SEC: Terraform Labs Knowingly or Recklessly, Employed Devices, Schemes, or Artifices to Defraud

SECOND CLAIM FOR RELIEF

Fraud in Connection with the Purchase or Sale of Securities (Violations of Section 10(b) of the Exchange Act and Rule 10b-5 Thereunder)

176. The Commission re-alleges and incorporates by reference the allegations contained in paragraphs 1 through 172. 177. By reason of the conduct described above, Defendants, directly or indirectly, in connection with the purchase or sale of securities, by the use of the means or instrumentalities of interstate commerce or of the mails, or of any facility of any national securities exchange, knowingly or recklessly, (i) employed devices, schemes, or artifices to defraud; (ii) made untrue statements of a material fact or omitted to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading; and (iii) engaged in acts, practices, or courses of business which operated or would operate as a fraud or deceit upon any persons, including purchasers of the securities.

178. By reason of the conduct described above, Defendants violated, and unless restrained and enjoined will continue to violate, Exchange Act Section 10(b), 15 U.S.C. § 78j(b), and Rule 10b-5, 17 C.F.R. § 240.10b-5, thereunder.