SEC v. Joseph R. Earle Jr, Barry D. Reagh, William Clayton, Francis T. Dudley, Steven E. Bryant, Upper Street Marketing, Inc. and Project Growth International, Inc. (boiler rooms, 2022)

Alleged — pending

These are allegations. SEC has filed an action; nothing in it has been proven, and the respondents have not been found liable. Everything described on this page is what the regulator alleges, not what a court has found. See our editorial policy.

✓ 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 2022, the SEC filed charges in the Southern District of California against five individuals and two companies over a 2018 and 2019 pump-and-dump of Upper Street Marketing stock, alongside sales of new shares through what the release calls a boiler room. The SEC seeks injunctions, disgorgement, penalties and bars; the case was unresolved at the release date. Consent final judgments were entered on July 6, 2026 against two of the seven defendants, Dudley and Bryant; no outcome for the others was found.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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Alleged gain

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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 December 5, 2022 as litigation release 25586. The defendants named are Joseph R. Earle Jr, Barry D. Reagh, William Clayton, Francis T. Dudley, Steven E. Bryant, Upper Street Marketing, Inc. and Project Growth International, Inc. As alleged, Mr Earle and Mr Reagh pumped Upper Street's price and volume with paid research reports and recycled press releases and Mr Reagh dumped shares he secretly controlled through a brokerage account opened in Mr Clayton's name, while the company, Mr Earle, Mr Bryant and Project Growth sold new shares in an unregistered private offering. The release describes the share sales as made through a boiler room.

This library tags the matter as boiler rooms, pump and dump, based on the conduct the document describes. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.

Partial outcome. The Southern District of California docket shows final judgments dated July 6, 2026 as to defendants Francis Dudley and Steven Bryant (docket entries 189 and 190), each reciting that the defendant consented to entry. I did not find an outcome for Joseph Earle, Barry Reagh, William Clayton or the two companies, so the record stays at filed; checked on 2026-10-04: no outcome for the lead defendant found on SEC pages.

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.

• Boiler rooms — 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

1. 2022-12-05 Litigation release published
2. 2026-07-06 Consent final judgments entered as to Francis T. Dudley and Steven E. Bryant

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
• Final judgment as to Francis T. Dudley (S.D. Cal.)
• Final judgment as to Steven E. Bryant (S.D. Cal.)

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. If this matter has since resolved, been withdrawn or been dismissed, we want to know: submit a correction.