U.S. Securities and Exchange Commission v. C3 International, Inc.

I. INTRODUCTION

On September 28, 2021, plaintiff United States Securities and Exchange Commission (“SEC”) filed this action against defendants C3 International, Inc., (“C3”), Steele Clark Smith III (“Steele Smith”), and Theresa Smith (collectively, “defendants”). Dkt. 1 (“Compl.”). The complaint brings five claims for relief: (1) Fraud in Connection with the Purchase or Sale of Securities, in violation of Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”), 15 U.S.C. § 78)(b), and Rule 10b-5 thereunder, 17 C_F.R. § 240.10b-5 (against C3 and Steele Smith); (2) Fraud in the Offer or Sale of Securities in violation of Sections 17(a)(1), (2), and (3) of the Securities Act of 1933 (“Securities Act’), 15 U.S.C. §77(q)(a) (against C3 and Steele Smith); (3) Aiding and Abetting Violations of Section 17(a) of the Securities Act (against Theresa Smith): (4) Aiding and Abetting Violations of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder (against Theresa Smith); and (5) Unregistered Offer and Sale of Securities Violations of Sections 5(a) and 5(c) of the Securities Act (against all defendants). Id. 66-75. On January 7, 2022, after having received no…