USA v. Gagalis et al.

2006 DNH 033
CourtDistrict Court, D. New Hampshire
DecidedMarch 20, 2006
DocketCR-04-126-PB
StatusPublished

This text of 2006 DNH 033 (USA v. Gagalis et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
USA v. Gagalis et al., 2006 DNH 033 (D.N.H. 2006).

Opinion

USA v . Gagalis et a l . CR-04-126-PB 03/20/06

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

United States of America

v. Case N o . 04-cr-126-01/06-PB Opinion N o . 2006 DNH 033 Robert J. Gagalis, et a l .

MEMORANDUM AND ORDER

Defendants are charged with several counts of securities

fraud in connection with their roles as officers and employees of

Enterasys Network Systems, Inc. (“Enterasys”). Before me are

their motions to dismiss count five of the superseding

indictment, which charges the defendants with making false and

misleading statements to Enterasys’s outside auditors in 2001.

The government objects. For the reasons set forth below, I deny

defendants’ motions.

I. BACKGROUND

Count five of the superseding indictment, entitled

“Securities Fraud: False Statements to Auditors; Aiding and

Abetting,” charges that the defendants: [K]nowingly and willfully made, and caused to be made, materially false and misleading statements, and omitted to state or caused others to omit to state material facts, necessary to make the statements made not misleading, to Enterasys’ outside auditors, in connection with an examination of the financial statements, quarterly review, and the preparation and filing of a document and report required to be filed with the SEC. Specifically, the defendants: (a) concealed, and caused others to conceal, from Enterasys’ outside auditors, revenue associated with the GEMMS, Paraprotect and Worldlink transactions so as to hide the true substance of those transactions; (b) stated and caused others to state that the altered Letter of Agreement in the Ariel transaction was executed on or about August 3 1 , 2001, when, in fact, they knew it was not executed until on or about September 2 0 , 2001; (c) concealed and caused others to conceal the secret side letters in the Ariel and Tech Data transactions; and (d) falsely stated, and caused others to falsely state, in a management representation letter that: (i) the company had made available to its outside auditors all relevant records, including side letters; (ii) there had been no instances of fraud by any member of management and by employees who have significant roles in internal control; (iii) there had been no instances of fraud by others at Enterasys that could have a material effect on the company’s financial information; (iv) there had been no violations and no possible violations of laws or regulations the effects of which should be considered for disclosure in financial information; and (v) revenue recognized had been modified to the extent appropriate when a right of return or other significant future obligation existed.

All in violation of Title 1 5 , United States Code, Sections 78ff, Title 1 7 , Code of Federal Regulations, Section 240.13b2-2, and Title 1 8 , United States Code, Section 2 .

Superseding Indictment ¶ 104.

-2- Count five charges defendants with violating 15 U.S.C.

§ 78ff, 17 C.F.R. § 240.13b2-2 (“Rule 13b2-2”) and 18 U.S.C.

§ 2. 1 15 U.S.C. § 78ff(a) imposes criminal liability for willful

violations of the Securities Exchange Act of 1934 (“Exchange

Act”) or “any rule or regulation thereunder the violation of

which is made unlawful or the observance of which is required

under the terms of [the Act]”. At the time defendants’ alleged

conduct occurred, Rule 13b2-2 provided:

No director or officer of an issuer shall, directly or indirectly,

(a) Make or cause to be made a materially false or misleading statement, or

(b) Omit to state, or cause another person to omit to state, any material fact necessary in order to make statements made, in the light of the circumstances under which such statements were made, not misleading to an accountant in connection with (1) any audit or examination of the financial statements of the issuer required to be made pursuant to this subpart or (2) the preparation or filing of any document or report required to be filed with the Commission pursuant to this subpart or otherwise.

1 18 U.S.C. § 2 , the federal aiding and abetting statute, provides that anyone who “commits an offense against the United States or aids, abets, counsels, commands, induces or procures its commission, is punishable as a principal.” 18 U.S.C. § 2 ( a ) .

-3- 17 C.F.R. § 240.13b2-2 (2003) (amended May 2 8 , 2003).

II. DISCUSSION

Defendants argue that count five should be dismissed

because: (1) the Securities Exchange Commission (“SEC”) lacked

the statutory authority to promulgate Rule 13b2-2, on which count

five is based; (2) Rule 13b2-2 could not have served as the basis

for a prosecution under 15 U.S.C. § 78ff in 2001, when defendants

allegedly violated the rule; and (3) 15 U.S.C. § 78m(b)(5)

prohibits the imposition of criminal liability for the conduct on

which count five is based. I address each argument in turn.

A. SEC’s authority to promulgate Rule 13b2-2

In order to address defendants’ argument that the SEC lacked

the statutory authority to promulgate Rule 13b2-2, I first

discuss the history of the Rule.

1. History of Rule 13(b)2-2

Beginning in 1973, as a result of the Watergate scandal,

the SEC began investigating the undisclosed use of corporate

funds for illegal domestic political contributions. See

Securities Exchange Act Release N o . 13185, 11 SEC Docket 1514,

-4- 1977 WL 174077, at *2 (January 1 9 , 1977). On May 1 2 , 1976, the

SEC issued a report to Congress entitled “Report on Questionable

and Illegal Corporate Payments and Practices,” which included its

findings and recommendations for legislation to prevent further

abuses.

Before Congress acted on the SEC’s recommendations, the SEC

announced four proposed rules that would: (1) require registered

issuers to “maintain books and records accurately reflecting the

transactions and dispositions of assets of the issuer;” (2)

require such issuers to “maintain an adequate system of internal

accounting controls designed to provide reasonable assurance that

specified objectives are satisfied;” (3) “prohibit the

falsification of an issuer’s accounting records;” and (4)

“prohibit the officers, directors, or stockholders of an issuer

from making false, misleading or incomplete statements to an

accountant engaged in an examination of the issuer.” Id. at * 1 .

After the proposed rules were released for public comment

but before they were adopted, Congress enacted § 13(b)(2) of the

Exchange Act (codified at 15 U.S.C. § 78(m)(b)(2)).2 The

2 Section 13(b)(2) of the Exchange Act was enacted as part of the Foreign Corrupt Practices Act (“FCPA”). See Pub. L . N o .

-5- original Senate bill ( S . 305) included all four of the SEC’s

proposed rules. H.R. Conf. Rep. N o .

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