Following the filing of a criminal complaint in February 2019, a federal grand jury in New Jersey returned a twelve-count indictment against Gene Levoff for securities and wire fraud. The government alleges that Levoff, who served as Senior Director of Corporate Law for a global technology company in California, orchestrated a scheme to defraud his employer and its shareholders by misappropriating and trading on material nonpublic information about the company’s financial results over a period of five years, gaining $227,000 and avoiding losses of approximately $377,000. Levoff’s responsibilities in the corporate law department included ensuring compliance with the securities laws and the company’s insider trading policy. As a member of the Disclosure Committee, Levoff had access to draft SEC filings and earnings materials. He was subject to blackout periods that prohibited him from engaging in trades involving the company’s stock in advance of public disclosure of earnings reports, and yet he executed the favorable trades during the blackout periods. According to the government’s allegations, Levoff’s conduct violated his employer’s insider trading policy, his fiduciary duty, 15 USC §§ 78j(b), 78ff, 17 CFR §§ 240.10b-5 and 240.10b5-2, as well as 18 USC §§ 1343 and 2.