SEC v. Bonan Huang and Nan Huang (insider trading, 2015)

Judgment entered

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In January 2015 the SEC sued Capital One data analysts Bonan Huang and Nan Huang for insider trading on sales data taken from the employer's database; this March 2015 release reports a preliminary injunction by consent. Bonan Huang settled in December 2015 for more than $4.7 million in disgorgement, interest and penalty combined. A jury found Nan Huang liable in January 2016, and on February 25, 2016 the court ordered $4,403,545 disgorgement, $288,965 interest and an $8,807,090 penalty.

The record

What was ordered

Civil penalty

—

Disgorgement

—

Prejudgment interest

—

Total relief

—

Alleged gain

$2.8m

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 this matter on March 10, 2015 as release LR-23216, a notice that on March 2, 2015 the Eastern District of Pennsylvania entered, by consent, a preliminary injunction against Bonan Huang and Nan Huang extending an asset freeze imposed on January 21, 2015. The SEC alleged they used keyword searches of their employer Capital One's database of customer card activity to anticipate retailers' quarterly sales announcements and trade ahead of them. This library tags the matter as insider trading; the tagging is ours, not the regulator's. This record appears to cover the same case as two other records in this library.

Outcome. Per release 23438 (December 23, 2015), Bonan Huang consented on December 3, 2015, without admitting or denying, to a final judgment enjoining him from violating Exchange Act section 10(b) and Rule 10b-5 and paying disgorgement, interest and a penalty totalling more than $4.7 million; the release does not split that total. Per release 23445 (January 14, 2016), a jury found Nan Huang liable. Per release 23476 (February 26, 2016), the court issued a memorandum opinion and final judgment the day before, enjoining him and ordering $4,403,545 in disgorgement, $288,965 in prejudgment interest and an $8,807,090 penalty, about $13.5 million. Because Bonan Huang's amount is not itemised, no money fields are stored here. The three releases mention no criminal case, and we did not look for one.

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. 2015-03-10 Litigation release published
2. 2015-12-03 Final judgment by consent against Bonan Huang
3. 2016-01-14 Jury verdict against Nan Huang announced
4. 2016-02-25 Final judgment against Nan Huang: disgorgement, interest and penalty

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 23438 (Bonan Huang settlement)
• SEC litigation release 23445 (jury verdict)
• SEC litigation release 23476 (final judgment, Nan Huang)

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 3 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.