Case 2:21-cv-00632-JCM-DJA Document 1 Filed 04/16/21 Page 1 of 25
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`KENNETH W. DONNELLY
`District of Columbia Bar (No. 462996)
`(LR IA 11-3 pro hac vice motion pending)
`Email: donnellyk@sec.gov
`Telephone: (202) 551-4946
`SAMANTHA M. WILLIAMS
`Maryland Bar (No. 0012190024)
`(LR IA 11-3 pro hac vice motion pending)
`Email: williamssam@sec.gov
`Telephone: (202) 551-4061
`MELISSA ARMSTRONG
`Texas Bar (No. 24050234)
`(LR IA 11-3 pro hac vice motion pending)
`Email: armstrongme@sec.gov
`Tel: (202) 551-4724
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`Attorneys for Plaintiff
`Securities and Exchange Commission
`100 F Street N.E.
`Washington, D.C. 20549-5949
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`UNITED STATES DISTRICT COURT
`DISTRICT OF NEVADA
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`SECURITIES AND EXCHANGE
`COMMISSION,
`Plaintiff,
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`vs.
`SPOT TECH HOUSE, LTD., formerly
`known as, SPOT OPTION, LTD.,
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`MALHAZ PINHAS
`PATARKAZISHVILI, also known as
`PINI PETER and PINHAS PETER,
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`and
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`RAN AMIRAN,
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`Defendants,
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`2:21-cv-00632
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`COMPLAINT
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`Plaintiff Securities and Exchange Commission (the “SEC”) alleges:
`This case concerns a multi-million dollar fraudulent scheme involving
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`unregistered offers and sales of security-based “binary options” to retail investors in
`the United States from at least April 2012 through August 2017 (the “Relevant
`Period”). The scheme was overseen by Malhaz Pinhas Patarkazishvili (“Pini Peter”)
`and Ran Amiran (“Amiran”) through a company they owned and controlled called
`Spot Option, Ltd. (“Spot Option”) now known as Spot Option Tech House, Ltd.
`(collectively, the “Defendants”).
`For the scheme to succeed, Spot Option needed to find investors who
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`could be persuaded to trade the binary options that it issued through its proprietary
`online trading platform. To do so, Spot Option contracted with third parties, which it
`referred to as “Partners,” “White Labels,” and “Brands” (hereinafter, “Partners”), to
`market its binary options. Unbeknownst to investors, Spot Option structured its
`business model so that its Partners were the counterparty on every trade. Under this
`structure, Spot Option and its Partners made their money principally from investor
`losses.
`To make the scheme profitable, Spot Option set the payout terms on its
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`options in a way that made it likely that most investors would lose all or a substantial
`portion of their investment within the first five months of trading. Spot Option
`trained its Partners, however, to deceptively market the binary options as profitable
`investments. Spot Option used additional deceptive and manipulative practices to
`increase investors’ losses and boost Spot Options’ income stream. These practices
`included manipulating the trading platform to increase the probability that trading
`would be unprofitable and offering investors a so-called “bonus” to lock-up investor
`funds and prevent withdrawals, which, when combined with the payout terms,
`virtually guaranteed investor losses.
`Through these and other deceptive and fraudulent acts, Spot Option
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`sought and reached thousands of investors in the United States, including retirees,
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`who traded through its platform. Many of those investors lost most of their money
`including, in some cases, hundreds of thousands of dollars meant for retirement. Spot
`Option and its Partners, on the other hand, raked in millions in profits.
`As a result of its conduct, Defendant Spot Option violated the
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`registration provisions of Section 5(a) and 5(c) of the Securities Act of 1933
`(“Securities Act”) [15 U.S.C. §§ 77e(a) and 77e(c)], the antifraud provisions of
`Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)], and the antifraud provisions
`of Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C.
`§§ 78j(b)], and Rule 10b-5 thereunder [17 C.F.R. § 240.10b‒5].
`Defendants Pini Peter and Amiran are liable for violations of Section 5
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`of the Securities Act because they each played a substantial role in Spot Option’s
`offers and sales of binary options. Pini Peter and Amiran are also liable for Spot
`Option’s violations of the Exchange Act because they are controlling persons of Spot
`Option as defined by the Exchange Act. The SEC seeks disgorgement of Defendants’
`ill-gotten gains, prejudgment interest, civil monetary penalties, an injunction against
`further violations of the federal securities laws as to all Defendants, a specific
`conduct based injunction as to the individual defendants, and other appropriate relief.
`SUBJECT MATTER JURISDICTION AND VENUE
`This Court has subject matter jurisdiction under Section 22 of the
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`Securities Act [15 U.S.C. § 77v], Sections 21(d) and 27 of the Exchange Act [15
`U.S.C. §§ 78u(d) and 78aa], and 28 U.S.C. § 1331.
`Venue is proper in this district under Section 22(a) of the Securities Act
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`[15 U.S.C. § 77v(a)] and Section 27(a) of the Exchange Act [15 U.S.C. § 78aa(a)]
`because certain of the transactions, acts, practices, and courses of conduct
`constituting violations of the federal securities laws occurred within this district,
`including offers of security-based binary options to at least one investor who in this
`district traded through Spot Option’s platform via a Spot Option Partner and lost a
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`substantial amount of her retirement savings. Venue also is proper here under 28
`U.S.C. § 1391(c)(3) because all Defendants reside outside of the United States.
`DEFENDANTS
`Spot Option Tech House, Ltd., formerly known as, Spot Option, Ltd., is
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`a private Israeli company headquartered or formerly headquartered in Israel.
`Currently, it does not appear to be engaged in any business activities.
`10. Malhaz Pinhas Patarkazishvili, also known as Pini Peter or Pinhas Peter,
`age 45, resides in Israel. Pini Peter is the primary founder of Spot Option and, during
`the Relevant Period, was an Executive Chairman, Director, and/or Chief Executive
`Officer of Spot Option. During the Relevant Period, Pini Peter was the chief architect
`of Spot Option’s business model and business plans, had ultimate authority over Spot
`Option’s financial accounts, and was in charge of Spot Option’s entire management
`and business affairs. During nearly all of this period, he owned over 90% of Spot
`Option’s shares. On March 13, 2017, Pini Peter transferred his ownership interest in
`Spot Option, about 94.22% of its then outstanding shares, to his wife, Limor
`Patarkazishvili.
`11. Ran Amiran, age 50, also resides in Israel. During the Relevant Period,
`Amiran served first as Head of Business Development and then as Spot Option’s
`President and Director. Around March 2017, Amiran took over as Spot Option’s
`Chief Executive Officer. During the Relevant Period, Amiran owned approximately
`2.5% of Spot Option’s shares and, by the end of February 2015, was Spot Option’s
`second largest shareholder. Amiran was responsible for Spot Option’s sales,
`marketing and business development, and he managed the day-to-day relationships
`with Spot Option’s Partners.
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`THE SCHEME
`12. A “binary option” is a financial instrument that expires at a
`predetermined time where the payout is contingent on the outcome of a yes/no
`proposition. These options are “binary” because upon expiration they carry only two
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`possible outcomes. If the holder’s prediction is correct, he will receive a
`predetermined amount of money. If it is incorrect, he will forfeit all or nearly all of
`his investment. In one common form, the holder predicts whether a publicly-traded
`asset will be above or below a specific price at a specific time. The underlying
`referenced asset in a binary option can be a security, currency, or commodity.
`13. Spot Option offered binary options based on all of these asset classes.
`Spot Option offered binary options based on the price of common stocks of many
`companies traded on United States exchanges, such as TEVA, Google, Coca-Cola,
`and Nike. Spot Options also offered binary options based on various indices of
`securities, such as the NASDAQ Composite and the Dow Jones Industrial Average.
`These binary options are referred to hereinafter as “security-based” binary options.
`14. Binary options in which the underlying financial asset is a security or
`securities within the meaning of Section 2(a)(1) of the Securities Act [15 U.S.C. §
`77b(a)(1)] and Section 3(a)(10) of the Exchange Act [15 U.S.C. § 78c(a)(10)]
`(including any group or index of securities) are themselves “securities” within the
`meaning of those provisions. The security-based binary options issued, offered, and
`sold by Spot Option were therefore securities.
`15. Under the Securities Act, any offer or sale of securities must be
`registered unless an exemption applies. None of the security-based binary options
`offered by Spot Option were registered with the SEC, and no exemption applied.
`16. Spot Option determined and structured the key terms of the binary
`options offered and sold through its platform. Specifically, Spot Option’s platform
`provided investors with a choice of: (a) several forms of binary option; (b) numerous
`reference assets from multiple asset classes, including securities; (c) various
`expirations; (d) the investment amount; and (e) whether to predict the price of the
`reference asset would go up (e.g., buy a “call” option) or go down (e.g., buy a “put”
`option). Spot Option also set the amounts investors would receive for winning trades
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`or would forfeit for losing trades (i.e., the profit/loss ratio), sometimes with the input
`of the Partners.
`17. Spot Option structured the profit/loss ratio so that on any one trade
`investors always risked losing more money on an incorrect prediction than they stood
`to gain on a correct prediction. Spot Option typically set the ratio at a 70% to 85%
`profit for correct predictions and a 90% to 100% loss for incorrect predictions.
`Defendants knew that this payout structure made it extremely difficult if not
`impossible for investors to trade Spot Option’s binary options profitably over time
`because, on average, investors only won half of their trades.
`Investors purchased binary options by accessing Spot Option’s trading
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`platform via a Partner website and choosing among the binary options offered.
`Generally, the investor then chose an underlying asset for the binary option, and the
`trading platform displayed that asset’s historical prices and current price through a
`price ticker updated in real time. The platform also displayed the percentage profit
`for correct predictions and the dollar amount of the return based on the amount of a
`specific investment. The investor then chose an available expiration and predicted
`whether, on expiration, the asset would be above or below the price at the time of
`purchase.
`19. Typically, after the investor selected the parameters for the option, the
`investor executed the trade by clicking a button labelled “Apply,” and/or “Approve.”
`At this juncture, the investor was immediately and irrevocably committed to the
`purchase of the binary option.
`20. Spot Option provided its Partners with the image shown below as an
`example of what investors would see when accessing Spot Option’s platform through
`the Partner website:
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`In this example, at about 9:00 am on a 24-hour clock format, the investor
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`is looking at information on four binary options where the underlying assets are:
`TADAWUL, the Saudi Arabian stock exchange, DUBAI, the Dubai stock exchange,
`TEVA, a pharmaceutical company with stock trading on the New York Stock
`Exchange, and the Tel Aviv stock exchange. The investor has chosen to view
`detailed information on the binary option based on the Dubai stock exchange. The
`detailed information includes a graph tracking the recent Dubai exchange level and
`showing the level at 2099.73. The investor has the option to predict whether the level
`of the Dubai exchange will be above (“Put”) or below (“Call”) 2099.73 by 9:30 am.
`If the investor chooses to invest the default amount, which is $25, and makes a
`correct prediction, the investment will pay $44 (a $19 profit). If the investor makes
`an incorrect prediction, the investor will lose the $25.
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`I.
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`Spot Option’s Partners.
`22. Spot Option developed and provided its Partners with a turnkey package
`of products, software, and services that included nearly all of the tools necessary to
`offer and sell Spot Option’s security-based and other binary options online to anyone.
`23. Spot Option advertised to potential Partners that its package “generates
`great revenues with minimal efforts” and that it would enable Partners, under their
`own brand names, to operate an online business selling binary options in as little as
`four to six weeks. Spot Option described what if offered as a “business in a package”
`that allowed Partners to succeed “without doing the work.” Spot Option similarly
`said that its package “generates great revenues with minimal efforts as most of the
`work is done by the Spot Option team.” Spot Option also touted to prospective
`Partners the profitability of the business by noting that the average investor lost 80%
`of their investment within five months.
`24. Spot Option offered this turnkey package to its Partners under so-called
`“White Label” agreements. Under these agreements, Spot Option provided: (1) a
`customized, “user-friendly,” website resembling the website of a legitimate broker
`and that allowed investors to access Spot Option’s trading platform; (2) website
`content including charts, graphs, chat features, news and tutorials for retail investors;
`(3) content management system or “CMS” software that allowed the brokers to create
`and edit content on their websites; (4) hosting and management of the Partners’
`websites; (5) customer relationship management or “CRM” software; (6) third-party
`payment processing services linked to its trading platform that allowed investors to
`make deposits by credit card; (7) risk management services, which Spot Option
`provided twenty-four hours a day, seven days a week, and described as “the core of
`the business;” (8) training on all aspects of Spot Option’s turnkey package, including
`how to market binary options to retail investors; (9) assistance with affiliate
`marketing which generated investor leads for the brokers; (10) iPhone and Android
`applications for Spot Option’s trading platform; (11) miscellaneous back office
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`systems and ongoing support to resolve technical or other problems with any Spot
`Option product or service; and (12) a dedicated Spot Option account manager to
`ensure the brokers’ businesses were “running smoothly.”
`Investors accessed Spot Option’s trading platform through the Partners’
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`websites. Many of the Partners’ websites were hosted on Spot Option’s server space,
`and all were connected through the internet to the servers hosting Spot Option’s
`trading platform.
`26. Spot Option’s Partners used various brand names, such as “Bloombex
`Options,” “Lbinary,” “Ivory Option,” “SpotFN,” and “Banc de Binary” and claimed
`in advertising materials that it offered and sold binary options through more than 300
`Partners.
`27. Because it relied on Partners to drive traders to its platform, under the
`White Label agreements, Spot Option required its Partners to use their best efforts to
`“advertise, market, and promote” their websites and Spot Option’s “trading platform
`as widely as possible.” The agreement also required the Partners to pay Spot Option
`an initial, fixed startup-fee and a monthly fee, which generally was calculated as a
`percentage of the total amount of monies that investors deposited in a month less the
`monies that Partners returned to investors in that same month.
`II.
`Spot Option Trained its Partners to Recruit Investors, Including with
`False Statements; It Created False Advertising for its Partners.
`28. Reliant on the Partners to bring investors to its platform, Spot Option
`trained its Partners on how to recruit and retain investors.
`29. Spot Option gave a “welcome package” to new Partners that included
`written training materials and sales scripts for the employees at the Partners’ call
`centers. It also offered its Partners and their employees, through the “Spot Option
`Academy,” in-person and online training on how to recruit and retain investors.
`30. Spot Option’s “welcome package” included a template for how to
`structure a “call center” to solicit investors by telephone and email. The template
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`explained that a call center should include “conversion employees,” whose job was to
`convince investors to deposit funds, and “retention employees,” whose job was to
`increase the “value” of existing investors by persuading them to deposit as much as
`possible and by encouraging them to trade. Spot Option’s template also included
`formulas for compensating call center employees and the terms of employee bonuses
`(including a commission structure based on investor deposits minus withdrawals).
`31. Spot Option trained Partners’ on the “pros and cons” of various
`marketing techniques, including “affiliate marketing,” “Pay-per-Click” advertising,
`“Google Adwords,” web-banners, and search engine optimization.
`32. Spot Option supported its Partners’ solicitation efforts by providing them
`with scripts that endorsed high pressure sales tactics and included false statements.
`Among other things, Spot Option’s scripts instructed the Partners’ call center
`employees to tell investors that most traders earned thousands of dollars a month
`trading binary options. For example, a Spot Option training script provided:
`Most <Brand Name> clients produce an income of 1000s of $ / month, just
`from trading in their spare time on our simple, efficient, and comprehensive
`platform.
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`Most of our clients activate their trading account with a small deposit of 4-
`5,000$ to start learning how to trade and supplement, and in some cases
`replace, their income stream.
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`33. The script also instructed Partner call center employees to convince
`investors that the Partner’s employees and training material could teach the investor
`to make correct predictions:
`Using a range of simple tools provided by <Brand Name>, you can correctly
`predict market movements due to imminently occur, allowing you to gain
`returns of up to 85%, in as quickly as 60 seconds.
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`[P]revious knowledge is not required - we provide all the tools and guidance to
`become a successful trader.
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`After learning everything required for trading from our experts and educational
`materials, our clients started to comfortably trade and make a lot of money.
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`[Y]ou can correctly predict market movements due to imminently occur,
`allowing you to gain returns of up to 85% in as quickly as 60 seconds[.]
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`34. Spot Option’s script also instructed Partner call center employees to tell
`investors that any profits they had made were likely to continue. For example:
`Sir, as you can see, you have made 50% return on your fund investment, within
`only 2 days. This means you can make 150% a week, 600% a month! If you
`leverage your investment by 10 and increase your fund to be 5,000$, think of
`how much money you would have made by now?!
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`I wouldn’t recommend that you reduce your fund. You have succeeded to earn
`XX% in X short period. Doing so, will decrease your chances to continue
`making such an amazing income.
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`35. The scripts even instructed Partners’ call center employees to tell
`investors that “[b]inary options are a great way to make faster money with lower
`risk.”
`36. Not only did Spot Option train its Partners to make false statements to
`investors, it created misleading advertisements for them. For example, Spot Option
`created and disseminated video advertisements stating that “Binary options are the
`fastest and most efficient way to convert your financial decisions into substantial
`profits.”
`37. All of the statements identified in paragraphs 32 through 36 were false
`or misleading. Trading Spot Option’s security-based and other binary options was
`not a way – efficient, fast, or otherwise – to earn substantial profits; nor was it low
`risk. The typical Spot Option investor did not earn thousands of dollars a month, was
`not trained to make enough correct predictions, was not able to make a sufficient
`amount of profitable trades to earn a return on his or her investment, and, ultimately,
`lost most of his or her invested funds.
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`38. All of the above misrepresentations were material. A reasonable
`investor would consider the likely profitability of Spot Option’s security-based and
`other binary options highly relevant in determining whether to trade them.
`III. At Spot Option’s Instruction, the Partners Induced Investors to Trade
`More or Refrain from Withdrawing Funds by Offering an Illusory Bonus.
`39. Spot Option’s platform permitted Partners to offer investors a “bonus”
`pitched as a benefit to investors. In reality, the bonus’s purpose was to induce
`investors to make large deposits and then prevent them from withdrawing that
`money. Under the terms of the bonus, investors had to meet a “turnover
`requirement.” This meant that they could not withdraw any funds from their
`account—not even bonus funds—until they executed trades that totaled in value
`twenty-five times or more the value of the bonus. Because on any one trade, an
`investor always risked losing more money on an incorrect prediction than he could
`gain on a correct prediction, the increased volume of trades caused by the turnover
`requirement virtually guaranteed that investors lost most or all of their money before
`they even met the turnover requirement.
`40. The scripts that Spot Option provided to the Partners for use by their call
`center employees included statements on how to dissuade investors who had lost
`money from withdrawing any remaining funds. For example, one script instructed
`Partners to offer a bonus as a lure to encourage losing investors to make additional
`deposits. That script instructed the call centers employees to pitch the bonus as a way
`to “recover part of the los[s]es.”
`41. The statements that the bonus was beneficial or that it was a way for
`investors to recoup losses were false. The bonus was really a way to induce investors
`to make larger deposits and then prevent investors from ever withdrawing their funds.
`42. These statements were material. A reasonable investor would want to
`know the real reason the bonus was offered and that the bonus turnover requirements
`would likely cause the investor to incur greater losses.
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`IV. Spot Option Manipulated its Platform to Influence Investors’ Decisions
`and to Make it Easier or More Difficult for Specific Traders to Profit.
`43. One of the key services that Spot Option touted on its website and in its
`advertising to Partners was a service called “Risk Management.” Spot Option
`claimed to offer Partners “the most profit maximizing Risk Management available,”
`and that its Risk Management Services “ensured” the Brand’s “profitability.”
`44. Because the Partners’ profits and Spot Option’s fee came entirely from
`investor losses, Spot Option’s Risk Management Services was advertised as a means
`to “ensure” and “maximize” investor losses.
`45. Spot Option’s Risk Management Services allowed Spot Option, on its
`own initiative or as requested by the Partners, to designate investors as “low,”
`“medium,” or “high” risk. The risk setting was displayed to the Partners through the
`CRM software. When investors made too much money, Partners requested Spot to
`change the investor’s profile to “high risk” to make it more probable the investor’s
`future trades would lose money. As a Spot Option employee who worked in Risk
`Management explained to a Partner, changing an investor’s risk level to “high,”
`“should be more aggressive and reducing his profits in the soon future.”
`46. On November 17, 2014, for example, a Spot Option Risk Management
`employee informed a Partner that Spot Option’s system had placed a successful trader
`on the highest risk setting. “We are familiar with the client, he won some
`consecutive EUR/USD positions on Friday morning and won them all. Our system
`already put him with highest risk level. Let’s hope he will keep trading.” Spot
`Option’s Risk Management employees even provided Partners with updates on the
`losses incurred by investors whose risk level had been increased. For example, on
`April 22, 2014, an employee of Spot Option emailed an employee at one of its
`Partners stating: “He [the investor] lost 621$ in the last 6 days (16-22/4).
`Eventually, we believe the changes will do the work.”
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`47. Similarly, the Partners could request that an investor be placed on a low
`risk setting in the hopes that making profitable trades would induce reluctant
`investors to trade or trade more, or add additional funds to their account. For
`example, on July 10, 2014, an employee at a Partner asked his manager to “Please
`make sure he [investor] is on low risk. I feel he is loaded.” On October 13, 2014,
`another employee wrote, “please put [investor] on low risk until i resive [sic] more
`money from him.” On the same day, another employee wrote “put [investor] on low
`risk need to put more money tnx.” On June 26, 2015, to induce a particular investor
`to deposit more funds, a Partner emailed Spot Option, “I need this client off high risk
`because we are getting too many losses and looks bad.”
`Spot Option Never Appropriately Disclosed That Its Partners Only Made
`V.
`Money When The Investors Lost Money.
`48. Because the Partners’ compensation, and Spot Option’s fee, were
`dependent on investor losses, Spot Option closely monitored the Partners’
`performance and, more specifically, the level of investor losses.
`49. Spot Option generated periodic “Risk” and other reports in which it
`evaluated the Spot Option Partners’ performance, as a group and at times
`individually, on certain key aspects of their operations, which Spot Option referred to
`as “Key Performance Indicators” or “KPIs.” Generally, these reports showed for
`certain time periods, and among other things, how many new investors the Partners’
`had recruited, the amounts investors had deposited to and withdrawn from their
`trading accounts, the total dollar value of investor trading (which Spot Option
`referred to as “turnover”), and the total dollar value of investor losses. Spot Option
`sent Risk reports that included this data to Pini Peter and Amiran.
`50. Spot Option developed benchmarks for certain of the KPIs that it had
`identified, and it instructed its Partners to constantly monitor their KPIs and to meet
`the prescribed benchmarks to improve their profitability.
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`51. At times, Spot Option, through a dedicated Spot Option account
`manager, analyzed that Partner’s performance on certain KPIs, and reviewed that
`analysis with the Partner. In those reviews, Spot Option made suggestions for
`improvements, such as hiring an employee dedicated to mobile advertising or hiring a
`bulk email sender, and it instructed the Partners to meet the benchmarks that Spot
`Option had established.
`52. For example, one Spot Option account manager instructed a Partner that
`the ratio of first-time deposits to new deposits by existing investors “should be 30-
`70,” and its turnover should be seven to ten times the value of investor deposits,
`because that way, “[p]eople lose their money very fast.”
`53. Spot Option instructed another Partner that the average turnover “is 8-
`10,” meaning the total dollars traded should be eight to ten times the total value of
`investor deposits. Spot Option indicated that, in one month, the Partner’s turnover
`was only approximately four times the value of total investor deposits and, as a result,
`this month was “very bad” and the Partner should “[m]ake your customers trader [sic]
`more.”
`54. Spot Option also instructed its Partners not to allow investors to
`withdraw more than a small percentage of their deposits.
`55. The Partners, as a group, successfully achieved KPI benchmarks. Spot
`Option reports show that, for the period December 2014 through June 2016, on a
`monthly basis, investors across all Spot Option Partners withdrew only 18% to 25%
`of the total dollars that they deposited. These documents also show that the Partners’
`monthly net deposits (which represented investor losses and Partner revenue),
`correspondingly totaled approximately 75% to 82% of investors’ total deposits.
`Other Spot Option reports show that for the period January 2014 through September
`2017, on average, investors across all Spot Option Partners lost approximately 72%
`of their principal investments.
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`56. Spot Option and its Partners, however, failed to appropriately disclose to
`investors that the Partners were the counterparty on trades or that the Partners made
`money exclusively from investor losses.
`VI. Spot Option’s Partners Used the Fraudulent Techniques Spot Option had
`Trained them on to Offer and Sell Binary Options to U.S. Residents.
`57. The Partners used the fraudulent techniques Spot Option had trained
`them on to offer and sell Spot Option’s binary options to United States residents.
`58. For example, during the Relevant Period, a Partner using the brand
`names “BinaryBook” and “BigOption,” structured its call centers to comport with
`Spot Option’s call center template. Employees working in these call centers,
`including Lee Elbaz, Lissa Mel, Shira Uzan, Yair Hadar, Liora Welles, and Austin
`Smith (“Partner Employees”), told prospective investors that trading S