SEC v. Amit Bhardwaj, et al. (insider trading, 2022)

Settled

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In July 2022 the SEC charged Lumentum security chief Amit Bhardwaj and four friends with insider trading ahead of two Lumentum acquisition announcements. All five consented to final judgments, the last on September 24, 2024, with disgorgement totalling about $5.28 million that was deemed satisfied by criminal forfeiture orders. All five had pleaded guilty in parallel criminal cases.

The record

What was ordered

Civil penalty

—

Disgorgement

$5.3m

Prejudgment interest

—

Total relief

$5.3m

Alleged gain

—

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

The Securities and Exchange Commission announced the complaint on July 26, 2022 as litigation release 25450; it was filed on July 25 in the Southern District of New York.

The complaint alleges Bhardwaj learned of the planned acquisitions through his job, bought Coherent securities before the January 2021 announcement and tipped Dhirenkumar Patel on the understanding that gains would be shared, and that the group later traded ahead of the NeoPhotonics deal.

No outcome is reported. The earlier record named 'Amit Bhardwaj, et al.' with an unknown status.

Outcome. Two SEC releases describe the end of the case against all five named defendants. LR-26027 (June 13, 2024) reports consent final judgments against Bhardwaj, Srinivasa Kakkera and Abbas Saeedi, and LR-26131 (September 26, 2024) reports consent final judgments entered September 24, 2024 against Dhirenkumar Patel and Ramesh Chitor. Each is permanently enjoined under Section 10(b) and Rule 10b-5 and barred as an officer or director of public companies: permanently for Bhardwaj and Saeedi, and for seven and a half years for Kakkera, Patel and Chitor. The disgorgement amounts are $462,598.91 (Bhardwaj), $2,453,687.99 (Kakkera), $691,104.73 (Saeedi), $423,074 (Patel) and $1,244,801 (Chitor), each with prejudgment interest whose payment, like the disgorgement, was deemed satisfied by forfeiture orders in the criminal cases. The recorded disgorgement is the sum of the five figures; the interest amounts are not stated in the releases.

The SEC also voluntarily dismissed its unjust-enrichment claims against four relief defendants. The releases say all five defendants pleaded guilty in the parallel criminal actions; they do not give sentences. The consent judgments were entered without findings, so the original trading allegations were not adjudicated in the civil case.

For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the release.

What technique is this, and how does it work?

This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

• Insider trading — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2022-07-26 Litigation release published
2. 2024-06-13 Consent final judgments entered against Bhardwaj, Kakkera and Saeedi
3. 2024-09-24 Consent final judgments entered against Patel and Chitor

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• SEC litigation release
• SEC litigation release 26027 (Bhardwaj, Kakkera, Saeedi judgments)
• SEC litigation release 26131 (Patel, Chitor judgments)

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Same matter

The library links these 2 records because they appear to concern one matter: the same lead defendant, an overlapping technique tag and close filing dates, or a shared court docket or a release that cites the other. Records are listed by date filed.

This grouping is the library's, made by matching names, techniques, dates and citations when the site is built. It is not the regulator's or a court's determination that the records are one case, and it errs towards missing a link rather than making a false one.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added September 10, 2026. submit a correction.