You edited the headline to make it sound like some kind of thoughtcrime.

The analyst came out of a non-deal roadshow meeting, told his proprietary traders to sell everything, told his top hedge fund clients to sell, maintained the buy rating, told his colleagues he maintained the buy rating to keep the investment banking relationship.

from the release https://www.sec.gov/litigation/admin/2016/34-77150.pdf

16. On March 28, 2012, Grom and DBSI hosted Big Lots’ Chief Executive Officer and
Senior Vice President of Finance at a non-deal roadshow (“NDR”) at DBSI’s Boston office.
Beginning at about 7:30 a.m. and continuing until about 3:15 p.m., the Big Lots executives held
private meetings with DBSI clients. Grom attended all of these meetings.

17. Before the NDR, Grom was bullish on Big Lots: he believed the company’s first
quarter financial performance, particularly its first quarter comparable store sales, would be strong,
with comparable store sales “up four or five, maybe six percent.” At some point early during the
NDR, Grom’s view changed and he ultimately concluded that Big Lots’ first quarter comparable
stores sales would increase by only two to three percent, a significant shift in Grom’s view. Grom
believed, and his financial models reflected, that even a one percent change in Big Lots’
comparable store sales could significantly impact its earnings per share. Grom became particularly
concerned during the NDR when Big Lots’ executives made what Grom believed to be cautious
comments about Big Lots’ consumables business, which comprised approximately twenty-five to
thirty percent of Big Lots’ total sales at the time.

18. At 8:51 a.m. on March 28, 2012, shortly after the first NDR meeting had ended,
Grom called the DBSI trader responsible for trading Big Lots’ stock. At 9:31 a.m., within a minute
of the market opening, the trader placed an order to sell 25,000 shares of Big Lots’ stock, which he
had purchased the day before in a firm proprietary account.

19. In the early afternoon on the day of the NDR, Big Lots’ Chief Executive Officer
abruptly asked Grom whether he was going to downgrade Big Lots stock. At 1:23 p.m., Grom
emailed one of his junior analysts back in New York, simply stating, “this is gonna be hard.”
Three minutes later, the junior analyst responded, “uh oh.” At 1:26 p.m., Grom sent the junior
analyst another email, stating, “[p]retty clear that biz is just ok.”

20. Beginning within minutes after the NDR had ended, Grom communicated with
several DBSI clients, including Hedge Fund A, Hedge Fund B, Hedge Fund C, and Hedge Fund D.

After talking to Grom, all four of these DBSI clients subsequently sold their entire positions in Big Lots stock

[details of sales omitted]

22. On March 29, 2012, Grom issued a research report on Big Lots entitled “Not All Is
Good In Buckeye Land,” in which he reiterated his BUY rating. As required by Regulation AC of
the Exchange Act, Grom signed an Analyst Certification that was included at the end of the report,
which stated: “The views expressed in this report accurately reflect the personal views of the
undersigned lead analyst(s) about the subject issuer and the securities of the issuer.”

23. On March 29, 2012, at 7:30 a.m., roughly two hours after his Big Lots research
report had been publicly disseminated, Grom spoke about Big Lots on the DBSI morning
conference call with firm research and sales personnel. Grom said that he had maintained a BUY
rating on Big Lots because “obviously that we just had them in town so it’s not kosher to
downgrade on the heels of something like that.” Grom also said, “[B]ut more importantly than
that, I think there’s obviously time left in the quarter” and that he and his team was “gonna do our
homework on it” and “gonna be in front of ‘em.”

24. Less than a month later, Grom repeated his assertion that he had not downgraded
Big Lots on March 29, 2012 because he wanted to maintain his relationship with Big Lots’
management.