SEC v. Bhardwaj et al. (insider trading, 2024)

Judgment entered

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In September 2024 the Securities and Exchange Commission announced final consent judgments against Dhirenkumar Patel and Ramesh Chitor, tippees of former Lumentum employee Amit Bhardwaj, who traded ahead of Lumentum's acquisitions of Coherent and NeoPhotonics for combined gains of over $1.6 million. Each was enjoined and barred from serving as an officer or director for seven and a half years, and ordered to disgorge $423,074 and $1,244,801 with interest, deemed satisfied by criminal forfeitures after guilty pleas.

The record

What was ordered

Civil penalty

—

Disgorgement

$1.7m

Prejudgment interest

—

Total relief

$1.7m

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 these judgments on September 26, 2024 as release LR-26131, in a Southern District of New York case filed July 25, 2022; the judgments were entered on September 24, 2024.

Patel traded before the January 19, 2021 Coherent announcement and Chitor before the November 4, 2021 NeoPhotonics announcement. The recorded disgorgement is the sum of the two figures; the release does not report an outcome for Bhardwaj.

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. 2024-09-26 Litigation release published

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

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.