The Government hereby waives its right to file a response to the petition in this case, unless requested to do so by the Court.

While the SEC found that Petitioner had provided information that assisted SEC staff, it nonetheless found him ineligible due to his conviction for a criminal violation that was related to the SEC’s enforcement action.

Further, the SEC employed none of the well-established canons of statutory interpretation, including the Surplusage Canon.

Chief among them is that none of the facts contained in Petitioner’s charging instruments appear in Company-1’s and vice versa.

On this 29th day of March, 2023, I, Anthony G. Lantagne, hereby certify that this Petition for Writ of Certiorari was sent this same day FedEx 2nd Day Air to the Supreme Court of the United States.

I further certify that I have served this same date the required copies via USPS First Class Mail and email to the counsel of record listed below: Elizabeth B. Prelogar Solicitor General ofthe United States Room 5616 Department of Justice 950 Pennsylvania Avenue, NW Washington, DC 20530-0001 supremectbriefs@usdoj .gov I declare under penalty of perjury that the foregoing is true and correct.

Executed on this 29th day of March, 2023. ,

) ) to-wit: Anthony G. Lantagne appeared before me th11i§.S~ffi::-G6~ attested that the foregoing affidavit is .

e and and belief.

I, Anthony G. Lantagne, hereby certify that the above referenced Petition for Writ of Certiorari, as indicated by the word count feature of MS Word and including footnotes but excluding those parts enumerated for exclusion under the rules, contains 5,451 words.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on this 29th day of March, 2023.

Doe challenges the SEC's interpretation of two key terms in 15 U.S.C. § 78u-6(2)(B): “convicted” and “related to.” He argues that he was not “convicted” and that his criminal conduct was not “related to” the bribery scheme at issue in the Covered and Related Actions.

Instead, the SEC simply noted its longstanding interpretation of the term “convicted” as it addressed Doe's argument that his conviction was not “related to” the Covered and Related Actions.

Doe pleaded guilty to facilitating bribery payments that came from the same principal briber, targeted government officials in the same country, and sought benefits in the same industry as the scheme charged in the Covered and Related Actions.

Additionally, Claimant 1's information was derived from multiple sources that were not readily identified and accessed by members of the public without specialized knowledge, unusual effort, or substantial cost.

In determining the amount of the awards to Claimant 1, we considered the following factors set forth in Exchange Act Rule 21F-6 as they apply to the facts and circumstances of Claimant 1's application: (1) the significance of information; (2) the assistance provided; (3) the law enforcement interest in deterring violations by granting awards; (4) participation in internal compliance systems; (5) culpability; (6) unreasonable reporting delay; and (7) interference with internal compliance and reporting systems.

WHEREAS on February 3, 2025, Plaintiff filed a letter requesting that this action be closed; WHEREAS on February 4, 2025, the Court ordered the Defendants, Garnishees, and Interested Parties to advise as to whether they object to dismissing this case not later than February 11, 2025; and WHEREAS as of today, February 12, 2025, no objections have been filed.

IT IS HEREBY ORDERED that this case is DISMISSED.

The Clerk of the Court is respectfully directed to terminate the case.

United States District Judge

445-06 (PAE) Upon the application of the United States of America, with the consent of the undersigned counsel, and the defendant having requested discovery under Fed. R. Crim.

The Government will make disclosure to the defendant of documents, objects and information, including electronically stored information (“ESI”), pursuant to Federal Rule of Criminal Procedure 32.1 and the Government’s general obligation to produce exculpatory and impeachment material in criminal cases, all of which will be referred to herein as “Disclosure Material.” The Government’s Disclosure Material may include material that (i) affects the privacy, confidentiality and business interests of individuals and entities; (ii) would risk prejudicial pretrial publicity if publicly disseminated; (iii) may be produced with more limited redactions than would otherwise be necessary; and (iv) that is not authorized to be disclosed to the public or disclosed beyond that which is necessary for the defense of this criminal case.

Certain of the Government’s Disclosure Material, referred to herein as “Sealed Material,” contains information that identifies, or could lead to the identification of, witnesses who may be subject to intimidation or obstruction, and whose lives, persons, and 2023.11.26 property, as well as the lives, persons and property of loved ones, will be subject to risk of harm absent the protective considerations set forth herein.

Certain materials in this case raise a particular risk of affecting the privacy or safety of victims or witnesses.

Except for Disclosure Material that has been made part of the record of this case, the defense shall return to the Government or securely destroy or delete all Disclosure Material, 2023.11.26 including any ESI, within 30 days of the expiration of the period for direct appeal from any verdict in the above-captioned case; the period of direct appeal from any order dismissing any of the charges in the above-captioned case; and the granting of any motion made on behalf of the Government dismissing any charges in the above-captioned case, whichever date is later, subject to defense counsel’s obligation to retain client files under the Rules of Professional Conduct.