SEC v. Hari Prasad Sure, et al., Civ. Act. (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.
In 2022 the SEC alleged that three Twilio software engineers and four relatives and friends traded on advance knowledge of Twilio's first-quarter 2020 results. On January 9, 2025 the court entered final judgments against all seven defendants on consent, with injunctions plus disgorgement and prejudgment interest or civil penalties depending on the defendant. Two defendants had pleaded guilty in parallel criminal cases.
The record
| Agency | SEC |
|---|---|
| Release number | LR-25350 |
| Date filed | 2022-03-29 |
| Date resolved | 2025-01-09 |
| Status | settled |
| Criminal parallel | Yes: guilty plea (Hari Sure and Dileep Kamujula), U.S. District Court, Northern District of California |
| Defendants | Hari Prasad Sure ; Lokesh Lagudu ; Chotu Pulagam ; Dileep Kamujula ; Sai Nekkalapudi ; Abhishek Dharmapurikar ; Chetan Pulagam |
| Cited as charged or alleged | Exchange Act s.10(b) and Rule 10b-5 |
| Techniques | Insider trading |
What was ordered
- Civil penalty
- —
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- —
- Alleged gain
- $1m
What is alleged to have happened
The Securities and Exchange Commission announced the complaint on March 29, 2022 as litigation release 25350, filed in the Northern District of California.
The complaint alleges Hari Sure, Lokesh Lagudu and Chotu Pulagam concluded in a group chat that the stock would rise, and tipped or used the accounts of Dileep Kamujula, Sai Nekkalapudi, Abhishek Dharmapurikar and Chetan Pulagam despite a company policy forbidding it. Criminal charges were announced against Kamujula.
The release records no outcome. The earlier record named only 'Hari Prasad Sure, et al., Civ. Act.' and left the status unknown.
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. SEC litigation release 26217 (January 14, 2025) says the Northern District of California entered final judgments on January 9, 2025 against all seven named defendants (Hari Prasad Sure, Lokesh Lagudu, Chotu Prabhu Tej Pulagam, Dileep Kumar Reddy Kamujula, Sai Mounika Nekkalapudi, Abhishek Dharmapurikar and Chetan Prabhu Sree Karteek Pulagam). Each consented to the judgment, which means the allegations were resolved by agreement rather than by a court finding after trial. The release says the judgments carry permanent injunctions, disgorgement with prejudgment interest for five defendants, and civil penalties for five (with some defendants bearing both). It also says Sure and Kamujula had earlier pleaded guilty in parallel criminal cases. We opened the judgment documents for Sure (disgorgement of $100,000 plus interest of $5,531.69), Kamujula ($731,322.72 plus $40,454.42), Lagudu (penalty of $38,775.40), Nekkalapudi ($38,775.40 disgorgement, $2,144.94 interest, $38,775.40 penalty) and Dharmapurikar ($4,364.00, $241.41, $4,364.00 penalty). We did not open the two Pulagam judgments, so no combined money figure is recorded here, and criminal sentences are not covered by these sources. 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
- 2022-03-29 Litigation release published
- 2025-01-09 Final judgments entered against all seven defendants on consent
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 26217 (final judgments)
- Final judgment as to Sure
- Final judgment as to Kamujula
- Final judgment as to Lagudu
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 |
|---|---|---|---|
| 2022-03-29 | SEC | SEC v. Hari Prasad Sure, et al., Civ. Act. (insider trading, 2022) | Settled |
| 2025-01-14 | SEC | SEC v. Hari Prasad Sure, et al. (insider trading, 2025) | 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. Trijya Vakil and Neeraj Visen (insider trading, 2026) | SEC | 2026-09-04 | Insider Trading | $109k | settled |
| CFTC v. Gabriel Perez (insider trading, 2026) | CFTC | 2026-08-28 | Insider Trading | $65k | judgment |
| SEC v. Gavin Wolfe and others (insider trading, 2026) | SEC | 2026-08-21 | Insider Trading | — | filed |
| SEC v. Jesse R. Mitchell (insider trading, 2026) | SEC | 2026-08-21 | Insider Trading | — | filed |
| SEBI v. Arun Kumar Somani and others (insider trading review, Indian Oil Corporation, 2026) | SEBI (India) | 2026-08-13 | Insider Trading | — | dismissed |
| SEC v. Benjamin Tesfaye (insider trading, 2026) | SEC | 2026-08-11 | Insider Trading | $18.7k | settled |