Sripetch v. SEC · ¶70

We will soon need to address whether disgorgement under § 78u(d)(7) is a legal remedy. The Circuits have already split on the answer. Compare Hallam, 42 F. 4th, at 341, with SEC v. Ahmed, 72 F. 4th 379, 395 (CA2 2023). In my view, disgorgement is a legal remedy.

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