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No. 1 COMPLAINT against Manish Lachwani

Document Securities and Exchange Commission v. Lachwani, 5:21-cv-06554, No. 1 (N.D.Cal. Aug. 25, 2021)
Complaint
From at least 2018 through 2020, Manish Lachwani engaged in a fraudulent scheme to propel the valuation of his Silicon Valley technology start-up, HeadSpin, Inc., to over $1 billion by falsely inflating the company’s key financial metrics and doctoring its internal sales records.
To create the illusion of strong and consistent growth, Lachwani, who controlled all important aspects of HeadSpin’s financials and sales operations, falsely inflated the values of numerous customer deals that, in reality, were much smaller.
He made numerous false statements that were designed to convince investors that HeadSpin had hundreds of customers, including many of Silicon Valley’s biggest and most high-profile companies, signed up to long-term contracts totaling tens of millions of dollars per year.
Defendant, by engaging in the conduct described above, directly or indirectly, in connection with the purchase or sale of securities, by use of means or instrumentalities of interstate commerce, or of the mails, with scienter: a. Employed devices, schemes, or artifices to defraud; b.
Defendant, by engaging in the conduct described above, directly or indirectly, in the offer or sale of securities, by use of the means of instruments of transportation or communication in interstate commerce or by use of the mails, a. with scienter, employed devices, schemes, or artifices to defraud;
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No. 25 CASE MANAGEMENT STATEMENT and Proposed Order filed by Securities and Exchange Commission

Document Securities and Exchange Commission v. Lachwani, 5:21-cv-06554, No. 25 (N.D.Cal. Dec. 27, 2021)
Bar No. 217853) CLARENCE DYER & COHEN LLP 899 Ellis Street San Francisco, California 94109 Attorneys for Defendant Manish Lachwani
The SEC alleges that Defendant engaged in the fraudulent offer and sale of securities issued by the Silicon Valley- based technology start-up company HeadSpin, Inc. (“HeadSpin”), which he co-founded and led as the Chief Executive Officer.
To create the illusion of strong and consistent growth, Defendant, who controlled all important aspects of HeadSpin’s financials and sales operations, falsely inflated the values of numerous customer deals that, in reality, were much smaller.
Defendant knowingly or recklessly made numerous false and misleading statements about HeadSpin’s valuation, its seeming financial success, and its customer base to prospective investors.
On September 22, 2021, the Court granted the parties’ stipulation and ordered that the parties could begin issuing subpoenas pursuant to Federal Rule of Civil Procedure 45 to non-parties.
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No. 18

Document Securities and Exchange Commission v. Lachwani, 5:21-cv-06554, No. 18 (N.D.Cal. Sep. 22, 2021)

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