SEC v. Christopher Salis, Douglas Miller, Edward Miller, and Barrett Biehl (insider trading, 2016)

Settled

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In June 2016 the SEC charged former SAP executive Christopher Salis, Douglas Miller and Edward Miller with insider trading ahead of SAP's acquisition of Concur. Consent final judgments on June 12, 2019 order about $358,520 in disgorgement and $52,216 in interest, deemed satisfied by criminal forfeiture, and the SEC dismissed charges against Barrett Biehl.

The record

What was ordered

Civil penalty

—

Disgorgement

$359k

Prejudgment interest

$52.2k

Total relief

$411k

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 this matter on June 16, 2016 as release LR-23571. The respondents named are Christopher Salis, Douglas Miller, Edward Miller and Barrett Biehl (4 individuals, 0 entities).

This library tags the matter as insider trading, based on the conduct the regulator describes. Each tag links to a page explaining how that technique works, what statute it engages, and what penalties comparable actions have attracted. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.

The conduct is recorded against options.

SEC release 24499 reports that the Northern District of Indiana entered final judgments on consent against Salis and the Miller brothers on June 12, 2019 (the judgment documents carry a filing date of June 10), without admitting or denying the allegations. Salis owes disgorgement of $90,400 and interest of $2,067, Douglas Miller $119,003 and $22,258, and Edward Miller $149,117 and $27,891, with each amount deemed satisfied by forfeiture orders in the parallel criminal cases. The judgments enjoin further insider trading; the SEC dismissed the charges originally filed against Barrett Biehl. In the criminal cases Salis was sentenced to six months in prison, Douglas Miller to twenty-four months and Edward Miller to six months; the sentence field holds Salis's. The money fields add the three defendants' figures. Checked on 2026-10-04.

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. 2016-06-16 Litigation release published
2. 2019-06-12 Consent final judgments against Salis and the Miller brothers; Biehl charges dismissed (SEC LR-24499)

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 24499 (final judgments)
• Final judgment as to Salis

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.