SEC v. Gannon Giguiere and others (matched orders, 2018)
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.
In July 2018 the SEC sued Gannon Giguiere and four others over alleged manipulation of two microcap stocks, including a matched-order scheme. Giguiere consented to a bifurcated judgment in April 2023 and was ordered in June 2024 to pay about $10.7 million; three co-defendants also reached judgments, the last on 8 January 2025, though one named defendant's outcome was not found.
The record
| Agency | SEC |
|---|---|
| Release number | LR-24201 |
| Date filed | 2018-07-16 |
| Date resolved | 2025-01-08 |
| Status | settled |
| Asset class | equities |
| Criminal parallel | Yes: charged (defendants in the SEC complaint (release does not say who was charged)), U.S. District Court, Southern District of California, 2018-07-16 |
| Bars imposed | penny stock bar, officer-and-director bar, conduct-based injunction |
| Defendants | Gannon Giguiere ; Oliver-Barret Lindsay ; Kevin Gillespie ; Annetta Budhu ; Andrew Hackett |
| Cited as charged or alleged | Exchange Act s.10(b) and Rule 10b-5 ; Securities Act s.5 |
| Techniques | Matched orders , Pump and dump |
What was ordered
- Civil penalty
- $880k
- Disgorgement
- $7.8m
- Prejudgment interest
- $2.1m
- Total relief
- $10.7m
- Alleged gain
- —
What is alleged to have happened
the Securities and Exchange Commission announced this matter on July 16, 2018 as release LR-24201. The respondents named are Gannon Giguiere, Oliver-Barret Lindsay, Kevin Gillespie, Annetta Budhu and Andrew Hackett (5 individuals, 0 entities).
The complaint alleges that a stock promoter took control of a purported medical-device company and ran a matched-trading scheme with a Cayman broker, caught by an undercover FBI operation. No undisclosed-payment promotion is alleged, so the paid-promotion tag has been replaced with matched orders and pump and dump.
This library tags the matter as matched orders and pump and dump, 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 equities.
Non-monetary relief recorded: officer-and-director bar, penny stock bar.
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.
Later SEC litigation releases show how the case ended for four of the five named defendants. Budhu consented to a judgment on 31 January 2023 with a penny stock bar, $5,000 disgorgement plus interest and a $5,000 penalty. Gillespie consented on 11 July 2022 to a bifurcated judgment with penny stock and officer-and-director bars, and the SEC told the court in April 2023 it would seek nothing further. Giguiere consented to a bifurcated judgment on 17 April 2023 with the same bars, and on 11 June 2024 the court granted the SEC's motion for $7,760,415.97 in disgorgement, $2,091,439.85 in interest and $875,000 in penalties. On 8 January 2025 the court entered judgment against Hackett, on summary judgment based on his criminal conviction, with an injunction, a penny stock bar and disgorgement and interest deemed satisfied by criminal restitution. The money fields sum the Giguiere and Budhu figures only; Budhu's interest and Hackett's amounts are not stated in the releases. The releases do not mention Oliver-Barret Lindsay, so his outcome was not checked. A separate 2021 SEC case against Giguiere over Long Blockchain stock (LR-25920) is a different matter and is not recorded here.
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 2 techniques 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.
- Matched orders — see how it works, what statute it engages, and every other action tagged the same way.
- Pump and dump — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
- 2018-07-16 Litigation release published
- 2023-01-31 Consent judgment entered against Annetta Budhu
- 2023-05-12 SEC reports resolution as to Kevin Gillespie (bifurcated consent judgment of 11 July 2022)
- 2024-06-11 Court grants SEC monetary remedies against Giguiere ($7.76 million disgorgement, $2.09 million interest, $875,000 penalty)
- 2025-01-08 Judgment entered against Andrew Hackett after summary judgment
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 LR-25631 (Budhu)
- SEC litigation release LR-25724 (Gillespie)
- SEC litigation release LR-26024 (Giguiere monetary judgment)
- SEC litigation release LR-26222 (Hackett)
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.
| Date filed | Agency | Record | Status |
|---|---|---|---|
| 2018-07-16 | SEC | SEC v. Gannon Giguiere and others (matched orders, 2018) | Settled |
| 2024-01-03 | SEC | SEC v. Gannon Giguiere (insider trading, 2024) | Judgment entered |
Related actions
Other actions in the library sharing at least one technique tag with this one.
| Action | Agency | Filed | Technique | Penalty | Status |
|---|---|---|---|---|---|
| SEC v. Giguiere et al. (undisclosed control blocks, 2024) | SEC | 2024-06-13 | Undisclosed Control Blocks , Matched Orders +1 | $875k | judgment |
| SEC v. Beaufort Secs. Ltd. and Kyriacou. (pump and dump, 2019) | SEC | 2019-07-29 | Matched Orders , Pump And Dump | — | judgment |
| SEC v. Timary Delorme (pump and dump, 2018) | SEC | 2018-03-27 | Pump And Dump , Matched Orders | $50k | settled |
| SEC v. Beaufort Securities Ltd. and others (matched orders, 2018) | SEC | 2018-03-16 | Matched Orders , Pump And Dump | — | settled |
| SEC v. Jeffrey D. Martin, Thomas L. Tedrow and others (Mainstream Entertainment pump and dump, 2017) | SEC | 2017-08-01 | Pump And Dump , Paid Stock Promotion +2 | $142k | judgment |
| SEC v. James M. Farinella, et al. (matched orders, 2017) | SEC | 2017-06-21 | Matched Orders , Pump And Dump | — | settled |