Case 1:20-cv-00799 Document 1 Filed 03/23/20 Page 1 of 16
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF COLUMBIA
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`Civil Action No. _____
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`ALAN D. JACOBSON,
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`RICHARD M. BURR,
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`v.
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`Plaintiff,
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`Defendant.
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`COMPLAINT
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`Plaintiff Alan D. Jacobson (“Plaintiff”) alleges the following based upon personal
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`knowledge as to himself and his own acts, and information and belief as to all other matters:
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`INTRODUCTION
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`1.
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`This lawsuit is brought to redress acts of securities fraud committed by Defendant
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`Richard M. Burr, a United States Senator, who has acted as a scofflaw in a time of national crisis.
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`On February 13, 2020, exploiting material information unavailable to the public, Senator Burr and
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`his wife engaged in 33 transactions by which he sold securities in a variety of publicly-traded
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`companies for his personal gain. In so doing, he injured shareholders—including Plaintiff Alan
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`D. Jacobson—who purchased and/or continued to hold securities in those same companies.
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`Plaintiff’s ability to procure relief in the federal courts is unimpaired by the fact that Senator Burr
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`is a Member of the U.S. Senate, where in his capacity as Chairman of the Senate Intelligence
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`Committee he learned the nonpublic material information on which he based his stock trades.
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`1439176.4
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`Case 1:20-cv-00799 Document 1 Filed 03/23/20 Page 2 of 16
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`2.
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`Senator Burr’s abuse of his powers as a U.S. Senator, at a time of national crisis, is
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`incidental to the relief sought herein. This suit targets Senator Burr’s self-enrichment at the
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`expense of members of the public; it neither infringes impeachment powers vested in the U.S.
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`Congress, nor rights North Carolina voters hold to elect a senator of their choosing. For the reasons
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`set forth below, this is a case of elementary securities fraud.
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`PARTIES
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`3.
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`Plaintiff Alan D. Jacobson is an individual who held shares of Wyndham Hotels &
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`Resorts, Inc. (“Wyndham”) at the time Senator Burr and his wife sold their Wyndham shares at
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`prices that, because the market did not possess the material information then known by Senator
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`Burr, were artificially inflated. Plaintiff has been damaged thereby.
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`4.
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`Senator Burr is, and was, at all relevant times, a United States Senator from North
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`Carolina. Senator Burr was and is the Chairman the Senate Select Committee on Intelligence and
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`is a member of the Senate Committee on Health, Education Labor & Pensions.
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`JURISDICTION AND VENUE
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`5.
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`This action arises under Sections 10(b) and 20A of the Securities and Exchange Act
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`of 1934 (“Exchange Act”), 15 U.S.C. §§ 78j(b), 78t-1(a), SEC Rule 10b-5, 17 C.F.R. § 240.10b5,
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`promulgated thereunder, and the Stop Trading On Congressional Knowledge Act of 2012, Pub. L.
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`112-105, 126 Stat 291 (“STOCK” Act).
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`6.
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`This Court has jurisdiction over the subject matter of this action pursuant to 28
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`U.S.C. § 1331 and Section 27 of the Exchange Act, 15 U.S.C. § 78aa.
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`7.
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`Venue is proper in this District under Section 27 of the Exchange Act and 28 U.S.C.
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`§ 1391(b)(2). Many of the acts and conduct complained of herein, including Senator Burr’s receipt
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`Case 1:20-cv-00799 Document 1 Filed 03/23/20 Page 3 of 16
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`of material nonpublic information on which he based his stock trades, occurred in substantial part
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`in this District.
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`8.
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`In connection with the acts and omissions alleged in this complaint, Senator Burr,
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`directly or indirectly, used the means and instrumentalities of interstate commerce, including, but
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`not limited to, the mails, interstate telephone communications, and the facilities of the national
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`securities markets.
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`BACKGROUND FACTS
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`9.
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`According to the World Health Organization (“WHO”), the worldwide outbreak of
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`the novel coronavirus, COVID-19, has become a global “pandemic” due to its extraordinary
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`“speed and scale of transmission.” The WHO Director-General has stated that the organization is
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`“deeply concerned by both the alarming levels of spread and severity, and by the alarming levels
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`of inaction.” “We have never before seen a pandemic sparked by a coronavirus . . . . We have
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`rung the alarm bell loud and clear.” As of the filing of this Complaint, COVID-19 has infected
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`more
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`than 330,000 people and caused approximately 14,500 deaths worldwide, and
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`epidemiologists estimate that the number of COVID-19 cases in the world doubles every six days.
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`Currently, there is no vaccine available to prevent the spread of COVID-19.
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`10.
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` In the United States, fears over the spread and lethality of COVID-19 have had
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`devastating economic and social consequences. Large public gatherings and major events have
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`been canceled. Employees have been told to work from home, universities have moved all classes
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`online, and elementary schools have closed for sanitizing. And the Governors of six states—
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`California, New York, Illinois, Connecticut, Oregon, and New Jersey—have issued various types
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`of “stay at home” orders.
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`Case 1:20-cv-00799 Document 1 Filed 03/23/20 Page 4 of 16
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`11.
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`Senator Burr, who chairs the Senate Select Committee on Intelligence (the “Senate
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`Intelligence Committee”) and who is also a member of the Senate Committee on Health, Education
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`Labor & Pensions (the “Senate Health Committee”), received daily confidential updates from the
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`intelligence community on the COVID-19 outbreak during January and February 2020.
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`12. While members of the public, including Plaintiff, were being told by the United
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`States government, including by Senator Burr, that the United States was prepared to face
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`emerging public health threats like the coronavirus and that COVID-19 would not have a
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`significant impact on the economy, Senator Burr was in possession of material nonpublic
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`information to the contrary.
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`13.
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`The Senate Health Committee, of which Senator Burr is a member, hosted a private
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`briefing for Senators by administration officials about the outbreak of COVID-19 on January 24,
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`2020. See Senate Health Committee Announces Briefing to Update Senators on Coronavirus,
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`Senate Health Committee on Heath, Education Labor & Pensions, Jan. 23, 2020,
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`https://bit.ly/2Um7r6L. Upon information and belief, during this briefing, Senator Burr was given
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`material nonpublic information regarding the outbreak of COVID-19.
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`14.
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`On February 7, 2020, Senator Burr assured the public that “the United States today
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`is better prepared than ever before to face emerging public health threats like the coronavirus.”
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`Sen. Lamar Alexander and Sen. Richard Burr, Coronavirus prevention steps the U.S. government
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`is taking to protect you, Fox News, Feb. 7, 2020, https://fxn.ws/33x0Cx. On February 12, 2020,
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`the Dow Jones industrial average closed at its highest-ever point: 29,551.42. The Dow had
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`remained steady around 29,000 for weeks.
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`15.
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`On February 13, 2020, Senator Burr and his wife collectively made 33 separate
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`stock sale transactions according to a period transaction report Senator Burr filed on February 27,
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`Case 1:20-cv-00799 Document 1 Filed 03/23/20 Page 5 of 16
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`2020. Richard M. Burr, Period Disclosure of Financial Transactions, Feb. 26, 2020. Attached
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`hereto as Exhibit A is a true and correct copy of this report.
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`16.
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`The stock sales Senator Burr made represented all or most of Senator Burr’s assets.
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`Two years ago, “Roll Call” estimated that Senator Burr had a total net worth of about $1.7 million.
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`In other words, on that day in February, Senator Burr suddenly decided to liquidate virtually every
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`asset he owned.
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`17.
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`The following is a list of the stock that Senator Burr sold on February 13, 2020:
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`Company
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`Senator Richard Burr
`1. Abbvie, Inc. (ABBV)
`2. Axalta Coating Systems Ltd. (AXTA)
`3.
`Bank of New York Mellon Corp. (BK)
`4.
`Colfax Corporation (CFX)
`5.
`CenturyLink Inc. (CTL)
`6. Dorman Products, Inc. (DORM)
`7.
`FedEx Corp.(FDX)
`8.
`Fairfax Financial Holdings Ltd. (FRFHF)
`9. Mohawk Industries, Inc. (MHK)
`10. 3M Company (MMM)
`11. Orion Engineered Carbons SA (OEC)
`12. Koninklijke Philips NV (PHG)
`13. Park Hotels & Resorts Inc. (PK)
`14. Everest Re Group (RE)
`15. Extended Stay America, Inc. (STAY)
`16. Constellation Brands Inc. (STZ)
`17. Wyndham Hotels & Resorts Inc. (WH)
`18. CSX Corp. (CSX)
`Senator Richard Burr’s Spouse
`19. Abbvie, Inc. (ABBV)
`20. Axalta Coating Systems Ltd. (AXTA)
`21. Bank of New York Mellon Corp. (BK)
`22. CSX Corp. (CSX)
`23. CenturyLink Inc. (CTL)
`24. Dorman Products, Inc. (DORM)
`25. Fairfax Financial Holdings Ltd. (FRFHF)
`26. 3M Company (MMM)
`27. Orion Engineered Carbons SA (OEC)
`28. Koninklijke Philips NV (PHG)
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`1439176.4
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`Sale Date
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`Sale Value
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`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
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`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
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`$15,001 to $50,000
`$15,001 to $50,000
`$1,001 to $15,000
`$15,001 to $50,000
`$15,001 to $50,000
`$1,001 to $15,000
`$1,001 to $15,000
`$15,001 to $50,000
`$1,001 to $15,000
`$1,001 to $15,000
`$1,001 to $15,000
`$15,001 to $50,000
`$1,001 to $15,000
`$15,001 to $50,000
`$15,001 to $50,000
`$15,001 to $50,000
`$15,001 to $50,000
`$1,001 to $15,000
`
`$50,001 to $100,000
`$50,001 to $100,000
`$15,001 to $50,000
`$15,001 to $50,000
`$50,001 to $100,000
`$15,001 to $50,000
`$15,001 to $50,000
`$15,001 to $50,000
`$15,001 to $50,000
`$15,001 to $50,000
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`Case 1:20-cv-00799 Document 1 Filed 03/23/20 Page 6 of 16
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`29. Park Hotels & Resorts Inc. (PK)
`30. Everest Re Group (RE)
`31. Extended Stay America, Inc. (STAY)
`32. Constellation Brands Inc. (STZ)
`33. Wyndham Hotels & Resorts Inc. (WH)
`TOTAL
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`
`
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
`2/13/2020
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`$15,001 to $50,000
`$50,001 to $100,000
`$50,001 to $100,000
`$50,001 to $100,000
`$50,001 to $100,000
`$628,033 to
`$1.72 million
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`18.
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`The stock sales by Senator Burr and his wife included sales of stock in Wyndham.
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`Senator Burr and his wife sold up to $150,000 worth of shares in Wyndham, which has lost almost
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`2/3 of its market value since February 13, 2020.
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`19.
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`Senator Burr’s February 13, 2020 selling spree was his largest stock selling day of
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`at least the past 14 months (according to a ProPublica review of Senate records). Unlike his
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`typical disclosure reports, which are a mix of sales and purchases, all of the transactions on
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`February 13 were sales.
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`20.
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`On February 13, 2020, the day that Senator Burr and his wife dumped $150,000
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`of Wyndham stock, Wyndham’s stock traded at a high of $59.37. Over the next several weeks,
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`Wyndham’s stock dropped precipitously as the market was belatedly informed of the severity of
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`COVID-19, as well as its potential expected impact on the economy. In particular, Wyndham, as
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`a hotel chain, obviously stood to lose substantial business as a result of quarantine measures,
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`border closures, and substantial reductions in tourism.
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`21.
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`By February 28, 2020, Wyndham’s stock price had dropped to $49.40. By March
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`17, 2020, Wyndham’s stock price had further dropped to $31.10. By March 19, 2020, Wyndham
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`stock traded at $20.61—a 65% decrease from February 13.
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`22.
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`As of the filing of the Complaint, the Dow Industrial average has lost nearly 1/3
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`of its value since February 13, 2020.
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`23.
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`Senator Burr’s knowledge of the devastating impact of COVID-19 on the United
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`States, the mitigation measures that would be taken in efforts to curtail its spread, and the coming
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`hit to the economy is evident not only by the fact that he received confidential briefings on COVID-
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`19 and then sold all of the shares he held in the stock market but by comments he made to a small
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`group of private investors.
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`24.
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`On February 27, 2020, Senator Burr, when speaking to a small private audience of
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`well-connected constituents, organized by the Tar Heel Circle, a nonpartisan group whose
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`membership consists of businesses and organizations in North Carolina, said that COVID-19 “is
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`much more aggressive in its transmission than anything we have seen in recent history,” comparing
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`it to the 1918 flu pandemic. David Merrill and Esha Day, What the Dow’s 28% Crash Tells Us
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`About the Economy, Bloomberg, Mar. 18, 2020, https://bloom.bg/3a9hgLY. He warned them they
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`should prepare for dire economic and societal effects from the spread of COVID-19. Senator Burr
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`advised the attendees at the luncheon: “Every company should be cognizant of the fact that you
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`may have to alter your travel. You may have to look at your employees and judge whether the trip
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`they’re making to Europe is essential or whether it can be done on video conference. Why risk
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`it?”
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`25.
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`Sixteen days before North Carolina closed its schools over the threat of COVID-
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`19, Senator Burr warned that it could happen. “There will be, I’m sure, times that communities,
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`probably some in North Carolina, have a transmission rate where they say, ‘Let’s close schools for
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`two weeks. Everybody stay home,’” he said.
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`26.
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`Senator Burr also told the luncheon attendees of the possibility that the military
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`might be mobilized to combat COVID-19: “We’re going to send a military hospital there; it’s
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`going to be in tents and going to be set up on the ground somewhere,’ Burr said at the luncheon.
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`‘It’s going to be a decision that the president and DOD make. And we’re going to have medical
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`professionals supplemented by local staff to treat the people that need treatment.’” Weeks Before
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`Virus Panic, Intelligence Chairman Privately Raised Alarm, Sold Stocks, NPR, Mar. 19, 2020,
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`https://www.npr.org/2020/03/19/818192535/burr-recording-sparks-questions-about-private-
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`comments-on-covid-19.
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`COUNT I
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`Violation of the STOCK Act, Section 10(b) of the Exchange Act, and SEC Rule 10b-5
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`Plaintiff repeats and realleges each and every allegation contained above as if fully
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`27.
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`set forth herein.
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`28.
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`The STOCK Act specifically prohibits Members of Congress from using nonpublic
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`information for private profit and affirms that Members are not exempt from federal securities law
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`prohibiting insider trading.
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`29.
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`The STOCK Act affirms that “Members of Congress . . . are not exempt from the
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`insider trading prohibitions arising from the securities laws, including section 10(b) of the
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`Securities Exchange Act and Rule 10b-5 thereunder.” STOCK Act § 4, Pub. L. 112-105, 126 Stat
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`291.
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`30.
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`Under the STOCK Act, “each Member of Congress . . . owes a duty arising from a
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`relationship of trust and confidence to Congress, the United States Government, and the citizens
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`of the United States with respect to material, nonpublic information derived from such person’s
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`position as a Member of Congress . . . or gained from the performance of such person’s official
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`responsibilities.” 15 U.S.C. § 78u-1(g)(1).
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`31.
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`On and around February 13, 2020, Senator Burr possessed material nonpublic
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`information regarding the impact of COVID-19 on the United States, and in particular on the U.S.
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`stock market. Senator Burr learned this material nonpublic information by virtue of his duties as
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`a United States Senator. Senator Burr owed a duty to Congress, the United States government,
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`and citizens of the United States, including Plaintiff, not to use material nonpublic information that
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`he learned by virtue of his duties as a United States Senator in connection with the sale or purchase
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`of any security. Senator Burr breached that duty by selling stock, including Wyndham stock, based
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`on that material nonpublic information.
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`32. While Wyndham’s securities traded at artificially inflated and distorted prices,
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`Senator Burr personally profited by selling shares of Wyndham common stock at a price of
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`approximately $59.37 on February 13, 2020, while in possession of adverse, material nonpublic
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`information about the COVID-19. Had Plaintiff and the market known of the material nonpublic
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`information in Senator Burr’s possession regarding COVID-19, and on which Senator Burr traded,
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`Wyndham’s stock price on February 13, 2020 would have been substantially lower. Senator Burr
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`and his wife sold up to $150,000 of Wyndham stock on that date, and therefore he and his wife
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`pocketed up to $150,000 in illegal insider trading proceeds at Plaintiff’s expense.
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`33.
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`Plaintiff suffered damages because, in reliance on the integrity of the market, he
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`maintained his stock holdings in Wyndham at artificially inflated prices as a result of Defendant’s
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`violations of Section 10(b) and 20A of the Exchange Act.
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`COUNT II
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`Violation of the STOCK Act and Section 20A of the Exchange Act
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`Plaintiff repeats and realleges each and every allegation contained above as if fully
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`34.
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`set forth herein.
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`35.
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`Plaintiff purchased and continues to hold Wyndham stock. As set forth above,
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`Senator Burr and his wife sold Wyndham stock at artificially inflated prices based on material
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`Case 1:20-cv-00799 Document 1 Filed 03/23/20 Page 10 of 16
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`nonpublic information that Senator Burr learned by virtue of his duties as a United States Senator.
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`Senator Burr had a duty to keep this information confidential and not to trade securities based on
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`that information. Senator Burr breached his duty by trading Wyndham stock on February 13, 2020
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`based on that information, thereby causing Plaintiff damages.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff demands judgment against Richard M. Burr as follows:
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`(1) Awarding compensatory damages in favor of Plaintiff against Defendant
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`for all damages sustained as a result of Defendant’s wrongdoing, in an
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`amount to be proven at trial, including pre-judgment and post-judgment
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`interest thereon;
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`(2) Awarding Plaintiff his costs and expenses in this litigation, including
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`reasonable experts’ fees and other costs and disbursements;
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`(3) Awarding Plaintiff such other and further relief as this Court deems just
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`and appropriate.
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`DEMAND FOR JURY TRIAL
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`Plaintiff hereby demands a trial by jury in this action of all issues so triable.
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`Dated: March 23, 2020
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`/S/ ERIC M. GEORGE
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`ERIC M. GEORGE (D.C. BAR NO. 992046)
`THOMAS P. O’BRIEN (PRO HAC VICE
`APPLICATION TO BE FILED)
`BROWNE GEORGE ROSS LLP
`2121 AVENUE OF THE STARS, SUITE 2800
`LOS ANGELES, CALIFORNIA 90067
`PHONE: (310) 274-7100
`FAX: (310) 275-5697
`EMAIL: EGEORGE@BGRFIRM.COM
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`Case 1:20-cv-00799 Document 1 Filed 03/23/20 Page 12 of 16
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` Exhibit A
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`Case 1:20-cv-00799 Document 1 Filed 03/23/20 Page 13 of 16
`Case 1:20-cv-00799 Document 1 Filed 03/23/20 Page 13 of 16
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`Case 1:20-cv-00799 Document 1 Filed 03/23/20 Page 14 of 16
`Case 1:20-cv-00799 Document 1 Filed 03/23/20 Page 14 of 16
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`Case 1:20-cv-00799 Document 1 Filed 03/23/20 Page 15 of 16
`Case 1:20-cv-00799 Document 1 Filed 03/23/20 Page 15 of 16
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`Case 1:20-cv-00799 Document 1 Filed 03/23/20 Page 16 of 16
`Case 1:20-cv-00799 Document 1 Filed 03/23/20 Page 16 of 16
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`