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`Case 2:21-cv-01108 Document 1 Filed 08/18/21 Page 1 of 11
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF WASHINGTON
`
`SEATTLE DIVISION
`
`
`SECURITIES AND EXCHANGE COMMISSION,
`
`Plaintiff,
`
`v.
`
`SUNG MO JUN, JOON MO JUN, JUNWOO
`CHON, AYDEN LEE, and JAE HYEON BAE,
`
`Defendants.
`
`
`
`No. 2:21-cv-1108
`
`
`
`COMPLAINT
`
`
`
`
`
`
`
`
`
`Plaintiff Securities and Exchange Commission (the “SEC”) alleges:
`SUMMARY OF THE ACTION
`1.
`This action concerns a three-year scheme that netted over $3 million in illicit
`profits from insider trading in Netflix securities. From July 2016 to July 2019, the defendants
`misappropriated and traded on confidential Netflix subscriber information in advance of 13
`separate Netflix earnings announcements. The SEC brings the instant action to hold these
`defendants accountable for their violations of the federal securities laws.
`2.
`Defendant Sung Mo “Jay” Jun was at the center of the insider trading ring, both
`while he was employed as a software engineer at Netflix and after he left the company. During
`
`COMPLAINT
`SEC V. SUNG MO JUN ET AL. (NO. 2:21-cv-1108)
`
`1
`
`
`
`
`
`Securities and Exchange Commission
`44 Montgomery Street, Suite 2800
`San Francisco, California 94104
`(415) 705-2500
`
`

`

`Case 2:21-cv-01108 Document 1 Filed 08/18/21 Page 2 of 11
`
`
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`his employment at Netflix, Sung Mo Jun accessed material nonpublic information regarding
`Netflix’s subscriber growth—a key driver of the subscription-based video streaming company’s
`revenue and its success—in advance of four consecutive Netflix quarterly earnings
`announcements. From July 2016 through April 2017, Sung Mo Jun used this information to tip
`his brother, Joon Mo Jun, and his close friend, Junwoo Chon, to trade Netflix securities in
`advance of each quarterly earnings announcement. Joon Jun and Chon profitably traded Netflix
`securities based on that information, and Chon paid Sung Mo Jun $60,000 in cash from the
`profits he made by trading in Netflix securities.
`3.
`After Sung Mo Jun left Netflix, he continued to obtain confidential Netflix
`subscriber information from another Netflix insider, defendant Ayden Lee, who worked with
`Sung Mo Jun at Netflix and became his friend. From June 2017 through July 2019, Lee
`repeatedly tipped Sung Mo Jun with Netflix subscriber information. Sung Mo Jun traded ahead
`of, and tipped Joon Jun and Chon to trade ahead of, nine Netflix quarterly earnings
`announcements from June 2017 through July 2019.
`4.
`Sung Mo Jun’s former Netflix colleague, defendant Jae Hyeon Bae, returned to
`work at Netflix after Sung Mo Jun left the company. From at least February 2018 through July
`2019, Sung Mo Jun, Joon Jun, Chon, and Bae were participants in a group messaging channel
`(the “Messaging Channel”) they used to share stock trading tips. In July 2019, while he was
`employed with Netflix, Bae used the Messaging Channel to tip Joon Jun about Netflix’s
`subscriber information in advance of Netflix’s July 2019 earnings announcement. Joon Jun
`traded on Netflix securities based on that material, non-public information.
`5.
`In total, Sung Mo Jun, Joon Jun, and Chon netted over $3.1 million in illicit
`profits from trading Netflix securities based on material, non-public information provided by
`Netflix insiders Sung Mo Jun, Lee, and Bae from July 2016 through July 2019.
`JURISDICTION AND VENUE
`6.
`The SEC brings this action pursuant to Sections 21(d), 21(e), and 21A of the
`Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. §§ 78u(d), 78u(e), and 78u-1].
`
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`COMPLAINT
`SEC V. SUNG MO JUN ET AL. (NO. 2:21-cv-1108)
`
`2
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`
`
`
`
`Securities and Exchange Commission
`44 Montgomery Street, Suite 2800
`San Francisco, California 94104
`(415) 705-2500
`
`

`

`Case 2:21-cv-01108 Document 1 Filed 08/18/21 Page 3 of 11
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`
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`7.
`This Court has jurisdiction over this action pursuant to Sections 21(d), 21(e),
`21A, and 27 of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), 78u-1, and 78aa].
`8.
`Defendants, directly or indirectly, made use of the means or instruments or
`instrumentalities of transportation or communication in interstate commerce, or of the mails, or
`the facilities of a national securities exchange, in connection with the transactions, acts,
`practices, and courses of business alleged herein.
`9.
`Venue is proper in this District pursuant to Section 27 of the Exchange Act [15
`U.S.C. § 78aa]. Certain of the acts, practices, courses of business, and transactions constituting
`the violations alleged herein occurred within the Western District of Washington. Pursuant to
`LCR 3(e)(1), assignment to the Seattle Division is appropriate because a substantial part of the
`relevant conduct occurred in King County.
`DEFENDANTS
`Sung Mo “Jay” Jun, 49 years old, resides in Bellevue, Washington. Sung Mo
`10.
`Jun was employed as a software engineer at Netflix from December 2013 through February
`2017. After leaving Netflix, until late 2018, he was employed by a large technology company
`outside the United States. From approximately 2019 to 2020, Sung Mo Jun was a senior software
`engineer at a Seattle-area technology company.
`Joon Mo Jun, 45 years old, resides in Issaquah, Washington. Joon Jun and Sung
`11.
`Mo Jun are brothers.
`Junwoo Chon, 49 years old, resides in Bellevue, Washington. Chon is a close
`12.
`friend of Sung Mo Jun, and the two have known each other for approximately 20 years.
`Ayden Lee, 33 years old, resides in San Jose, California. From May 2016 to
`13.
`approximately February 2021, Lee was a software engineer at Netflix. Lee met Sung Mo Jun
`when interviewing for his position at Netflix and worked with him from May 2016 through
`February 2017. Lee considered Sung Mo Jun a mentor in their work at Netflix.
`Jae Hyeon Bae, 42 years old, resides in San Jose, California. Bae worked at
`14.
`Netflix as a software and data engineer during two periods: first between July 2012 and April
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`COMPLAINT
`SEC V. SUNG MO JUN ET AL. (NO. 2:21-cv-1108)
`
`3
`
`
`
`
`
`Securities and Exchange Commission
`44 Montgomery Street, Suite 2800
`San Francisco, California 94104
`(415) 705-2500
`
`

`

`Case 2:21-cv-01108 Document 1 Filed 08/18/21 Page 4 of 11
`
`
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`2015 and again from June 2017 through July 2019. Bae became friends with Sung Mo Jun
`during his first period working at Netflix and the two worked in the same group.
`RELEVANT ENTITY
`Netflix, Inc. is a Delaware corporation headquartered in Los Gatos, California.
`15.
`Netflix is a subscription-based video streaming service offering online TV shows and movies.
`Netflix’s common stock is registered with the Commission pursuant to Section 12(b) of the
`Exchange Act and is listed on NASDAQ under the ticker “NFLX.”
`FACTUAL ALLEGATIONS
`A. Netflix Subscriber Information Is Material and Confidential Company
`Information.
`16.
`During the entire relevant period for this action, July 2016 through July 2019,
`Netflix’s revenue growth largely depended on increasing the number of customers who
`purchased subscriptions. As the company and investors recognized, subscriber performance
`numbers, which Netflix announced in its quarterly earnings releases, was material information.
`17.
`Netflix makes its periodic subscriber numbers available to its employees through
`its intranet on an ongoing basis. Netflix treats the subscriber numbers as confidential information
`according to its company policies, including its insider trading policy, which all employees must
`acknowledge. That insider trading policy prohibits Netflix employees from trading Netflix
`securities based upon material nonpublic information, and further prohibits its employees from
`making recommendations or expressing opinions about trading in Netflix securities based upon
`such information.
`B. July 2016 to April 2017: Netflix Insider Sung Mo Jun Tips Material Nonpublic
`Netflix Subscriber Information to Joon Jun and Chon.
`18. While employed at Netflix, Sung Mo Jun had access from at least July 2016
`through February 2017 to confidential Netflix subscriber information in advance of Netflix’s
`earnings announcements. Sung Mo Jun knew, or was reckless in not knowing, he owed Netflix a
`duty to keep that material nonpublic information confidential, and that he was prohibited from
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`COMPLAINT
`SEC V. SUNG MO JUN ET AL. (NO. 2:21-cv-1108)
`
`4
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`
`
`
`Securities and Exchange Commission
`44 Montgomery Street, Suite 2800
`San Francisco, California 94104
`(415) 705-2500
`
`

`

`Case 2:21-cv-01108 Document 1 Filed 08/18/21 Page 5 of 11
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`using that information to trade Netflix securities or from sharing that information with anyone
`else for purposes of trading Netflix securities.
`19.
`From at least July 2016 through February 2017, in violation of his duties to
`Netflix, Sung Mo Jun tipped Joon Jun and Chon about Netflix’s material nonpublic subscriber
`information in advance of Netflix earnings announcements. Sung Mo Jun did so with the
`expectation that Joon Jun and Chon would trade in Netflix securities based on that material
`nonpublic subscriber information. Sung Mo Jun’s tips to Joon Jun and Chon were gifts of
`confidential information to his trading relative and friend, and Sung Mo Jun further benefitted
`through cash payments out of the trading proceeds.
`20.
`Joon Jun and Chon knew, or were reckless it not knowing, that Sung Mo Jun was
`breaching the duties he owed to his employer by giving them inside information and understood
`it was improper for them to trade Netflix securities based upon the material non-public
`subscriber information that Sung Mo Jun provided to them. Nonetheless, acting in coordination
`with each other and with Sung Mo Jun, Joon Jun and Chon traded Netflix securities in advance
`of Netflix’s quarterly earnings announcements based upon that material nonpublic subscriber
`information in July 2016, October 2016, January 2017, and April 2017.
`21.
`On many occasions during that period, Joon Jun and Chon placed trades minutes
`apart for identical Netflix options contracts. A stock options contract gives the owner the right to
`buy or sell a stock at a fixed price, known as the strike price, on or before a specified date,
`known as the expiration date. A “call” option contract typically gives the owner the right to
`purchase 100 shares of the underlying stock at a strike price for a specified period of time. A
`“put” option contract gives the owner the right to sell 100 shares of the underlying stock at a
`strike price for a specified period of time.
`22.
`Although Sung Mo Jun ended his employment with Netflix in February 2017, he
`accessed material nonpublic Netflix subscriber information relating to the first quarter of 2017
`before he left Netflix and tipped that information to Joon Jun and Chon for purposes of trading
`Netflix securities in advance of Netflix’s earnings announcement in April 2017. In further
`violation of his duties to Netflix, Sung Mo Jun also personally traded in Netflix securities in
`
`COMPLAINT
`SEC V. SUNG MO JUN ET AL. (NO. 2:21-cv-1108)
`
`5
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`
`
`
`Securities and Exchange Commission
`44 Montgomery Street, Suite 2800
`San Francisco, California 94104
`(415) 705-2500
`
`

`

`Case 2:21-cv-01108 Document 1 Filed 08/18/21 Page 6 of 11
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`advance of Netflix’s April 2017 quarterly earnings announcement based on the material
`nonpublic Netflix subscriber information he had accessed while he was a Netflix employee.
`23.
`Sung Mo Jun, Joon Jun, and Chon communicated about their Netflix trading
`activities through an encrypted messaging application to evade detection. Joon Jun made
`approximately $215,000 and Chon made approximately $521,000 in profits from trading Netflix
`securities based on the material nonpublic Netflix subscriber information in advance of Netflix’s
`quarterly earnings announcements in July 2016, October 2016, January 2017, and April 2017.
`Chon paid Sung Mo Jun $60,000 in cash from his trading profits in return for the material
`nonpublic Netflix information Sung Mo Jun had provided him.
`C. June 2017 to July 2019: Netflix Insider Ayden Lee Tips Sung Mo Jun, Who
`Then Trades and Tips Joon Jun and Chon.
`24.
`Lee met Sung Mo Jun while interviewing for a position at Netflix in 2016. When
`Lee joined the company in May 2016, he worked in the same group as Sung Mo Jun.
`25. While employed at Netflix, Lee had access to confidential Netflix subscriber
`information. Lee received and acknowledged Netflix’s insider trading policy when he began his
`employment, and he knew, or was reckless in not knowing, that he owed Netflix a duty to keep
`material nonpublic information such as Netflix’s subscriber information confidential. Lee further
`knew, or was reckless it not knowing, that he was prohibited from using that information to trade
`Netflix securities and from sharing that information with anyone else for purposes of trading
`Netflix securities.
`26.
`After Sung Mo Jun left Netflix in February 2017, he repeatedly asked Lee to
`provide him the confidential Netflix subscriber information that Sung Mo Jun had directly
`accessed while he was employed at Netflix. Lee viewed Sung Mo Jun as a mentor and friend.
`Therefore, in violation of his duties to Netflix, Lee repeatedly provided Netflix’s confidential,
`internal subscriber information to Sung Mo Jun between June 2017 and July 2019. Lee
`understood that Sung Mo Jun would use the material nonpublic information for the purpose of
`trading Netflix securities. Lee tipped this information as gifts of confidential information to a
`friend.
`
`COMPLAINT
`SEC V. SUNG MO JUN ET AL. (NO. 2:21-cv-1108)
`
`6
`
`
`
`
`
`Securities and Exchange Commission
`44 Montgomery Street, Suite 2800
`San Francisco, California 94104
`(415) 705-2500
`
`

`

`Case 2:21-cv-01108 Document 1 Filed 08/18/21 Page 7 of 11
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`27.
`Sung Mo Jun knew, or was reckless in not knowing, Lee was breaching the duties
`he owed to Netflix by giving him inside information, and that it was improper for Sung Mo Jun
`to trade in Netflix securities or tip others for trading based upon that information.
`28.
`From June 2017 through July 2019, Sung Mo Jun passed on the material
`nonpublic Netflix information he received from Lee to Joon Jun and Chon for the purpose of
`trading in Netflix securities. Joon Jun and Chon knew, or were reckless in not knowing, Sung
`Mo Jun had obtained the subscriber information from Lee, a Netflix insider and Sung Mo Jun’s
`former mentee. Joon Jun and Chon also knew, or were reckless in not knowing, that Lee was
`breaching his duties to his employer by giving Sung Mo Jun the inside information, and that it
`was improper for them to trade in Netflix securities based on that information. From June 2017
`through July 2019, Sung Mo Jun made approximately $453,000, Joon Jun made approximately
`$813,000, and Junwoo Chon made approximately $1.1 million trading in advance of nine
`consecutive Netflix earnings announcements.
`D. Jae Hyeon Bae Tips Joon Jun In Advance of the July 2019 Netflix Earnings
`Announcement.
`29. While he was employed at Netflix, Sung Mo Jun also met and worked in the same
`group as Bae, another software engineer at Netflix, and the two became friends. During his
`employment at Netflix, Bae had access to confidential Netflix subscriber information. Bae
`received and acknowledged Netflix’s insider trading policy when he began his employment, and
`he knew, or was reckless in not knowing, he owed Netflix a duty to keep material nonpublic
`information such as Netflix’s subscriber information confidential. Bae further knew, or was
`reckless in not knowing, that he was prohibited from using that information to trade Netflix
`securities and from sharing that information with anyone else for purposes of trading Netflix
`securities.
`30.
`In February 2018, Bae joined a Messaging Channel, called “Rage Against the
`Market,” hosted on a popular business communication platform, that also included Sung Mo Jun,
`Joon Jun, and Chon. The Messaging Channel was used to discuss stock trading as well as social
`
`
`COMPLAINT
`SEC V. SUNG MO JUN ET AL. (NO. 2:21-cv-1108)
`
`7
`
`
`
`
`
`Securities and Exchange Commission
`44 Montgomery Street, Suite 2800
`San Francisco, California 94104
`(415) 705-2500
`
`

`

`Case 2:21-cv-01108 Document 1 Filed 08/18/21 Page 8 of 11
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`information. Bae, Sung Mo Jun, and Joon Jun communicated on the Messaging Channel, and
`Bae hoped to obtain information on the Messaging Channel that would help him make money
`trading securities.
`31.
`Just prior to Netflix’s quarterly earnings announcement in July 2019, Joon Jun
`used the Messaging Channel to ask Bae for his opinion about Netflix’s performance. Bae
`understood this request related to trading in Netflix securities, and told Joon Jun that he should
`sell Netflix shares. Bae did so based on his knowledge of Netflix’s confidential subscriber
`information, which he understood to be below analyst’s then-current expectations. Bae knew, or
`was reckless in not knowing, that he was violating his duties to Netflix by making this
`recommendation to Joon Jun. Bae tipped this information as a gift of confidential information to
`a trading friend and in order to preserve the opportunity to access information through the
`Messaging Channel that could yield future gain.
`32.
`Joon Jun understood that Bae was employed at Netflix, that Bae’s
`recommendation was based on his knowledge of Netflix’s confidential subscriber information,
`and that Bae was breaching his duties to his employer by giving Joon Jun the inside information.
`Joon Jun further understood that it was improper for him to trade Netflix securities based upon
`that recommendation. Nonetheless, based on the tip from Bae, along with the material nonpublic
`Netflix information Sung Mo Jun had obtained from Lee and tipped to Joon Jun, Joon Jun traded
`Netflix securities in advance of Netflix’s July 2019 earnings announcement and generated illegal
`profits of $72,875.
`
`TOLLING AGREEMENTS
`33.
`In May 2021, Defendants Sung Mo Jun, Joon Jun, and Chon each signed tolling
`agreements with the Commission. Each tolling agreement specifies a period of time (a “tolling
`period”) in which the “running of any statute of limitations applicable to any action or
`proceeding against [the defendant] authorized, instituted, or brought by or on behalf of the
`Commission or to which the Commission is a party arising out of the investigation (‘any
`proceeding’), including any sanctions or relief that may be imposed therein, is tolled and
`suspended for the period beginning on May 21, 2021 through July 20, 2021 ….” Each tolling
`
`COMPLAINT
`SEC V. SUNG MO JUN ET AL. (NO. 2:21-cv-1108)
`
`8
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`
`
`
`Securities and Exchange Commission
`44 Montgomery Street, Suite 2800
`San Francisco, California 94104
`(415) 705-2500
`
`

`

`Case 2:21-cv-01108 Document 1 Filed 08/18/21 Page 9 of 11
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`agreement further provides that the defendant and any of his agents or attorneys “shall not
`include the tolling period in the calculation of any running of the statute of limitations or for any
`other time-related defense applicable to any proceeding, including any sanctions or relief that
`may be imposed therein, in asserting or relying upon any such time-related defense.”
`FIRST CLAIM FOR RELIEF
`Violations of Section 10(b) of the Exchange Act and Rule 10b-5 Thereunder
`(Against Defendants Sung Mo Jun, Joon Jun, Junwoo Chon, Ayden Lee,
`and Jae Hyeon Bae)
`34. The SEC realleges and incorporates by reference paragraphs 1 through ____, as
`though fully set forth herein.
`35. By engaging in the conduct described above, Defendants Sung Mo Jun, Joon Jun,
`Junwoo Chon, Ayden Lee, and Jae Hyeon Bae, in connection with the purchase or sale of
`securities, directly or indirectly, by the use of the means or instrumentalities of interstate
`commerce, or of the mails, or of the facilities of a national securities exchange, with scienter:
`(a)
`employed devices, schemes, or artifices to defraud;
`(b)
`made untrue statements of material fact or omitted to state material facts
`necessary in order to make the statements made, in the light of the circumstances
`under which they were made, not misleading; and/or
`engaged in acts, practices, or courses of business which operated or would operate
`as a fraud or deceit upon other persons, including purchasers and sellers of
`securities.
`36. By engaging in the foregoing conduct, Defendants Sung Mo Jun, Joon Jun,
`Junwoo Chon, Ayden Lee, and Jae Hyeon Bae each violated Section 10(b) of the Exchange Act
`[15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].
`
`
`
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`
`
`(c)
`
`COMPLAINT
`SEC V. SUNG MO JUN ET AL. (NO. 2:21-cv-1108)
`
`9
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`
`
`
`Securities and Exchange Commission
`44 Montgomery Street, Suite 2800
`San Francisco, California 94104
`(415) 705-2500
`
`

`

`Case 2:21-cv-01108 Document 1 Filed 08/18/21 Page 10 of 11
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`PRAYER FOR RELIEF
`WHEREFORE, the SEC respectfully requests that this Court enter a judgment:
`I.
`Finding that each of Defendants Sung Mo Jun, Joon Jun, Junwoo Chon, Ayden Lee, and
`Jae Hyeon Bae committed the violations alleged herein;
`II.
`Permanently enjoining Defendants Sung Mo Jun, Joon Jun, Junwoo Chon, Ayden Lee,
`and Jae Hyeon Bae from directly or indirectly violating Section 10(b) of the Exchange Act [15
`U.S.C. § 78j(b)], and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5];
`III.
`Ordering Defendants Sung Mo Jun, Joon Jun, Junwoo Chon, Ayden Lee, and Jae Hyeon
`Bae each to pay a civil penalty pursuant to Section 21A of the Exchange Act [15 U.S.C. § 78u-l];
`IV.
`Barring Defendant Sung Mo Jun, pursuant to Section 21(d)(2) of the Exchange Act [15
`U.S.C. § 78u(d)(2)], from acting as an officer or director of any issuer that has a class of
`securities registered pursuant to Section 12 of the Exchange Act [15 U.S.C. § 78l] or that is
`required to file reports pursuant to Section 15(d) of the Exchange Act [15 U.S.C. § 78o(d)];
`V.
`Retaining jurisdiction of this action in accordance with the principles of equity and the
`Federal Rules of Civil Procedure in order to implement and carry out the terms of all orders and
`decrees that may be entered, or to entertain any suitable application or motion for additional
`relief within the jurisdiction of this Court; and
`
`
`
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`COMPLAINT
`SEC V. SUNG MO JUN ET AL. (NO. 2:21-cv-1108)
`
`10
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`
`
`
`
`Securities and Exchange Commission
`44 Montgomery Street, Suite 2800
`San Francisco, California 94104
`(415) 705-2500
`
`

`

`Case 2:21-cv-01108 Document 1 Filed 08/18/21 Page 11 of 11
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`VI.
`Granting such other and further relief as this Court may deem just, equitable, and
`necessary.
`Dated: August 18, 2021
`
`Respectfully submitted,
`
`
`s/Rahul Kolhatkar
`
`
`
`Rahul Kolhatkar (Conditionally Admitted
`Pursuant to LCR 83.1(c)(2))
`Securities and Exchange Commission
`44 Montgomery Street, Suite 2800
`San Francisco, California 94104
`Telephone: (415) 705-2500
`Facsimile: (415) 705-2501
`Email: kolhatkarr@sec.gov
`Attorney for Plaintiff Securities and
`Exchange Commission
`
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`COMPLAINT
`SEC V. SUNG MO JUN ET AL. (NO. 2:21-cv-1108)
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`11
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`Securities and Exchange Commission
`44 Montgomery Street, Suite 2800
`San Francisco, California 94104
`(415) 705-2500
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