Market Manipulation. Search

SEC v. John Special and John Kenneth Davidson (insider trading, 2019)

Settled

Checked against the primary document on October 3, 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 December 2019 the SEC announced settlements with Oklahoma oil and gas executives John Special and John Davidson over trading in Covidien before Medtronic's takeover, with more than $1.5 million in profit. Combined, they and relief defendant Michael Murphy agreed to $1,561,454 disgorgement, $235,604 interest and $1,561,454 in penalties, subject to court approval.

The record

Structured fields for this action, as recorded in our case library.
Agency SEC
Release number LR-24690
Date filed 2019-12-12
Date resolved 2019-12-12
Court U.S. District Court, Western District of Oklahoma
Status settled
Criminal parallel No
Defendants John Special (individual) ; John Kenneth Davidson (individual) ; Michael Murphy (individual)
Cited as charged or alleged Exchange Act s.10(b) and Rule 10b-5 (statutes and rules cited in the document; not a finding that they were violated)
Techniques Insider trading

What was ordered

Civil penalty
$1.6m
Disgorgement
$1.6m
Prejudgment interest
$236k
Total relief
$3.4m
Alleged gain
$1.5m

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 SEC alleged that Davidson learned of the deal from a director neighbour despite a warning not to trade, bought shares, and told Special in confidence; Special bought stock and options, including in Murphy's account, and sold the next morning. Special agreed to disgorge $1,182,472, pay $231,782 interest and a $1,542,242 penalty; Davidson $19,212, $3,822 and $19,212; Murphy, a relief defendant not charged with wrongdoing, $359,770 representing profits from the trading in his account. The stored figures are the sums.

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.

Timeline

  1. 2019-12-12 Litigation release published

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

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.

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

Record added September 10, 2026. submit a correction.