Case No. 21-cv-1919 (JGK) 

ECF Case 

CONSENT ORDER FOR PERMANENT INJUNCTION, CIVIL MONETARY PENALTY 

AND OTHER EOUIT ABLE RELIEF AGAINST 

DEFENDANT JIMMY GALE WATS ON 

I. INTRODUCTION 

On March 5, 2021, Plaintiff Commodity Futures Trading Commission ("Commission" or 

"CFTC") filed a Complaint against Defendants John David McAfee ("McAfee") and Jimmy 

Gale Watson ("Watson") seeking injunctive and other equitable relief, as well as the imposition 

of civil penalties, for violations of the Commodity Exchange Act ("Act"), 7 U.S.C. §§ 1-26, and 

the Commission's Regulations ("Regulations") promulgated thereunder, 17 C.F.R. pts. 1-190 

(2021). 

II. CONSENTS AND AGREEMENTS 

To effect settlement of all charges alleged in the Complaint against Watson without a trial 

on the merits or any further judicial proceedings, Watson: 

1. Consents to the entry of this Consent Order for Permanent Injunction, Civil 

Monetary Penalty, and Other Equitable Relief Against Defendant Jimmy Gale Watson ("Consent 

Order"); 
Case 1:21-cv-01919-JGK Document 38 Filed 07/14/22 Page 2 of 16

Case 1:21-cv-01919-JGK Document 35-1 Filed 07/13/22 Page 2 of 16 

2. Affirms that he has read and agreed to this Consent Order voluntarily, and that no 

promise, other than as specifically contained herein, or threat, has been made by the CFTC or 

any member, officer, agent, or representative thereof, or by any other person, to induce consent 

to this Consent Order; 

3. Acknowledges service of the summons and Complaint; 

4. Admits the jurisdiction of this Court over him and the subject matter of this action 

pursuant to Section 6c of the Act, 7 U.S.C. § 13a-1; 

5. Admits the jurisdiction of the CFTC over the conduct and transactions at issue in 

this action pursuant to the Act; 

6. Admits that venue properly lies with this Court pursuant to 7 U.S.C. § 13a-l(e); 

7. Waives: 

(a) Any and all claims that he may possess under the Equal Access to Justice 

Act, 5 U.S.C. § 504 and 28 U.S.C. § 2412, and/or the rules promulgated by the 

Commission in conformity therewith, Part 148 of the Regulations, 17 C.F .R. pt. 

148 (2021 ), relating to, or arising from, this action; 

(b) Any and all claims that he may possess under the Small Business 

Regulatory Enforcement Fairness Act of 1996, Pub. L. No. 104-121, tit. II, 

§§ 201-53, 110 Stat. 847, 857-74 (codified as amended at 28 U.S.C. § 2412 and 

in scattered sections of 5 U.S.C. and 15 U.S.C.), relating to, or arising from, this 

action; 

(c) Any claim of Double Jeopardy based upon the institution of this action or 

the entry in this action of any order imposing a civil monetary penalty or any 

other relief, including this Consent Order; and 

( d) Any and all rights of appeal from this action; 

8. Consents to the continued jurisdiction of this Court over him for the purpose of 

implementing and enforcing the terms and conditions of this Consent Order and for any other 

purpose relevant to this action, even if Watson now or in the future resides outside the 

jurisdiction of this Court; 
Case 1:21-cv-01919-JGK Document 38 Filed 07/14/22 Page 3 of 16

Case 1:21-cv-01919-JGK Document 35-1 Filed 07/13/22 Page 3 of 16 

9. Agrees that he will not oppose enforcement of this Consent Order on the ground, 

if any exists, that it fails to comply with Rule 65(d) of the Federal Rules of Civil Procedure and 

hereby waives any objection based thereon; 

10. Agrees that neither he nor any of his agents or employees under his authority or 

control shall take any action or make any public statement denying, directly or indirectly, any 

allegation in the Complaint or the Findings of Fact or Conclusions of Law in this Consent Order, 

or creating or tending to create the impression that the Complaint and/or this Consent Order is 

without a factual basis; provided, however, that nothing in this provision shall affect his: (a) 

testimonial obligations, or (b) right to take legal positions in other proceedings to which the 

CFTC is not a party. Watson shall comply with this agreement, and shall undertake all steps 

necessary to ensure that all of his agents and/or employees under his authority or control 

understand and comply with this agreement; 

11. Consents to the entry of this Consent Order without admitting or denying the 

allegations of the Complaint or any findings or conclusions in this Consent Order, except as to 

jurisdiction and venue, which he admits; 

12. Consents to the use of the findings and conclusions in this Consent Order in this 

proceeding and in any other proceeding brought by the Commission or to which the Commission 

is a party or claimant, and agrees that they shall be taken as true and correct and be given 

preclusive effect therein, without further proof; 

13. Does not consent, however, to the use of this Consent Order, or the findings and 

conclusions herein, as the sole basis for any other proceeding brought by the Commission or to 

which the Commission is a party, other than a: statutory disqualification proceeding; proceeding 

in bankruptcy, or receivership; or proceeding to enforce the terms of this Order; 
Case 1:21-cv-01919-JGK Document 38 Filed 07/14/22 Page 4 of 16

Case 1:21-cv-01919-JGK Document 35-1 Filed 07/13/22 Page 4 of 16 

14. Agrees to provide immediate notice to this Court and the CFTC by certified mail, 

in the manner required by paragraph 44 of Part VI of this Consent Order, of any bankruptcy 

proceeding filed by, on behalf of, or against him, whether inside or outside the United States; and 

15. Agrees that no provision of this Consent Order shall in any way limit or impair 

the ability of any other person or entity to seek any legal or equitable remedy against Watson in 

any other proceeding. 

III. FINDINGS OF FACT AND CONCLUSIONS OF LAW 

The Court, being fully advised in the premises, finds that there is good cause for the entry 

of this Consent Order and that there is no just reason for delay. The Court therefore directs the 

entry of the following Findings of Fact, Conclusions of Law, permanent injunction and equitable 

relief pursuant to Section 6c of the Act, 7 U.S.C. § 13a-1, as set forth herein. The findings and 

conclusions in this Consent Order are not binding on any other party to this action. 

THE PARTIES AGREE AND THE COURT HEREBY FINDS: 

A. Findings of Fact 

The Parties to this Consent Order 

16. Plaintiff Commodity Futures Trading Commission is an independent federal 

regulatory agency that is charged by Congress with administering and enforcing the Act and the 

Regulations. 

17. Defendant Jimmy Gale Watson Jr. is a natural person who currently resides in 

Texas. Watson has never been registered with the Commission. 

Overview of Virtual Currencies 

18. A virtual currency is a type of digital asset defined here as a digital representation 

of value that functions as a medium of exchange, a unit of account, and/or a store of value, but 

does not have legal tender status in any jurisdiction. Bitcoin, ether, verge, dogecoin, reddcoin, 
Case 1:21-cv-01919-JGK Document 38 Filed 07/14/22 Page 5 of 16

Case 1:21-cv-01919-JGK Document 35-1 Filed 07/13/22 Page 5 of 16 

and other virtual currencies are distinct from "real" currencies, which are the coin and paper 

money of the United States or another country that are designated as legal tender, circulate, and 

are customarily used and accepted as a medium of exchange in the country of issuance. 

19. Digital assets, such as bitcoin, ether, and other virtual currencies such as verge, 

dogecoin, and reddcoin, identified in the Complaint are encompassed by the definition of 

"commodity" under Section la(9) of the Act, 7 U.S.C. § la(9). 

Defendants' Scheme to Manipulate 

20. From at least in or around December 2017 through at least in or around February 

2018 (the "Relevant Period"), Watson was employed by and acted in concert with co-Defendant 

John David McAfee ("McAfee") and others while engaged in a digital asset "pump and dump" 

manipulative and deceptive scheme in which Defendants endorsed several digital assets through 

social media distributed nation- and worldwide, for the purpose of inducing investors, including 

those in New York, New York, into entering into contracts of sale of virtual currency, including 

bitcoin, verge, dogecoin, and reddcoin, among others, through electronic web-based virtual 

currency trading platforms based in various states and countries, thereby increasing short-term 

demand and higher prices for the digital assets that Defendants had secretly purchased shortly 

before. 

21. As part of the scheme, Watson assisted McAfee with strategically selecting digital 

assets that would be suitable for the pump-and-dump scheme. 

22. Dogecoin Strategy. For example, on or around January 3, 2018, Watson assisted 

McAfee by strategizing as to the next digital asset to be the vehicle of the pump-and-dump 

scheme. Watson recommended dogecoin. Watson also recommended that McAfee wait for 

dogecoin to increase in price after their building of a position before tweeting out the promotion. 
Case 1:21-cv-01919-JGK Document 38 Filed 07/14/22 Page 6 of 16

Case 1:21-cv-01919-JGK Document 35-1 Filed 07/13/22 Page 6 of 16 

Watson predicted to McAfee that the market price of dogecoin would likely "skyrocket" almost 

immediately after McAfee's tweet, just as other digital assets touted by McAfee had done. 

23. Dogecoin Build. Watson built a position in dogeco1n, spending approximately 

4.1 btc to purchase approximately 6.7 million dogecoin. 

24. Dogecoin Pump. On or around January 8, 2018, or about five days after Watson 

recommended to McAfee dogecoin as the next coin to promote, McAfee's Twitter account 

issued a tweet endorsing dogecoin as his "Coin of the Week." The tout did not disclose 

Defendants' financial interest in dogecoin, their intent to dump dogecoin as the price spiked after 

being touted, or the fact that McAfee was not endorsing dogecoin without bias as a long-term 

value for investors. 

25. Dogecoin Dump. Almost immediately after McAfee's tout by tweet of dogecoin, 

Watson sold his dogecoin position for a net profit of more than 2.9 btc. 

26. During the Relevant Period, McAfee and Watson, directly and through others, 

engaged in similar iterations of the pump-and-dump scheme with respect to other digital assets as 

well. 

B. Conclusions of Law 

Jurisdiction and Venue 

27. This Court possesses jurisdiction over this action pursuant to 28 U.S.C. § 1331 

(codifying federal question jurisdiction) and 28 U.S.C. § 1345 (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). Section 6c(a) of the Act, 7 U.S.C. § 13a-l(a), 

provides that the Commission may bring actions for injunctive relief or to enforce compliance 

with the Act or any rule, regulation, or order thereunder in the proper district court of the United 

States whenever it shall appear to the Commission that any person has engaged, is engaging, or 
Case 1:21-cv-01919-JGK Document 38 Filed 07/14/22 Page 7 of 16

Case 1:21-cv-01919-JGK Document 35-1 Filed 07/13/22 Page 7 of 16 

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. 

28. Venue properly lies with this Court pursuant to 7 U.S.C. § 13a-l(e), because the 

acts and practices in violation of the Act occurred within this District. 

Fraud and Manipulation by Deceptive Device or Contrivance 

Violations of Section 6(c)(l) of the Act, 7 U.S.C. § 9(1), and Regulation 180.l(a), 

17 C.F.R. § 180.l(a) (2021) 

29. Section 6(c)(l) of the Act, 7 U.S.C. § 9(1), makes it unlawful for any person, 

directly or indirectly, to: 

use or employ, or attempt to use or employ, in connection with any 

swap, or a contract of sale of any commodity in interstate commerce, 

or for future delivery on or subject to the rules of any registered 

entity, any manipulative or deceptive device or contrivance, in 

contravention of such rules and regulations as the Commission shall 

promulgate by not later than 1 year after [July 21, 2010, the date of 

enactment of the Dodd-Frank Wall Street Reform and Consumer 

Protection Act] .... 

30. Commission Regulation 180.l(a), 17 C.F.R. § 180.l(a), provides in part: 

It shall be unlawful for any person, directly or indirectly, in 

connection with any swap, or contract of sale of any commodity in 

interstate commerce, or contract for future delivery on or subject to 

the rules of any registered entity, to intentionally or recklessly: 

(1) Use or employ, or attempt to use or employ, any manipulative 

device, scheme, or artifice to defraud; 

(2) Make, or attempt to make, any untrue or misleading statement of 

a material fact or to omit to state a material fact necessary in order 

to make the statements made not untrue or misleading; 

(3) Engage, or attempt to engage, in any act, practice, or course of 

business, which operates or would operate as a fraud or deceit upon 

any person .... 

31. Watson willfully aided, abetted, counseled and worked in combination and in 

concert with McAfee in making or attempting to make untrue or misleading statements of 
Case 1:21-cv-01919-JGK Document 38 Filed 07/14/22 Page 8 of 16

Case 1:21-cv-01919-JGK Document 35-1 Filed 07/13/22 Page 8 of 16 

material fact or omitting to state or attempting to omit material facts necessary in order to make 

statements made not untrue or misleading. Therefore, pursuant to Section 13(a) of the Act, 7 

U.S.C. § 13c(a), Watson is liable as a principal for violations of Section 6(c)(l) of the Act and 

Regulation 180.1. 

Price Manipulation 

Violations of Sections 6(c)(3) and 9(a)(2) of the Act, 7 U.S.C. §§ 9(3), 13(a)(2), and 

Regulation 180.2, 17 C.F.R. § 180.2 (2021) 

32. Section 6(c)(3) of the Act, 7 U.S.C. § 9(3) makes it unlawful for "any person, 

directly or indirectly, to manipulate or attempt to manipulate the price of any swap, or of any 

commodity in interstate commerce, or for future delivery on or subject to the rules of any 

registered entity." 

33. Section 9(a)(2) of the Act, 7 U.S.C. § 13(a)(2), makes it unlawful for "[a]ny 

person to manipulate or attempt to manipulate the price of any commodity in interstate 

commerce, or for future delivery on or subject to the rules of any registered entity, or any 

swap .... " 

34. Commission Regulation 180.2, 17 C.F.R. § 180.2, makes it "unlawful for any 

person, directly or indirectly, to manipulate or attempt to manipulate the price of any swap, or of 

any commodity in interstate commerce, or for future delivery on or subject to the rules of any 

registered entity." 

35. Watson willfully aided, abetted, counseled and worked in combination and in 

concert with McAfee in attempting to manipulate the price of a commodity in interstate 

commerce or for future delivery on or subject to the rules of any registered entity. Therefore, 

pursuant to Section 13(a) of the Act, 7 U.S.C. § 13c(a), Watson is liable as a principal for 

violations of Section 6(c)(l) of the Act and Regulation 180.1. 
Case 1:21-cv-01919-JGK Document 38 Filed 07/14/22 Page 9 of 16

Case 1:21-cv-01919-JGK Document 35-1 Filed 07/13/22 Page 9 of 16 

36. Unless restrained and enjoined by this Court, there is a reasonable likelihood that 

Watson will continue to engage in the acts and practices alleged in the Complaint and in similar 

acts and practices in violation of the Act and Regulations. 

IV. PERMANENT INJUNCTION 

IT IS HEREBY ORDERED THAT: 

37. Based upon and in connection with the foregoing conduct, pursuant to Section 6c 

of the Act, 7 U.S.C. § 13a-l, Watson is permanently restrained, enjoined and prohibited from 

directly or indirectly: 

a. in connection with contracts of sale of commodities in interstate 

commerce, making or attempting to make untrue or misleading statements 

of material fact or omitting to state or attempting to omit material facts 

necessary in order to make statements made not untrue or misleading, such 

as misleadingly characterizing digital asset recommendations as based on 

substantial research into long-term value, rather than simply digital assets 

susceptible to the pump-and-dump scheme; misleadingly issuing 

purportedly unbiased digital asset touts by tweet while disclaiming 

financial interest in a short-term price rise; and misrepresenting or 

concealing the true motive of Defendants' digital asset touts by tweet, 

namely, to contribute to a short-term price rise and secretly trade out of the 

position into that price rise, in violation of Section 6( c )(1) of the Act, 7 

U.S.C. § 9(1), and Regulation 180.l(a), 17 C.F.R. § 180.l(a); 

b. manipulating or attempting to manipulate the price of a commodity in 

interstate commerce or for future delivery on or subject to the rules of any 

registered entity in violation of Sections 6(c)(3) and 9(a)(2) of the Act and 

Regulation 180.2. 

38. Watson is also permanently restrained, enjoined and prohibited from directly or 

indirectly: 

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

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

b. Entering into any transactions involving "commodity interests" (as that 

term is defined in Regulation 1.3, 17 C.F .R. § 1.3 (2021 ), for his own 

personal account or for any account in which he has a direct or indirect 

interest; 
Case 1:21-cv-01919-JGK Document 38 Filed 07/14/22 Page 10 of 16

Case 1:21-cv-01919-JGK Document 35-1 Filed 07/13/22 Page 10 of 16 

c. Having any commodity interests traded on his behalf; 

d. 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; 

e. Soliciting, receiving or accepting any funds from any person for the 

purpose of purchasing or selling any commodity interests; 

f. Applying for registration or claiming exemption from registration with the 

Commission in any capacity, and engaging in any activity requiring such 

registration or exemption from registration with the Commission, except 

as provided for in Regulation 4.14(a)(9), 17 C.F.R § 4.14(a)(9) (2021); 

and/or 

g. Acting as a principal (as that term is defined in Regulation 3.l(a), 17 

C.F.R. § 3.l(a) (2021)), agent or any other officer or employee of any 

person (as that term is defined in 7 U.S.C. § la(38)), registered, exempted 

from registration or required to be registered with the Commission except 

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

V. DISGORGEMENT AND CIVIL MONETARY PENAL TY 

A. Disgorgement 

39. Watson shall pay disgorgement in the amount of One Hundred Forty Four 

Thousand Seven Hundred Thirty Six Dollars ($144,736) ("Disgorgement Obligation"), 

representing the gains received in connection with such violations, within thirty days of the date 

of the entry of this Consent Order. If the Disgorgement Obligation is not paid in full within 

thirty days of the date of entry of this Consent Order, then post-judgment interest shall accrue on 

the Disgorgement Obligation beginning on the date of entry of this Consent Order and shall be 

determined by using the Treasury Bill rate prevailing on the date of entry of this Consent Order 

pursuant to 28 U.S.C. § 1961. 

40. Watson shall pay his Disgorgement Obligation and any post-judgment interest by 

electronic funds transfer, U.S. postal money order, certified check, bank cashier's check, or bank 

money order. If payment is to be made other than by electronic funds transfer, then the payment 
Case 1:21-cv-01919-JGK Document 38 Filed 07/14/22 Page 11 of 16

Case 1:21-cv-01919-JGK Document 35-1 Filed 07/13/22 Page 11 of 16 

shall be made payable to the Commodity Futures Trading Commission and sent to the address 

below: 

MMAC/ESC/ AMK326 

Commodity Futures Trading Commission 

Division of Enforcement 

6500 S. MacArthur Blvd. 

HQ Room 181 

Oklahoma City, OK 73169 

( 405) 954-6569 office 

(405) 954-1620 fax 

Tonia.King@faa.gov 

If payment by electronic funds transfer is chosen, Watson shall contact Tonia King or her 

successor at the address above to receive payment instructions and shall fully comply with those 

instructions. Watson shall accompany payment of the Disgorgement Obligation with a cover 

letter that identifies Watson and the name and docket number of this proceeding. Watson shall 

simultaneously transmit copies of the cover letter and the form of payment to the Chief Financial 

Officer, Commodity Futures Trading Commission, Three Lafayette Centre, 1155 21st Street, 

NW, Washington, D.C. 20581. 

B. Civil Monetary Penalty 

41. Watson shall pay a civil monetary penalty in the amount of One Hundred Forty 

Four Thousand Seven Hundred Thirty Six Dollars ($144,736) ("CMP Obligation"), within thirty 

days of the date of the entry of this Consent Order. If the CMP Obligation is not paid in full 

within thirty days of the date of entry of this Consent Order, then post-judgment interest shall 

accrue on the CMP Obligation beginning on the date of entry of this Consent Order and shall be 

determined by using the Treasury Bill rate prevailing on the date of entry of this Consent Order 

pursuant to 28 U.S.C. § 1961. 

42. Watson shall pay his CMP Obligation and any post-judgment interest, by 

electronic funds transfer, U.S. postal money order, certified check, bank cashier's check, or bank 
Case 1:21-cv-01919-JGK Document 38 Filed 07/14/22 Page 12 of 16

Case 1:21-cv-01919-JGK Document 35-1 Filed 07/13/22 Page 12 of 16 

money order. If payment is to be made other than by electronic funds transfer, then the payment 

shall be made payable to the Commodity Futures Trading Commission and sent to the address 

below: 

MMAC/ESC/ AMK.326 

Commodity Futures Trading Commission 

Division of Enforcement 

6500 S. MacArthur Blvd. 

HQ Room 181 

Oklahoma City, OK 73169 

( 405) 954-6569 office 

(405) 954-1620 fax 

Tonia.King@faa.gov 

If payment by electronic funds transfer is chosen, Watson shall contact Tonia King or her 

successor at the address above to receive payment instructions and shall fully comply with those 

instructions. Watson shall accompany payment of the CMP Obligation with a cover letter that 

identifies Watson and the name and docket number of this proceeding. Watson shall 

simultaneously transmit copies of the cover letter and the form of payment to the Chief Financial 

Officer, Commodity Futures Trading Commission, Three Lafayette Centre, 1155 21st Street, 

NW, Washington, D.C. 20581. 

C. Provisions Related to Monetary Sanctions 

43. Partial Satisfaction: Acceptance by the Commission of any partial payment of 

Watson's Disgorgement Obligation, or CMP Obligation shall not be deemed a waiver his 

obligation to make further payments pursuant to this Consent Order, or a waiver of the 

Commission's right to seek to compel payment of any remaining balance. 
Case 1:21-cv-01919-JGK Document 38 Filed 07/14/22 Page 13 of 16

Case 1:21-cv-01919-JGK Document 35-1 Filed 07/13/22 Page 13 of 16 

VI. MISCELLANEOUS PROVISIONS 

44. Until such time as Watson satisfies in full his Disgorgement Obligation and CMP 

Obligation under this Consent Order, upon the commencement by or against Watson of 

insolvency, receivership or bankruptcy proceedings or any other proceedings for the settlement 

of Watson's debts, all notices to creditors required to be furnished to the Commission under Title 

11 of the United States Code or other applicable law with respect to such insolvency, 

receivership bankruptcy or other proceedings, shall be sent to the address below: 

Secretary of the Commission 

Legal Division 

Commodity Futures Trading Commission 

Three Lafayette Centre 

115 5 21st Street N. W. 

Washington, DC 20581 

45. Notice: All notices required to be given by any provision in this Consent Order, 

except as set forth in paragraph 44, above shall be sent certified mail, return receipt requested, as 

follows: 

Notice to Commission: 

Manal M. Sultan, Deputy Director 

Division of Enforcement 

Commodity Futures Trading Commission 

Ted Weiss Federal Building 

290 Broadway, Suite 600 

New York, NY 10007 

Notice to Defendant Watson: 

Jimmy Gale Watson 

c/o Arnold Spencer, Esq. 

Spencer & Associates 

5956 Sherry Lane, Suite 2000 

Dallas, Texas 75225 

All such notices to the Commission shall reference the name and docket number of this action. 

46. Change of Address/Phone: Until such time as Watson satisfies in full his 

Disgorgement Obligation, and CMP Obligation as set forth in this Consent Order, Watson shall 
Case 1:21-cv-01919-JGK Document 38 Filed 07/14/22 Page 14 of 16

Case 1:21-cv-01919-JGK Document 35-1 Filed 07/13/22 Page 14 of 16 

provide written notice to the Commission by certified mail of any change to his telephone 

number and mailing address within ten calendar days of the change. 

4 7. Entire Agreement and Amendments: This Consent Order incorporates all of the 

terms and conditions of the settlement among the parties hereto to date. Nothing shall serve to 

amend or modify this Consent Order in any respect whatsoever, unless: (a) reduced to writing; 

(b) signed by all parties hereto; and ( c) approved by order of this Court. 

48. Invalidation: If any provision of this Consent Order or if the application of any 

provision or circumstance is held invalid, then the remainder of this Consent Order and the 

application of the provision to any other person or circumstance shall not be affected by the 

holding. 

49. Waiver: The failure of any party to this Consent Order at any time to require 

performance of any provision of this Consent Order shall in no manner affect the right of the 

party at a later time to enforce the same or any other provision of this Consent Order. No waiver 

in one or more instances of the breach of any provision contained in this Consent Order shall be 

deemed to be or construed as a further or continuing waiver of such breach or waiver of the 

breach of any other provision of this Consent Order. 

50. Continuing Jurisdiction of this Court: This Court shall retain jurisdiction of this 

action to ensure compliance with this Consent Order and for all other purposes related to this 

action, including any motion by Watson to modify or for relief from the terms of this Consent 

Order. 

51. Injunctive and Equitable Relief Provisions: The injunctive and equitable relief 

provisions of this Consent Order shall be binding upon Watson, upon any person under his 

authority or control, and upon any person who receives actual notice of this Consent Order, by 
Case 1:21-cv-01919-JGK Document 38 Filed 07/14/22 Page 15 of 16

Case 1:21-cv-01919-JGK Document 35-1 Filed 07/13/22 Page 15 of 16 

personal service, e-mail, facsimile or otherwise insofar as he or she is acting in active concert or 

participation with Watson. 

52. Counterparts and Facsimile Execution: This Consent Order may be executed in 

two or more counterparts, all of which shall be considered one and the same agreement and shall 

become effective when one or more counterparts have been signed by each of the parties hereto 

and delivered (by facsimile, e-mail, or otherwise) to the other party, it being understood that all 

parties need not sign the same counterpart. Any counterpart or other signature to this Consent 

Order that is delivered by any means shall be deemed for all purposes as constituting good and 

valid execution and delivery by such party of this Consent Order. 

53. Contempt: Watson understands that the terms of the Consent Order are 

enforceable through contempt proceedings, and that, in any such proceedings he may not 

challenge the validity of this Consent Order. 

54. Agreements and Undertakings: Watson shall comply with all of the 

undertakings and agreements set forth in this Consent Order. 

There being no just reason for delay, the Clerk of the Court is hereby ordered to enter this 

Consent Order for Permanent Injunction, Civil Monetary Penalty and Other Equitable Relief 

Against Defendant Jimmy Gale Watson forthwith and without further notice. 

~ ~'7' ~i> ~ ~~

<?'tt:J ~ 

~~ 
Case 1:21-cv-01919-JGK Document 38 Filed 07/14/22 Page 16 of 16

Case 1:21-cv-01919-JGK Document 35-1 Filed 07/13/22 Page 16 of 16 

CONSENTED TO AND APPROVED BY: 

/Jr 

Jl~;\lY GALE WATSON 

L-7· - -- ? BI)'l ' "' Jv;,1 f: I_...) ...:2.D..2.2_ , l ~-. - -------

;'J / // R-// ! I ~~ G--J: =- \, fa~J!.'-~ ~ David W. Oakland 

Commodity Futures Trading Commission 

Ted Weiss Federal Building 

290 Broadway, Suite 600 

(646) 746-9769 

(6460 746-9940 (facsimile) 

doakland@cftc.gov