The Securities and Exchange Commission today filed an amended complaint charging Saeid Jaberian, a resident of Hopkins, Minnesota, and Christopher J. Rajkaran, a resident of Woodhaven, New York, with defrauding retail investors through a pump-and-dump scheme along with previously charged defendant Mark A. Miller.

According to the SEC's amended complaint, Jaberian and Rajkaran worked with Miller in a scheme to hijack or control at least seven defunct public issuers between September 2017 and April 2019. The amended complaint alleges that Jaberian and Rajkaran participated in the drafting and issuance of a press release containing misrepresentations of material fact about an issuer and that Jaberian posed as that issuer's CEO. Rajkaran also allegedly promoted false information about certain issuers in the scheme on various social media platforms in order to generate trading activity, and Jaberian agreed to share trading profits with Miller. By purchasing issuer shares at Miller's direction and then selling after false information was disseminated, Jaberian and Rajkaran allegedly reaped approximately $240,000 and $65,000 in profits, respectively. The amended complaint alleges that Jaberian's and Rajkaran's conduct also aided and abetted Miller's previously charged primary violations.

The SEC's amended complaint, filed in federal district court in Minnesota, charges Jaberian and Rajkaran with violating the antifraud provisions of Section 17(a) of the Securities Act of 1933 and Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder, and with aiding and abetting Miller's violations of the antifraud provisions of Section 17(a) of the Securities Act of and Section 10(b) of the Exchange Act and Rule 10b-5 thereunder. The SEC seeks injunctive relief, disgorgement with prejudgment interest, civil penalties, and officer and director and penny stock bars against both Jaberian and Rajkaran.

The SEC's investigation, which is ongoing, was conducted by Raven A. Winters, Kathleen M. Sweeney, and Kristine Rodriguez, and supervised by Amy S. Cotter of the Chicago Regional Office. Alyssa A. Qualls leads the litigation.

The SEC appreciates the assistance of the U.S. Attorney's Office for the District of Minnesota, the United States Postal Service, the FBI, and the Financial Industry Regulatory Authority (FINRA).

See Litigation Release No. 25118 (June 21, 2021).