SEC v. David S. Sargent and Christopher M. Klundt (insider trading, 2022)

Settled

✓ Checked against the primary document on October 4, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

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In January 2022 the SEC sued attorney David Sargent and Christopher Klundt over alleged insider trading in Chegg ahead of an earnings release. A Commission order states that on December 27, 2024 the Northern District of Illinois entered a consent judgment enjoining Sargent and ordering a $215,174.90 penalty.

The record

What was ordered

Civil penalty

$215k

Disgorgement

—

Prejudgment interest

—

Total relief

$215k

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 January 11, 2022 as release LR-25305. The respondents named are David S. Sargent and Christopher M. Klundt (2 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.

The release references a parallel criminal proceeding. Where a criminal case exists, the civil and criminal outcomes are recorded separately, because they resolve on different standards of proof.

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.

Outcome: the Commission's January 6, 2025 order (File No. 3-22388) states that on December 27, 2024 the court permanently enjoined Sargent, by consent, from violating Section 10(b) and Rule 10b-5 and ordered him to pay a civil penalty of $215,174.90; it also suspends him from appearing before the Commission as an attorney. The order puts his alleged profit at $107,587.45. It does not mention Klundt, whose outcome was not checked, so this record covers Sargent only.

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. 2022-01-11 Litigation release published
2. 2024-12-27 Consent judgment entered against Sargent (N.D. Ill.), as described in the Commission order of Jan. 6, 2025

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 Order, Exchange Act Release 102117 (Jan. 6, 2025)

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.

Related actions

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

Record added September 10, 2026. submit a correction.