I’m getting 100’s or people ringing me from all over the world thinking that I know what the latest update is within Traffic Monsoon…
I am in the same position as you…I hope no one gets to lose their money…
Its in my interest to help everyone in my team get the the latest Traffic Monsoon Update and all I got so far is the report below…
My Sponsor IMY ASLAM has removed me from the Traffic Monsoon Skype group for whatever reason he may have for that…Imy Aslam hasn’t had the courtesy to even call me with any Traffic Monsoon Updates over the last 7 months…
The last time I spoke to Imy Aslam was when I called him over 6 months ago when I complained to him about the way I was treated by another affiliate called Anita Langley at
a Traffic Monsoon event back towards the end of 2015…
I’m very disappointed in the way that I have been treated by my Sponsor Imy Aslam and Anita Langley…
Daniel J. Wadley (10358)
Amy J. Oliver (8785)
Alison J. Okinaka (7954)
Cheryl M. Mori (8887)
Attorneys for Plaintiff Securities and Exchange Commission
351 South West Temple, Suite 6.100
Salt Lake City, Utah 84101
IN THE UNITED STATES DISTRICT COURT
DISTRICT OF UTAH
SECURITIES AND EXCHANGE
TRAFFIC MONSOON, LLC, a Utah Limited
Liability Company, and CHARLES DAVID
SCOVILLE, an individual,
Case No.: 2:16-cv-00832-DB
Judge Dee Benson
Plaintiff, Securities and Exchange Commission (the “Commission”), for its Complaint
against Defendants Traffic Monsoon, LLC and Charles David Scoville (collectively,
“Defendants”) alleges as follows:
1. This matter involves an ongoing Ponzi scheme and offering fraud operated by
Charles David Scoville (“Scoville”) and Traffic Monsoon, LLC (“Traffic Monsoon”),
Case headquartered in Murray, Utah. Scoville formed Traffic Monsoon in October 2014.
2. Since inception, defendants have taken in from investors approximately $207
million in sales of a product called the “Banner AdPack” (“AdPack”). Over 162,000 investors
throughout the world have invested in AdPacks. As of the beginning of 2016, Traffic Monsoon
was taking in approximately $25 million in cash each month.
3. Defendants solicit investors through Traffic Monsoon’s website and through
YouTube videos featuring Charles Scoville. The website states that Traffic Monsoon’s mission is “to
provide high quality ad services for affordable prices, and share revenues for a perfect winning
combination that will lead to the ultimate success of our customers.”
4. Defendants market Traffic Monsoon as a successful Internet advertising services
company. They represent that it is a combination of an Internet traffic exchange, where users
browse each others’ websites, and a pay-per-click program, where users are paid to click on
others’ website banner ads. Defendants represent that its profit is derived from seven different
highly desirable advertising products.
5. In reality, Traffic Monsoon’s advertising business is a illusion designed to
obscure the fact that it is offering and selling a security in a pure Ponzi scheme. Over 99% of
Traffic Monsoon’s revenue comes from the sale of AdPacks. The company has virtually no
other revenue from any other source. All payments to investors are made out of these funds.
6. On an ongoing basis, Traffic Monsoon and Charles Scoville are violating the antifraud
provisions of the federal securities laws, Sections 17(a)(1) and (3) of the Securities Act of 1933
(“Securities Act”) and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”),
and Rules 10b-5(a) and (c) thereunder; and the registration provisions of Sections 5(a) and 5(c)
of the Securities Act.
7. In order to halt the ongoing fraud being perpetrated on investors, the Commission
seeks a civil injunctive order against Traffic Monsoon and Charles Scoville against further violations of
the federal securities laws, as well as disgorgement, prejudgment interest and civil penalties from
Traffic Monsoon and Charles Scoville. The Commission also seeks emergency relief in the form of an
ex parte temporary restraining order, a preliminary injunction, an ex parte asset freeze and order
appointing a receiver over Traffic Monsoon and its customer funds, and the funds of Scoville,
and an order prohibiting the destruction of documents, accelerating discovery, and requiring an
JURISDICTION AND VENUE
8. This Court has subject matter jurisdiction by authority of Sections 20 and 22 of
the Securities Act [15 U.S.C. §§ 77t and 77v] and Sections 21 and Section 27 of the Exchange
Act [15 U.S.C. §§ 78u and 78aa].
9. Defendants, directly and indirectly, singly and in concert, have made use of the
means and instrumentalities of interstate commerce and the mails in connection with the
transactions, acts and courses of business alleged herein, certain of which have occurred within
the District of Utah.
10. Venue for this action is proper in the District of Utah under Section 22(a) of the
Securities Act [15 U.S.C. § 77v(a)] and under Section 27 of the Exchange Act [15 U.S.C. §78aa]
because certain of the transactions, acts, practices, and courses of business alleged in this
Complaint took place in this district and because the Defendants reside in and transact business
in this district.
11. Defendants, unless restrained and enjoined by this Court, will continue to engage
in the transactions, acts, practices, and courses of business alleged herein and in transactions,
acts, practices, and courses of business of similar purport and object.
12. Defendants’ conduct took place in connection with the offer, purchase and/or sale
13. Traffic Monsoon, LLC, is a Utah limited liability company formed in October
2014. Traffic Monsoon’s principal place of business is in Murray, Utah.
14. Charles David Scoville, 36, is a resident of Murray, Utah. Charles Scoville is the only
member and controlling person of Traffic Monsoon. He controls and oversees all of its business
STATEMENT OF FACTS
The AdPack Product
15. Traffic Monsoon offers and sells seven different Internet advertising products.
Only one of these products, the AdPack, entitles the member to share in the company’s profits.
16. Traffic Monsoon has two kinds of members, “free” and “paying.” A “free”
member is someone who participates in the traffic exchange without buying any services, merely
clicking on ads which Traffic Monsoon calls “cash links.” A “paying” member is someone who
has purchased any product, including the AdPack, from the Traffic Monsoon website.
17. AdPacks cost $50 each. For this price, the investor receives 20 clicks to his
banner ad, 1,000 visitors to his website from the traffic exchange, and the ability to share in
Traffic Monsoon’s profit.
18. If the 20 clicks and 1,000 traffic exchange credits were purchased separately from
Traffic Monsoon, they would cost $10.95. The investor is paying just under $40 for the
remaining component of the AdPack, the profit sharing opportunity.
19. Of the $50 paid for each AdPack, Scoville distributes10% as a commission to the
person who introduced the investor; 4.5% for payment of Traffic Monsoon expenses; 1.5% to the
company’s programmer; 79% to the company reserve fund; and 5% to a fund for sharing profit
with AdPack purchasers.
20. Charles Scoville uses the reserve fund, which initially was maintained at PayPal Holdings
Inc. (“PayPal”), to supplement investors’ profit sharing. His system automatically adds reserve
funds to the profit sharing every hour. The reserve fund is used in this way to “smooth out” the
profit sharing payments.
21. Investors are not informed that the reserve fund is used to supplement the sharing
of Traffic Monsoon profit.
22. Charles Scoville has programmed the Traffic Monsoon system to share profits with
qualified accounts based on sales that took place 24 hours earlier. In YouTube videos he has
created for Traffic Monsoon, Scoville uses the analogy of a bucket, which fills gradually with
small drops of profit until the contents reach the “fill line” of $55.
In order to buy AdPacks, the member must have a banner ad. If the member does not have a
banner ad, Traffic Monsoon will supply a Traffic Monsoon banner ad to him. Many members
simply use these company banners.
23. Once the AdPack earns $55 it cannot earn additional profit. The investor may
then withdraw his funds or, if he wishes to continue to participate in profit sharing, he may buy a
24. The Traffic Monsoon website claims that there is no set timeframe for the
investor’s account to reach $55, or any assurance that it will ever in fact reach $55.
25. Traffic Monsoon treats the investor’s $50 payment for an AdPack (except for the
10% referral commission portion) as revenue to the company at the time it is paid.
26. Traffic Monsoon’s website discloses that the $50 payment for an AdPack is all
deemed revenue to the company at the time it is paid. The website provides no assurance that
the investor’s “bucket” will ever reach the $55 “fill line.”
27. Nevertheless, historically, investor accounts receive a return of about $1 a day,
meaning that investors receive their $50 back, plus a $5 return, after about two months. This
equates to a return of 10% over approximately two months.
28. If investors continue to roll their returns over to purchase a new AdPack every
two months, they will receive an annual return on investment of approximately 60% a year.
29. Charles Scoville established this 10% rate of return and controls how quickly investors
accounts accumulate returns, in part by adding to the profit sharing from the reserve fund.
30. In order to share in company profit, AdPack investors must “qualify.” To qualify,
they must click on 50 banner ads in the traffic exchange in any given 24-hour period.
31. Traffic Monsoon makes it very easy for investors to complete their 50 clicks.
When they log into their dashboard they see (1) a banner ad to click on; and (2) the hours and
minutes remaining in the 24-hour period. The investor is required to view each banner ad for
only 5 seconds, and a counter appears that counts down the 5 seconds for him. At the end of that
time the investor must click on an image that appears, to verify that he is a human, and then the
next banner ad appears automatically. The act of completing the 50 clicks takes the investor 4.1
minutes per day.
32. Regardless of how many AdPacks an investor owns, he is only required to click
on 50 banner ads for 5 seconds each in a 24-hour period to remain qualified to share in profits.
Traffic Monsoon Revenue
33. Traffic Monsoon and Charles Scoville represent to investors that the company generates
profit from all the advertising services it sells. Scoville went further in posting a statement on his
website www.charlesscoville.com to the effect that the AdPack was a lower volume product than
the other Traffic Monsoon products:
We sell 1 service LOWER in demand which includes a profit sharing position,
and share profits from the services with HIGHER demand with those who click a
minimum of 10 ads per day.
34. Scoville does not disclose to investors that Traffic Monsoon’s revenue comes
almost exclusively from the sale of the AdPack product. Instead, Defendants imply that the
majority of the revenue comes from the sale of Traffic Monsoon’s many advertising products.
35. Traffic Monsoon’s revenue sources since October 2014, when it was formed, are
36. Since inception, more than 99% of the money Traffic Monsoon has distributed to
investors came from investors purchasing new AdPacks. Only approximately 0.4% of the
money it has distributed to investors came from all of its other advertising products, combined.
37. Of its revenue since inception, Traffic Monsoon has shared approximately $618
million with AdPack purchasers. Almost all the company’s revenue, however, comes from the
sales of AdPacks, with only approximately $3 million coming from other sources.
38. There is no way any returns could be paid to investors without the sale of new
AdPacks. This fact is not, however, disclosed to Traffic Monsoon investors.
39. Traffic Monsoon’s website falsely implies that revenues come from all of its
advertising products, rather than almost exclusively from AdPacks:
It’s from the sale of all our services that we share revenues.
When our members purchase a service from TrafficMonsoon, the revenues from
that purchase are held by the company. Then, you can qualify to receive share of
the profits! Naturally there is a cost associated with providing services. Each
service provided generates a profit margin. We share those profits with you!
40. Scoville also omits to disclose to investors that the shared profit is periodically
supplemented by payments from the reserve fund at Scoville’s discretion and is, therefore, not
truly revenue sharing.
41. Traffic Monsoon cannot in fact deliver the numbers of visitors it has promised to
42. AdPack purchasers are supposed to receive 20 clicks to their banner ads, and
1,000 credits in the traffic exchange.3
These traffic exchange credits come from the 50 clicks a
day required of each member who owns one or more AdPacks.
43. As of May 16, 2016, Traffic Monsoon had sold 15,225,689 AdPacks. For each
such AdPack, however, it must deliver 1,000 visitors, amounting to 15 billion visitors total. As
of July 24, 2016, however, the Traffic Monsoon website states that the company had “delivered
1,618,996,340 visitors to our member’s [sic] websites to date.” This is only about a tenth of
what would be required by Scoville’s own program.
Payment Processors and Accounts Used by Traffic Monsoon and Scoville
44. Up until February 2016, when PayPal froze the Traffic Monsoon account,
Scoville used PayPal almost exclusively to process payments both into and out of Traffic
Monsoon. Almost all member funds were kept in PayPal, and each member had a PayPal
subaccount and possessed the ability to log in and view his account balance. The company’s
funds were kept in PayPal as well.
45. Since inception, $134 million in investor cash went into PayPal, and
approximately $61 million was paid out to Traffic Monsoon investors prior to the PayPal freeze
of Traffic Monsoons’s accounts.
46. In early January 2016, PayPal contacted Scoville and notified him that it was
considering limiting his account. PayPal’s compliance department had noted that Traffic
Monsoon’s account had some earmarks of a Ponzi scheme, such as very rapid growth and almost
no chargebacks or refund requests.
A credit in the traffic exchange entitles the member to a visit to his website.
47. On January 11, 2016, PayPal notified Scoville that it was blocking any transfers
of funds out of PayPal, while still allowing member funds to be deposited. On February 11,
2016, PayPal notified Scoville that it was freezing the Traffic Monsoon account completely for a
period of 180 days.
48. On January 12, 2016, Charles Scoville created and posted a YouTube video for current
and prospective investors. In the video he explained that for the sake of convenience he was
planning to transition away from PayPal to eventually open a “Traffic Monsoon bank.” He did
not disclose the PayPal freeze.
49. Charles Scoville did not disclose the PayPal freeze to investors until February 11, 2016,
when he posted a news release on the Traffic Monsoon website and also posted another video on
YouTube. During the intervening month, because PayPal was allowing investor funds in but not
allowing them to be withdrawn, members who bought advertising services and transferred funds
to Traffic Monsoon had no idea their funds would be frozen. Scoville, however, was aware of
50. As of February 11, 2016, approximately $60 million was frozen in Traffic
Monsoon’s PayPal accounts.
51. After the PayPal freeze, Charles Scoville began using other payment processors more
extensively: Solid Trust Pay, headquartered in Ontario, and Payza, headquartered in London with
offices in New York. He has also used an account at JPMorgan Chase to receive investor funds.
52. Since the freeze, PayPal has allowed Traffic Monsoon members to reverse
AdPack purchases, refunding to them only their cash in and not any purported gains. As a result
of the claims paid, the Traffic Monsoon account at PayPal had $46,515,787 in the account as of
July 11, 2016.
53. The PayPal freeze expired on July 11, 2016. Immediately after the expiration of
the freeze, Scoville began withdrawing funds from PayPal.
54. PayPal withdrawals are limited to $100,000 per request. Since July 11, 2016,
Charles Scoville has made 256 withdrawal requests and withdrawn over $25 million. Scoville did
attempt to withdraw an additional $10 million on July 21, 2016, but PayPal reversed those
55. As of July 21, 2016, the TM account at PayPal had a balance of $23,316,843.
56. Charles Scoville has wired the funds withdrawn from PayPal to the Traffic Monsoon
account at JPMorgan Chase in Park City, Utah. From there, he has transferred at least $21
million to his personal JPMorgan Chase account.
57. Charels Scoville has never disclosed to investors, whether on the Traffic Monsoon website
or on YouTube, that the PayPal freeze has expired, and has never informed members that they
can request that their AdPack purchases be reversed. Since the freeze was lifted he has been
withdrawing funds, apparently for his own benefit, as quickly as possible.
58. Scoville locates investors primarily through Traffic Monsoon’s website, his
personal website and YouTube videos. He also finds new investors by attending international
seminars. Finally, Scoville offers a referral program in which sponsors can earn a commission
on the purchases of new investors.
59. Traffic Monsoon investors are participating in its program not because they are
interested in its advertising services, but because they are interested in the profit sharing
60. Most investors own multiple AdPacks.
61. Traffic Monsoon reports that it has sold approximately 14 million AdPacks to
about 162,000 investors. This equates to an average of 86.4 AdPacks per investor. Many
investors, however, own tens of thousands of dollars’ worth of AdPacks. Hundreds of investors
have deposited more than $100,000 each into the Traffic Monsoon account at PayPal.
62. In the last three months of 2015, Traffic Monsoon took in increasing amounts of
new cash, reaching approximately $1 million each day by the end of the year.
63. After the PayPal freeze, Scoville began using the JPMorgan Chase account more
extensively for investor deposits. From March through June 2016, the information from this
account shows that the largest single investment was $200,000, which would represent 4,000
AdPacks. Average funds per investor were as follows:
Month in 2016 Average invested by:
March $ 8,125 122 investors
April 9,220 122 investors
May 6,664 137 investors
June 5,500 175 investors
64. Most investors have been allowing their funds to accumulate in their Traffic
Monsoon accounts and are using these account balances to purchase additional AdPacks.
65. The majority of the traffic to Traffic Monsoon member sites now comes from
inside Traffic Monsoon, meaning that members are simply clicking on other members’ ads.
66. Approximately 90%, or 145,000, of Traffic Monsoon investors reside outside the
U.S. The program appears to be most popular in countries that are also some of the poorest in
the world.4 For example, the Traffic Monsoon website is the 385th most visited website in
Bangladesh, 366th in Venezuela, and 517th most visited site in Morocco.
Traffic Monsoon is a Ponzi Scheme
67. Scoville offers six Internet advertising products besides the AdPack, to create the
appearance that Traffic Monsoon is a legitimate and profitable business. However, only
approximately 0.4% of its revenue comes from these other advertising products, combined.
68. More than 99% of Traffic Monsoon’s revenue comes from the sale of AdPacks.
Traffic Monsoon could not pay returns to investors without the sale of new AdPacks. Traffic
Monsoon is a classic Ponzi scheme in which investors are paid from money contributed from
new investors, and there is little real business activity.
69. The $50 price of the AdPack has nothing to do with the price of the advertising
services it includes.
70. There is no rationale for the $55 profit sharing ceiling, other than that it represents
a 10% return on the AdPack purchase amount.
71. Scoville has always been the sole owner and controlling member of Traffic
Monsoon. He is the architect of the Traffic Monsoon program.
Some of these may be “free” rather than “paying” members.
72. Charles Scoville is aware that the AdPacks could be considered an investment. In Traffic
Monsoon’s website and his YouTube videos, he goes out of his way to argue that the program
does not involve a security or an investment.
73. In order to participate, Traffic Monsoon investors must agree to the company’s
Terms of Service, which include the following: “[y]ou agree to recognize TrafficMonsoon as a
true advertising company which shares its revenues, and not as any form of investment of any
74. On his website and in his videos, Scoville deliberately avoids calling the $55
payout a “return,” and emphasizes that there is no assurance that it will be paid. However, the
$55 payout has always been paid to investors.
75. The scienter of Scoville can be imputed to Traffic Monsoon because he is its only
member and controlling person.
The AdPacks Are Securities Being Sold in Unregistered Transactions
76. The purchase of AdPacks involves the investment of money, in the form of the
$50 purchase price.
77. Investor funds are aggregated together in PayPal, at other payment processors,
and at JPMorgan Chase. Investors can see their status by logging into their subaccounts. A
portion of investor funds also went to the Traffic Monsoon reserve fund, which was also
maintained at PayPal. Payments are made out of the reserve fund to supplement profit sharing
payments back to investors.
78. Payment of the investors’ returns is almost entirely dependent on Scoville’s
ability to sell AdPacks. The financial success or failure of the investors are inextricably tied to
the efforts of Scoville and Traffic Monsoon.
79. Investors have no role in managing Traffic Monsoon and rely on Traffic Monsoon
to operate the traffic exchange, collect revenue, supplement the revenue from its reserve fund,
and distribute it to members. Traffic Monsoon also sets up the banner ad rotator and tracks
clicks by members seeking to qualify to share in profits.
80. The only actions that investors are required to take to participate in profit sharing
is to click 50 ads each day for 5 seconds each. Whether an investor owns a single AdPack or
several thousand, he is still only required to click 50 ads each day. The system automatically
populates the investor’s dashboard with the required 50 ads and counts down the 5-second time
81. Traffic Monsoon has raised millions of dollars in an unregistered continuous
offering from tens of thousands of investors worldwide, from October 2014 through the present.
82. The AdPacks have been offered and sold through Traffic Monsoon’s website.
They have also been offered and sold by means of Scoville’s YouTube videos. Both these media
are open and publicly available to any user.
83. The AdPacks were offered and sold to persons who are not accredited within the
meaning of the federal securities laws. Traffic Monson made no effort to determine whether
these offerees were accredited.
FIRST CAUSE OF ACTION
EMPLOYMENT OF A DEVICE, SCHEME OR ARTIFICE TO DEFRAUD
Violation of Section 17(a)(1) of the Securities Act [15 U.S.C. § 77q(a)(1)]
84. The Commission realleges and incorporates by reference the allegations contained
in Paragraphs 1 through 83, above.
85. Defendants Traffic Monsoon and Scoville, by engaging in the conduct described
above, directly or indirectly, in the offer or sale of securities, by the use of the means or instruments
of transportation or communication in interstate commerce or by use of the mails, with scienter,
employed devices, schemes, or artifices to defraud.
86. By reason of the foregoing, Defendants, directly or indirectly violated, and unless
enjoined will continue to violate, Sections 17(a)(1) of the Securities Act [15 U.S.C. § 77q(a)(1)].
SECOND CAUSE OF ACTION
FRAUD IN THE OFFER OR SALE OF SECURITIES
Violation of Section 17(a)(3) of the Securities Act [15 U.S.C. § 77q(a)(3)]
87. The Commission realleges and incorporates by reference the allegations contained
in Paragraphs 1 through 83, above.
88. Defendants Traffic Monsoon and Scoville, by engaging in the conduct described
above, directly and indirectly, in the offer and sale of securities, by the use of the means or
instruments of transportation or communication in interstate commerce or by use of the mails,
engaged in transactions, practices, or courses of business which operate or would operate as a
fraud or deceit upon the purchaser.
89. By reason of the foregoing, Defendants, directly or indirectly, violated, and unless
restrained and enjoined by this Court, will continue to violate, Section 17(a) (3) of the Securities
Act [15 U.S.C. § 77q(a)(3)].
THIRD CAUSE OF ACTION
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES
Violation of Section 10(b) of the Securities Act [15 U.S.C. § 78j(b)] and Rule 10b-5(a) and
(c) thereunder [17 U.F.R. § 240.10b-5(a) and (c)]
90. The Commission realleges and incorporates by reference the allegations contained
in Paragraphs 1 through 83, above.
91. Defendants Traffic Monsoon and Scoville, by engaging in the conduct described
above, directly or indirectly, by the use of means or instrumentalities of interstate commerce or
use of the mails, in connection with the purchase or sale of securities, with scienter, employed
devices, schemes, or artifices to defraud, or engaged in acts, practices, or courses of business that
operated or would operate as a fraud and deceit upon other persons.
92. By reason of the foregoing, Defendants, violated, and unless restrained and
enjoined will continue to violate Section 10(b) of the Exchange Act [15 U.S.C. §78j(b)] and Rule
10b-5(a) and (c) thereunder [17 C.F.R. § 240.10b-5(a) and (c)].
FOURTH CAUSE OF ACTION
OFFER AND SALE OF UNREGISTERED SECURITIES
Violation of Sections 5(a) and (c) of the Securities Act [15 U.S.C. § 77e(a) and (c)]
93. The Commission realleges and incorporates by reference the allegations contained
in Paragraphs 1 through 83, above.
94. Defendants Traffic Monsoon and Scoville, by engaging in the conduct described
above, directly or indirectly, through use of the means or instruments of transportation or
communication in interstate commerce or the mails, offered to sell or sold securities or, directly
or indirectly, or carried such securities through the mails or in interstate commerce, for the
purpose of sale or delivery after sale.
95. No registration statement has been filed with the Commission or has been in
effect with respect to these securities.
96. By reason of the foregoing, Defendants, directly or indirectly violated, and unless
enjoined will continue to violate Sections 5(a) and (c) of the Securities Act [15 U.S.C. § 77e(a)
WHEREFORE, the Commission respectfully requests that this Court:
Issue findings of fact and conclusions of law that Defendants committed the violations
Issue in a form consistent with Rule 65(d) of the Federal Rules of Civil Procedure orders
that temporarily, preliminarily and permanently enjoin Traffic Monsoon and Scoville and their
officers, agents, servants, employees, attorneys, and accountants, and those persons in active
concert or participation with any of them, who receive actual notice of the order by personal
service or otherwise, and each of them, from engaging in transactions, acts, practices, and
courses of business described herein, and from engaging in conduct of similar purport and object
in violation of Sections 17(a)(1) and (3) and Sections 5(a) and (c) of the Securities Act, Section
10(b) of the Exchange Act and Rule 10b-5(a) and (c) thereunder.
Issue, in a form consistent with Rule 65(d) of the Federal Rules of Civil Procedure,
orders that temporarily, preliminarily and permanently enjoin Defendants, and their officers,
agents, servants, employees, attorneys, and accountants, and those persons in active concert or
participation with any of them, who receive actual notice of the order by personal service or
otherwise, and each of them, from: (A) transferring, changing, wasting, dissipating, converting,
concealing, or otherwise disposing of, in any manner, any funds, assets, claims, or other property
or assets owned or controlled by, or in the possession or custody of these Defendants; and (B)
transferring, assigning, selling, hypothecating, or otherwise disposing of any assets of Traffic
Monsoon or related entities, including but not limited to those entities identified in
Issue in a form consistent with Rule 65(d) of the Federal Rules of Civil Procedure orders
that temporarily, preliminarily and permanently restrain and enjoin Defendants, and each of
them, and their officers, agents, servants, employees, attorneys, and accountants, and those
persons in active concert or participation with any of them, who receive actual notice of the order
by personal service or otherwise, and each of them, from destroying, mutilating, concealing,
transferring, altering, or otherwise disposing of, in any manner, books, records, computer
programs, computer files, computer printouts, correspondence, including e-mail, whether stored
electronically or in hard copy, memoranda, brochures, or any other documents of any kind that
pertain in any manner to the business of Defendants.
Enter an order directing Defendants to pay civil money penalties pursuant to Section
20(d) of the Securities Act and Section 21(d)(3) of the Exchange Act.
Enter an order directing Defendants to disgorge all ill-gotten gains received during the
period of violative conduct and pay prejudgment interest on such ill-gotten gains.
Grant such further equitable relief as this Court deems just, appropriate, and necessary,
including, but not limited to, a freeze of assets, appointment of a receiver for Traffic Monsoon
and the acceleration of discovery, including the forthwith production of documents..
Retain jurisdiction of this action in accordance with the principles of equity and the
Federal Rules of Civil Procedure in order to implement and carry out the terms of all orders and
decrees that may be entered, or to entertain any suitable application or motion for additional
relief within the jurisdiction of this Court.
Dated July 26, 2016.
/s/ Daniel J. Wadley
Amy J. Oliver
Alison J. Okinaka
Cheryl M. Mori
Attorneys for Plaintiff
Securities and Exchange Commission
351 S. West Temple, Suite 6.100
Salt Lake City, Utah 84101
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