The SEC's Allegations Against Do Kwon and Terraform Just Keep On Coming

FOURTH CLAIM FOR RELIEF

Unregistered Offers and Sales of Securities Violation of Sections 5(a) and 5(c) of the Securities Act

182. The Commission re-alleges and incorporates by reference the allegations contained in paragraphs 1 through 172.

183. By virtue of the foregoing, Defendants, directly and indirectly: without a registration statement in effect as to that security, (a) made use of the means and instruments of transportation or communications in interstate commerce or of the mails to sell securities through the use or medium of any prospectus or otherwise; (b) carried or caused to be carried through the mails or in interstate commerce, by any means or instruments of transportation, any such security for the purpose of sale or for delivery after sale; and (c) made use of the means and instruments of transportation or communication in interstate commerce or of the mails to offer to sell through the use or medium of a prospectus or otherwise, securities as to which no registration statement had been filed.

184. By their conduct described above, Defendants violated, and unless restrained and enjoined will continue to violate, Sections 5(a) and 5(c) of the Securities Act, 15 U.S.C. § 77e(a) and 77e(c).